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HomeMy WebLinkAboutSanLuisRanchFinalEIRpdfSan Luis Ranch Specific Plan Final Environmental Impact Report SCH#2015101083; Project# SPEC/ANNX/ER 1502-2015 prepared by  City of San Luis Obispo  Community Development Department  919 Palm Street  San Luis Obispo, CA 93401  Contact: Doug Davidson, Deputy Director  John Rickenbach, AICP, Project Manager  prepared with the assistance of  Rincon Consultants  1530 Monterey Street, Suite D  San Luis Obispo, CA 93401  May 2017  This page left intentionally blank.  San Luis Ranch Specific Plan Final Environmental Impact Report SCH#2015101083; Project# SPEC/ANNX/ER 1502-2015 prepared by  City of San Luis Obispo  Community Development Department  919 Palm Street  San Luis Obispo, CA 93401  Contact: Doug Davidson, Deputy Director  John Rickenbach, AICP, Project Manager  prepared with the assistance of  Rincon Consultants  1530 Monterey Street, Suite D  San Luis Obispo, CA 93401  May 2017 This page left intentionally blank.      San Luis Ranch Project EIR Table of Contents City of San Luis Obispo i TABLE OF CONTENTS Page Executive Summary ............................................................................................................................. ES-1 1.0 Introduction ..................................................................................................................................... 1-1 1.1 Project Background ........................................................................................................ 1-1 1.2 Purpose and Legal Authority ....................................................................................... 1-6 1.3 Scope and Content ......................................................................................................... 1-7 1.4 Lead, Responsible and Trustee Agencies ................................................................... 1-8 1.5 Environmental Review Process ................................................................................... 1-9 2.0 Project Description .......................................................................................................................... 2-1 2.1 Summary ......................................................................................................................... 2-1 2.2 Project Proponent ........................................................................................................... 2-1 2.3 Project Location .............................................................................................................. 2-1 2.4 Existing Site Characteristics .......................................................................................... 2-1 2.5 Project Characteristics ................................................................................................... 2-6 2.6 Project Objectives ......................................................................................................... 2-22 2.7 Required Approvals .................................................................................................... 2-26 3.0 Environmental Setting.................................................................................................................... 3-1 3.1 Regional Setting .............................................................................................................. 3-1 3.2 Site Specific Setting ........................................................................................................ 3-2 3.3 Cumulative Development ............................................................................................. 3-2 4.0 Environmental Impact Analysis ................................................................................................... 4-1 4.1 Aesthetics ..................................................................................................................... 4.1-1 4.2 Agricultural Resources ............................................................................................... 4.2-1 4.3 Air Quality ................................................................................................................... 4.3-1 4.4 Biological Resources ................................................................................................... 4.4-1 4.5 Cultural Resources ...................................................................................................... 4.5-1 4.6 Greenhouse Gas Emissions ....................................................................................... 4.6-1 4.7 Hazards/Hazardous Materials ................................................................................. 4.7-1 4.8 Hydrology and Water Quality .................................................................................. 4.8-1 4.9 Land Use/Policy Consistency ................................................................................... 4.9-1 4.10 Noise ........................................................................................................................... 4.10-1 4.11 Recreation .................................................................................................................. 4.11-1 4.12 Transportation ........................................................................................................... 4.12-1 4.13 Water Resources ........................................................................................................ 4.13-1 4.14 Issues Addressed in the Initial Study .................................................................... 4.14-1 5.0 Other CEQA-required Discussions .............................................................................................. 5-1 5.1 Growth-Inducing Effects .............................................................................................. 5-1 5.2 Significant Unavoidable Effects ................................................................................... 5-3 5.3 Significant Irreversible Environmental Effects .......................................................... 5-4 5.4 Energy Use and Conservation ..................................................................................... 5-4 San Luis Ranch Project EIR Table of Contents City of San Luis Obispo ii 6.0 Alternatives ...................................................................................................................................... 6-1 6.1 Introduction .................................................................................................................... 6-1 6.2 Project Objectives ........................................................................................................... 6-1 6.3 Significant and Unavoidable Impacts of the Project ................................................. 6-2 6.4 Alternatives Analysis .................................................................................................... 6-3 6.5 Environmentally Superior Alternative ..................................................................... 6-21 7.0 References and EIR Preparers ....................................................................................................... 7-1 7.1 References ....................................................................................................................... 7-1 7.2 EIR Preparers ............................................................................................................... 7-12 8.0 Responses to Comments on the Draft EIR .................................................................................. 8-1 8.1 Introduction ................................................................................................................... 8-1 8.2 Master Responses .......................................................................................................... 8-2 8.3 Responses to Public Testimony on the Draft EIR ................................................... 8-10 8.4 Responses to Written Comments on the Draft EIR ................................................ 8-21 8.5 Responses to Comments on the Draft EIR Recirculation .................................... 8-352 List of Figures Figure 2-1 Regional Location ............................................................................................ 2-1 Figure 2-2 Project Site Location ........................................................................................ 2-3 Figure 2-3a Existing Conditions Photoplates .................................................................... 2-4 Figure 2-3b Existing Conditions Photoplates .................................................................... 2-5 Figure 2-4 Proposed Project Pre-Zoning ......................................................................... 2-7 Figure 2-5 Project Land Use Plan ..................................................................................... 2-8 Figure 2-6 Project Site Plan ................................................................................................ 2-9 Figure 2-7 Bicycle Circulation Plan ................................................................................ 2-13 Figure 2-8 Vehicular Circulation Plan ........................................................................... 2-15 Figure 2-9 Wastewater System Layout .......................................................................... 2-16 Figure 2-10 Water Supply System Layout ....................................................................... 2-17 Figure 2-11 Recycled Water System Layout ................................................................... 2-18 Figure 2-12 Stormwater Detention Plan .......................................................................... 2-21 Figure 2-13 Project Grading Plan ...................................................................................... 2-23 Figure 2-14 Project Phasing Plan ...................................................................................... 2-25 Figure 4.2-1 Soils on the Project Site ................................................................................ 4.2-4 Figure 4.2-2 Important Farmland on the Project Site ..................................................... 4.2-8 Figure 4.4-1 Vegetation Communities and Jurisdictional Features ............................. 4.4-3 Figure 4.4-2 Sensitive Elements Reported in the California Natural Diversity Database and Federally Designated Critical Habitats Located within 5 miles ................................................................................................ 4.4-7 Figure 4.5-1 Built Environment Resources ...................................................................... 4.5-5 Figure 4.5-2a San Luis Ranch Complex Structure Photographs .................................... 4.5-6 Figure 4.5-2b San Luis Ranch Complex Structure Photographs .................................... 4.5-7 Figure 4.5-2c San Luis Ranch Complex Structure Photographs .................................... 4.5-8 Figure 4.5-2d San Luis Ranch Complex Structure Photographs .................................... 4.5-9 Figure 4.5-2e San Luis Ranch Complex Structure Photographs .................................. 4.5-10 Figure 4.7-1 ALUP Airport Safety Zones in the Specific Plan Area ............................ 4.7-4 San Luis Ranch Project EIR Table of Contents City of San Luis Obispo iii Figure 4.7-2 Caltrans Handbook Airport Safety Zones Applied to San Luis Obispo County Regional Airport ............................................................... 4.7-5 Figure 4.8-1 San Luis Obispo Creek Watershed ............................................................. 4.8-2 Figure 4.8-2 Existing Drainage and Floodplain Conditions ......................................... 4.8-3 Figure 4.8-3 Proposed Post-Development 100-Year Floodplain ................................ 4.8-30 Figure 4.10-1 Existing Sound Level Contours on the Project Site ................................ 4.10-4 Figure 4.10-2 Airport Land Use Plan Airport Noise Contours on the Project Site .... 4.10-6 Figure 4.10-3 Modeled Noise Receptor Locations ........................................................ 4.10-22 Figure 4.10-4 Unmitigated Existing + Project On-Site Noise Levels ......................... 4.10-29 Figure 4.10-5 Unmitigated Year 2035 Prado Road Interchange + Project On-Site Noise Levels ................................................................................ 4.10-30 Figure 4.10-6 Unmitigated Year 2035 Prado Road Overcrossing + Project On-Site Noise Levels ................................................................................ 4.10-31 Figure 4.11-1 City of San Luis Obispo Parks and Recreation Facilities ....................... 4.11-5 Figure 4.12-1 Roadways in the Vicinity of the Project Site .......................................... 4.12-2 Figure 4.12-2 Study Area Intersections ........................................................................... 4.12-9 Figure 4.12-3 Existing Intersection Peak Hour Traffic Volumes ................................ 4.12-10 Figure 4.12-4 Existing Segment Average Daily Traffic Volumes ............................... 4.12-11 Figure 4.12-5 Existing Plus Project Peak Hour Traffic Volumes ................................ 4.12-44 Figure 4.12-6 Year 2025 Near Term Peak Hour Traffic Volumes ............................... 4.12-45 Figure 4.12-7 Year 2025 Near Term Plus Project Peak Hour Traffic Volumes ......... 4.12-46 Figure 4.12-8 Year 2035 Full Build Prado Road Interchange Peak Hour Traffic Volumes ...................................................................................................... 4.12-88 Figure 4.12-9 Year 2035 Full Build Prado Road Interchange Plus Project Peak Hour Traffic Volumes............................................................................... 4.12-90 Figure 4.13-1 Non-Potable Irrigation Water Sources ..................................................... 4.13-3 Figure 6-1 No Project, Measure J Entitlements Alternative Site Plan and Development Area ........................................................................................... 6-8 Figure 6-2 Historic Resource Preservation Alternative Development Area ............ 6-12 Figure 6-3 50% On-Site Agriculture/Open Space Alternative Development Area .................................................................................................................. 6-17 List of Tables Table ES-1 Class I, Significant and Unavoidable Environmental Impacts ............... ES-6 Table ES-2 Class II, Significant but Mitigable Environmental Impacts .................. ES-18 Table ES-3 Class III, Less than Significant Environmental Impacts ........................ ES-49 Table 1-1 City of San Luis Obispo Land Use Element Performance Standards for San Luis Ranch Specific Plan Area .......................................................... 1-3 Table 2-1 Planned San Luis Ranch Specific Plan Area Development ...................... 2-10 Table 2-2 Planned Specific Plan Area Development Compared to Land Use Element Buildout Potential ........................................................................... 2-14 Table 3-1 Total Future Development Capacity within the Planning Subarea under the General Plan Land Use Element .................................................. 3-5 Table 4.2-1 San Luis Obispo County Comparative Agricultural Values .................. 4.2-1 Table 4.2-2 San Luis Obispo County Agricultural Summary ..................................... 4.2-2 Table 4.2-3 Project Site Soil Characteristics ................................................................... 4.2-5 Table 4.2-4 LESA Analysis Summary for Project Site ................................................ 4.2-16 San Luis Ranch Project EIR Table of Contents City of San Luis Obispo iv Table 4-3-1 San Luis Obispo Climate Conditions ......................................................... 4.3-1 Table 4-3-2 Current Federal and State Ambient Air Quality Standards ................... 4.3-2 Table 4.3-3 Ambient Air Quality Data at the San Luis Obispo Station ..................... 4.3-3 Table 4.3-4 SLOAPCD Operational Emissions Significance Thresholds .................. 4.3-9 Table 4.3-5 Project Consistency with Applicable 2001 CAP Land Use and Transportation Control Measures ............................................................ 4.3-10 Table 4.3-6 Estimated Construction Maximum Quarterly Air Pollutant Emissions ..................................................................................................... 4.3-14 Table 4.3-7 Estimated Mitigated Construction Maximum Quarterly Air Pollutant Emissions .................................................................................... 4.3-18 Table 4.3-8 Estimated Operational Daily Air Pollutant Emissions .......................... 4.3-19 Table 4.3-9 Estimated Operational Annual Air Pollutant Emissions ...................... 4.3-20 Table 4.3-10 Applicable Mitigation Measures from SLOAPCD CEQA Air Quality Handbook ...................................................................................... 4.3-21 Table 4.3-11 Estimated Mitigated Operational Daily Air Pollutant Emissions ........ 4.3-29 Table 4.3-12 Estimated Mitigated Operational Annual Air Pollutant Emissions .... 4.3-29 Table 4.4-1 Summary of Vegetation/Land Cover Types within the Project Site ..... 4.4-2 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site ................................................................................................................... 4.4-9 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site .................................................................................................... 4.4-25 Table 4.4-4 Sensitive Plant Communities within the Regional Vicinity of the Project Site .................................................................................................... 4.4-39 Table 4.4-5 Summary of Potentially Jurisdictional Wetlands, Waters and Riparian Habitats ........................................................................................................ 4.4-41 Table 4.6-1 Estimated Construction Emissions of GHGs .......................................... 4.6-17 Table 4.6-2 Combined Annual Emissions of GHGs ................................................... 4.6-17 Table 4.6-3 Project Consistency with Applicable Climate Action Plan Measures ...................................................................................................... 4.6-18 Table 4.6-4 Combined Mitigated Annual Emissions of GHGs ................................. 4.6-21 Table 4.7-1 Fatal Aircraft Accidents within the Vicinity of the Airport .................... 4.7-7 Table 4.8-1 Prefumo and San Luis Obispo Creek (below Osos Street) TMDLs ....... 4.8-5 Table 4.8-2 Beneficial Uses for Prefumo Creek ............................................................. 4.8-6 Table 4.8-3 Flood Risk Management Legislation and Local Responsibilities ......... 4.8-10 Table 4.8-4 Combined Peak Discharge from Proposed Drainage Basins ................ 4.8-26 Table 4.9-1 Consistency with City of San Luis Obispo General Plan ...................... 4.9-10 Table 4.9-2 Preliminary Consistency with LAFCO Policies for Annexation and Agricultural Land ....................................................................................... 4.9-40 Table 4.10-1 Human Response to Different Levels of Groundborne Vibration ....... 4.10-3 Table 4.10-2 Noise Measurement Results ...................................................................... 4.10-5 Table 4.10-3 Maximum Noise Exposure for Noise-Sensitive Land Use Areas Due To Transportation Noise Sources ..................................................... 4.10-8 Table 4.10-4 City Maximum Noise Exposure for Noise-Sensitive Land Use Areas Due to Stationary Noise Sources ................................................... 4-10-9 Table 4.10-5 Exterior Noise Limits ................................................................................ 4.10-10 Table 4.10-6 Maximum Time Periods for Increased Noise Levels ........................... 4.10-10 San Luis Ranch Project EIR Table of Contents City of San Luis Obispo v Table 4.10-7 Maximum Noise Levels for Nonscheduled, Intermittent, Short-Term Operation (Less than 10 Days) of Mobile Equipment at Residential Properties ...................................................... 4.10-11 Table 4.10-8 Maximum Noise Levels for Repetitively Scheduled, Relatively Long-Term Operation (10 Days or More) of Stationary Equipment at Residential Properties ...................................................... 4.10-11 Table 4.10-9 Summary of Compatibility of Land Uses with CNEL Contours ....... 4.10-12 Table 4.10-10 California Department of Transportation Vibration Annoyance Potential Criteria ....................................................................................... 4.10-15 Table 4.10-11 Noise Ranges of Typical Construction Equipment .............................. 4.10-16 Table 4.10-12 Vibration Source Levels for Construction Equipment......................... 4.10-19 Table 4.10-13 Calculated Exterior Noise Associated with Traffic on Surrounding Roadways ........................................................................... 4.10-23 Table 4.10-14 Parking Lot Noise Sources at 25 Feet ..................................................... 4.10-26 Table 4.10-15 Estimated Exterior Sound Levels at Proposed Receptors Associated with Traffic on Project Site and Surrounding Roadways ................................................................................................... 4.10-32 Table 4.10-16 Calculated Interior Sound Levels at Proposed Receptors Associated with Traffic on Project Site and Surrounding Roadways ................................................................................................... 4.10-33 Table 4.10-17 Mitigated Exterior Sound Levels at Proposed Receptors Associated with Traffic on Project Site and Surrounding Roadways ................................................................................................... 4.10-37 Table 4.11-1 Existing City of San Luis Obispo Parks and Recreation Facilities ....... 4.11-2 Table 4.11-2 Existing City of San Luis Obispo Special Facilities ................................ 4.11-4 Table 4.12-1 Mitigation Summary Table ........................................................................ 4.12-3 Table 4.12-2 City of San Luis Obispo Level of Service Standards and Modal Priorities ..................................................................................................... 4.12-12 Table 4.12-3 Modal Priority Ranking ........................................................................... 4.12-12 Table 4.12-4 HCM 2010 Segment Automobile LOS ................................................... 4.12-13 Table 4.12-5 HCM 2010 Pedestrian LOS ...................................................................... 4.12-13 Table 4.12-6 HCM 2010 Bicycle & Transit LOS ........................................................... 4.12-13 Table 4.12-7 HCM 2010 Freeway Segments LOS ........................................................ 4.12-14 Table 4.12-8 Existing Conditions Intersection Level of Service: Automobile Analysis ...................................................................................................... 4.12-15 Table 4.12-9 Existing Conditions 95th Percentile Queuing Analysis ....................... 4.12-16 Table 4.12-10 Existing Conditions Intersection Level of Service: Pedestrian Analysis ...................................................................................................... 4.12-17 Table 4.12-11 Existing Conditions Intersection Level of Service: Bicycle Analysis ...................................................................................................... 4.12-19 Table 4.12-12 Existing Conditions Segment Level of Service: Automobile Analysis ...................................................................................................... 4.12-22 Table 4.12-13 Existing Conditions Segment Level of Service: Pedestrian Analysis ...................................................................................................... 4.12-24 Table 4.12-14 Existing Conditions Segment Level of Service: Bicycle Analysis ....... 4.12-26 Table 4.12-15 Existing Conditions Segment Level of Service: Transit Analysis....... 4.12-28 Table 4.12-16 Existing Conditions Segment Level of Service: Freeway Analysis .... 4.12-30 San Luis Ranch Project EIR Table of Contents City of San Luis Obispo vi Table 4.12-17 Project Trip Generation ............................................................................ 4.12-39 Table 4.12-18 Project Trip Generation ............................................................................ 4.12-40 Table 4.12-19 Cumulative (Year 2035) Full Build Fair Share Calculations ............... 4.12-41 Table 4.12-20 Existing Plus Project Conditions Intersection Level of Service: Automobile Analysis ................................................................................ 4.12-47 Table 4.12-21 Near-Term Plus Project Conditions Intersection Level of Service: Automobile Analysis ................................................................................ 4.12-48 Table 4.12-22 Existing Plus Project Conditions Intersection Level of Service: Pedestrian Analysis .................................................................................. 4.12-49 Table 4.12-23 Near-Term Plus Project Conditions Intersection Level of Service: Pedestrian Analysis .................................................................................. 4.12-51 Table 4.12-24 Existing Plus Project Conditions Intersection Level of Service: Bicycle Analysis ......................................................................................... 4.12-53 Table 4.12-25 Near-Term Plus Project Conditions Intersection Level of Service: Bicycle Analysis ......................................................................................... 4.12-55 Table 4.12-26 Existing Plus Project Conditions: Intersection Queuing Analysis ..... 4.12-59 Table 4.12-27 Near-Term Plus Project Conditions: Intersection Queuing Analysis ...................................................................................................... 4.12-60 Table 4.12-28 Existing Plus Project Conditions Segment Level of Service: Automobile Analysis ................................................................................ 4.12-64 Table 4.12-29 Near-Term Plus Project Conditions Segment Level of Service: Automobile Analysis ................................................................................ 4.12-66 Table 4.12-30 Existing Plus Project Conditions Segment Level of Service: Pedestrian Analysis .................................................................................. 4.12-68 Table 4.12-31 Near-Term Plus Project Conditions Segment Level of Service: Pedestrian Analysis .................................................................................. 4.12-70 Table 4.12-32 Existing Plus Project Conditions Segment Level of Service: Bicycle Analysis ......................................................................................... 4.12-72 Table 4.12-33 Near-Term Plus Project Conditions Segment Level of Service: Bicycle Analysis ......................................................................................... 4.12-74 Table 4.12-34 Existing Plus Project Conditions Segment Level of Service: Transit Analysis......................................................................................... 4.12-76 Table 4.12-35 Near-Term Plus Project Conditions Segment Level of Service: Transit Analysis......................................................................................... 4.12-78 Table 4.12-36 Cumulative Plus Project Conditions Intersection Level of Service: Automobile Analysis ................................................................................ 4.12-89 Table 4.12-37 Cumulative Plus Project Conditions Intersection Level of Service: Pedestrian Analysis .................................................................................. 4.12-91 Table 4.12-38 Cumulative Plus Project Conditions Intersection Level of Service: Bicycle Analysis ......................................................................................... 4.12-93 Table 4.12-39 Cumulative Plus Project Conditions Intersection Queue Capacity Analysis ...................................................................................................... 4.12-97 Table 4.12-40 Cumulative Plus Project Conditions Segment Level of Service: Automobile Analysis .............................................................................. 4.12-102 Table 4.12-41 Cumulative Plus Project Conditions Segment Level of Service: Pedestrian Analysis ................................................................................ 4.12-104 San Luis Ranch Project EIR Table of Contents City of San Luis Obispo vii Table 4.12-42 Cumulative Plus Project Conditions Segment Level of Service: Bicycle Analysis ....................................................................................... 4.12-106 Table 4.12-43 Cumulative Plus Project Conditions Segment Level of Service: Transit Analysis....................................................................................... 4.12-108 Table 4.12-44 Cumulative Plus Project Conditions Segment Level of Service: U.S. 101 ..................................................................................................... 4.12-110 Table 4.13-1 City Water Resource Availability ............................................................. 4.13-4 Table 4.13-2 Current Water Demand and Water Availability in the City of San Luis Obispo .......................................................................................... 4.13-5 Table 4.13-3 Current Water Demand at the Project Site .............................................. 4.13-5 Table 4.13-4 City Municipal Water Use Factors for Land Use Categories .............. 4.13-10 Table 4.13-5 San Luis Ranch Project Water Demand: City Water Use Factors ...... 4.13-11 Table 4.13-6 San Luis Ranch Project Water Demand: Project-Specific .................... 4.13-12 Table 4.13-7 Comparison of City Water Supply to Project Use ................................ 4.13-12 Table 4.13-8 Estimated Water Demand from Cumulative Projects in the City of San Luis Obispo .................................................................................... 4.13-14 Table 4.14-1 San Luis Ranch Student Generation ....................................................... 4.14-10 Table 4.14-2 District Enrollment and Capacity ........................................................... 4.14-10 Table 5-1 Project Energy Use Relative to Statewide Energy Use ............................... 5-7 Table 5-2 Project Operational Vehicle Fuel Consumption .......................................... 5-7 Table 5-3 Summary of Mitigation Measure Energy Reduction .................................. 5-9 Table 6-1 Alternative Impact Comparison to the San Luis Ranch Specific Plan .................................................................................................................. 6-22 List of Appendices (provided on enclosed CD) Appendix A: Notice of Preparation and Initial Study Appendix B: Draft San Luis Ranch Specific Plan Appendix C: LESA Modeling Worksheets, Agricultural Suitability Memorandum Appendix D: Air Quality/Greenhouse Gas Emissions Modeling Appendix E: Soil Engineering Report Appendix F: Biological Resources Reports Appendix G: Cultural Resources Survey and Evaluation Appendix H: Hydrogeologic Description and PCE Characterization Report Appendix I: Johnson Aviation Report Appendix J: Preliminary Storm Water Control & Treatment Strategy and Preliminary Drainage Report Appendix K: 45dB.com Noise Study and Noise Modeling Worksheets Appendix L: Multimodal Transportation Impact Analysis Report Appendix M: Water Supply Analysis Appendix N Agricultural Topsoil Memorandum Appendix O Mitigation Monitoring and Reporting Program San Luis Ranch Project EIR Table of Contents City of San Luis Obispo viii This page intentionally left blank. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-1 EXECUTIVE SUMMARY This section summarizes the characteristics of the proposed San Luis Ranch Project, alternatives to the project, as well as environmental impacts, mitigation measures, and residual impacts associated with the project. PROJECT SYNOPSIS Lead Agency City of San Luis Obispo Community Development Department 919 Palm Street San Luis Obispo, California 93401 Contact: Doug Davidson, Deputy Director John Rickenbach, AICP, Project Manager Project Proponent Coastal Community Builders c/o Marshall Ochylski (Project Representative) 979 Osos, Suite F7 San Luis Obispo, CA 93401 P.O. Box 13 Pismo Beach, CA 93449 Project Description The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment/Pre-Zoning, and Development Plan/Vesting Tentative Tract Map for a 131-acre project site, including annexation of the site into the City of San Luis Obispo. It would also address a Development Agreement/Memorandum of Understanding, which provides a mechanism for project implementation. The project is intended to be consistent with the development parameters described in the City’s Land Use and Circulation Element (adopted in December 2014). The project includes construction of up to 580 residential units, 150,000 square feet of commercial development, 100,000 square feet of office development, and a 200-room hotel, with a portion of the site preserved for agriculture and open space uses. The project is planned to be constructed in six phases, beginning in 2017. The specific location and characteristics of the project are described in greater detail in Section 2.0, Project Description. ALTERNATIVES As required by Section 15126(d) of the State CEQA Guidelines, this EIR examines a range of reasonable alternatives to the project that could feasibly achieve similar objectives. This includes the following four alternatives: San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-2 • Alternative 1: No Project, No Development • Alternative 2: No Project, Measure J Entitlements • Alternative 3: Historical Resource Preservation • Alternative 4: 50% On-Site Agriculture/Open Space Alternative 1 assumes that the San Luis Ranch Specific Plan is not adopted, that none of the proposed entitlements are implemented, including annexation to the City, and that no further development would occur on the project site. Alternative 2 also assumes that the Specific Plan is not adopted and that none of the proposed entitlements are implemented, including annexation to the City. However, this alternative represents a project that would be processed by San Luis Obispo County, and considers what would be reasonably expected to occur in the foreseeable future based on current plans and consistency with available infrastructure and community services. There are existing entitlements on the project site for development in the County from the voter-approved initiative known as “Measure J,” which include 60 multi-family dwelling units, 560,000 square feet of regional commercial and outdoor sales areas, 198,000 square feet of office space, a 150- room hotel and ancillary facilities. Because the Measure J entitlements would leave the project site under the jurisdiction of the County, but surrounded entirely by the City limit, these entitlements would also require the use of private water from onsite wells and an onsite wastewater treatment facility. Since this alternative (Alternative 2) assumes that the project site would be developed under an existing entitlement, this alternative would not require environmental review under CEQA. Alternative 3 would preserve the San Luis Ranch Complex, as well as associated eucalyptus trees, located in the northwest portion of the project site would be retained, and assumes that the proposed multi-family residential development would be relocated and integrated into the proposed single-family residential development area on the central portion of the project site. By preserving the San Luis Ranch Complex, this alternative would avoid the project’s significant and unavoidable impact to historic resources. In addition, this alternative would also reduce other potential environmental impacts to air quality, GHG emissions, noise, biological resources, land use/policy consistency, and hydrology and water quality, while resulting in slightly increased impacts to transportation. Alternative 4 would retain 50 percent of the net site acreage as on-site agricultural and open space uses to be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f. This alternative would retain the portion of land designated for commercial uses (NC) southeast of Froom Ranch Way and southwest of Prado Road in agriculture. This alternative would reduce the portion of the site available for residential and commercial development on the project site. The No Project, No Development Alternative (Alternative 1) would have the fewest environmental impacts. However, since this is a “No Project” alternative, CEQA requires that a separate alternative also be identified as the Environmentally Superior Alternative. Because Alternative 3 would avoid the significant and unavoidable impact to historic resources identified for the project, as well as reducing other potential environmental effects due to the preservation of the eucalyptus grove in the northwest portion of the project site along Madonna Road, and due to the reduced overall development footprint this alternative is identified as the environmentally superior alternative over other alternatives. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-3 The complete alternatives analysis is included in Section 6.0, Alternatives. AREAS OF CONCERN Pursuant to State CEQA Guidelines §15123(b)(2), this EIR acknowledges the areas of controversy and issues to be resolved which are known to the City of San Luis Obispo or were raised during the scoping process. A Notice of Preparation (NOP) was prepared and circulated for a 30-day public review period that began on October 26, 2015 and ended November 24, 2015. Several comment letters from public agencies and members of the public were received in response to the NOP. The NOP and Initial Study, and NOP comment letters are included in Appendix A of this EIR. Primary environmental areas of concern raised by the commenting agencies and public include: AREA OF CONCERN EIR SECTION Access to U.S. Highway 101 Section 4.12: Transportation Drainage characteristics, hydrology, flooding, and other impacts associated with the area floodplain Section 4.8: Hydrology and Water Quality Aviation Safety and airport/aviation hazards Section 4.7: Hazards, Section 4.9: Land Use/Policy Consistency Construction equipment regulation and permit requirements associated with air pollution emissions Section 4.3: Air Quality Existing structure demolition and potential to encounter asbestos containing materials Section 4.7: Hazards Naturally occurring asbestos exposure Section 4.3: Air Quality Operational permit requirements associated with air pollutant emissions Section 4.3: Air Quality Long-term and short-term air quality impacts Section 4.3: Air Quality Impacts associated with greenhouse gas emissions Section 4.6: Greenhouse Gas Emissions Alternatives to the project Section 6.0: Alternatives Routing plans relative to access to site and nearby land uses Section 4.12: Transportation Residential displacement Section 4.9: Land Use/Policy Consistency, Section 4.14: Issues Addressed in the Initial Study FINAL EIR ERRATA In accordance with Section 15088 of the State CEQA Guidelines, Draft EIR was circulated for a 52-day public review period that began December 9, 2016 and concluded on January 31, 2017. Each written and verbal comment that the City received is included in Section 8.0, Responses to Comments. Responses to these comments have been prepared to address the environmental concerns raised by the commenters and to indicate where and how the Draft EIR addresses pertinent environmental issues. The Draft EIR and responses to comments collectively comprise the Final EIR for the project. The responses to comments summarize the comment and direct the commenter to the section of the Draft EIR that addresses their comment. In some cases, revisions have been made to the San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-4 Draft EIR to clarify information, data, or intent, or to make minor typographical corrections or minor working changes. Any changes made to the text of the Draft EIR to are noted in the Final EIR as changes from the Draft EIR. Where a comment results in a change to the Draft EIR text, a notation is made in the response indicating that the text is revised. Changes in the Draft EIR text are signified by strikeouts where text is removed and by underline font where text is added. If text is added where the font is already bold or underlined, additions are noted using underlined bold font. Mitigation measures in the Draft EIR that were revised as part of the responses to comments are listed below. Revisions to these mitigation measures are also shown in Table ES- 1, applicable sections of the Draft EIR, and in Section 8.0, Responses to Comments.  AG-1. Agricultural Conservation.  AQ-2(a). Fugitive Dust Control Measures.  AQ-2(b). Standard Control Measures for Construction Equipment.  AQ-2(e). Construction Activity Management Plan.  AQ-3(a). Standard Operational Mitigation Measures.  BIO-1(e). Steelhead Impact Avoidance and Minimization.  BIO-1(f). Great Blue Heron and Monarch Butterfly Impact Avoidance and Minimization.  BIO-2(b). Tree Replacement.  CR-1(a). Historical Structure Relocation and Reconstruction Plan.  HAZ-5(a). Groundwater Assessment for Contamination at Untested Wells.  HAZ-5(b). Groundwater Remediation.  HWQ-3(a). Stormwater Quality Treatment Controls.  N-4(b). Parking Lot/Loading Dock Orientation and Noise Barrier.  N-5(a). Interior Noise Reduction.  N-5(c). Froom Ranch Way Noise Barrier.  N-5(d). U.S. Highway 101 Noise Barrier at Hotel. In addition, a portion of the Draft EIR was recirculated for a 45-day public review period that began March 3, 2017 and concluded on April 17, 2017. The portion of the Draft EIR that was recirculated (“Recirculated Portions”) was Section 5.0, Other CEQA-Related Discussions, which was revised to include an updated discussion of energy use and conservation related to the project. This recirculation also included the relevant portions of Appendix D as originally contained in the Draft EIR. As a result of this new discussion, no new significant impacts or mitigation measures were identified. Pursuant to Section 15088.5(c) of the State CEQA Guidelines, if the revisions subject to recirculation are limited to a few portions of the Draft EIR, the lead agency need only recirculate the portions that have been modified. Section 8.0, San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-5 Responses to Comments, includes responses to all comments received on the recirculated portions of the Draft EIR during the additional public review period. None of the comment received in response to the recirculated portions of the Draft EIR required revisions to the Draft EIR. SUMMARY OF IMPACTS AND MITIGATION MEASURES Tables ES-1 through ES-3 provide a summary of the potential environmental impacts of the project. The mitigation measures associated with each impact, which are to be implemented in order to reduce the environmental impacts to the maximum extent feasible, are also summarized therein. In accordance with the State CEQA Guidelines, the tables identify the following types of potential impacts associated with the project:  Class I, Significant and Unavoidable: An impact that cannot be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires a ‘Statement of Overriding Considerations’ to be issued if the project is approved per §15093 of the State CEQA Guidelines.  Class II, Significant but Mitigable: An impact that can be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires ‘Findings’ to be made under §15091 of the State CEQA Guidelines.  Class III, Not Significant: An impact that may be adverse, but does not exceed the threshold levels and does not require mitigation measures. However, mitigation measures that could further lessen the environmental effect may be suggested if readily available and easily achievable. Significant and Unavoidable Impacts The project would result in twelve significant and unavoidable (Class I) impacts. Issue areas with Class I impacts include air quality (Clean Air Plan consistency and cumulative air quality impacts), cultural resources (historic resources and cumulative historic resources), land use/policy consistency (General Plan policy consistency), noise (construction noise), and transportation (existing and near-term intersection operations, existing and near-term lane capacities, existing and near-term segment operations, cumulative intersection operations, cumulative lane capacities, and cumulative segment operations). San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-6 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact AIR QUALITY Impact AQ-1. The project would be inconsistent with the SLOAPCD 2001 Clean Air Plan because it would result in an increase in vehicle miles traveled (VMT) that would exceed the rate of population growth. This impact would be Class I, significant and unavoidable. AQ-1. Encourage Telecommuting. The project applicant or developers of individual projects within the Specific Plan Area shall include provisions to encourage employers within the proposed commercial, office, and hotel components of the project to implement telecommuting programs and include teleconferencing capabilities, such as web cams or satellite linkage, which will allow employees to attend meetings remotely without requiring them to travel out of the area. Mitigation is not available that would reduce projected VMT such that the project’s vehicle trip rate increase would not exceed population growth in the region. Therefore, impacts related to consistency with the 2001 CAP would remain significant and unavoidable. Cumulative Air Quality Impacts. The project is inconsistent with the 2001 CAP and would exceed SLOAPCD construction and operational thresholds. As such, cumulative impacts on air quality would be Class I, significant and unavoidable. No additional mitigation is available to address cumulative air quality impacts. Cumulative air quality impacts would remain significant and unavoidable. CULTURAL RESOURCES Impact CR-1. The project would result in the relocation, demolition, and removal of structures on the San Luis Ranch property which are individually identified as historic resources. In addition, the project would eliminate the San Luis Ranch Complex, which is eligible for listing as a historic resource. Relocation, demolition, and/or removal of these historic resources would permanently alter the historic context of the project site and on-site structures. This impact CR-1(a). Historical Structure Relocation and Reconstruction Plan. In order to implement Specific Plan Policy 2.5, a relocation and reconstruction plan for the former spectator’s barn/viewing stand, and main residence, and main barn shall be developed by a qualified historic architect. The plan shall include a structural/architectural report documenting existing integrity and conditions and include detailed treatment methods and measures to ensure that historic integrity is retained and that all identified character defining features will be preserved. CR-1(b). Archival Documentation of Historic Buildings. The applicant shall provide archival documentation of the San Luis Ranch Complex in as-built and as- found condition in the form of an Historic American Building Survey (HABS) Level II documentation. The documentation shall comply with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation (NPS 1990), and shall include large-format photographic recordation, detailed historic narrative report, and compilation of historic research. The documentation shall be completed by a qualified architectural historian or historian who meets the Secretary of the Interior’s The removal and/or demolition of the historically significant main barn and the relocation, demolition, and removal of other structures in the San Luis Ranch Complex would change the historic context of the San Luis Ranch property. Furthermore, mitigation would not avoid the removal of the main barn, despite the proposed reuse of salvageable materials from the structure to the greatest extent possible in the construction of a new barn in the project’s proposed Agricultural Heritage and Learning Center. Therefore, the potential San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-7 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact would be Class I, significant and unavoidable. Professional Qualification Standards for History and/or Architectural History (NPS 1983). The original archival-quality documentation shall be offered as donated material to the History Center of San Luis Obispo County. Archival copies of the documentation shall also be submitted to the San Luis Obispo County Library. CR-1(c). Informational Display of Historic Resources. A retrospective interpretive display detailing the history of the San Luis Ranch Complex and the project site, its significance, and its important details and features shall be developed by the applicant. The information should be incorporated into a publicly-accessed building on the project site, such as the proposed Agricultural Heritage Facilities and Learning Center, or a publicly-accessed outdoor location. The display shall include images and details from the HABS documentation described in Mitigation Measure CR-1(b) and any collected research pertaining to the historic property. The content shall be prepared by a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualification Standards for History and/or Architectural History (NPS 1983). impact to the San Luis Ranch Complex and the main barn individually would remain significant and unavoidable despite implementation of the required mitigation. Cumulative Cultural Resources Impacts. The project would result in a significant and unavoidable impact associated with the removal, relocation, or reconstruction of individually historic structures that are part of the historically significant San Luis Ranch Complex. As such, the project would contribute to the cumulative loss of historic resources in the City. Therefore, the project would result in a Class I, significant and unavoidable, cumulative impact to historical resources. No additional mitigation is available to address cumulative cultural resources impacts. Cumulative cultural resources impacts would remain significant and unavoidable. LAND USE Impact LU-1. The project would be potentially inconsistent with adopted City policies in the General Plan designed to The following Mitigation Measures would apply to this impact: • Section 4.1, Aesthetics: AES-1(a) and AES-1(b) • Section 4.2, Agricultural Resources: AG-1, AG-3 • Section 4.4, Biological Resources: BIO-1(a) through BIO-1(h) and BIO-2(a) Specific Plan conflicts with Land Use Element Policy 1.10.4 (Design Standards), Land Use Element Policy 8.1.4 (SP-2, San Luis Ranch San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-8 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact protect historical resources, and ensure provision of parkland. This would be a Class I, significant and unavoidable, impact. through BIO-2(c) • Section 4.5, Cultural Resources: CR-1(a) through CR-1(c) • Section 4.7, Hazards and Hazardous Materials: HAZ-4, HAZ-5(a), HAZ-5(b), HAZ-6 • Section 4.10, Noise: N-1(a) through N-1(g), N-4(a), N-4(b), N-5(a) through N- 5(d) • Section 4.12, Transportation and Circulation: T-1(a) through T-1(i), T-2(a) through T-2(j), T-3(a) through T-3(d), T-4, T-5, T-6, T-7, T-8(a) through T-8(g), T-9(a) through T-9(m), T-10(a) through T-10(c) • Section 4.14, Issues Addressed in the Initial Study: GEO-1, GEO-3 (Dalidio) Specific Plan Area), and Conservation and Open Space Element Policy 3.3.2 (Demolitions) would remain potentially inconsistent. The City acknowledges the importance and breadth of the potential inconsistencies associated with the Specific Plan by finding them to be Class I, significant and unavoidable impacts. NOISE Impact N-1. Temporary construction activity would create noise that could exceed City of San Luis Obispo Municipal Code regulations. Mitigation is available to address construction noise, but it may not be feasible to reduce the impact to less than the applicable threshold. Impacts would be Class I, significant and unavoidable. N-1(a). Construction Vehicle Travel Route. Construction vehicles and haul trucks shall utilize roadways which avoid residential neighborhoods and sensitive receptors where possible. The applicant shall submit a proposed construction vehicle and hauling route for City review and approval prior to grading/building permit issuance. The approved construction vehicle and hauling route shall be used for soil hauling trips prior to construction as well as for the duration of construction. N-1(b). Construction Activity Timing. Except for emergency repair of public service utilities, or where an exception is issued by the Community Development Department, no operation of tools or equipment used in construction, drilling, repair, alteration, or demolition work shall occur daily between the hours of 7:00 PM and 7:00 AM, or any time on Sundays, holidays, or after sunset, such that the sound creates a noise disturbance that exceeds 75 dBA for single family residential, 80 dBA for multi-family residential, and 85 dBA for mixed residential/commercial land uses across a residential or commercial property line. N-1(c). Construction Equipment Best Management Practices (BMPs). For all construction activity at the project site, noise attenuation techniques shall be employed to ensure that noise levels are maintained within levels allowed by the City of San Luis Obispo Municipal Code, Title 9, Chapter 9.12 (Noise Control). Such techniques shall include: • Sound blankets on noise-generating equipment. • Stationary construction equipment that generates noise levels above 65 dBA at the project boundaries shall be shielded with barriers that meet a sound transmission class (a rating of how well noise barriers attenuate sound) of 25. • All diesel equipment shall be operated with closed engine doors and shall be Mitigation Measures N-1(a) through N-1(g) require implementation of noise reduction devices and techniques during construction, and would reduce noise associated with on- and off-site construction activity to the maximum extent feasible. Noise from trucks can reach up to 88 dBA at 50 feet from the source. Although Mitigation Measure N-1(a) would reduce impacts from haul trucks by requiring the haul route to avoid residential areas and noise sensitive uses where possible, haul truck noise would continue to exceed the 75 dBA threshold for intermittent noise. Therefore, noise impacts from haul trucks would be minimized, but not eliminated. As a result, temporary noise impacts associated with off-site construction activity would be significant and unavoidable. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-9 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact equipped with factory-recommended mufflers. • For stationary equipment, the applicant shall designate equipment areas with appropriate acoustic shielding on building and grading plans. Equipment and shielding shall be installed prior to construction and remain in the designated location throughout construction activities. • Electrical power shall be used to power air compressors and similar power tools. • The movement of construction-related vehicles, with the exception of passenger vehicles, along roadways adjacent to sensitive receptors shall be limited to the hours between 7:00 AM and 7:00 PM, Monday through Saturday. No movement of heavy equipment shall occur on Sundays or official holidays (e.g., Thanksgiving, Labor Day). • Temporary sound barriers shall be constructed between construction sites and affected uses. TRANSPORTATION Impact T-1. Under Existing and Near-Term Plus Project conditions nine study area intersections would operate at unacceptable automobile, bicycle, or pedestrian LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at seven of these intersections to an acceptable level. However, impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections would be Class I, significant and unavoidable. T-1(a) Intersection #1: Madonna Road & Los Osos Valley Road. • City optimize signal timing to accommodate increased project volumes (ongoing) T-1(b) Intersection #3: Madonna Road & Dalidio Drive/Prado Road. • Extend existing westbound left turn lane on Madonna Road to Dalidio Drive/Prado Road to 310’ (Phase 1) • Install 2nd westbound 310’ left turn lane on Madonna Road to Dalidio Drive/Prado Road (Phase 1) • Install eastbound 250’ right turn pocket on Madonna Road to Dalidio Drive/Prado Road (Phase 1) • Install 2nd northbound left shared with through-lane on Prado Road/Dalidio Drive to Madonna Road (Phase 1) • Prohibit westbound U-turns on Madonna Road (Phase 1) • Provide split phase operations & optimize signal timing (Phase 1) T-1(c) Intersection #5: Madonna Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass-Only, Phase 2) T-1(d) Intersection #8: Higuera Street & South Street. • Optimize Signal Timing Potential right-of-way constraints at Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way may reduce the feasibility of mitigation at these intersections. Accordingly, some of the potential impacts associated with multimodal level of service standards identified for Existing and Near-Term Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with multimodal level of service standards at these intersections under Existing and Near-Term Plus Project conditions would remain significant and unavoidable. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-10 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact T-1(e) Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Install dedicated 230’ right turn lane on Los Osos Valley Road northbound Froom Ranch Way approach to northbound Froom Ranch Way Los Osos Valley Road (with Froom Ranch Way bridge construction) • Extend right turn lane on Los Osos Valley Road southbound Froom Ranch Way approach to southbound Froom Ranch Way Los Osos Valley Road to 110’ (with Froom Ranch Way bridge construction) • Install 2nd southbound left turn lane on Froom Ranch Way approach to eastbound Los Osos Valley Road (with Froom Ranch Way bridge construction) T-1(f) Intersection #10: Los Osos Valley Road & Auto Park Way. • Signalization (Phase 1) • Construct Prado Road Overpass (Overpass Only, Phase 2) T-1(g) Intersection #16: S. Higuera Street & Tank Farm Road. • Construct Prado Road Overpass (Overpass Only Phase 2) • Extend northbound right turn pocket to 230’ and channelize movement (Phase 1) T-1(h) Intersection #21: Prado Road/Dalidio Drive & Froom Ranch Way. • Install multilane roundabout control (when connection is constructed) T-1(i) Intersection #25: Prado Road/Dalidio Drive & SC Project Driveway. • Install multilane roundabout control or restricted access (when connection is constructed) impacts, as these improvements would occur within existing roadway rights-of-way, or within urbanized paved/landscaped areas immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange. During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long- term impacts of the Prado Road/U.S. 101 overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. Impact T-2. Under Existing and Near-Term Plus Project conditions, the volume of traffic at 19 study area intersections would exceed lane capacities. Mitigation would reduce impacts at 18 of these intersections to an T-2(a) Intersection #1: Madonna Road & Los Osos Valley Road. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(b) Intersection #2: Madonna Road & Oceanaire Drive. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(c) Intersection #5: Madonna Road & U.S. 101 S.B Ramps. Potential right-of-way constraints at Los Osos Valley Road & Froom Ranch Way may reduce the feasibility of mitigation at this intersection. Accordingly, some of the potential impacts associated with lane capacities identified for San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-11 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact acceptable level. However, impacts at the Los Osos Valley Road & Froom Ranch Way intersection would be Class I, significant and unavoidable. • Extend northbound Madonna Road left turn lane to 150’ (Phase 1) T-2(d) Intersection #6: Madonna Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(e) Intersection #7: Madonna Road & Higuera Street. • Construct Prado Road Overpass (Overpass Plus U.S. 101 northbound ramps, Phase 2) T-2(f) Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Install dedicated 230’ right turn lane on Los Osos Valley Road approach to northbound Froom Ranch Way (with Froom Ranch Way bridge construction) • Extend right turn lane on Los Osos Valley Road approach to southbound Froom Ranch Way to 110’ (with Froom Ranch Way Bridge construction) • Install 2nd southbound left turn lane on Froom Ranch Way approach to eastbound Los Osos Valley Road (with Froom Ranch Way bridge construction) T-2(g) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps. • Extend off-ramp left turn pocket to 320’ (Phase 1) T-2(h) Intersection #13: Los Osos Valley Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(i) Intersection #14: Los Osos Valley Road & Higuera Street. • Extend eastbound right turn lane to 180’ (Phase 1) T-2(j) Intersection #18: Prado Road & Higuera Street. • Install 2nd U.S. 101 northbound left turn lane (Phase 1) • Extend westbound right turn pocket to 400’ (Phase 1) Existing and Near-Term Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts to lane capacities at this intersection under Existing and Near-Term Plus Project conditions would remain significant and unavoidable. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual impacts, as these improvements would occur within existing roadway rights-of-way, or within urbanized paved/landscaped areas immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange. During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long- term impacts of the Prado Road/U.S. 101 San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-12 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. Impact T-3. Under Existing and Near-Term conditions four study area segment groups would operate at unacceptable automobile, bicycle, pedestrian, and transit LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at three of these segment groups to an acceptable level. However, impacts at Higuera Street roadway segments would be Class I, significant and unavoidable T-3(a) Segments #1 - #6: Madonna Road (Los Osos Valley Road to Higuera Street) • Construct Prado Road Overpass (Overpass Only, Phase 2) • Fund assessment of decreasing transit headways to 25 min • Construct parallel Class I multiuse paths or bike boulevard (Phase 1) T-3(b) Segments #7 - #8: Higuera Street (Madonna Road to Prado Road) • Construct Prado Road Overpass (Overpass and U.S. 101 northbound ramps, Phase 2) • Construct parallel Class I multiuse paths or bike boulevard (Phase 1) T-3(c) Segments #13 - #17: Los Osos Valley Road (Madonna Road to Higuera Street) • Construct Prado Road Overpass (Overpass and U.S. 101 northbound ramps, Phase 2) • Construct parallel Class I multiuse paths or bike boulevard (Phase 3) T-3(d) Segments #18 - #20: Dalidio Drive/Prado Road (Froom Ranch Way to Higuera Street) • Construct parallel Class I multiuse paths or bike boulevard (when Prado Road is constructed/improved) Implementation of the identified mitigation measures would improve LOS at all impacted study area roadway segments to acceptable levels, and impacts on these facilities under Existing and Near- Term Plus Project conditions would be less than significant after mitigation. However, potential right- of-way constraints along Higuera Street (Segments #7 and #8) may reduce the feasibility of mitigation along these segments. Accordingly, some of the potential impacts associated with multimodal level of service standards identified for Existing and Near-Term Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with multimodal level of service standards at these roadway segments under Existing and Near-Term Plus Project conditions would remain significant and unavoidable. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual impacts, as these improvements would occur within existing roadway San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-13 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact rights-of-way, or within urbanized paved/landscaped areas immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange. During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long- term impacts of the Prado Road/U.S. 101 overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. Impact T-8. Under Cumulative Plus Project conditions nine study area intersections would operate at unacceptable automobile, bicycle, or pedestrian LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation T-8(a). Intersection #3: Madonna Road & Dalidio Drive/Prado Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-1[b]) T-8(b). Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[e]/Mitigation Measure T-2[f]) T-8(c). Intersection #10: Los Osos Valley Road & Auto Park Way. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-1[f]) Potential right-of-way constraints at Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way may reduce the feasibility of mitigation at these intersections. Accordingly, some of the potential impacts associated with multimodal level of service standards identified for Cumulative San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-14 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact would reduce impacts at seven of these intersections to an acceptable level. However, impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections would be Class I, significant and unavoidable. T-8(d). Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-8(e). Intersection #13: Los Osos Valley Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-8(f). Intersection #14: Los Osos Valley Road & S. Higuera Street. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-8(g). Intersection #16: S. Higuera Street & Tank Farm Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-1[f]) Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with multimodal level of service standards at these intersections under Cumulative Plus Project conditions would remain significant and unavoidable. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual impacts, as these improvements would occur within existing roadway rights-of-way, or within urbanized paved/landscaped areas immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange. During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long- term impacts of the Prado Road/U.S. 101 overpass/interchange would include San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-15 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. Impact T-9. Under Cumulative Plus Project conditions, the volume of traffic at 18 study area intersections would exceed lane capacities. Mitigation would reduce impacts at 18 of these intersections to an acceptable level. Mitigation would reduce impacts at 17 of these intersections to an acceptable level. However, impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections would be Class I, significant and unavoidable. T-9(a). Intersection #1: Madonna Road & Los Osos Valley Road. • Extend northbound right turn pocket on Los Osos Valley Road to 295’ • Extend southbound left turn pocket on Madonna Road to 395’ T-9(b). Intersection #2: Madonna Road & Oceanaire Drive. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-1[b]) • Extend westbound right turn land on Madonna Road to 200’ T-9(c). Intersection #3: Madonna Road & Dalidio Drive. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-1[b]) T-9(d). Intersection #4: Madonna Road & El Mercado. • Existing & Near-Term Plus Project Mitigation (Mitigation Measures T-1[b]) T-9(e). Intersection #5: Madonna Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(f). Intersection #6: Madonna Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(g). Intersection #8: Higuera Street & South Street. • Extend northbound Higuera Street left turn pocket to 120’ • Extend eastbound South Street right turn pocket to 100’ T-9(h). Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[d]/Mitigation Measure T-2[f]) T-9(i). Intersection #11: Los Osos Valley Road & Calle Joaquin. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and Potential right-of-way constraints at Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way may reduce the feasibility of mitigation at these intersections. Accordingly, some of the potential impacts associated with lane capacities identified for Cumulative Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts to lane capacities at these intersections under Cumulative Plus Project conditions would remain significant and unavoidable. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual impacts, as these improvements would occur within existing roadway rights-of-way, or within urbanized paved/landscaped areas immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange. During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-16 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact southbound ramps) T-9(j). Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(k). Intersection #14: Los Osos Valley Road & S. Higuera Street. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(l). Intersection #16: S. Higuera Street & Tank Farm Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-1[g]) T-9(m). Intersection #18: Higuera Street & Prado Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T-2[j]) include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long- term impacts of the Prado Road/U.S. 101 overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. Impact T-10. Under Cumulative Plus Project conditions five study area segment groups, as well as mainline segments of U.S. 101, would operate at unacceptable automobile, bicycle, pedestrian, and transit LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at each of the five study area segment groups to an acceptable level. However, impacts at the mainline segments of U.S. 101 at Los Osos Valley Road and Madonna Road would be Class I, significant and unavoidable. T-10(a). Segments #1 - #6: Madonna Road (Higuera Street to Los Osos Valley Road). • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-10(b). Segments #15 - #16: Los Osos Valley Road (Calle Joaquin to U.S. 101 Northbound Ramps). • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-10(c). Segment #24: Prado Road/Dalidio Drive (Project Driveway to Froom Ranch Way). • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) Potential impacts identified for the northbound and southbound lanes of the mainline segments of U.S. 101 at Los Osos Valley Road and Madonna Road under Cumulative Plus Project conditions would not be mitigated to a less than significant level. As a result, impacts under Cumulative Plus Project conditions would remain significant and unavoidable. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual impacts, as these improvements would occur within existing roadway rights-of-way, or within urbanized paved/landscaped areas San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-17 Table ES-1 Class I, Significant and Unavoidable Environmental Impacts Impact Mitigation Measures Residual Impact immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange. During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long- term impacts of the Prado Road/U.S. 101 overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-18 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact AGRICULTURAL RESOURCES Impact AG-1. The project would result in the direct conversion of 59.356 acres of Prime Farmland, as mapped by the FMMP, to non-agricultural uses. Therefore, impacts would be Class II, significant but mitigable. AG-1. Agricultural Conservation. Prior to issuance of any grading permits the project proponent shall provide that for every one (1) acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to non-agricultural use as a result of project development, one (1) acre of land of comparable agricultural productivity shall be preserved in perpetuity. The land dedicated to agriculture pursuant to this measure shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. The acreage required to meet the 1:1 ratio may be met by the off-site agricultural conservation easement/deed restriction proposed by the project applicant, as long as this land meets the conditions outlined in this measure. Said mitigation shall be satisfied by the applicant through: 1) Granting a perpetual conservation easement(s), deed restriction(s), or other farmland conservation mechanism(s) to the City or qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, for the purpose of permanently preserving agricultural land. The required easement(s) area or deed restriction(s) shall therefore total a minimum of 59.356 acres of Prime Farmland. The land covered by said on- and/or off-site easement(s) or deed restriction(s) shall be located within or contiguous to the City’s Urban Reserve Line or Greenbelt subject to review and approval of the City’s Natural Resources Manager; or 2) Making an in-lieu payment to a qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, to be applied toward the future purchase of a minimum of 59.356 acres of Prime Farmland in San Luis Obispo County, together with an endowment amount as may be required. The payment amount shall be determined by the qualifying entity or a licensed appraiser; or 3) Making an in-lieu payment to a qualifying entity which has been approved by the City and that is organized for conservation purposes, to be applied toward a future perpetual conservation easement, deed restriction, or other farmland conservation mechanism to preserve a minimum of 59.356 acres of Prime Farmland in San Luis Obispo County. The amount of the payment shall be determined by the qualifying entity or a licensed appraiser; or 4) Any combination of the above. W ith implementation of Mitigation Measure AG-1, this impact would be reduced to a less than significant level. Impact AG-3. The project would include development of commercial and residential uses adjacent to agricultural uses on AG-3(a). Agricultural Conflict Avoidance Measures. The following language shall be added to Section 4.2.1, Agricultural Buffer, of the San Luis Ranch Specific Plan: Agricultural buffers will include City-approved measures to reduce availability of W ith implementation of Mitigation Measures AG-3(a) through AG-3(c) this impact would be reduced to a less than significant level. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-19 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact the project site. This may result in conflict with existing or future urban and agricultural zoning and uses and adversely affect the long-term viability of the remaining agricultural uses onsite and at the adjacent SLO City Farm. However, with implementation of agricultural buffers, and compliance with standard APCD dust control measures and City policies, this impact would be Class II, significant but mitigable. public access to agricultural cultivation areas adjacent to the project site (e.g., fencing, signs, etc.). Future residents will be notified of agricultural buffers as part of purchase or lease agreements. AG-3(b). Agricultural Fencing. The project applicant shall coordinate with the City to fund installation of fencing and signs along Froom Ranch Way and Dalidio Drive/Prado Road to minimize potential for increases in trespass and vandalism of adjacent agricultural areas. AG-3(c). Buffer Landscaping. To reduce the potential for noise, dust, and pesticide drift to affect future residents on the project site, the project applicant shall ensure that project landscape plans include planting of a windrow of trees and shrubs within the agricultural buffer along Froom Ranch Way at a sufficient density to buffer the site from surrounding agricultural operations. AIR QUALITY Impact AQ-2. Construction of the project would generate temporary increases in localized air pollutant emissions. Construction emissions of ROG, NOX, and DPM would exceed SLOAPCD construction thresholds. Impacts would be Class II, less than significant with mitigation incorporated. AQ-2(a). Fugitive Dust Control Measures. Construction projects shall implement the following dust control measures so as to reduce PM10 emissions in accordance with SLOAPCD requirements. • Reduce the amount of the disturbed area where possible; • Water trucks or sprinkler systems shall be used during construction in sufficient quantities to prevent airborne dust from leaving the site. Increased watering frequency shall be required whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water or a SLOAPCD-approved dust suppressant shall be used whenever possible;, to reduce the amount of potable water used for dust control; • All dirt stock pile areas shall be sprayed daily as needed; • Permanent dust control measures identified in the approved project revegetation and landscape plans shall be implemented as soon as possible following completion of any soil disturbing activities; • Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading shall be sown with a fast germinating, non- invasive grass seed and watered until vegetation is established; • All disturbed soil areas not subject to revegetation shall be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the SLOAPCD; • All roadways, driveways, sidewalks, etc. to be paved shall be completed as soon as possible after grading unless seeding or soil binders are used; According to the SLOAPCD CEQA Air Quality Handbook, if estimated construction emissions are expected to exceed either of the SLOAPCD Quarterly Tier 2 thresholds of significance after the standard and BACT measures are factored into the estimation, then an SLOAPCD approved Construction Activity Management Plan (CAMP) and offsite mitigation need to be implemented in order to reduce potential air quality impacts to a less than significant level. If construction emissions do not exceed Tier 2 thresholds with implementation of standard and BACT measures, SLOAPCD considers emissions less than significant, even if Tier 1 thresholds continue to be exceeded. Table 4.3-7 shows mitigated construction emissions with implementation of San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-20 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact • Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site; • All trucks hauling dirt, sand, soil, or other loose materials are to be covered or shall maintain at least two feet of freeboard (minimum vertical distance between top of load and top of trailer) in accordance with California Vehicle Code Section 23114; • Install wheel washers where vehicles enter and exit unpaved roads onto streets, or wash off trucks and equipment leaving the site; • Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers with reclaimed water shall be used where feasible; • All of these fugitive dust mitigation measures shall be shown on grading and building plans; and • The contractor or builder shall designate a person or persons to monitor the fugitive dust emissions and enhance the implementation of the measures as necessary to minimize dust complaints, reduce visible emissions below 20 percent opacity, and to prevent transport of dust offsite. Their duties shall include holidays and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the SLOAPCD Compliance Division prior to the start of any grading, earthwork or demolition. AQ-2(b). Standard Control Measures for Construction Equipment. The following standard air quality mitigation measures shall be implemented during construction activities at the project site: • Maintain all construction equipment in proper tune according to manufacturer’s specifications; • Fuel all off-road and portable diesel powered equipment with ARB certified motor vehicle diesel fuel (non-taxed version suitable for sue off-road); • Use diesel construction equipment meeting ARB’s Tier 2 certified engines or cleaner off-road heavy-duty diesel engines, and comply with the State Off-Road Regulation; • Use on-road heavy-duty trucks that meet the ARB’s 2007 or cleaner certification standard for on-road heavy-duty diesel engines, and comply with the State On-Road Regulation; • Construction or trucking companies with fleets that do not have engines in their fleet that meet the engine standards identified in the above two measures (e.g. captive or NOX exempt area fleets) may be eligible by proving alternative compliance; Tier 3 off-road engine compliance and level 2 diesel particulate filters required by Mitigation Measure AQ- 2(c), as well as low VOC-emission paint required by Mitigation Measure AQ-2(d). As shown therein, with implementation of Mitigation Measures AQ-2(c) and AQ-2(d) construction emissions would not exceed either of the SLOAPCD Quarterly Tier 2 thresholds of significance. Therefore, implementation of a CAMP and offsite mitigation is not required and impacts would be less than significant with mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-21 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact • On-road diesel vehicles shall comply with Section 2485 of Title 13 of the California Code of Regulations. This regulation limits idling from diesel-fueled commercial motor vehicles with gross vehicular weight ratings of more than 10,000 pounds and licensed for operation on highways. It applies to California and non-California based vehicles. In general, the regulation specifies that drivers of said vehicles: 1. Shall not idle the vehicle's primary diesel engine for greater than 5-minutes at any location, except as noted in Subsection (d) of the regulation; and, 2. Shall not operate a diesel-fueled auxiliary power system (APS) to power a heater, air conditioner, or any ancillary equipment on that vehicle during sleeping or resting in a sleeper berth for greater than 5.0 minutes at any location when within 1,000 feet of a restricted area, except as noted in Subsection (d) of the regulation. • Off-road diesel equipment shall comply with the 5-minute idling restriction identified in Section 2449(d)(2) of the California Air Resources Board's In-Use Off-Road Diesel regulation. • All on and off-road diesel equipment shall not idle for more than 5 minutes. Signs shall be posted in the designated queuing areas and or job sites to remind drivers and operators of the 5 minute idling limit; • In addition to the state required diesel idling requirements, the project applicant shall comply with these more restrictive requirements to minimize impacts to nearby sensitive receptors: 1. Signs that specify the no idling areas shall be posted and enforced at the site. 2. Diesel idling within 1,000 feet of sensitive receptors is not permitted; 3. Staging and queuing areas shall not be located within 1,000 feet of sensitive receptors; 4. Use of alternative fueled equipment is recommended; • Electrify equipment when feasible; • Substitute gasoline-powered in place of diesel-powered equipment, where feasible; and • Use alternatively fueled construction equipment on-site where feasible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel. AQ-2(c). Best Available Control Technology (BACT) for Construction Equipment. The following BACT for diesel-fueled construction equipment shall be implemented during construction activities at the project site, where feasible: • Further reducing emissions by expanding use of Tier 3 and Tier 4 off-road and San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-22 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact 2010 on-road compliant engines where feasible; • Repowering equipment with the cleanest engines available; and • Installing California Verified Diesel Emission Control Strategies, such as level 2 diesel particulate filters. These strategies are listed at: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm AQ-2(d). Architectural Coating. To reduce ROG and NOX levels during the architectural coating phase, low or no VOC-emission paint shall be used with levels of 50 g/L or less. AQ-2(e). Construction Activity Management Plan. Emissions reduction measures and construction practices required to comply with Mitigation Measures AQ-2(a) through AQ-2(d) shall be documented in a Construction Activity Management Plan (CAMP) and submitted to SLOAPCD for review and approval at least three months before the start of construction. The CAMP shall include a Dust Control Management Plan, tabulation of on and off-road construction equipment (age, horse-power and miles and/or hours of operation), construction truck trip schedule, construction work-day period, and construction phasing. If implementation of the Standard Mitigation and Best Available Control Technology measures cannot bring the project below the Tier 1 threshold (2.5 tons of NOX+ROG per quarter), off-site mitigation shall be implemented in coordination with SLOAPCD to reduce NOX and ROG emissions to below the Tier 1 threshold. Impact AQ-3. Operation of the project would generate air pollutant emissions on an ongoing daily and annual basis. The project’s daily emissions would exceed SLOAPCD daily emissions thresholds, but would not exceed annual thresholds. Implementation of SLOAPCD’s standard mitigation measures and off-site mitigation would reduce emissions to a less than significant level. Impacts would be Class II, less than significant with mitigation incorporated. AQ-3(a). Standard Operational Mitigation Measures. Prior to issuance of grading permits, the applicant shall define and incorporate into the San Luis Ranch Specific Plan standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook to reduce emissions to below daily threshold levels. Emission reduction measures may shall include, but would not be limited to: • Prohibit residential wood burning appliances; • Install a ‘Park and Ride’ lot with bike lockers in a location of need defined by SLOCOG; • Trusses for south-facing portions of roofs shall be designed to handle dead weight loads of standard solar-heated water and photovoltaic panels. Roof design shall include sufficient south facing roof surface, based on structures size and use, to accommodate adequate solar panels. For south facing roof pitches, the closest standard roof pitch to the ideal average solar exposure shall be used; • Increase the building energy rating by 20 percent above 2013 Title 24 requirements (used in the California Emissions Estimator Model) or consistent Implementation of the measures identified in Mitigation Measure AQ- 3(a) and AQ-3(b) would reduce impacts to regional air quality. For informational purposes, Table 4.3- 11 and Table 4.3-12 show anticipated project emissions with incorporation of measures achieving a 20 percent exceedance of Title 24 requirements and a prohibition on residential wood burning devices, which are quantifiable in CalEEMod. As shown in Table 4.3-11 and Table 4.3-12, implementation of these measures alone would not reduce daily operational emissions of San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-23 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact with 2016 Title 24 requirements, whichever is stricter. Measures used to reach the 20 percent rating cannot be double counted; • Design building to include roof overhangs that are sufficient to block the high summer sun, but not the lower winter sun, from penetrating south facing windows (passive solar design); • Utilize high efficiency gas or solar water heaters; • Install door sweeps and weather stripping (if more efficient doors and windows are not available); • Install energy-reducing programmable thermostats; • Participate in and implement available energy-efficient rebate programs including air conditioning, gas heating, refrigeration, and lighting programs; • Use roofing material with a solar reflectance values meeting the U.S. EPA/DOE Energy Star® rating to reduce summer cooling needs. • Utilize onsite renewable energy systems (e.g., solar, wind, geothermal, low- impact hydro, biomass and bio-gas); and • Provide and require the use of battery powered or electric landscape maintenance equipment for new development; • Provide a display case or kiosk displaying transportation information in a prominent area accessible to employees or residents; • Provide neighborhood electric vehicles/ car share program; • Provide bicycle-share program;. • Provide bicycle lockers for ‘Park and Ride’ lots; • Provide vanpool, shuttle, mini bus service (alternative fueled preferred); • Provide free-access telework terminals and/or wi-fi access in multi-family projects. In addition, the proposed hotel component of the Specific Plan shall participate in the SLO Car Free Program, provide incentives to car-free travelers, and promote the program in their communication tools. AQ-3(b). Off-Site Mitigation. If implementation of standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook described in Mitigation Measure AQ-3(a) is insufficient to reduce emissions to below daily threshold levels, then the applicant shall coordinate with SLOAPCD to provide funding for off-site emission reduction measures to reduce emissions to below daily threshold levels. In accordance with SLOAPCD methodology, the excess emissions shall be multiplied by the cost effectiveness of mitigation as defined in the State’s current Carl Moyer Incentive Program Guidelines to determine the annual off-site mitigation amount. This amount shall then be extrapolated over the life of the project to determine total ROG, NOX, DPM, or dust to below SLOAPCD’s daily significance thresholds. However, with implementation of Mitigation Measures AQ-3(a), Standard Operational Mitigation Measures, and AQ-3(b), Off-Site Mitigation, annual emissions would be reduced below SLOAPCD’s annual operational thresholds. Therefore, long-term operational impacts would be less than significant. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-24 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact off-site mitigation. Off-site emission reduction measures may include, but would not be limited to: • Developing or improving park-and-ride lots; • Retrofitting existing homes in the project area with SLOAPCD-approved wood combustion devices; • Retrofitting existing homes in the project area with energy-efficient devices; • Constructing satellite worksites; • Funding a program to buy and scrap older, higher emission passenger and heavy-duty vehicles; • Replacing/re-powering transit buses; • Replacing/re-powering heavy-duty diesel school vehicles (i.e. bus, passenger or maintenance vehicles); • Funding an electric lawn and garden equipment exchange program; • Retrofitting or re-powering heavy-duty construction equipment, or on-road vehicles; • Re-powering marine vessels; • Re-powering or contributing to funding clean diesel locomotive main or auxiliary engines; • Installing bicycle racks on transit buses; • Purchasing particulate filters or oxidation catalysts for local school buses, transit buses or construction fleets; • Installing or contributing to funding alternative fueling infrastructure (i.e. fueling stations for CNG, LPG, conductive and inductive electric vehicle charging, etc.); • Funding expansion of existing transit services; • Funding public transit bus shelters; • Subsidizing vanpool programs; • Subsidizing transportation alternative incentive programs; • Contributing to funding of new bike lanes; • Installing bicycle storage facilities; and • Providing assistance in the implementation of projects that are identified in City or County Bicycle Master Plans. BIOLOGICAL RESOURCES Impact BIO-1. Implementation of the project could have a substantial adverse effect on candidate, sensitive, or special status species that may occur BIO-1(a). Best Management Practices. The applicant shall ensure the following general wildlife Best Management Practices (BMPs) are required for construction activity within the San Luis Ranch Specific Plan Area: • No pets or firearms shall be allowed at the project site during construction activities. Implementation of BIO-1(a) through BIO-1(h) would reduce impacts to listed, candidate or special-status plant and wildlife species to a less than significant level and ensure San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-25 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact on the project site. Impacts would be Class II, potentially significant but mitigable. • All trash that may attract predators must be properly contained and removed from the work site. All such debris and waste shall be picked up daily and properly disposed of at an appropriate site. • All refueling, maintenance, and staging of equipment and vehicles shall occur at least 100 feet from Prefumo Creek and in a location where a spill would not drain toward aquatic habitat. A plan must be in place for prompt and effective response to any accidental spills prior to the onset of work activities. All workers shall be informed of the appropriate measures to take should an accidental spill occur. • Pallets or secondary containment areas for chemicals, drums, or bagged materials shall be provided. Should material spills occur, materials and/or contaminants shall be cleaned from the project site and recycled or disposed of to the satisfaction of the Regional Water Quality Control Board (RWQCB). • Prior to construction activities in areas adjacent to Prefumo Creek and Cerro San Luis Channel, the drainage features shall be fenced with orange construction fencing and signed to prohibit entry of construction equipment and personnel unless authorized by the City. Fencing should be located a minimum of 20 feet from the edge of the riparian canopy or top of bank and shall be maintained throughout the construction period for each phase of development. Once all phases of construction in this area are complete, the fencing may be removed. • To control sedimentation during and after project implementation, appropriate erosion control BMPs (e.g., use of coir rolls, jute netting, etc.) shall be implemented to minimize adverse effects on Prefumo Creek. No plastic monofilament netting shall be utilized on site. • Construction equipment shall be inspected at the beginning of each day to ensure that wildlife species have not climbed into wheel wells or under tracks since the equipment was last parked. Any sensitive wildlife species found during inspections shall be gently encouraged to leave the area by a qualified biological monitor or otherwise trained personnel. • All vehicles and equipment shall be in good working condition and free of leaks. • Environmentally Sensitive Areas shall be delineated by a qualified biologist prior to construction to confine access routes and construction areas. • Construction work shall be restricted to daylight hours (7:00 AM to 7:00 PM) to avoid impacts to nocturnal and crepuscular (dawn and dusk activity period) species. No construction night lighting shall be permitted within 100 yards of the top of the Prefumo Creek bank. • Concrete truck and tool washout shall be limited to locations designated by a qualified biologist such that no runoff will reach Prefumo Creek or Cerro San that the project would comply with COSE Policies 7.3.1, Protect Listed Species, and 7.3.2, Species of Local Concern. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-26 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact Luis Channel. • All open trenches shall be constructed with appropriate exit ramps to allow species that accidentally fall into a trench to escape. Trenches will remain open for the shortest period necessary to complete required work. • Existing facilities and disturbed areas shall be used to the extent possible to minimize the amount of disturbance and all new access roads other than the Froom Ranch Way Bridge shall be cited to avoid high quality habitat and minimize habitat fragmentation. • In the event that construction must occur within the creek or creek setback, a biological monitor shall be present during all such activities with the authority to stop or redirect work as needed to protect biological resources. BIO-1(b). Worker Environmental Awareness Program Training. Prior to the initiation of construction activities (including staging and mobilization), the applicant shall ensure all personnel associated with project construction attend a Worker Environmental Awareness Program (WEAP) training. • The training shall be conducted by a qualified biologist, to aid workers in recognizing special status resources that may occur in the project area. The specifics of this program shall include identification of the sensitive species and habitats, a description of the regulatory status and general ecological characteristics of sensitive resources, and review of the limits of construction and avoidance measures required to reduce impacts to biological resources within the work area. A fact sheet conveying this information shall also be prepared for distribution to all contractors, their employers, and other personnel involved with construction of the project. All employees shall sign a form provided by the trainer documenting they have attended the WEAP and understand the information presented to them. BIO-1(c) . Western Pond Turtle and Two-Striped Garter Snake Impact Avoidance and Minimization. The applicant shall ensure the following actions are implemented to avoid and minimize potential impacts to western pond turtle and two-striped garter snake (these reptiles utilize similar habitats; therefore, implementation of the proposed measures for western pond turtle are also suitable and appropriate for two-striped garter snake): • A qualified biologist(s) shall conduct a pre-construction survey within 24 hours prior to the onset of work activities within and around areas that may serve as potential western pond turtle habitat. If this species is found and the individuals are likely to be injured or killed by work activities, the approved biologist shall be allowed sufficient time to move them from the project site before work San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-27 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact activities begin. The biologist(s) must relocate the any western pond turtle the shortest distance possible to a location that contains suitable habitat that is not likely to be affected by activities associated with the project. • Access routes, staging, and construction areas shall be limited to the minimum area necessary to achieve the project goal and minimize potential impacts to western pond turtle habitat including locating access routes and construction staging areas outside of wetlands and riparian areas to the maximum extent practicable. BIO-1(d) . California Red-legged Frog, Western spadefoot, and Coast Range Newt Impact Avoidance and Minimization. The applicant shall implement the following to avoid and minimize potential impacts to CRLF. Because coast range newt and western spadefoot are amphibians that utilize similar habitats to CRLF, implementation of the following measures provided for CRLF shall be implemented for these species as well. • Only USFWS-approved biologists shall participate in activities associated with the capture, handling, and monitoring of CRLF. • Ground disturbance shall not begin until written approval is received from the USFWS that the biologist is qualified to conduct the work. If the USFWS does not authorize the relocation of CRLF occurring within the project site, CRLF found within the project site shall be avoided with a 100-foot buffer and no activities shall occur within that buffer until the CRLF has left the project site on its own. • Areas of the project site that lie within 100 feet upland from riparian or jurisdictional areas shall be surrounded by a solid temporary exclusion fence (such as silt fencing) that shall extend at least three feet above the ground and be buried into the ground at least 6 inches to exclude CRLF from the project site. Plastic monofilament netting or other similar material will not be used. The location of the fencing shall be determined by a qualified biologist. The fence shall remain in place throughout construction activities. Installation of the exclusion fencing shall be monitored by a qualified biologist to ensure that it is installed correctly. • During new grading activities in habitats within 100 feet upland from riparian or jurisdictional areas, a qualified biologist shall be on-site to recover any spadefoot toads that may be excavated/unearthed with native material or found under vegetation. If the animals are in good health, they shall be immediately relocated to a designated release area. If they are injured, the animals shall be turned over to an approved wildlife rehabilitator until they are in a condition to be released into the designated release area. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-28 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact • To ensure that diseases are not conveyed between work sites by the approved biologist, the fieldwork code of practice developed by the Declining Amphibian Populations Task Force shall be followed at all times. BIO-1(e) . Steelhead Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to steelhead: • Before any activities begin on the project, a qualified biologist will conduct a training session for all construction personnel. At a minimum, the training will include a description of the steelhead and its habitat, the specific measures that are being implemented to conserve this species for the project, and the boundaries within which the project may be accomplished. Brochures, books, and briefings may be used in the training session, provided that a qualified person is on hand to answer any questions. • During the duration of project activities, all trash that may attract predators will be properly contained and secured, promptly removed from the work site, and disposed of regularly. Following construction, all trash and construction debris will be removed from the work areas. • All refueling, maintenance, and staging of equipment and vehicles will occur at least 100 feet from riparian habitat or bodies of water and in a location where a potential spill would not drain directly toward aquatic habitat (e.g., on a slope that drains away from the water source). The monitor shall ensure that contamination of suitable habitat does not occur during such operations. Prior to the onset of work activities, a plan must be in place for prompt and effective response to any accidental spills. All workers shall be informed of the importance of preventing spills and of the appropriate measures to take should an accidental spill occur. • The number of access routes, size of staging areas, and the total area used for construction activities shall be limited to the minimum area necessary to achieve the project goals. • The City will only permit work within the immediate vicinity of Prefumo Creek for times of the year when potential impacts to steelhead would be minimal. Work shall be restricted during the wet season (October 15 through April 30) and should ideally occur during the late summer and early fall during the driest portion of the year; however, water may still be present during construction. If work is proposed in the streambed and water is present during construction, a diversion will be required to dewater the work area and the following avoidance and minimization measures will apply: (1) Upstream and downstream passage for fish, including juvenile San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-29 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact steelhead, shall be provided through or around the construction site at all times construction is occurring within the Prefumo Creek streambed. (2) A qualified biologist shall conduct a pre-construction survey and be present onsite during the diversion installation and dewatering process to capture and relocate any trapped steelhead and/or other fish. Upon approval from the NMFS, the biologist(s) must relocate these individuals the shortest distance possible to a location that contains suitable habitat that is not likely to be affected by activities associated with the project. (3) Dewatering operations shall employ a five millimeter mesh screen fastened to the intake hose to exclude fish and other wildlife species from the pump. (4) Steelhead shall be excluded from the construction zone with block nets installed upstream and downstream the of the bridge construction zone. The distance upstream and downstream for block net installation will depend on the type of construction activities occurring in the streambed. • To control sedimentation during and after project implementation, the following BMPs shall be implemented. If the BMPs are somehow ineffective, consultation with the City and appropriate resource agencies will be undertaken, and all attempts to remedy the situation will commence immediately. (1) It shall be the owner’s/contractor’s responsibility to maintain control of the entire construction operations and to keep the entire site in compliance. (2) The owner/contractor shall be responsible for monitoring erosion and sediment control measures (including but not limited to fiber rolls, inlet protections, silt fences, and gravel bags) prior, during and after storm events, monitoring includes maintaining a file documenting onsite inspections, problems encountered, corrective actions, and notes and a map of remedial implementation measures. (3) Erosion shall be controlled by covering stockpiled construction materials (i.e. soil, spoils, aggregate, fly-ash, stucco, hydrated lime, etc.) All earth stockpiles over 2.0 cubic yards that are not actively being used, shall be covered with a tarp consistent with the applicable construction general permit, or through other means of erosion control approved by the City (e.g., and ringedsurrounding with straw bales or silt fencing). The site shall be maintained to minimize sediment-laden runoff to any storm drainage system including existing drainage swales and/or sand watercourses. (a) Construction operations shall be carried out in such a manner that erosion and water pollution will be minimized. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-30 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact (b) State and local laws concerning pollution abatement shall be complied with. (c) If grading operations are expected to denude slopes, the slopes shall be protected with erosion control measures immediately following grading on the slopes. (4) Specifically, in order to prevent sedimentation and debris from entering Prefumo Creek during construction, silt fencing shall be installed along the top of the banks on the west side of the channel prior to the onset of construction activities. • The project biologist will monitor construction activities, in stream habitat, and overall performance of BMPs and sediment controls for the purpose of identifying and reconciling any condition that could adversely affect steelhead or their habitat. The biologist will halt work if necessary and will recommend site-specific measures to avoid adverse effects to steelhead and their habitat. • Equipment will be checked daily for leaks prior to the initiation of construction activities. A spill kit will be placed near the creek and will remain readily available during construction in the event that any contaminant is accidentally released. • In addition to these avoidance and minimization measures, Mitigation Measure BIO-2(a) would also ensure that potential temporary and permanent indirect impacts to steelhead from the project are reduced as much as practicable. BIO-1(f). Great Blue Heron and Monarch Butterfly Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to overwintering monarch butterflies and nesting great blue herons. • Tree trimming/removal and construction activities that affect eucalyptus trees near or within the monarch overwintering grove or active great blue heron nests identified in the San Luis Ranch Monarch Trees Inspection Memo, Results of 2015 and 2016 San Luis Ranch Heron Rookery Surveys Memo, and San Luis Ranch – Prefumo Creek Widening Biological Constraints Memo prepared by Althouse and Meade (Appendix F), shall not be conducted during the monarch butterfly overwintering season from October 1 through March 31 if monarch butterflies are present, or while great blue heron nests are active from February 1 to August 31. If construction activities must be conducted during these periods, a qualified biologist shall conduct overwintering monarch surveys and/or nesting great blue heron surveys within one week of habitat disturbance. If surveys do not locate clustering monarchs or nesting great blue herons, construction activities may be conducted. If clustering monarchs and/or nesting San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-31 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact great blue herons are located, no construction activities shall occur within 100 feet of the edge of the overwintering grove and/or active nest(s) until the qualified biologist determines that no more monarchs are overwintering in the grove or the nest(s) are no longer active. • A qualified biologist shall prepare and implement a habitat enhancement plan prior to issuance of grading permits to enhance and restore overwintering and nesting habitat that is to be preserved. The habitat enhancement plan shall include native shrubs and trees such as Monterey Cypress (Hesperocyparis macrocarpa) that may support heron roosting and monarch butterfly overwintering. As eucalyptus trees senesce, they shall be replaced with native species. Native trees and shrubs shall also be used to supplement gaps in canopy or act as windbreaks. • Create new offsite nesting habitat for great blue herons to mitigate for removal of onsite nesting habitat. With a qualified biologist present, the current rookery may be moved to a suitable offsite location where the same great blue herons can resume nesting, following methods detailed in Crouch et al. (2002). It should be noted that creating offsite nesting habitat for great blue herons is experimental and that the relocation techniques described in Crouch et al. (2002) were used to relocate black-crowned night heron (Nycticorax nycticorax). In addition, an agreement with the City will be required prior to implementation of the offsite strategy on their property. The methods detailed in Crouch et al. (2002) include: (a) This entails at least one year of pre-construction monitoring of the rookery, where the timing of rookery activities will be noted: arrival of breeding adults, egg laying, hatching, and fledging. During this time, audio recordings of adults and juveniles shall be made. (b) Following the completion of the nesting season in late summer, a certified arborist specializing in the translocation of trees will examine the mature trees onsite and work with the City’s Natural Resources Manager to determine whether or not it is feasible to relocate the mature trees containing nests the mature trees containing nests shall be boxed and moved across Madonna Road to a suitable location at Laguna Lake Open Space. (c) Prior to the start of the next nesting season (based on timing of adult arrival in previous years), nesting adults will be recruited to the new location via decoys and playback of vocalizations. The new location will be monitored regularly by a qualified biologist for the following three breeding seasons. BIO-1(g). Nesting Birds Impact Avoidance and Minimization. The applicant shall San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-32 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact ensure the following actions are undertaken to avoid and minimize potential impacts to nesting birds: • For construction activities occurring during the nesting season (generally February 1 to September 15), surveys for nesting birds covered by the California Fish and Game Code and the Migratory Bird Treaty Act shall be conducted by a qualified biologist no more than 14 days prior to vegetation removal. The surveys shall include the disturbance area plus a 500-foot buffer around the site. If active nests are located, all construction work shall be conducted outside a buffer zone from the nest to be determined by the qualified biologist. The buffer shall be a minimum of 50 feet for non-raptor bird species and at least 300 feet for raptor species. Larger buffers may be required depending upon the status of the nest and the construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and young have fledged the nest prior to removal of the buffer. • If feasible, removal of vegetation within suitable nesting bird habitats will be scheduled to occur in the fall and winter (between September 1 and February 14), after fledging and before the initiation of the nesting season. BIO-1(h) . Roosting Bats Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to roosting bats: • Prior to issuance of grading permits, a qualified biologist shall conduct a survey of existing structures within the project site to determine if roosting bats are present. The survey shall be conducted during the non-breeding season (November through March). The biologist shall have access to all interior attics, as needed. If a colony of bats is found roosting in any structure, further surveys shall be conducted sufficient to determine the species present and the type of roost (day, night, maternity, etc.) If the bats are not part of an active maternity colony, passive exclusion measures may be implemented in close coordination with CDFW. These exclusion measures must include one-way valves that allow bats to exit the structure but are designed so that the bats may not re-enter the structure. • If a bat colony is excluded from the project site, appropriate alternate bat habitat as determined by a qualified biologist shall be installed on the project site or at an approved location offsite. • Prior to removal of any trees over 20 inches diameter-at-breast-height (DBH), a survey shall be conducted by a qualified biologist to determine if any of the San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-33 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact trees proposed for removal or trimming harbor sensitive bat species or maternal bat colonies. If a non-maternal roost is found, the qualified biologist, in close coordination with CDFW shall install one-way valves or other appropriate passive relocation method. For each occupied roost removed, one bat box shall be installed in similar habitat and should have similar cavity or crevices properties to those which are removed, including access, ventilation, dimensions, height above ground, and thermal conditions. Maternal bat colonies may not be disturbed. Impact BIO-2. Implementation of the project would have a substantial adverse effect on sensitive habitats, including riparian areas. Impacts would be Class II, potentially significant but mitigable. BIO-2(a). Habitat Mitigation and Monitoring Plan. A Habitat Mitigation and Monitoring Plan (HMMP) shall be prepared which will provide a minimum 2:1 ratio (replaced: removed) for temporary and permanent impacts to riparian habitat. The HMMP will identify the specific mitigation sites and it will be implemented immediately following project completion. The HMMP shall include, at a minimum, the following components: • Description of the project/impact site (i.e. location, responsible parties, areas to be impacted by habitat type); • Goal(s) of the compensatory mitigation project [type(s) and area(s) of habitat to be established, restored, enhanced, and/or preserved; specific functions and values of habitat type(s) to be established, restored, enhanced, and/or preserved]; • Description of the proposed compensatory mitigation site (location and size, ownership status, existing functions and values of the compensatory mitigation site); • Implementation plan for the compensatory mitigation site (rationale for expecting implementation success, responsible parties, schedule, site preparation, planting plan [including plant species to be used, container sizes, seeding rates, etc.]); • Maintenance activities during the monitoring period, including weed removal and irrigation as appropriate (activities, responsible parties, schedule); • Monitoring plan for the compensatory mitigation site, including no less than quarterly monitoring for the first year (performance standards, target functions and values, target acreages to be established, restored, enhanced, and/or preserved, annual monitoring reports); • Success criteria based on the goals and measurable objectives; said criteria to be, at a minimum, at least 80 percent survival of container plants and 80 percent relative cover by vegetation type; • An adaptive management program and remedial measures to address negative impacts to restoration efforts; Implementation of Mitigation Measures BIO-1(a), BIO-2(a), BIO- 2(b), BIO-2(c), and BIO-3 would reduce direct impacts to sensitive habitats, including riparian areas, by implementing construction BMPs, including containing construction activities, debris, and sediment in appropriate locations outside of sensitive habitat to the maximum extent practicable, and by providing compensatory mitigation for permanently impacted riparian habitat. In addition Mitigation Measures HWQ-1(a) and HWQ-1(b) include construction management practices that would reduce construction related impacts to water quality. When combined with standard regulatory measures (including required permitting from USACE, CDFW, and RWQCB), and regulatory oversight during construction by the Environmental Monitor, implementation of required mitigation measures would reduce impacts to a less than significant level and ensure that the project would comply with applicable General Plan policies for the protection of habitat and other San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-34 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact • Notification of completion of compensatory mitigation and agency confirmation; and • Contingency measures (initiating procedures, alternative locations for contingency compensatory mitigation, funding mechanism). BIO-2(b) . Tree Replacement. Riparian trees four inches or greater measured at diameter-at-breast-height (DBH) shall be replaced in-kind at a minimum ratio of 3:1 (replaced: removed). Trees 24 inches or greater inches DBH shall be replaced in- kind at a minimum ratio of 10:1. Willows and cottonwoods may be planted from live stakes following guidelines provided in the California Salmonid Stream Habitat Restoration Manual for planting dormant cuttings and container stock (CDFW 2010). • Tree replacement shall be conducted in accordance with a Natural Habitat Restoration and Enhancement Plan to be approved by the City’s Natural Resource Manager. • The Natural Habitat Restoration and Enhancement Plan shall prioritize the planting of replacement trees on-site where feasible, but shall allow that replacement trees may be planted off-site with approval of the City’s Natural Resource Manager. • Replacement trees may be planted in the fall or winter of the year in which trees were removed. All replacement trees will be planted no more than one year following the date upon which the native trees were removed. BIO-2(c). Froom Ranch Way Bridge Design to Avoid Riparian Areas. The Froom Ranch Way Bridge crossing footings shall be placed outside mapped riparian areas. The placement of the bridge and footings shall be indicated on the Development Plan, VTM, and HMMP, and shall show the bridge’s placement in relation to existing vegetation and the bed and bank of Prefumo Creek. biological resources. Impact BIO-3. Construction of the project could have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act. Impacts would be Class II, potentially significant but mitigable. Implementation of Mitigation Measures BIO-1(a) and BIO-2(a) would reduce impacts to a less than significant level. No additional mitigation is required. Implementation of Mitigation Measures BIO-1(a) andBIO-2(a would reduce potential impacts to federally protected wetlands, any riparian habitat, or other sensitive natural communities to a less than significant level and ensure that the project would be consistent with COSE Policy 7.5.5. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-35 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact Impact BIO-4. Development of the San Luis Ranch Specific Plan Area would not permanently interfere with the movement of resident or migratory fish or wildlife species or with established resident or migratory wildlife corridors along Prefumo Creek and through open agricultural lands on the project site. This impact would be Class II, potentially significant but mitigable. Implementation of BIO-1(a) requires construction BMPs that would reduce potential impacts to riparian habitat within the Prefumo Creek corridor. Implementation of Mitigation Measures BIO-1(c), BIO-1(d), and BIO-1(e), would reduce impacts to western pond turtle, CRLF, coast range newt, and steelhead by requiring pre- construction surveys by qualified biological staff and construction worker training to ensure individuals of these species are not impacts during project construction activity within or adjacent to riparian and riverine habitat. Implementation of Mitigation Measure BIO-1(f) would reduce impacts to heron rookeries by requiring preconstruction surveys, mapping, exclusionary fencing, and offsite compensatory mitigation. Implementation of Mitigation Measure BIO-1(h) would reduce impacts to birds by requiring construction monitoring for nesting birds, and requiring appropriate buffers for construction activity in proximity to active nests. Implementation of Mitigation Measure BIO-1(h) would reduce impacts to bats roosting in trees by requiring trees that may provide habitat for roosting bats to be surveyed by a qualified biologist prior to removal. Implementation of Mitigation Measures BIO-2(a) would reduce potential impacts to federally protected wetlands, any riparian habitat, or other sensitive natural community to a less than significant level. Implementation of Mitigation Measures BIO-1(a), BIO-1(c), BIO- 1(d), BIO-1(e), BIO-1(f), BIO-1-(h), and BIO-2(a) would reduce potential impacts to wildlife species, wildlife nursery sites, riparian corridors, and other sensitive natural communities to a less than significant level. Cumulative Biological Resources Impacts. Consistent with the LUCE Update EIR, the project would implement mitigation measures to ensure compliance with the applicable goals and policies of the General Plan. As a result, the project’s contribution to this cumulative impact would be potentially significant but mitigable. Implementation of Mitigation Measures BIO-1(a) through BIO-1(h) and BIO-2(a) through BIO-2(c) would reduce cumulative impacts to biological resources to a less than significant level. Implementation of required mitigation measures would reduce cumulative impacts to a less than significant level. CULTURAL RESOURCES Impact CR-2. Identified archaeological resources on the project site are ineligible for listing in the CRHR and NRHP, and disturbance of these resources would not constitute a significant impact. However, the CR-2(a). Retain a Qualified Principal Investigator. In accordance with Conservation and Open Space Policies 3.5.6 and 3.5.7, a qualified principal investigator, defined as an archaeologist who meets the Secretary of the Interior’s Standards for professional archaeology (hereafter qualified archaeologist), shall be retained to carry out all mitigation measures related to archaeological resources. Monitoring shall involve inspection of subsurface construction disturbance at or in Implementation of Mitigation Measures CR-2(a) and CR-2(b) would reduce impacts to archaeological resources to a less than significant level. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-36 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact potential remains for the project to result in impacts to previously unidentified archaeological resources. Therefore, this impact would be Class II, significant but mitigable. the immediate vicinity of known sites, or at locations that may harbor buried resources that were not identified on the site surface. A Native American monitor shall also be present because the area is a culturally sensitive location. The monitor(s) shall be on-site on a full-time basis during earthmoving activities, including grading, trenching, vegetation removal, or other excavation activities. CR-2(b). Unanticipated Discovery of Archaeological Resources. In the event that archaeological resources are exposed during construction, all work shall be halted in the vicinity of the archaeological discovery until a qualified archaeologist can visit the site of discovery and assess the significance of the cultural resource. In the event that any artifact or an unusual amount of bone or shell is encountered during construction, work shall be immediately stopped and relocated to another area. The lead agency shall stop construction within 100 feet of the exposed resource until a qualified archaeologist/paleontologist can evaluate the find (see 36 CFR 800.11.1 and CCR, Title 14, Section 15064.5[f]). Examples of such cultural materials might include: ground stone tools such as mortars, bowls, pestles, and manos; chipped stone tools such as projectile points or choppers; flakes of stone not consistent with the immediate geology such as obsidian or fused shale; historic trash pits containing bottles and/or ceramics; or structural remains. If the resources are found to be significant, they must be avoided or will be mitigated consistent with State Historic Preservation Office (SHPO) Guidelines. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-37 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact HAZARDS/HAZARDOUS MATERIALS Impact HAZ-4. Hazardous materials sites identified on and upgradient to the project site as well as residual pesticides and agricultural chemicals in soil due to historical use of pesticides and other agricultural chemicals onsite could create a hazard to construction workers during the construction phase of the project. Impacts would be Class II, significant but mitigable. HAZ-4. Soil Sampling and Remediation. Prior to issuance of any grading permits, a contaminated soil assessment shall be completed in the portions of land to be graded for development. Soil samples shall be collected under the supervision of a professional geologist or environmental professional to determine the presence or absence of contaminated soil in these areas. The sampling density shall be in accordance with guidance from San Luis Obispo County Environmental Health Services, so as to define the volume of soil that may require remediation. Laboratory analysis of soil samples shall be analyzed for the presence of organochlorine pesticides, in accordance with EPA Test Method SW8081A, and heavy metals in accordance with EPA Test Methods 6010B and 7471A. If soil sampling indicates the presence of pesticides or heavy metals exceeding applicable environmental screening levels, the soil assessment shall identify the volume of contaminated soil to be excavated. If concentrations of contaminants exceed EPA action levels and therefore warrant remediation, contaminated materials shall be remediated either prior to concurrent with construction and an Environmental Site Assessment (ESA) shall be prepared. Cleanup may include excavation, disposal, bio-remediation, or any other treatment of conditions subject to regulatory action. All necessary reports, regulations and permits shall be followed to achieve cleanup of the site. The contaminated materials shall be remediated under the supervision of an environmental consultant licensed to oversee such remediation and under the direction of the lead oversight agency. The remediation program shall also be approved by a regulatory oversight agency, such as the San Luis Obispo County Environmental Health Services, the Regional Water Quality Control Board (RWQCB), or DTSC. All proper waste handling and disposal procedures shall be followed. Upon completion of the remediation, the environmental consultant shall prepare a report summarizing the project, the remediation approach implemented, and the analytical results after completion of the remediation, including all waste disposal or treatment manifests. With implementation of Mitigation Measure HAZ-4, impacts related to exposure to residual agricultural chemicals would be reduced to a less than significant level. Impact HAZ-5. Tetrachloroethene (also called perchloroethylene, or PCE) has been detected in the shallow aquifer in concentrations that exceed the Maximum Contaminant Level (MCL) in active irrigation wells on the HAZ-5(a). Groundwater Assessment for Contamination at Untested Wells. Any groundwater wells on the project site that would be used for agricultural irrigation shall be sampled by a registered soils engineer or remediation specialist to determine the presence or absence of regulated contaminants prior to issuance of grading permits. This assessment shall target on-site PCE associated with off-site dry cleaning operations. HAZ-5(b). Groundwater Remediation. If groundwater sampling indicates the W ith incorporation of these mitigation measures, this impact would be less than significant. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-38 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact eastern portion of the site. As future on-site residents or workers could potentially be exposed to PCE from irrigation water, this would be a Class II, significant but mitigable, impact. presence of any contaminant in hazardous quantities, the project applicant (or authorized agent thereof) shall contact the Regional Water Quality Control Board (RWQCB) and Department of Toxic Substances (DTSC) to determine the level of any necessary remediation efforts. These may include: • Installation of charcoal filtration into well-head systems at wells where PCE is identified in hazardous quantities. After installation of charcoal filtration, groundwater wells shall be re-sampled consistent with Mitigation Measure HAZ- 5(a). • Groundwater remediation to contaminant concentrations below applicable standards in compliance with applicable laws prior to issuance of grading permits. A copy of the applicable remediation certification from Regional Water Quality Control Board (RWQCB) and/or Department of Toxic Substances (DTSC), or written confirmation that a certification is not required, shall be submitted to the Community Development Department. Impact HAZ-6. The project site is located in an area where geologic analysis for NOA is required prior to grading and could potentially result in exposure of people to NOA during grading and construction activities. Therefore, this impact would be Class II, significant but mitigable. HAZ-6. Naturally Occurring Asbestos Exposure Avoidance and Minimization: a. Prior to earthwork activities, a site-specific health and safety plan shall be developed per California Occupational Safety and Health Administration (CalOSHA) requirements. The plan shall include appropriate health and safety measures if NOA is detected in soil or bedrock beneath the project site. All construction workers that have the potential to come into contact with contaminated soil/bedrock and groundwater shall be knowledgeable of the requirements in the health and safety plan, which includes proper training and personal protective equipment. The health and safety plan shall prescribe appropriate respiratory protection for construction workers. b. Prior to beginning construction, a soil and bedrock analysis for asbestos using polarized light microscopy and transmission electron microscopy by a qualified laboratory shall be conducted. Samples of soil shall be collected from multiple locations across the site, and bedrock samples shall be collected from locations where excavation into bedrock is anticipated. If NOA is detected, appropriate regulations pertaining to excavation, removal, transportation, and disposal of NOA shall be followed. The sampling strategy shall take into account the locations of potential source areas, and the anticipated lateral and vertical distribution of contaminants in soil and/or groundwater. The results of the investigation shall be documented in a report that is signed by a California Professional Geologist. The report shall include recommendations based upon the findings for additional investigation/remediation if contaminants are detected above applicable screening levels (e.g., excavate and dispose, groundwater and/or soil vapor extraction, or in situ bioremediation). With implementation of Mitigation Measure HAZ-6, impacts related to exposure to NOA would be reduced to a less than significant level. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-39 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact c. During earthwork activities, appropriate procedures shall be incorporated in the event that NOA is detected in soil or bedrock beneath the project site. These procedures shall be followed to eliminate or minimize construction worker or general public exposure to potential contaminants in soil. Procedures shall include efforts to control fugitive dust, contain and cover excavation debris piles, appropriate laboratory analysis of soil for waste characterization, and segregation of contaminated soil from uncontaminated soil. The applicable regulations associated with excavation, removal, transportation, and disposal of contaminated soil shall be followed (e.g., tarping of trucks and waste manifesting). These procedures may be subject to San Luis Obispo APCD requirements under the California ARB ATCM for Construction, Grading, Quarrying, and Surface Mining Operations. HYDROLOGY AND WATER QUALITY Impact HWQ-1. During project construction, the surface soil would be subject to erosion and the downstream watershed would be subject to pollution. The project’s impact on water quality during construction would be Class II, significant but mitigable. HWQ-1(a). Stormwater Pollution Prevention Plan. All required actions shall be implemented pursuant to a SWPPP and SWMP to be prepared by the project applicant and submitted by the City to the Regional Water Quality Control Board under the NPDES Phase II program. At a minimum, the SWPPP/SWMP shall including the following BMPs: • The use of sandbags, straw bales, and temporary de-silting basins during project grading and construction during the rainy season to prevent discharge of sediment-laden runoff into stormwater facilities; • Revegetation as soon as practicable after completion of grading to reduce sediment transport during storms; • Installation of straw bales, wattles, or silt fencing at the base of bare slopes before the onset of the rainy season (October 15th through April 15th); • Installation of straw bales, wattles, or silt fencing at the project perimeter and in front of storm drains before the onset of the rainy season (October 15th through April 15th); and/or • Alternative BMPs as approved by the RWQCB as part of the SWPPP submittal. HWQ-1(b). Berms and Basins. As specified in the SWPPP, the applicant shall be required to manage and control runoff by constructing temporary berms, sediment basins, runoff diversions, or alternative BMP’s as approved by the RWQCB as part of the SWPPP submittal, in order to avoid unnecessary siltation into local streams during construction activities where grading and construction shall occur in the vicinity of such streams. • Berms and basins shall be constructed when grading commences and be periodically inspected and maintained. The project applicant shall sufficiently Implementation of the mitigation measures and compliance with existing regulations would ensure that the potentially significant construction runoff and associated impacts to water quality would be reduced to a less than significant level. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-40 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact document, to the CCRWQCB satisfaction, the proper installation of such berms and basins during grading. HWQ-1(c). Concept Grading Plan and Master Drainage Plan. As specified in the SWPPP and the City’s Floodplain Management Regulations, the applicant shall be required to submit a Grading Plan and Master Drainage Plan to the Planning Division and City Public Works Director for approval prior to approval of the VTTM. The grading and drainage plans shall be designed to minimize erosion and water quality impacts, to the extent feasible, and shall be consistent with the project’s SWPPP. The plans shall include the following: a. Graded areas shall be revegetated with deep-rooted, native, non-invasive drought tolerant species to minimize slope failure and erosion potential. Geotextile fabrics shall be used if necessary to hold slope soils until vegetation is established; b. Temporary storage of construction equipment shall be limited to a minimum of 100 feet away from drainages on the project site; and c. Erosion control structures shall be installed. d. Demonstrate peak flows and runoff for each phase of construction. e. Be coordinated with habitat restoration efforts, including measures to minimize removal of riparian and wetland habitats and trees (Mitigation Measures BIO- 2[a] and BIO-2[b]). f. Grading and drainage plans shall be submitted for review and approval by the Planning Division. The applicant shall ensure installation of erosion control structures prior to beginning of construction of any structures, subject to review and approval by the City. Impact HWQ-3. During operation, the proposed residential, and commercial, and agricultural uses would increase the quantities of pollutants associated with runoff and sedimentation. The project’s impact on water quality would be Class II, significant but mitigable impact. HWQ-3(a). Stormwater Quality Treatment Controls. BMP devices shall be incorporated into the stormwater quality system depicted in the Master Drainage Plan (refer to Mitigation Measure HWQ-1[c]). The final design of the stormwater quality system shall be reviewed and approved by the City. The Master Drainage Plan shall contain the following relevant BMPs: • Vegetated bioswales to reduce sediment and particulate forms of metals and other pollutants along corridors of planted grasses. • Vegetated buffer strips to reduce sediment and particulate forms of metals and nutrients. • Hydrodynamic separation products to reduce suspended solids greater than 240 microns, trash, and hydrocarbons. These hydrodynamic separators shall be sized to handle peak flows from the project site consistent with applicable regulatory standards. Implementation of required mitigation measures and compliance with existing regulations would ensure that the potentially significant impacts to water quality resulting from runoff during operation of the project would be reduced to a less than significant level. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-41 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact HWQ-3(b). Stormwater BMP Maintenance Manual. The project applicant shall prepare a development maintenance manual for the stormwater quality system BMPs (refer to Mitigation Measure HWQ-3[a]). The maintenance manual shall include detailed procedures for maintenance and operations of all stormwater facilities to ensure long-term operation and maintenance of post-construction stormwater controls. The maintenance manual shall require that stormwater BMP devices be inspected, cleaned, and maintained in accordance with the manufacturer’s maintenance specifications. The manual shall require that devices be cleaned prior to the onset of the rainy season (i.e., October 15th) and immediately after the end of the rainy season (i.e., May 15th). The manual shall also require that all devices be checked after major storm events. HWQ-3(c). Stormwater BMP Semi-Annual Maintenance Report. The property manager(s) or acceptable maintenance organization shall submit to the City of San Luis Obispo Public Works Department a detailed report prepared by a licensed Civil Engineer addressing the condition of all private stormwater facilities, BMPs, and any necessary maintenance activities on a semi-annual basis (October 15th and May 15th of each year). The requirement for maintenance and report submittal shall be recorded against the property. Impact HWQ-4. Approximately 98 acres of the project site is within the existing 100-year flood zone. However, proposed grading and elevation modifications would ensure that the project would not place housing within a 100-year flood hazard area or expose people or structures downstream of the Specific Plan Area to flood hazards due to increased runoff or loss of floodplain storage. This impact would be Class II, significant but mitigable. HWQ-4. Conditional Letter of Map Revision/Letter of Map Revision. The applicant, in conjunction with the City of San Luis Obispo, shall prepare the CLOMR application and obtain a LOMR from FEMA. Implementation of Mitigation Measure HWQ-4 and compliance with existing regulations would ensure that this impact would be reduced to a less than significant level. LAND USE Impact LU-2. The Specific Plan would be potentially consistent with LAFCO policies for Mitigation Measures AG-1 and AG-3 would ensure that the Specific Plan would not result in conflicts between the San Luis Obispo LAFCO agricultural policies and the Specific Plan. Implementation of Mitigation Measures AG-1 and AG-3 would ensure that this impact would San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-42 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact annexation. This impact would be Class II, less than significant with mitigation incorporated. remain less than significant. Cumulative Land Use Impacts. The proposed uses are consistent with the intent of the goals and policies established within the City’s General Plan and Zoning Regulations after implementation of mitigation, and would not cumulatively contribute to the loss of open space or agricultural land beyond that already anticipated in the City’s LUCE Update and EIR. Furthermore, the Specific Plan is not expected to cumulatively contribute to potential airport noise and/or safety issues. As such, cumulative land use impacts would be less than significant with incorporation of the mitigation included in this EIR. The following Mitigation Measures would apply to this impact: • Section 4.1, Aesthetics: AES-1(a) and AES-1(b) • Section 4.2, Agricultural Resources: AG-1, AG-3 • Section 4.4, Biological Resources: BIO-1(a) through BIO-1(h) and BIO-2(a) through BIO-2(c) • Section 4.5, Cultural Resources: CR-1(a) through CR-1(c) • Section 4.7, Hazards and Hazardous Materials: HAZ-4, HAZ-5(a), HAZ-5(b), HAZ-6 • Section 4.10, Noise: N-1(a) through N-1(g), N-4(a), N-4(b), N-5(a) through N- 5(d) • Section 4.12, Transportation and Circulation: T-1(a) through T-1(i), T-2(a) through T-2(j), T-3(a) through T-3(d), T-4, T-5, T-6, T-7, T-8(a) through T-8(g), T-9(a) through T-9(m), T-10(a) through T-10(c) • Section 4.14, Issues Addressed in the Initial Study: GEO-1, GEO-3 This impact would be less than significant without mitigation. NOISE Impact N-4. Future development on the project site would generate operational noise typically associated with residential, commercial, office, and hotel development. Noise from the project would not exceed acceptable levels at existing off-site sensitive receptors. However, noise from new on-site commercial uses may exceed applicable City standards at proposed on-site N-4(a). HVAC Equipment. Retail HVAC equipment shall be shielded and located on building rooftops, or a minimum of 100 feet from the nearest residential property line. N-4(b). Parking Lot/Loading Dock Orientation and Noise Barrier. Parking areas and loading docks within the proposed retail areas shall be located a minimum of 100 feet from the property lines of the nearest residential properties. For parking areas and loading docks located a minimum of 250 feet from the property line of residential properties to the west, or for parking areas and loading docks located a minimum of 150 feet from the property line of residential properties to the west with a building intervening line-of-sight between the parking area/loading dock and the residential property, no further mitigation would be required. If parking areas or loading docks would be located closer to the within 250 feet of This mitigation would ensure that noise levels at residences on the project site would not exceed the City’s standards for intermittent noise. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-43 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact residences. This impact would be Class II, less than significant with mitigation incorporated. the residential properties to the west than described above, a masonry noise barrier shall be installed along the eastern boundary of the proposed residences adjacent to the commercial land use area on the eastern portion of the project site. The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. Impact N-5. Existing noise sources near the project site include vehicles on local roadways and U.S. 101. Development of the project would expose future residents on the project site to traffic noise from local roadways and U.S. 101. With mitigation, traffic noise levels on the project site would not exceed City standards. Therefore, this impact would be Class II, less than significant with mitigation incorporated. N-5(a). Interior Noise Reduction. The project applicant shall implement the following measures, or similar combination of measures, which demonstrate that interior noise levels in proposed residences adjacent to Froom Ranch Way and Madonna Road, hotel, and offices would be reduced below the City’s 45 dBA CNEL interior noise standard. The required interior noise reduction shall be achieved through a combination of standard interior noise reduction techniques, which may include (but are not limited to): • In order for windows and doors to remain closed, mechanical ventilation such as air conditioning shall be provided for all units (Passive ventilation may be provided, if mechanical ventilation is not necessary to achieve interior noise standards, as demonstrated by a qualified acoustical consultant). • All exterior walls shall be constructed with a minimum STC rating of 50, consisting of construction of 2 inch by 4 inch wood studs with one layer of 5/8 inch Type “X” gypsum board on each side of resilient channels on 24 inch centers and 3 ½ inch fiberglass insulation. • All windows and glass doors shall be rated STC 39 or higher such that the noise reduction provided will satisfy the interior noise standard of 45 dBA CNEL. • An acoustical test report of all the sound-rated windows and doors shall be provided to the City for review by a qualified acoustical consultant to ensure that the selected windows and doors in combination with wall assemblies would reduce interior noise levels sufficiently to meet the City’s interior noise standard. • All vent ducts connecting interior spaces to the exterior (i.e., bathroom exhaust, etc.) shall have at least two 90 degree turns in the duct. • All windows and doors shall be installed in an acoustically-effective manner. Sliding window panels shall form an air-tight seal when in the closed position and the window frames shall be caulked to the wall opening around the perimeter with a non-hardening caulking compound to prevent sound infiltration. Exterior doors shall seal air-tight around the full perimeter when in the closed position. The applicant shall submit a report to the Community Development Department by a qualified acoustical consultant certifying that the specific interior noise reduction techniques included in residential, hotel, and office components of the project would This mitigation would ensure that traffic noise levels would not exceed City standards. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-44 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact achieve interior noise levels that would not exceed 45 dBA CNEL. N-5(b). Residential Outdoor Activity Area Noise Attenuation. Outdoor activity areas (e.g., patios and hotel pool areas) associated with shared multifamily residential recreational spaces, hotel, commercial, and office uses shall be protected from sound intrusion so that they meet the City’s exterior standard of 60 dBA CNEL. Outdoor activity areas shall be oriented away from traffic noise such that intervening buildings reduce traffic noise or shall include noise barriers capable of reducing traffic noise levels to meet the City’s exterior standard. Hotel pool areas shall be located a minimum of 500 feet from the U.S. 101 right-of-way. Noise barriers may be constructed of a material such as tempered glass, acrylic glass, or masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. The applicant shall submit a report to the Community Development Department by a qualified acoustic consultant certifying that the specific outdoor noise reduction techniques in combination with the orientation of outdoor activity areas of shared multifamily residential recreational spaces, hotel, commercial, and offices would achieve exterior noise levels that would not exceed 60 dBA CNEL. N-5(c). Froom Ranch Way Noise Barrier. A masonry noise barrier or alternative barrier, such as a landscaped berm, shall be installed along the southern property line of residential lots that abut Froom Ranch Way to protect outdoor activity areas (patios and pools) at these residences from sound intrusion from traffic along Froom Ranch Way. The noise barrier or berm shall provide, at minimum, a 6 foot high barrier between Froom Ranch Way and the neighboring residences from the final grade of whichever use (i.e., Froom Ranch Way or residences) has a higher final elevation. If a masonry noise barrier is implemented, tThe noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. If an alternative material is used, the developer shall submit a report to the Community Development Department by a qualified acoustical consultant certifying that the specific exterior noise reduction techniques included would achieve exterior noise levels that would not exceed 60 dBA CNEL. N-5(d). U.S. Highway 101 Noise Barrier at Hotel. If the hotel includes an outdoor activity area (such as a patio or pool) a masonry noise barrier or alternative barrier, such as berms, landscaping, or glass, must be installed along the eastern property line of the hotel where it abuts the U.S. 101 right of way to protect these outdoor activity areas from sound intrusion from traffic along U.S. 101. If a masonry noise San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-45 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact barrier is implemented, tThe noise barrier shall provide, at minimum, an 8 foot high barrier between U.S. 101 and the hotel from the final grade of whichever use (i.e., U.S. 101 or hotel) has a higher final elevation. Such a The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. If an alternative material is used, the developer shall submit a report to the Community Development Department by a qualified acoustical consultant demonstrating that the specific exterior noise reduction techniques included in the hotel component of the project would achieve exterior noise levels that would not exceed 60 dBA CNEL. RECREATION Impact REC-1. The project would accommodate new residents in the City of San Luis Obispo who will use existing and planned parks and recreation facilities. Provision of on-site parks and recreation facilities would not meet the adopted City parkland standard for the San Luis Ranch Specific Plan Area. Therefore, impacts to parks and recreational facilities would be Class II, potentially significant but mitigable. REC-1. Parkland In-lieu Fees. The project applicant shall pay parkland in-lieu fees in accordance with the City’s parkland in-lieu fee program for the parkland shortage. The project’s specific fee shall be determined by the City at the time of project approval, after accounting for parkland provided within the San Luis Ranch Specific Plan Area. The in-lieu fees collected from the project shall be directed to new projects or improvements to existing parks and recreation facilities within the City of San Luis Obispo parks system. With payment of the City’s required parkland in-lieu fees to ensure compliance with the policies and performance standards in the City’s General Plan as part of the project, impacts associated with parks and recreational facilities would be less than significant. Cumulative Recreation Impacts. The project would not meet the Citywide parkland standards and would exacerbate the exiting shortfall of parks and recreational facilities within the City. As a result, cumulative adverse physical effects on the environment from recreational development would be potentially significant, and the project’s contribution to this impact would be cumulatively considerable. With payment of the City’s required parkland in-lieu fees to ensure compliance with the policies and performance standards in the City’s General Plan as part of the project, required by Mitigation Measure REC-1, the project contribution to cumulative impacts associated with parks and recreational facilities would be reduced to a less than significant level. Implementation of required mitigation measures would reduce cumulative impacts to a less than significant level. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-46 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact TRANSPORTATION Impact T-4. Project construction activities would create traffic impacts due to construction vehicles causing congestion and deteriorating pavement conditions. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. T-4. Construction Traffic Management Plan. Prior to construction, a traffic management plan shall be prepared for review and approval by the City of San Luis Obispo Public Works Department. The traffic management plan shall be based on the type of roadway traffic conditions, duration of construction, physical constraints, nearness of the work zone to traffic and other facilities (bicycle, pedestrian, driveway access, etc.). The traffic management plan shall include: • Advertisement. The project developer shall prepare an advertisement campaign informing the public of the proposed construction activities. Advertisements shall occur prior to beginning work and periodically during the course of the project construction. The advertising shall include notification of changes to bus schedules and potential changes to bus stop locations, potential impacts during school drop-off and pick-up times, and major intersections that may be impacted during construction. • Property Access. Access to parcels along the construction area shall be maintained to the greatest extent feasible. Affected property owners shall receive advance notice of work adjacent to their property access and when driveways would be potentially closed. • Schools. Any construction adjacent to schools shall ensure that access is maintained for vehicles, pedestrians, and bicyclists, particularly at the beginning and end of the school day. • Buses, Bicycles, and Pedestrians. The work zone shall provide for passage by buses, bicyclists, and pedestrians, particularly in the vicinity of schools. • Intersections. Traffic control (i.e., use of flag persons) shall be used at intersections that are determined to be unacceptably congested due to construction traffic. Implementation of the identified mitigation would ensure that impacts associated with construction traffic would be less than significant after mitigation. Impact T-5. Construction of the proposed Froom Ranch Way bridge during phase 3 of the Specific Plan buildout would result in significant level of service and queuing impacts at study area intersections and roadway segments. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. T-5. Froom Ranch Way Bridge Phasing. The Froom Ranch Way bridge connection shall be completed prior to occupancy of Phase 1 of the Specific Plan buildout. Implementation of the identified mitigation would ensure that LOS and queuing impacts associated with the project’s proposed infrastructure phasing would be less than significant after mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-47 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact Impact T-6. The project site plan would result in and contribute to increased access conflicts. Proposed access controls are not consistent with General Plan policy. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. T-6. Project Site Intersection Roundabout Control. New roadway intersections within the Specific Plan Area shall be controlled using roundabout design, unless the City Public Works Department determines that roundabout control is infeasible. Implementation of the identified mitigation would ensure that the project would be consistent with General Plan Circulation Element Policy 7.1.2, and would ensure that transportation impacts due to access conflicts would be reduced to a less than significant level after mitigation. Impact T-7. The project site plan would result in on-site traffic volumes and speeds that may exceed General Plan policy thresholds, resulting potential traffic hazards within the project site. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. T-7. Traffic Calming Features. New roadway intersections along San Luis Ranch Road shall include neighborhood traffic circles at key intersections, and traffic- calming features, such as diverters, along longer uninterrupted segments. This mitigation would ensure that potential traffic hazards within the Specific Plan area would be reduced to a less than significant level after mitigation. ISSUES ADDRESSED IN THE INITIAL STUDY Due to the proximity of the site to the Los Osos Fault and Alquist-Priolo Zone, impacts associated with earthquakes and ground shaking would be potentially significant. In addition, the project site has been identified as being located in an area of very high liquefaction potential, moderate to high expansion potential, and high settlement potential. In addition, during historical drought years, groundwater levels in the site vicinity were lowered enough to cause GEO-1. Earthquake and Ground Acceleration Design and Construction Measures. Design and construction of the buildings, roadway infrastructure and all subgrades shall be specifically proportioned to resist Design Earthquake Ground Motions (Design amax) of SD1=0.481 and SDS=0.832 and engineered to withstand Maximum Considered Earthquake (MCE) peak ground acceleration (PGAM) equal to 0.519 g, as described in the Soils Engineering Report for the project (GeoSolutions, Inc., 2015). The design should take into consideration the soil type, potential for liquefaction, and the most current and applicable seismic attenuation methods that are available. GEO-2. Operational Seismic Safety Requirement. For retail stores included in the project, goods for sale may be stacked no higher than 8 feet from the floor in any area where customers are present, unless provisions are made to prevent the goods from falling during an earthquake of up to 7.5 magnitude. The stacking or restraint methods shall be reviewed and approved by the City before approval of occupancy permits, and shall be a standing condition of occupancy. With implementation of the mitigation described above, impacts related to geology and soils would be less than significant. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-48 Table ES-2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact subsidence. GEO-3. Geotechnical Design. The project plans and specifications shall include the geotechnical recommendations included in the Soils Engineering Report, prepared by GeoSolutions, Inc. on May 29, 2015. Recommendations therein that shall be incorporated into the final project building plans include specification for the following components of development preparation and design: • Building Pad Preparation • Paved Areas Preparation • Pavement Design • Interlocking Concrete Pavers • Conventional Foundations • Post-Tensioned Slabs • Slab-On-Grade Construction • Retaining Walls • Exterior Concrete Flatwork San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-49 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact AESTHETICS Impact AES-1. Although there are potentially adverse impacts to scenic viewsheds, the project would implement the open space and agricultural preservation and design elements included in the proposed Specific Plan. Therefore, potential impacts to scenic vistas and scenic resources within a state scenic highway would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Impact AES-2. The project would alter the existing visual character of the site by converting over half of the agricultural site into a predominantly residential and commercial use site. Due to the project’s visual compatibility with surrounding development, preservation of on-site open space and agricultural land, and compliance with design guidelines, the project’s impact on the visual character and quality of the site would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Impact AES-3. The project would introduce a new source of nighttime lighting and daytime glare, which could increase ambient light and affect the quality of the nighttime sky. However, project compliance with existing City requirements No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-50 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact and design guidelines would limit the magnitude of these effects. This would be Class III, less than significant. Cumulative Aesthetics Impacts. As determined in the LUCE Update EIR, all development that adheres to applicable General Plan policies would result in less than significant aesthetic impacts. Therefore, the overall aesthetic impact of cumulative development in the project vicinity would be less than significant. No mitigation is required. This impact would be less than significant without mitigation. AGRICULTURAL RESOURCES Impact AG-2. The project would alter the existing land use and zoning on the project site. However, these alterations would be consistent with the General Plan’s identification of the San Luis Ranch Specific Plan for a mix of urban, agricultural, and open space use. Therefore, this impact would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Impact AG-4. Re-grading of the project site would not result in significant degradation of viability of on-site agricultural land. Therefore, this impact would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-51 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact Cumulative Agricultural Resources Impacts. Consistent with the LUCE Update EIR, the project would implement Land Use Element Policies 1.8.1 and 1.9.2, and Conservation and Open Space Element Policy 8.6.3. As a result, cumulative impacts would be less than significant. No mitigation is required. This impact would be less than significant without mitigation. AIR QUALITY Impact AQ-4 . The project would not expose sensitive receptors to substantial pollutant concentrations. This impact would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. GREENHOUSE GAS EMISSIONS Impact GHG-1. The San Luis Ranch Specific Plan is consistent with the City’s Climate Action Plan. This impact would be Class III, less than significant. The San Luis Ranch Specific Plan is consistent with the City’s Climate Action Plan. No mitigation is required. This impact would be less than significant without mitigation. HAZARDS/ HAZARDOUS MATERIALS Impact HAZ-1. Small quantities of hazardous materials may be used in conjunction with the proposed residential and commercial retail uses on site. However, these materials would be limited in type and quantity such that they would not create a hazard to the public or environment. Therefore, this impact would be Class III, less No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-52 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact than significant. Impact HAZ-2. The project site is adjacent to U.S. Highway 101, on which accidents that involve hazardous materials could occur. Such accidents could potentially create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. However, compliance with applicable regulations related to the handling and storage of hazardous materials would minimize the risk of the public’s potential exposure to these substances, resulting in a Class III, less than significant, impact. Transport of hazardous materials on U.S. 101 and other roadways, including U.S. 101, would be required to comply with all federal, State, and local laws pertaining to the handling of hazardous materials. No mitigation is required. This impact would be less than significant without mitigation. Impact HAZ-3. Two schools are located within one-quarter mile of the project site. Compliance with existing federal, State, and local regulations would ensure that hazardous materials impacts to schools would remain Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Impact HAZ-7. Asbestos Containing Material (ACM) and Lead Based Paint (LBP) may be present in existing on-site structures. Demolition of these structures would be required to comply with applicable State and local policies and regulations for the control and No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-53 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact remediation of hazardous materials to prevent human exposure. Therefore, this impact would be Class III, less than significant. Impact HAZ-8. The project site is located within a San Luis Obispo County Regional Airport area of influence. The project would be consistent with the CALUPH Airport Safety Zones, which represent the extent of Airport-related safety hazard zones for people residing or working in these areas. Therefore, this impact would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Cumulative Hazards and Hazardous Materials Impacts. As described in the LUCE Update EIR, adherence to applicable General Plan policies and applicable State and federal regulatory requirements would reduce any cumulative hazards and hazardous materials impacts resulting from buildout of the City under the General Plan, including buildout of the San Luis Ranch Specific Plan, to a less than significant level. The uses proposed for the San Luis Ranch Project would be consistent with the CALUPH Airport Safety Zones, which represent the extent of Airport- related safety hazard zones for No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-54 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact people residing or working in these areas. As such, the project would not result in a substantial contribution to cumulative aircraft related hazards in the City. HYDROLOGY AND WATER QUALITY Impact HWQ-2. The project would alter the existing drainage pattern of the project site, which could result in flooding, erosion, or siltation onsite and offsite. However, the proposed retention and detention systems, along with compliance with applicable regulations, would ensure that this impact would remain Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Cumulative Hydrology and Water Quality Impacts. Water Quality. The project, in conjunction with pending cumulative development would not significantly increase the concentration of urban pollutants such as oil, grease, and vehicular heavy metals in surface runoff. Polluted runoff which may be generated during construction activities of cumulative development and projects considered in this analysis would be regulated by the SWRCB under General Construction, NPDES permits, and would be minimized through the implementation of standard No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-55 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact construction BMPs. Cumulative impacts would therefore be less than significant for water quality. Flooding. The proposed on-site drainage system would adequately capture associated runoff, and the project would not substantially contribute to flooding on- or off-site. The project grading plan has been designed such that the resulting post-development floodplain would exclude areas proposed for housing. Overall, cumulative impacts to hydrology and water quality would be less than significant. LAND USE Impact LU-3. The Specific Plan would be consistent with the land use strategy in SLOCOG’s 2014 Regional Transportation Plan/Sustainable Communities Strategy. This impact would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Impact LU-4. The Specific Plan would allow residential and non- residential land uses consistent with density and use restrictions in the City’s Airport Safety Zones, which represent the extent of Airport-related safety hazard zones for people residing or working in these areas. The LUCE Update EIR provided substantial evidence that the development of the San Luis No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-56 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact Ranch Specific Plan Area under the updated General Plan land use designations would be consistent with ALUP safety and noise standards. The project would not conflict with land use policies intended to prevent airport-related safety hazards. Therefore, this impact would be Class III, less than significant. NOISE Impact N-2. Short-term construction activities would generate intermittent levels of groundborne vibration. However, the expected vibration level during construction of the project would not be perceptible at the nearest residential receptors. This impact would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Impact N-3. Project-generated traffic would incrementally increase traffic-related noise on study area roadway segments, except on Madonna Road near the project site, which would potentially affect existing noise- sensitive receptors along local roadways. However, the increase in traffic noise levels along area roadways would not exceed 3 dBA, which is the increase threshold typically audible to the human ear. Therefore, the effect of increased traffic noise would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-57 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact Cumulative Noise Impacts. Traffic noise levels along roadways in the project vicinity would not increase by more than 0.5 dBA due to cumulative traffic. This increase would not be significant based on the applicable traffic noise increase threshold of 3 dBA. Therefore, the project’s contribution to traffic noise would not be cumulatively considerable or significant. No mitigation is required. This impact would be less than significant without mitigation. WATER RESOURCES Impact WR-1. The project would increase water demand as a result of new residential and commercial development on the project site. However, the project’s water demand would be within the City of San Luis Obispo’s projected primary water supply. Therefore, impacts to water supply would be Class III, less than significant. No mitigation is required. This impact would be less than significant without mitigation. Cumulative Water Resources Impacts. The project’s water demand would not exceed supply when combined with all possible future development within the City. In addition, the project would reduce the overall demand on the San Luis Obispo groundwater basin as a result of reduced on-site agricultural uses and, therefore, would not exacerbate potential cumulative impacts on the local No mitigation is required. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Executive Summary City of San Luis Obispo ES-58 Table ES-3 Class III, Less than Significant Environmental Impacts Impact Mitigation Measure Residual Impact groundwater basin associate with future development within the City. Accordingly, the project’s cumulative water supply impact would be less than significant. San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-1 INTRODUCTION 1.0 This document is an Environmental Impact Report (EIR) that examines the potential effects of approving a Specific Plan and constructing a development project that implements that plan on an approximately 131-acre site in what is currently unincorporated San Luis Obispo County and designated for annexation into the City of San Luis Obispo. The project is described in detail in Section 2.0, Project Description. This Introduction describes: (1) the general background of the project; (2) the purpose of and legal authority for the EIR; (3) the scope and content of the EIR; (4) lead, responsible and trustee agencies; and (5) the environmental review process required under the California Environmental Quality Act (CEQA). PROJECT BACKGROUND 1.1 1.1.1 Summary of Proposed Project The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment and pre-zone, Development Agreement/Memorandum of Understanding, and Development Plan/Vesting Tentative Tract Map for the 131-acre project site, including annexation of the site into the City of San Luis Obispo. The site is currently located in unincorporated San Luis Obispo County and is identified by assessor’s parcel number (APN) 067-121-022. The project is intended to be consistent with the development parameters described in the City’s General Plan Land Use and Circulation Elements, which were updated in December 2014. The project includes a mixture of residential, commercial, office, and hotel uses, with a portion approximately 53 acres of the site preserved for agriculture and approximately 7.4 acres preserved for open space uses. Phases 1, 2, and 3 of the project would consist of residential development. Phases 4, 5, and 6 would consist of non-residential (commercial and office) development. Construction is proposed to begin in 2017 with buildout of the site anticipated by 2023. There are existing entitlements on the project site for development in the County from the voter-approved initiative known as “Measure J,” which was passed in 2006 and upheld in 2009. However, the project applicant is pursuing developing under City jurisdiction, and has proposed an annexation of the site consistent with policy from the City’s General Plan Land Use Element, as discussed below. The Measure J entitlements include 60 multi-family dwelling units, 560,000 square feet of regional commercial and outdoor sales areas, 198,000 square feet of office space, a 150-room hotel and ancillary facilities1. Because the Measure J entitlements would leave the project site under the jurisdiction of the County, but surrounded entirely by the City limit, these entitlements would also require the use of private water from onsite wells and an onsite wastewater treatment facility. 1 The full text of Measure J is available on the County of San Luis Obispo’s website: http://www.slocounty.ca.gov/Assets/CR/Elections/Past+Elections/November+7$!2c+2006+general+election/Full+text +Measure+j-06.pdf San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-2 1.1.2 Land Use Background City of San Luis Obispo Land Use and Circulation Elements In December 2014, the City adopted the updated Land Use and Circulation Elements to address a variety of programs and policies that would guide private development and public improvements in the City for the next 10 to 20 years. Chapter 8 of the Land Use Element addresses “Special Focus Areas,” which consist of four Specific Plan Areas and twelve Special Planning Areas. The San Luis Ranch property is identified as a Specific Plan Area (SP-2). The 2014 updates to the Land Use and Circulation Elements include policies and the prescribed format, content, and regulatory elements of a specific plan for the San Luis Ranch Specific Plan Area (Sections 8.1.1, 8.1.2, and 8.1.4 of the Land Use Element). Under the City’s General Plan, prior to development the project site is required to be annexed with an approved Specific Plan defining how the site would be developed. Section 8.1.4 of the City’s Land Use Element provides guidance for development of the San Luis Ranch Specific Plan Area. The section includes the following purpose for the Specific Plan area: Purpose: This project site should be developed as a mixed use project that maintains the agricultural heritage of the site, provides a commercial / office transition to the existing commercial center to the north, and provides a diverse housing experience. Protection of the adjacent creek and a well-planned integration into the existing circulation system will be required. The specific plan for this area should consider and address the following land use and design issues. a. Provide land and appropriate financial support for development of a Prado Road connection. Appropriate land to support road infrastructure identified in the EIR (overpass or interchange) at this location shall be dedicated as part of any proposal. b. Circulation connections to integrate property with surrounding circulation network for all modes of travel. Connection to Froom Ranch and Calle Joaquin, if proposed, shall not bifurcate on- site or neighboring agricultural lands. Any connection to Calle Joaquin shall be principally a secondary / emergency access by design. c. Development shall include a transit hub. Developer shall work with transit officials to provide express connections to Downtown area. d. Maintain agricultural views along Highway 101 by maintaining active agricultural uses on the site, and maintain viewshed of Bishop Peak and Cerro San Luis. e. Maintain significant agricultural and open space resources on site. Land dedicated to Agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. f. Where buffering or transitions to agricultural uses are needed to support viability of the agricultural use, these shall be provided on lands not counted towards the minimum size for the agriculture / open space component. Provide appropriate transition to agricultural uses on-site. g. Integrate agricultural open space with adjacent SLO City Farm and development on property. h. Site should include walkable retail and pedestrian and bicycle connections to surrounding commercial and residential areas. San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-3 i. Commercial and office uses shall have parking placed behind and to side of buildings so as to not be a prominent feature. j. Neighborhood Commercial uses for proposed residential development shall be provided. k. Potential flooding issues along Prefumo Creek need to be studied and addressed without impacting off-site uses. l. All land uses proposed shall be in keeping with safety parameters described in this General Plan or other applicable regulations relative to the San Luis Obispo Regional Airport. m. Historic evaluation of the existing farm house and associated structures shall be included. Table 1-1 includes the performance standards specified in the Section 8.1.4 of the updated element for the Specific Plan area. Table 1-1. City of San Luis Obispo Land Use Element Performance Standards for San Luis Ranch Specific Plan Area Type Designations Allowed % of Site Minimum 1 Maximum Residential LDR MDR MHDR HDR 350 units 500 units Commercial NC CC 50,000 SF 200,000 SF Office/High Tech O 50,000 SF 150,000 SF Hotel/Visitor-Serving 200 rooms Parks PARK 5.8 acres Open Space/ Agriculture OS AG Minimum 50% 2 No maximum Public n/a Infrastructure n/a 1. There can be a reduction in the minimum requirement based on specific physical and/or environmental constraints. 2. The City Council may consider allowing a portion of required open space to be met through off-site dedication provided a. A substantial multiplier for the amount of open space is provided for the off-site property exchanged to meet the on-site requirement; and b. Off-site land is of similar agricultural and visual value to the community; and c. Off-site land is protected through an easement, dedication or fee title in perpetuity for agriculture/open space. Source: San Luis Obispo General Plan Land Use Element, Section 8.1.4, SP-2, San Luis Ranch (Dalidio) Specific Plan Area An EIR for the Land Use and Circulation Element Update was certified by the City in 2014. The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) addresses potential impacts of development of the project site in terms of the applicable Land Use and Circulation Element policies. However, the LUCE Update EIR does not address any specific land use development proposal for the San Luis Ranch Specific Plan Area. Airport Land Use Plan The San Luis Obispo County Airport Land Use Commission (ALUC) adopted the Airport Land Use Plan (ALUP) for the San Luis Obispo County Regional Airport (Airport) in 1973 pursuant to the California State Aeronautics Act. The ALUP was subsequently amended in 1974, 1977, 2002, 2004 and 2005. The purpose of the ALUP is to protect the long term economic viability of the Airport by ensuring compatible land uses in the vicinity of the airport; to protect the safety and well-being of the public by ensuring land use regulations minimize exposure of persons to San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-4 hazards associated with airport operations; to provide a set of policies and criteria to assist the ALUC in evaluating the compatibility of proposed local actions on the part of referring agencies with the Airport and in determining the consistency of proposed local actions with the ALUP; and to provide guidance to local agencies when presenting proposed local actions to the ALUC for review. The project site is within the Airport Land Use Planning Area and would be subject to the policies included in the ALUP. The ALUC is currently in the process of preparing a scope of work for an Amendment to the ALUP. In preparation for that amendment, the ALUC has prepared updated airport noise contours and boundaries of the aviation safety areas. However, those updates have not been formally adopted by the ALUC. 1.1.3 Relationship of the Project to the Land Use and Circulation Elements The San Luis Ranch property, identified in the City’s updated Land Use Element as Specific Plan Area (SP-2), is currently located in an unincorporated area of the County, and within the City’s Sphere of Influence. Policy 8.1.1 of the Land Use Element requires the completion and approval of a specific plan and associated General Plan Amendment prior to annexation and development of land within an area, such as the project site, which is designated as a Specific Plan Area (SP-2). The parameters for future development within SP-2 are included in Policy 8.1.4. The San Luis Ranch Specific Plan must meet performance standards prescribed in the Land Use Element, including minimum and maximum density requirements. Annexation would be subject to approval by the San Luis Obispo Local Agency Formation Commission (LAFCO) in coordination with both the City and County of San Luis Obispo. A full access interchange at U.S. Highway 101 (U.S. 101) and Prado Road has been a component of the San Luis Obispo County Regional Transportation Plan (RTP) and City Circulation Element for several decades. Environmental review and approval of programs, services, development and projects which have since been implemented have been in part predicated on a full access interchange at U.S. 101/Prado Road. Programmatic (policy-level) analysis conducted for the San Luis Ranch Specific Plan Area as part of the Land Use and Circulation Element Update identified that without a full access interchange at U.S. 101/Prado Road under buildout conditions, City streets and intersections would operate at unacceptable levels of service. The proposed San Luis Ranch Project does not include any improvements related to either a Prado Road overpass or interchange, but accommodates the potential development of either facility, if and when these are needed. The project proposes to dedicate the necessary right-of-way and financially participate in the overpass or interchange project in accordance with an equitable share analysis. The traffic study conducted for this EIR is, in part, intended to identify if and when implementation of the Prado Road overpass or interchange is necessary to achieve acceptable levels of service on City roadways and intersections, in consideration of vehicle trips generated by the proposed San Luis Ranch Project, in combination with existing and anticipated development in the City. Based on the review and analysis of potential traffic impacts identified for the project in Section 4.12, Transportation, the project would be required to pay an equitable share toward the Prado Road Overpass and U.S. 101 northbound ramps prior to Phase 2 of the project; and the Prado Road Overpass and U.S. 101 southbound ramps post project completion. San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-5 Policy 9.2.2 of the Circulation Element requires the sponsors of development projects that contribute to the need for the Prado Road interchange or overpass to prepare or fund the preparation of a Project Study Report (PSR) for the interchange project. A PSR is an engineering report prepared cooperatively by Caltrans and local and regional agencies for projects on the State highway system, with the purpose of documenting agreement on the scope, schedule and estimated cost of a project so the project can be considered for inclusion in a future programming document such as the State Transportation Improvement Program (STIP). The PSR for Highway 101/Prado Road is currently being undertaken, in parallel with the review of the proposed San Luis Ranch Project. Because the analysis in the LUCE Update EIR was completed at a policy level for the San Luis Ranch Specific Plan Area, the City allowed for open space requirements to be satisfied off-site if: (a) a substantial multiplier for the amount of open space is provided for the off-site property exchanged to meet the on-site requirement; (b) off-site land is of similar agricultural and visual value to the community; and (c) off-site land is protected through an easement, dedication or fee title in perpetuity for agriculture/open space. As described in Section 15152 of the State CEQA Guidelines, tiering refers to “using the analysis of general matters in a broader EIR (such as one prepared for a general plan or policy statement) with later EIRs and negative declarations on narrower projects; incorporating by reference the general discussions from the broader EIR; and concentrating the later EIR or negative declaration solely on the issues specific to the later project.” This EIR tiers from and incorporates by reference the City’s previously certified LUCE Update EIR (2014) and is intended to provide clear explanations as to whether project-level impacts were or were not within the scope of, and adequately addressed by, the policy-level analysis in the LUCE Update EIR. Similarly, for identified impacts, this EIR describes, and/or refines, the programmatic mitigation measures from the LUCE Update EIR, and the extent to which they address site-specific conditions for the San Luis Ranch Project. The LUCE Update EIR is available for public review at: http://www.slo2035.com/library/documents-reports/46-final- program-eir.html This EIR also provides a roadmap for future projects to determine consistency with the Specific Plan and associated EIR analysis, with the objective of minimizing redundant future CEQA review. For each impact in the project EIR, the discussion clearly delineates how the impact was (or was not) addressed in the LUCE Update EIR by providing a summary of the policy-level impact analysis. The discussion then describes how the policy-level analysis relates to the proposed Specific Plan, with respect to site-specific conditions, the consistency of the proposed Specific Plan with the analytical assumptions of the program EIR, the magnitude of the impact, and the applicability of programmatic mitigation measures. The General Plan contains policy support for incorporation of a transit hub as part of the Specific Plan land use concept. Future projects in the Specific Plan area may therefore be eligible for CEQA streamlining pursuant to SB 743. Adopted in 2013, SB 743 added a Statutory Exemption for projects which meet all of the following criteria: • The project is a residential, employment center, or mixed use project; • The project is located in a transit priority area; San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-6 • The project is consistent with a specific plan for which an environmental impact report was certified; • The project is consistent with an adopted sustainable communities strategy or alternative planning strategy. With adoption of the proposed Specific Plan, the area may satisfy the above qualifying criteria for Statutory Exemption of future projects consistent with the Specific Plan. Impacts of future projects within the Specific Plan area would be compared to what was analyzed in the EIR for the Specific Plan to determine the applicability of the SB 743 Statutory Exemption. The impacts identified in the LUCE Update EIR, the Notice of Preparation (NOP) process, and the Initial Study (Appendix A) have been utilized as a starting point in determining potential impacts of the project that must be analyzed in this EIR. A summary of related impacts and applicable mitigation from the LUCE Update EIR is included under the heading of Previous Environmental Review in the discussion of each environmental issue area in Section 4.0, Environmental Impact Analysis. This EIR provides an analysis of the impacts of the proposed development on the project site, which is described in detail in Section 2.0, Project Description. 1.1.4 Areas of Known Public Controversy Section 15123 of the CEQA Guidelines states that an EIR shall identify areas of controversy known to the Lead Agency, including issues raised by the agency and the public. Based on comments received from the public hearing and responses received during the NOP comment period, the following issues are known to be of concern and may be controversial. Each issue is further evaluated in the EIR. The NOP/Initial Study, as well as comment letters received regarding the NOP, are presented in Appendix A of this EIR. • Increased traffic congestion and impacts to circulation, especially between the U.S. 101 corridor between Los Osos Valley Road and Madonna Road; • Available water supply; • The drainage characteristics of the project site; • Airport safety and noise; • Permanent loss of prime agricultural land; • Naturally-occurring asbestos; • Greenhouse gas emissions; • Construction-related impacts such as interference with pedestrian and vehicle traffic circulation, dust, and other emissions; and • Project alternatives. PURPOSE AND LEGAL AUTHORITY 1.2 Several of the project’s proposed actions: amendments to the General Plan, adoption of the Specific Plan, annexation of the site to the City of San Luis Obispo, a Development Agreement, and a Development Plan, are discretionary actions requiring approval of the City Council. Therefore, the project is subject to the requirements of CEQA. In accordance with Section 15121 of the State CEQA Guidelines, the purpose of this EIR is to serve as an informational document that: San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-7 ...will inform public agency decision-makers and the public generally of the significant environmental effects of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project. This EIR is to serve as an informational document for the public and City of San Luis Obispo decision-makers. The process will culminate with Planning Commission and City Council hearings to consider certification of a Final EIR as well as the project’s requested approvals. Although the project is a specific plan and development plan, this EIR contains a project-level environmental review that fulfills the requirement of a project-level EIR. As defined in CEQA Guidelines Section 15161, a project-level EIR: …examines the environmental impacts of a specific development project. This type of EIR should focus primarily on the changes in the environment that would result from the development project. The EIR shall examine all phases of the project including planning, construction, and operation. Pursuant to CEQA Guidelines Section 15182, “where a public agency has prepared an EIR on a specific plan after January 1, 1980, no EIR or negative declaration need be prepared for a residential project undertaken pursuant to and in conformity to that specific plan if the project,” as long as the residential project is within the scope of the EIR, no new environmental effects are anticipated to occur, and no new mitigation measures are required for the residential project. SCOPE AND CONTENT 1.3 In accordance with the State CEQA Guidelines, a Notice of Preparation (NOP) for this EIR was distributed for review by affected agencies and the public on October 19, 2015. The NOP and Initial Study are presented in Appendix A of this EIR. Through the NOP and Initial Study process, the City of San Luis Obispo determined that there was no substantial evidence that the project would cause or otherwise result in significant environmental effects in the areas of Geology and Soils, Mineral Resources, Population and Housing, and Public Services. No further environmental review of these issues is necessary for the reasons summarized in the Section 5.0, Effects Found Not to be Significant. The substantiation for determining that these issues would result in no impact, or a less-than-significant impact is described in further detail in Appendix A, NOP and the Initial Study, pursuant to §15128 of the State CEQA Guidelines. This EIR addresses the issues determined to be potentially significant in the Initial Study, and based on responses to the NOP and scoping discussions among the public, consulting staff, and the City. The City of San Luis Obispo conducted an initial analysis of the proposed development’s impacts through the Initial Study and NOP process. The environmental issues addressed in impact sections in this EIR include: • Aesthetics • Agricultural Resources • Air Quality • Biological Resources • Cultural Resources • Greenhouse Gas Emissions • Hazards and Hazardous Materials • Hydrology and Water Quality • Land Use/ Planning • Noise • Recreation • Transportation/ Traffic • Utilities/ Service Systems San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-8 This EIR builds upon the programmatic analysis performed in the LUCE Update EIR and addresses the issues referenced above and identifies potentially significant environmental impacts, including site-specific and cumulative effects of the project in accordance with the provisions set forth in CEQA and the State CEQA Guidelines. In addition, the EIR recommends feasible mitigation measures, where possible, that would reduce or eliminate adverse environmental effects. A summary of cumulative impacts, which gives consideration to other projects in the vicinity, are described in each resource section within Section 4.0, Environmental Impact Analysis. Cumulative project analyses represent a comprehensive assessment of potential impacts on City resources using a list of past, present, and probable future projects capable of producing related or cumulative impacts. Alternatives to the project consistent with CEQA requirements are considered to examine a reasonable range of approaches to minimize environmental impacts while achieving most of the project objectives. The alternatives to the project are evaluated in Section 6.0, Alternatives, of this EIR. In preparing the EIR, use was made of pertinent City policies and guidelines, existing EIRs and background documents prepared by the City, and documents that guide land use in the City. A full reference list is contained in Section 7.0, References, of this EIR. The level of detail contained throughout this EIR is consistent with the requirements of CEQA and applicable court decisions. The State CEQA Guidelines provide the standard of adequacy on which this document is based. The Guidelines state: An EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of the proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection, but for adequacy, completeness, and a good faith effort at full disclosure. (Section 15151). LEAD, RESPONSIBLE, AND TRUSTEE AGENCIES 1.4 The State CEQA Guidelines define “lead,” “responsible” and “trustee” agencies. The City of San Luis Obispo is the lead agency for the project because it has the principal responsibility for approving the project. Discretionary approval of the project (including acquisition of the project site) is vested with the San Luis Obispo City Council. A “responsible agency” refers to public agencies other than the “lead agency” that have discretionary approval over the project. The Local Agency Formation Commission (LAFCO) would be the responsible agency for annexation of the project site to the City. The State Department of Transportation (Caltrans) would be a responsible agency for any improvements on U.S. Highway 101 (U.S. 101). Other responsible agencies include the Airport Land Use Commission, Army Corps of Engineers for review of a Nationwide or Individual permit (dependent upon the acreage of total wetland disturbance), and the Regional Water Quality San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-9 Control Board (RWQCB) for Section 401 Water Quality Certification and the National Pollutant Discharge Elimination System (NPDES) Storm Water Permit. A “trustee agency” refers to a state agency having jurisdiction by law over natural resources affected by a project that are held in trust for the people of the State of California. The California Department of Fish and Wildlife (CDFW) has jurisdiction over biological resources, including waters of the State and rare and endangered plant species, which may be affected by project development, and is, therefore, a trustee agency. ENVIRONMENTAL REVIEW PROCESS 1.5 The environmental impact review process, as required under CEQA, is outlined below. The steps are presented in sequential order. 1. Notice of Preparation. Immediately after deciding that an EIR is required, the lead agency must file a NOP soliciting input on the EIR scope to “responsible,” “trustee,” and involved federal agencies; to the State Clearinghouse, if one or more state agencies is a responsible or trustee agency; and to parties previously requesting notice in writing (State CEQA Guidelines Section 15082; Public Resources Code Section 21092.2). The NOP must be posted in the County Clerk’s office for 30 days. 2. Draft Environmental Impact Report. The Draft EIR must contain: a) table of contents or index; b) summary; c) project description; d) environmental setting; e) significant impacts (direct, indirect, cumulative, growth-inducing and unavoidable impacts); f) alternatives; g) mitigation measures; and h) irreversible changes. 3. Public Notice and Review. A lead agency must prepare a Notice of Availability of an EIR. The Notice must be placed in the County Clerk’s office for 30 days (Public Resources Code Section 21092). The lead agency must send a copy of its Notice to anyone requesting it (State CEQA Guidelines Section 15087). Additionally, public notice of DEIR availability must be given through at least one of the following procedures: (a) publication in a newspaper of general circulation; (b) posting on and off of the project site; or (c) direct mailing to owners and occupants of contiguous properties. The lead agency must consult with and request comments on the Draft EIR from responsible and trustee agencies, and adjacent cities and counties (Public Resources Code Sections 21104 and 21253). The minimum public review period for a Draft EIR is 30 days. When a DEIR is sent to the State Clearinghouse for review, the public review period must be 45 days unless a shorter period is approved by the Clearinghouse (Public Resources Code 21091). 4. Final EIR. A Final EIR must include: (a) the DEIR; (b) copies of comments received during public review; (c) a list of persons and entities commenting; and (d) responses to comments. 5. Final EIR Certification. Prior to approving a project, the lead agency must certify that: (a) the Final EIR has been completed in compliance with CEQA; (b) the Final EIR was presented to the decision-making body of the lead agency and that the lead agency San Luis Ranch Project EIR Section 1.0 Introduction City of San Luis Obispo 1-10 considered the information in the Final EIR; and c) the Final EIR reflects the lead agency’s independent judgment and analysis (State CEQA Guidelines Section 15090). 6. Lead Agency Decision. A lead agency may: (a) disapprove a project because of its significant environmental effects; (b) require changes to a project to reduce or avoid significant environmental effects; or (c) approve a project despite its significant environmental effects, if the proper findings and statement of overriding considerations are adopted (State CEQA Guidelines Sections 15042 and 15043). 7. Findings/Statement of Overriding Considerations. For each significant impact of the project identified in the EIR, the lead or responsible agency must find, based on substantial evidence, that either: (a) the project has been changed to avoid or substantially reduce the magnitude of the impact; (b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or (c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (State CEQA Guidelines Section 15091). If an agency approves a project with unavoidably significant environmental effects, it must prepare a written Statement of Overriding Considerations that set forth the specific social, economic or other reasons supporting the agency’s decision. 8. Mitigation Monitoring/Reporting Program. When a lead agency makes findings on significant effects identified in a Final EIR, it must adopt a reporting or monitoring program for mitigation measures that were adopted or made conditions of project approval to mitigate significant effects. 9. Notice of Determination. The lead agency must file a Notice of Determination after deciding to approve a project for which an EIR is prepared (State CEQA Guidelines Section 15094). A local agency must file the Notice with the County Clerk. The Notice must be posted for 30 days and sent to anyone previously requesting notice. Posting of the Notice starts a 30-day statute of limitations on CEQA challenges (Public Resources Code Section 21167[c]). San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-1 PROJECT DESCRIPTION 2.0 SUMMARY 2.1 The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment/Pre-Zoning, and Development Plan/Vesting Tentative Tract Map for a 131-acre project site, including annexation of the site into the City of San Luis Obispo. The project is intended to be consistent with the development parameters described in the City’s Land Use and Circulation Element (adopted in December 2014). The project includes a mixture of residential, commercial, office, and hotel uses, with a portion of the site preserved for agriculture and open space uses. The project is planned to be constructed in six phases, beginning in 2017. The specific characteristics of the project are described in greater detail below. PROJECT PROPONENT 2.2 Coastal Community Builders c/o Marshall Ochylski (Project Representative) 979 Osos, Suite F7 San Luis Obispo, CA 93401 P.O. Box 13 Pismo Beach, CA 93449 PROJECT LOCATION 2.3 The 131-acre project site is located in unincorporated San Luis Obispo County, completely surrounded by the corporate boundary of San Luis Obispo; it is also within the City’s Sphere of Influence. The project site is generally bounded by residential uses and Madonna Road to the west, commercial uses and Dalidio Drive to the north, United States Highway 101 (U.S. 101) to the east and the San Luis Obispo City Farm to the south. Prefumo Creek is located south of the site. The site is identified by assessor’s parcel number (APN) 067-121-022. Figure 2-1 shows the regional location of the City of San Luis Obispo. Figure 2-2 shows the site in its local context. EXISTING SITE CHARACTERISTICS 2.4 The project site is currently used for agricultural purposes, primarily as cultivated row crops. Dry and partially irrigated field crops, including garbanzo beans, dry beans, cabbage and lettuce, have been produced on the property. The site is important for its historic agricultural use, and is highly visible from U.S. 101. Its visually sensitive prominent location at a southern gateway to the City has led to a policy to preserve approximately half of the agriculture and open space on-site, both to preserve views and to maintain the City’s agricultural heritage. A single broad swale, referred to as Cerro San Luis Channel, bisects the property from east to west. This system drains toward Prefumo Creek at the project site’s southwestern boundary. Prefumo Creek is lined with multiple rows of mature blue gum eucalyptus trees, making that edge of the property visually prominent in the area. Figure 2-2 includes an aerial photograph of the site and surrounding area. Figures 2-3a and 2-3b present photos of the existing conditions at the project site. The San Luis Ranch Farm Complex, which includes a farm house and Regional Location Figure 2-1 City of San Luis Obispo Section 2.0 Project DescriptionSan Luis Ranch Project EIR ^_ Imagery provided by National Geographic Society, ESRI andits licensors © 2016. The topographic representation depictedin this map may not portray all of the features currentlyfound in the vicinity today and/or features depicted in this mapmay have changed since the original topographic map wasassembled. Project Location San Luis Obispo City Limits ±0 5,2002,600 Feet 2-2 £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r Post Office Water Resource Recovery Facility San Luis ObispoCity Farm San Luis RanchFarm Complex Project Site Location Figure 2-2 City of San Luis Obispo Section 2.0 Project DescriptionSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2015. ±0 600300 Feet Site Boundary 2-3 San Luis Ranch Project EIR Section 2.0 Project Description Existing Conditions Photoplates Figure 2-3a City of San Luis Obispo Photo 1: Looking northeast toward the project site from the former terminus of Calle Joaquin. Photo 2: Looking southeast from the eastern terminus of Dalidio Drive. 2-4 San Luis Ranch Project EIR Section 2.0 Project Description Existing Conditions Photoplates Figure 2-3b City of San Luis Obispo Photo 3: Looking west from the eastern terminus of Dalidio Drive. Photo 4: Looking south from the eastern terminus of Dalidio Drive. 2-5 San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-6 outbuildings, is located on the western portion of the property adjacent to Madonna Road (refer to Figure 2-2). 2.4.1 Surrounding Land Uses Over time, land uses surrounding the property have transitioned from agricultural to a variety of urban uses, including residential areas, shopping centers, and auto dealerships. With these changes, the project site is bordered urban uses on north, east, and west, and by the SLO City Farm to the south. In addition, almost half the site would remain as open space adjacent to where the proposed commercial and residential uses would be constructed. Existing uses surrounding the site area are shown on Figure 2-2, and include the following: West: Developed single-family properties in the City, zoned R-1. North: A post office is adjacent to the site at southwest corner of Madonna and Dalidio Road, zoned C-R-PD (Commercial Retail with a Planned Development overlay). The Central Coast Plaza Shopping Center (SLO Promenade) and Madonna Plaza Shopping Center, also zoned C- R-PD and C-R, are located immediately north of the site across Dalidio Drive. Laguna Lake Park and surrounding open space is across Madonna Road (zoned PF and C/OS-40, respectively). East: U.S. 101 is immediately east of the site, beyond which are a variety of public facilities, including the City’s Water Resource Recovery Facility. These areas are zoned PF (Public Facility). A drive-in theater is located east of the freeway and north of Prado Road, and is zoned Community-Commercial Special Focus (C-C-SF). The property just south of the drive-in theater at the northeast corner of Prado Road and Elks Lane is zoned O-PD (Office, with a Planned Development overlay) and is the planned location for the Homeless Services Center. South: The SLO City Farm is immediately south of the site (zoned C/OS-20 – Conservation/Open Space with a 20-acre minimum size), beyond which are a variety of commercial service uses, including auto dealerships (zoned C-S or C-S-PD, or Commercial Service, some with a Planned Development overlay) and a recently approved car dealership (Coast BMW) and 115 room hotel (zoned Tourist-Commercial Special Focus (C-T-SF). PROJECT CHARACTERISTICS 2.5 Adoption of the San Luis Ranch Specific Plan and approval of related entitlements would require several actions from the City and other public agencies as described in Section 2.8, including a Specific Plan, General Plan Amendment/Pre-Zoning, Development Plan/Vesting Tentative Tract Map, annexation of the site into the City of San Luis Obispo, and architectural review. It would also address a Development Agreement/Memorandum of Understanding, which provides a mechanism for project implementation. While not an entitlement, the Development Agreement/Memorandum of Understanding is considered part of potential project approval. Prior to construction, other approvals such as grading and building permits, and further architectural review would be required but are not being processed concurrently with this application. The project is described in detail in the August 2016 San Luis Ranch Specific Plan (refer to Appendix B) and summarized in this section. Figure 2-4 shows the project’s proposed pre-zoning and Figure 2-5 shows the proposed land use plan. Figure 2-6 is the proposed site plan for the project site and shows the layout of proposed commercial, £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r AG NG-10 NC NG-30 NG-23P-OS NC NC Proposed Project Pre-Zoning Figure 2-4 City of San Luis Obispo Section 2.0 Project DescriptionSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2015. ±0 500250 Feet Site Boundary Project Zoning Neighborhood General One Neighborhood General Two Neighborhood General Three Neighborhood Commercial Parks and Open Space Agriculture 2-7 Project Land Use Plan Figure 2-5 City of San Luis Obispo Section 2.0 Project DescriptionSan Luis Ranch Project EIR ±0 500250 Feet Site Boundary Agriculture Commercial Parks, Creek, Basins, Internal Open Space Medium Density Residential Low-Medium Density Residential High Density Residential Source: Coastal Community Builders, Inc., March 15, 2016 2-8 Figure 2-6 City of San Luis Obispo Section 2.0 Project DescriptionSan Luis Ranch Project EIR Project Site PlanSource: Coastal Community Builders, Inc., March 15, 2016 Agriculture NG-10 NG-23 NG-30 NC AG OS High Density Residential Medium Density Residential Low-Medium Density Residential Open Space Neighborhood Commercial Agriculture Site Boundary ±0 500250 Feet 2-9 San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-10 agricultural, open space, and residential uses. The following sections provide detailed descriptions of major project components outlined in the San Luis Ranch Specific Plan. 2.5.1 Annexation The project would require annexation to the City of San Luis Obispo. The project is within the City’s Sphere of Influence and Urban Reserve Line, and is designed to be consistent with both City and Local Agency Formation Commission (LAFCo) policies, including the requirement that the annexation be compatible with the City’s General Plan and supportable by the City’s infrastructure. 2.5.2 Land Use Concept As shown in Figure 2-4, the Specific Plan area is organized into six zones. These include Neighborhood General 1 (NG-10), Neighborhood General 2 (NG-23), Neighborhood General 3 (NG-30), Neighborhood Commercial (NC), Parks and Open Space (P-OS), and Agriculture (A). The applicable densities and development standards associated with each of these zones are described in detail below. Table 2-1 lists the proposed San Luis Ranch Specific Plan zone s, acreages, and maximum buildout potential within each zone of the Specific Plan Area. Table 2-1 Planned San Luis Ranch Specific Plan Area Development Type Specific Plan Zone Units Acreage Planned Development 1 Low-Medium Density Residential NG-10 200 units 16.0 acres Medium Density Residential NG-23 100 units 6.8 acres High Density Residential NG-30 200 units 10.4 acres Affordable Housing Density Bonus 2 80 units n/a Commercial NC up to 150,000 SF 9.7 acres Office NC up to 100,000 SF 3.9 acres Hotel and Conference Center NC 200 rooms 3.6 acres Public Parks 3.4 acres Regional Roads 8.1 acres Local Roads 9.4 acres Agricultural and Open Space Agriculture A 52.7 acres Internal Open Spaces P-OS 7.4 acres 1. Planned Development area is based on net site area of approximately 129.3 123.2 acres. The gross site area is approximately 131.3 acres, less approximately 8 acres of right-of-way associated with potential future City roadways and the future Prado Road overpass/interchange improvements. 2. The project includes up to 34 deed-restricted affordable units on site. Per Section 17.90.040(d) of the City's Affordable Housing Incentives, the included affordable housing allows for a 20% density bonus. Each land use component of the project is summarized below (refer to Figure 2-5 for the proposed land use plan and Figure 2-6 for the proposed site plan). San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-11 Residential The project includes a mix of 580 low-medium, medium, and high density residences that would be located primarily on the northwestern and central portion of the project site. Housing would range from detached single-family units to attached multi-family dwellings, and are described in detail Chapter 3 of the Specific Plan (Appendix B to this EIR). The low-medium density residential zone (NG-10) would allow for residential units at a density of up to 10 units per acre with a height limit of 35 feet. Residential products envisioned for this zone include single-family and small-lot residential. The medium-density residential zone (NG-23) would allow for residential units at a density of up to 23 units per acre with a height limit of 3540 feet. Residential products envisioned for this zone include detached townhomes, attached townhomes, and multi-family structures such as apartments or condos. The high-density multi- family residential zone (NG-30) would allow for residential units at a density of up to 30 units per acre with a height limit of 3540 feet. Residential products envisioned for this zone include detached townhomes, attached townhomes, and multi-family structures such as apartments or condos. The neighborhoods would be connected with a local street, bicycle circulation, and trail system, and would contain recreational areas. Internal circulation would include night lighting designed to meet ‘dark sky’ standards. In addition, the project includes an affordable housing component in accordance with City requirements. The San Luis Ranch Specific Plan proposes 34 deed-restricted affordable units on site for very low, low, and moderate income households, including 26 very low income units. Consistent with Section 17.90.040(d) of the City’s Affordable Housing Incentives, the proposed affordable housing would allow for an 80-unit density bonus, bringing the total allowable residential units in the Specific Plan Area from 500 to 580. Commercial The Specific Plan land use plan and pre-zoning would allow up to 150,000 square feet of commercial development, up to 100,000 square feet of office development, and a 200-room hotel with allowable building heights up to a 50-foot maximum. The commercial and hotel land uses are proposed on the portion of the project site adjacent to the extended Prado Road/Dalidio Drive and Froom Ranch Way. Commercial uses proposed for the project may include retail anchors, neighborhood retail, restaurants, offices, and a hotel. Future entitlements for these commercial project components would require subsequent City review and approval. Agriculture The project would preserve approximately 52.7 53 acres of the site in agriculture adjacent to the San Luis Obispo City Farm. The project would also preserve approximately 7.4 acres of the site in open space. Collectively, this would comprise approximately 48 43 percent of the net site acreage (when acreage set aside for regional roadways and the future Prado Road interchange or overpass is discounted) and 40 percent of the gross site acreage. As the project is developed, this agricultural property would be transitioned into organic (pesticide- and chemical-free) farming. The project also includes a commitment to procure an off-site agricultural conservation easement/deed restriction to comply with the City’s General Plan Land Use Element Policy 1.13.8 and Land Use Element Policy 8.1.4, which require that future development on the San Luis Ranch property dedicate one half of the total land or easements for open space use. As part of the proposed agricultural uses, the project also includes an Agricultural Heritage Facilities & Learning Center, which would be located along the southeast side of Froom Ranch San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-12 Way, southwest of the proposed commercial land use (refer to Figure 2-6). The project includes the adaptive reuse and relocation of two existing structures – the main residence and the former spectators’ barn/viewing stand, which are part of the existing San Luis Ranch Complex along Madonna Road – to new locations on the site within the Agricultural Heritage and Learning Center. In addition, salvageable materials from the main barn within the San Luis Ranch Complex are proposed to be reused to the greatest extent possible in the construction of a new barn in the Agricultural Heritage and Learning Center. The Agricultural Heritage Facilities & Learning Center would be intended as an educational center for local residents and an agricultural tourism destination. Structures in the Agricultural Heritage Facilities & Learning Center would have a maximum height limit of 35 feet; however, historical structures would be permitted to exceed this limit up to a 45-foot maximum. Open Space As shown on Figure 2-6, the proposed open space would be located on the northwestern portion of the project site along Prefumo Creek, as well as along Cerro San Luis Channel, which is a permanent surface drainage that traverses the property from east to west. The open space areas would also include a link in the Bob Jones Regional Trail. Multi-Modality: Bicycle and Pedestrian Circulation The project would establish links in the City’s Bicycle Transportation Plan. As discussed above, the project would construct a six-foot wide nature trail with bike routes on Froom Ranch Way and Dalidio Drive connecting a segment of the Bob Jones Bike Trail, providing and provide a connection from Laguna Lake Park and nearby neighborhoods and businesses along Madonna Road to the existing segment of the Bob Jones Trail near the Target shopping center at the southern portion of the City limit at Froom Ranch Way. The project would create interior bicycle trails and lanes, including a Class I Bike Trail and Class II Bike lanes. These facilities are consistent with the goals established by San Luis Obispo’s 2013 Bicycle Transportation Plan. Figure 2-7 shows the project’s proposed bicycle circulation plan. Land Use and Circulation Element Update Performance Standards for the San Luis Ranch Specific Plan Area As described in Section 1.0, Introduction, the 2014 Land Use and Circulation Element Update EIR (LUCE Update EIR) analyzed buildout of the project site with 350 to 500 residential units; 50,000 to 200,000 square feet of commercial development; 50,000 to 150,000 square feet of office development; a 200-room hotel; 5.8 acres of parks; and 66 acres of agriculture and open space. The project includes a similar extent of commercial, office, and hotel uses than would be permitted under the Land Use Element performance standards, and would allow up to 500 residential units. In addition, as described above, because the project includes an affordable housing component in accordance with City requirements, an additional 80 residential units would be allowed on the site as a density bonus. The total number of dwellings evaluated in this EIR would therefore be 580. The project includes a reduced on-site area of parks (approximately 3.4 acres) and a reduced on-site area of agriculture and open space (approximately 60.1 acres) compared to the concept envisioned in the Land Use Element. Table 2-2 compares the maximum buildout potential of the project site under the Land Use Element with the proposed project. Source: Coastal Community Builders, Inc., October 3, 2016.Bicycle Circulation PlanFigure 2-7City of San Luis ObispoSan Luis Ranch Project EIRSection 2.0 Project Description2-13 San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-14 Table 2-2. Planned Specific Plan Area Development Compared to Land Use Element Buildout Potential Description Proposed Project Land Use Element Buildout Potential Low-Medium Residential 300 units 350 units High Density Residential 200 units 150 units Affordable Housing Density Bonus 80 units - Residential total 580 units 500 units Commercial – Hotel 200 rooms 200 rooms Commercial – Office 100,000 square feet 150,000 square feet Commercial – Retail 150,000 square feet 200,000 square feet The Land Use Element includes Policy 2.4.2 to promote affordable housing in the City, which requires the City to approve a density bonus for projects that include affordable housing for seniors or lower income households consistent with the requirements of State Law. In addition, the Land Use Element includes specific policies to preserve the historic agricultural use of the site. Land Use Element Policy 1.13.8 and Land Use Element Policy 8.1.4 require that a minimum of 50 percent of the site be dedicated to open space/agriculture. Approximately 60.1 combined acres of agriculture and open space would be retained on the project site, including approximately 53 acres in agricultural use along the project site frontage with U.S. 101. Although approximately 47 percent of the site would be maintained as open space/agriculture, the project also includes a commitment to procure an off-site agricultural conservation easement/deed restriction or pay in lieu fees to comply with Land Use Element Policy 1.13.8 and Land Use Element Policy 8.1.4. The applicant has identified a potential site on the westerly edge of the City’s Greenbelt Boundary for an off-site agricultural conservation easement. City staff has provided preliminary concurrence as to the suitability of this site; however, final approval of this or any other off-site agricultural conservation easement site in terms of its ability to satisfy City requirements would require City Council action. 2.5.3 Infrastructure The key infrastructure components of the project are described below, and shown in Figure 2-8 (roadways and circulation), Figure 2-9 (wastewater infrastructure), Figure 2-10 (water infrastructure), and Figure 2-11 (recycled water infrastructure). Roadways and Circulation The project proposes to provide or pay fair share fees for such public improvements as a widening of Madonna Road along project frontage, additions to Dalidio Drive/Prado Road, an extension of Froom Ranch Way across Prefumo Creek in the southwest corner of the site, and to contribute in fair share towards an overpass or interchange connection for Prado Road. Some of these proposed improvements, including the Froom Ranch Way extension across Prefumo Creek, would be located off of the project site, but are part of project review. The existing street network in the project site vicinity includes U.S. 101 and the Madonna Road and Los Osos Valley Road arterials. The proposed street network within the Specific Plan area consists primarily of collector and residential streets. Access to the residential areas would be Source: Coastal Community Builders, Inc., October 3, 2016.Vehicular Circulation PlanFigure 2-8City of San Luis ObispoSan Luis Ranch Project EIRSection 2.0 Project Description2-15 San Luis Ranch Project EIR Section 2.0 Project Description Source: Coastal Community Builders, Inc., March 15, 2016.Wastewater System Layout Figure 2-9 City of San Luis Obispo /0 600 Feet 2-16 San Luis Ranch Project EIR Section 2.0 Project Description Source: Coastal Community Builders, Inc., March 15, 2016.Water Supply System Layout Figure 2-10 City of San Luis Obispo /0 600 Feet 2-17 San Luis Ranch Project EIR Section 2.0 Project Description Source: Coastal Community Builders, Inc., March 15, 2016.Recycled Water System Layout Figure 2-11 City of San Luis Obispo /0 600 Feet 2-18 San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-19 provided on the south from the proposed Froom Ranch Way extension and on the north from Madonna Road (refer to Figure 2-8, which shows the project’s vehicular circulation plan). In addition, the Specific Plan includes a transit center that would provide direct transit access between the project site and downtown San Luis Obispo. The location of the proposed transit center would be coordinated with SLO Transit and the Regional Transit Authority upon submittal of individual project plans. If transit ridership meets specified demand thresholds, direct Regional Transit Authority access will be considered at this future transit center. Wastewater Collection The City of San Luis Obispo provides public wastewater collection and treatment in the City. The existing City wastewater collection system that surrounds the site consists of an 8-inch gravity sewer main in Madonna Road and two 8-inch mains that create a siphon from the 15- inch sewer main in Oceanaire Drive under Prefumo Creek to a 15-inch and ultimately 18-inch gravity sewer main, which extends through an easement within the existing agricultural fields on the project site, under U.S. 101 to the Laguna Lift Station. The existing wastewater collection system from Prefumo Creek to the crossing at U.S. 101 is at capacity and is proposed to be upgraded to provide adequate capacity for existing flows and projected flows from the project. The new encased 24-inch sewer main crossing at U.S. 101 would provide capacity for projected development to the west along Calle Joaquin, with cost sharing agreements. The proposed wastewater infrastructure is shown in Figure 2-9. Potable and Recycled Water The City of San Luis Obispo is the sole purveyor of water within the City limits. New 12-inch potable water mains would extend through the site from Madonna Road to the existing 12-inch line at U.S. 101 across from Prado Road, as well as within the proposed Froom Ranch Way extension. The project would connect to the existing 8-inch potable water mains at the end of Froom Ranch Way, at the end of Oceanaire Drive and at the end of Dalidio Drive. Open Space areas along the creek, parks, and portions of the commercial and office areas would be irrigated using recycled water from an extension of the City’s recycled water distribution system. Proposed recycled water infrastructure improvements include a 6-inch recycled water main from Madonna Road through the project site. The existing private onsite wells will continue to be used for irrigation of ongoing agricultural uses on the project site. The proposed water infrastructure is shown in Figure 2-10, and the proposed recycled water infrastructure is shown in Figure 2-11. Stormwater Portions of the project site are located in a designated 100-year floodplain (1 percent probability of occurrence per year). The overall general flow of surface water is from northeast to southwest, along Cerro San Luis Channel and along the west side of U.S. 101, across the agricultural fields in a generally widening surface flow path, finally draining into Prefumo Creek. The project includes a floodplain management strategy with both preventative and corrective measures, including Low Impact Development (LID) measures. Drainage from the residential area, commercial areas, and hotel and office areas within the project site would be treated and detained on-site. Flows from these areas would be released to the project storm drain network which eventually outfalls to Prefumo Creek, or to Cerro San Luis Channel. New drainage facilities at Dalidio Drive in the vicinity of Cerro San Luis Channel San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-20 Box Culvert would be installed to convey the offsite flows generated by the 10-year storm under Dalidio Drive to Cerro San Luis Channel. Improvements to Dalidio Drive would convey via surface flow larger storms from properties to the north across Dalidio Drive to Cerro San Luis Channel. The project would provide regional detention for residential areas by taking water off of Cerro San Luis Channel and routing it through underground chambers within the project site. Flows would be released back to the channel at a rate which provides the required detention. For those areas not included in this regional detention (high density residential [NG-30] adjacent to the post office southwest corner of Madonna and Dalidio Road, commercial, hotel, office and Agricultural Heritage Facilities and Learning Center) on-site detention would be provided. Drainage from existing parking areas to the north which currently cross the proposed office parcel would be routed through that parcel and released back to the remaining agricultural area or through on-site piping to Prefumo Creek. The proposed single family residential area would provide required stormwater treatment within street landscape areas, the central park area, and areas adjacent to the creek and channel. Required stormwater detention would be provided on-site where possible or may be provided within other portions of the project site through the diversion of upstream runoff and remote detention. The proposed stormwater detention plan is depicted in Figure 2-12. Housing in the multi-family area would be arranged in a manner which would allow the incorporation of stormwater treatment and retention upstream of the discharge to adjacent waterways. This stormwater treatment would be addressed in park areas, at street medians and curb bump-outs in order to meet the requirements for the City’s Post Construction Stormwater Treatment. Required detention for this site would be provided on-site where possible, or may be provided within other portions of the project site through the diversion of upstream runoff and remote detention. The agricultural open space area would remain within the 100-year flood zone. No new development is proposed within the 100-year flood zone, and no stormwater treatment or detention is required for agricultural uses. Required storm water treatment associated with the Agricultural Heritage Facilities & Learning Center would be contained within that development area, and detention may be proposed in that area as well. Detention facilities may be located adjacent to Froom Ranch Road in the form of linear shallow basins or underground storage, if necessary, to contain flows from the remainder of the project site. Flows from these basins would be released to Prefumo Creek. Grading The project site is relatively level, with a gentle slope to the south and southwest. The medium (NG-23) and high density residential (NG-30) area would be graded using standard methods. The current limits of the 100-year flood plain extend across the proposed single-family and commercial areas. The project involves re-grading the site to lower the areas of the site that would be dedicated for active agriculture by approximately six inches to two feet. This grading is required to provide material for the development of the project site. Through the placement of fill from on- and off-site, these properties the proposed single-family and office and hotel sites areas would be graded such that, at a minimum, all structures would be removed from the Stormwater Detention PlanFigure 2-12Source: Coastal Community Builders, Inc., March 21, 2016City of San Luis ObispoSan Luis Ranch Project EIRSection 2.0 Project Description/0650FeetPROPOSED RETENTION(INCLUDING UNDERGROUND STORAGE)PROPOSEDDETENTION OUTFALLPROPOSEDBIOFILTRATIONAND RETENTIONPROPOSED STORMWATER DETENTION2-21 San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-22 flood plain, and the 100-year storm would be contained in the streets and the parking lots. The limits of the commercial area also lie within the 100-year flood plain and the potential office and hotel sites would also receive grading fill such that, at a minimum, structures would be removed from the flood plain. An overland drainage path would be provided via proposed on- site detention facilities, Cerro San Luis Channel, and Prefumo Creek to accommodate overland flood flows from the north. The agricultural area would remain within the 100-year flood plain, with cut grading taking place to offset the diverted flows from adjacent areas, such that no change in flood water depths or flows would occur on surrounding properties (refer to Section 4.8, Hydrology and Water Quality, for a detailed discussion of proposed grading and the post-development floodplain). Grading in the Agricultural Heritage Facilities & Learning Center area would include the placement of fill to protect the proposed structures from flooding. Grading of agricultural areas would include the preservation of active, high-quality topsoils through lifting and setting aside the top layer of soil material, and removal and stockpiling of the subsoil on the development area. The set-aside topsoil would then be redistributed back onto the graded area that would be dedicated for active agriculture stockpiling on-site during grading and excavation (refer to Section 4.2, Agricultural Resources, for a detailed discussion of proposed grading and potential effects on continued agricultural viability on the project site). In total, earthwork for buildout of the Specific Plan area is estimated to require 817,200 cubic yards (CY) of cut, and 569,200 CY of fill, resulting in a need for approximately 248,000 CY of soil import. Figure 2-13 shows the proposed grading plan. 2.5.4 Project Phasing Based on the project phasing plan, the project would be constructed in six phases. Phases 1, 2, and 3 would consist of residential build out, with construction planned to begin in 2017 and anticipated to be completed by 2020. Phases 4, 5, and 6 would consist of non-residential build out, with construction planned to begin in 2017 and anticipated to be completed by 2023. In addition to the land use components of the project, the project phasing plan indicates that the Froom Ranch Way extension and infrastructural improvements along Madonna Road would be constructed concurrent with Phases 1 and 2. Infrastructure improvements along Prado Road/Dalidio Drive, traffic signal improvements, and the Froom Ranch Way Bridge are proposed to be constructed beginning during Phase 3. Figure 2-14 shows the proposed phasing for project development. PROJECT OBJECTIVES 2.6 The applicant’s objectives for the project include: 1. Provide infill growth for the City that is anticipated and desired by City planning decisions and guidelines; 2. Preserve agricultural land and open space on site, maintain agricultural views from U.S. 101; 3. Create significant entry-level, workforce housing opportunities within the City that is specifically “affordable by design”; 4. Implement a walkable-bikeable neighborhood design that is integrated with public transit access and open space amenities that encourage alternative modes of transportation; Source: Cannon, October 14, 2015Project Grading PlanFigure 2-13City of San Luis ObispoSan Luis Ranch Project EIRSection 2.0 Project Description/0 225 450 FeetCabrillo Highway 101Madonna Road25 ACRES TRADITIONAL SINGLE FAMILY RESIDENTIAL10 ACRES SMALL SINGLE FAMILY RESIDENTIAL11 ACRES MULTI-FAMILY RESIDENTIAL17 ACRES COMMERCIAL6%AREASSTORMWATER TREATMENT AND RETENTION% REQUIRED7%7%7%1.5 ACRESAREA REQUIRED0.7 ACRES0.8 ACRES1.2 ACRES4’ OVER-EXCAVATIONUTILITY TRENCH SPOILSSTORM DET/RET SPOILSONSITE GRADINGCOMPACTION LOSSTotalImport:428,600ESTIMATED EARTHWORK QUANTITIES (CY)Fill25,90017,40097,300428,600Cut282,000106,600569,200248,000817,2002-23 Source: Coastal Community Builders, Inc., March 15, 2016.Project Phasing PlanFigure 2-14City of San Luis ObispoSan Luis Ranch Project EIRSection 2.0 Project Description2-25 San Luis Ranch Project EIR Section 2.0 Project Description City of San Luis Obispo 2-26 5. Create new commercial, office and hotel opportunities that will accommodate and complement existing businesses in downtown San Luis Obispo; 6. Develop an Agriculture Heritage Facilities & Learning Center offering seasonal attractions and local goods that promote the region’s agricultural richness; 7. Establish an important link in the Bob Jones Regional Trail; 8. Provide fair-share financial contribution towards important public circulation improvements. REQUIRED APPROVALS 2.7 The following entitlements and approvals would be required to implement the proposed project: • Specific Plan • General Plan Amendment/Pre-Zoning • Development Plan/Vesting Tentative Tract Map(s) • Development Agreement • Processing Memorandum of Understanding (outlining a framework for process, fees, and a methodology for determining a fair share for Prado Road improvements) • Architectural Review Other public agencies whose approval is required include: • Local Agency Formation Commission - Annexation • Caltrans review for any improvements associated with a potential U.S. 101/Prado Road interchange or overpass • Airport Land Use Commission review • Army Corps of Engineers Nationwide or Individual permit (depending on acreage of total wetland disturbance) • California Department of Fish and Wildlife Streambed Alteration Agreement • Regional Water Quality Control Board Section 401 Water Quality Certification, National Pollutant Discharge Elimination System Permit San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-1 3.0 ENVIRONMENTAL SETTING This section describes the general environmental setting in the vicinity of the project site. Specific description of the setting in each of environmental issue areas being studied in this Environmental Impact Report (EIR) can be found in the relevant chapters of Section 4.0, Environmental Impact Analysis. 3.1 REGIONAL SETTING The site is currently located in unincorporated San Luis Obispo County. However, the project applicant has elected to work with the City and has proposed an annexation of the site, such that the San Luis Ranch Project would be located within the City boundaries. San Luis Obispo County is bounded by the Pacific Ocean to the west, Monterey County to the north, Kern County to the east, and Santa Barbara County to the south. As a region, San Luis Obispo County is moderately urbanized, but remains as a generally low density, rural and agricultural area of California that has grown as a major tourist destination. The region includes seven incorporated cities: Arroyo Grande, Atascadero, Grover Beach, Morro Bay, Paso Robles, Pismo Beach, and San Luis Obispo. The seven incorporated urban areas include approximately 55 percent of the County’s total population (2010 Census). All of the urban areas within San Luis Obispo County are linked to either State Route 1 (SR 1) or U.S. Highway 101 (U.S. 101), which are the primary transportation corridors serving the region. The City of San Luis Obispo is located between the San Lucia Mountains and the coastal mountains that frame the Los Osos Valley, including the Irish Hills and volcanic Morros. The City of San Luis Obispo is the business and government hub of San Luis Obispo County, and is the largest incorporated city between Santa Maria and Salinas. Cuesta Ridge lies to the north and east of the City, the Edna Valley is to the southeast and the ridges of the Davenport and Irish Hills are to the southwest. Agricultural valleys and open space surround most of the City, including vineyards and field crops, scrub oak, and grassland communities. The City’s topography and its proximity to the Pacific Ocean serve not only as major contributors to the scenic nature of the area, but also define the local climate. San Luis Obispo enjoys a Mediterranean climate, with mild winters, warm summers, and moderate rainfall. Weather systems are dominated by the Pacific High, a pressure zone centered off the coast of California that diverts storm tracks northward during the summer. The warmest month is generally September with an average maximum of about 77 degrees Fahrenheit (ºF) and the coolest month is generally January with an average minimum of about 41ºF, though highs in the 90s and lows in the 30s are not uncommon. Precipitation primarily falls between November and April, with an average annual rainfall of about 22 inches. The prevailing winds are typically from the northwest, although there are important daily and seasonal variations in both direction and velocity. Locally, there is a tendency for the diurnal land/sea breeze cycle to cause prevailing winds to change direction and move offshore from early evening to morning and then return to the general onshore flow. Wind speed and direction in the winter is primarily a function of the location and strength of frontal systems that periodically move across the region. San Luis Obispo is located in a seismically active region subject to sporadic seismic events of varying intensity. San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-2 3.2 SITE SPECIFIC SETTING The San Luis Ranch property is located within unincorporated San Luis Obispo County but is surrounded by the corporate boundary of San Luis Obispo. The proposed project would be located within the San Luis Ranch Specific Plan area, a highly visible area west of U.S. 101 within the City’s Urban Reserve Line (URL). The property is currently used for agricultural purposes, primarily as cultivated row crops. Background views of Cerro San Luis are available across the property from northbound traffic on the freeway. Prefumo Creek forms the area’s western boundary, contributing to both the property’s high flood hazard potential, and to its wealth of biological resources. The topography of the property is generally flat with the exception of Prefumo Creek and the Cerro San Luis Channel in the northern portion of the site. Agricultural production is the current primary land use of the property. Dry and partially irrigated field crops on the site include garbanzo beans, dry beans and other field crops. More recent production includes irrigated crops such as cabbage and lettuce. The San Luis Ranch Complex, formerly known as the Dalidio Ranch Complex, which includes a farm house and outbuildings, is located on the northwest portion of the property near Madonna Road. The balance of the land along the Prefumo Creek drainage is screened by the presence of a mature grove of blue gum Eucalyptus trees that occur along the creek corridor. The relatively flat topography onsite and the low profile of the row crops provide for expansive views across the property. For northbound travelers on U.S. 101, foreground views to the west are of agricultural row crops, with middle-ground views of the San Luis Obispo Promenade (a nearby shopping mall), and background views of Cerro San Luis and Bishop Peak. Southbound travelers looking west view agricultural row crops in the foreground, vegetation associated with Prefumo Creek and the edges of the commercial uses clustered at the Los Osos Valley Road/U.S. 101 interchange in the middle-ground and the Irish Hills in the background. The San Luis Ranch property is located on the southwestern side of Dalidio Road, between Madonna Road and U.S. 101. The property is located within a transition area between the commercial development to the north and the residential development to the west. Adjacent land uses include residential, public, open space (including the SLO City Farm), park, office, general retail, and a major highway. 3.3 CUMULATIVE DEVELOPMENT A project’s cumulative impacts are the possible environmental effects that may be cumulatively considerable when considered with other reasonably foreseeable projects [Section 15065 (a)(3) of the California Environmental Quality Act (CEQA) Guidelines]. Cumulatively considerable impacts occur when the incremental effects of a particular project or program are significant when viewed in connection with the effects of other past, current, or probable future projects or programs that are not incorporated into baseline or existing conditions. As defined in Section 15355 of the CEQA Guidelines, a cumulative impact consists of an impact which is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts. According to Section 15130 of the CEQA Guidelines, the San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-3 discussion of cumulative impacts must reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by standards of practicality and reasonableness, and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects that do not contribute to the cumulative impact. Impacts that do not result in part from the project evaluated in the EIR need not be discussed. The impact sections of this EIR discuss the potential cumulative environmental impacts resulting from the proposed project in association with other planned, pending, and reasonably foreseeable projects in the vicinity of the project area. The cumulative impacts discussion considers the contribution to environmental effects of the proposed Specific Plan, General Plan Amendment/Pre-Zoning, Development Plan/Vesting Tentative Tract Map, Development Agreement/Memorandum of Understanding, and architectural review for the 131-acre project site, including annexation of the site into the City of San Luis Obispo. The CEQA Guidelines allow for the use of two different methods to determine the scope of projects for the cumulative impact analysis: • List method. A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency (Section 15130). • General Plan projection method. A summary of projections contained in an adopted General Plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact (CEQA Guidelines §15130). In accordance with CEQA Guidelines 15130, the scope of projects for cumulative impact analysis can include a summary of projections contained in an adopted General Plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact. In order to assess cumulative impacts, this EIR uses the General Plan projection method that considers projects and programs included in the City’s General Plan Land Use and Circulation Elements. The General Plan projection method used in this EIR is based on City-wide cumulative projections that establish conditions that would exist due to the build-out of the City’s General Plan, which is approximately twenty years out (Year 2035). This approach to cumulative impacts is consistent with the approach used in the Multimodal Transportation Impact Study (TIS) prepared for the project by Omni-Means (dated November 2016). The TIS is included as Appendix L to this EIR. Citywide buildout conditions include: • Special focus areas identified in the General Plan Land Use Element that contain specific guidelines for the future adoption of a specific plan, including: Airport Area and Margarita Area Specific Plans, Orcutt Area Specific Plan, and San Luis Ranch. • Buildout of areas within the existing City boundaries and planning sphere of influence. • Land use changes anticipated to occur under the 2014 Land Use and Circulation Element Update. San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-4 • Circulation improvements anticipated in the cumulative conditions described in the TIS. Cumulative impacts related to projects anticipated in the 2014 Land Use and Circulation Element Update are analyzed in the LUCE Update EIR, and this EIR incorporates and builds upon this information to utilize a tiered approached to assessment of these cumulative impacts. Potential future development capacity in the City reflects reasonable assumptions regarding factors such as land use designation requirements, development standards, existing development conditions, and the adopted and proposed performance standards for existing and proposed specific plan areas. Table 3-1, adapted from the LUCE Update EIR, shows the buildout potential future development in the Land Use Element Planning Subarea as envisioned by the Land Use Element (including the San Luis Ranch Specific Plan area). As shown in Table 3-1, buildout based on the Land Use Element could result in approximately 4,904 additional dwelling units, and an estimated 5,081,708 square feet of non-residential uses. San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-5 Table 3-1. Total Future Development Capacity within the Planning Subarea under the General Plan Land Use Element Acres Typical Density 1 Capacity Units 2 Non-Residential Square Footage 3 Residential (Units/Acre) Non- Residential (FAR) Single- Family Multi- Family Total Office Commercial Industrial Hotel Park (Acres) Total (includes hotels) Potential Development Areas 4 Foothill at Santa Rosa Area 0 80 80 0 -1,814 0 0 - -1,814 Caltrans Site 0 53 53 -3,792 -14,265 0 200 3.5 101,943 General Hospital Site 9 32 41 48,788 0 0 0 - 48,788 Broad Street Area 0 589 589 0 229,068 0 0 - 229,068 Sunset Drive-In Site 0 0 0 260,706 222,962 0 0 - 483,668 Dalidio/Madonna Area 320 180 500 150,000 200,000 0 200 8.3 470,000 Pacific Beach Site 0 38 38 -94,851 57,499 0 0 - -37,352 Calle Joaquin Auto Sales Area 0 0 0 0 128,066 0 120 - 200,066 Madonna Site on LOVR 0 115 115 16,770 236,000 0 139 - 336,170 LOVR Creekside Area 0 159 159 0 0 0 0 2.7 0 Broad Street at Tank Farm Road Site 0 41 41 73,180 62,726 0 0 - 135,906 Avila Ranch 405 295 700 0 25,000 0 0 - 25,000 Subtotal 734 1,582 2,316 450,801 1,145,242 0 659 14.5 1,991,443 Previously Approved Specific Plans 5 Margarita Area Specific Plan 741 127 868 959,017 10,000 0 0 25.9 969, Airport Area Specific Plan 6 0 0 0 427,191 616,983 747,642 0 - 1,791,815 Orcutt Area Specific Plan 540 439 979 0 11,000 0 0 12.0 11,000 Subtotal 1,281 566 1,847 1,386,208 637,983 747,642 0 37.9 2,771,832 Planned and Approved Projects 7 Chinatown Project 0 32 32 0 46,000 0 78 - 46,000 Pacific Courtyards 0 12 12 10,000 0 0 0 - 10,000 San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-6 Table 3-1. Total Future Development Capacity within the Planning Subarea under the General Plan Land Use Element Acres Typical Density 1 Capacity Units 2 Non-Residential Square Footage 3 Residential (Units/Acre) Non- Residential (FAR) Single- Family Multi- Family Total Office Commercial Industrial Hotel Park (Acres) Total (includes hotels) Mission Estates 10 0 10 0 0 0 0 - 0 Four Creeks (Creekston and Laurel Street) 0 166 166 0 0 0 0 - 0 Garden Street Terrace 0 8 8 0 25,000 0 72 - 25,000 131 South Street Apartments 0 43 43 0 0 0 0 - 0 Marsh Street Commons 0 11 11 0 3,000 0 0 - 3,000 ICON Project (1340 Taft) 0 7 7 0 4,000 0 0 - 4,000 Subtotal 10 279 289 10,000 78,000 - 150 - 88,000 Other Vacant Land (by General Plan Designation) 8 Suburban Residential 3 4.0 1 4 4 - - - Low Density Residential 53.4 6 320 320 - - - Medium Density Residential 7.1 10 71 71 - - - Medium-High Density Residential 0.4 16 - 6 6 - - - High Density Residential 2.7 19 - 51 51 - - - Neighborhood Commercial 0.2 0.30 - 2,614 - - 2,614 Community Commercial 3.2 0.30 - 41,818 - - 41,818 Tourist Commercial 1.0 0.35 - 15,246 - - 15,246 Office 3 1.3 0.35 - 19,820 - - 19,820 Services and Manufacturing 13.3 0.25 - 144,837 - - 144,837 Public 0.4 0.35 - 6,098 - - 6,098 San Luis Ranch Project EIR Section 3.0 Environmental Setting City of San Luis Obispo 3-7 Table 3-1. Total Future Development Capacity within the Planning Subarea under the General Plan Land Use Element Acres Typical Density 1 Capacity Units 2 Non-Residential Square Footage 3 Residential (Units/Acre) Non- Residential (FAR) Single- Family Multi- Family Total Office Commercial Industrial Hotel Park (Acres) Total (includes hotels) Subtotal 87 395 57 452 25,918 59,678 144,837 - - 230,433 Total Capacity 2,420 2,484 4,904 1,872,927 1,920,903 892,479 809 52.4 5,081,708 Source: City of San Luis Obispo LUCE Update EIR 2014 1. Typical density and FAR is based on a net acre assumption accounting for necessary infrastructure and facilities. To get the typical density, the maximum density was recalculated based on a development percent assumption on what is average for new development 2. Unit capacity for other vacant land is calculated by multiplying acres and the typical density. 3. Non‐residential square footage for specific plan area and planned projects is based on assumptions in specific plans and Community Development Project Status Report (December 31, 2012). Non‐residential square footage for vacant land is calculated by multiplying acres and the typical FAR. 4. Units and non‐residential square footage are calculated based on proposed general plan designations and input from the City. Some of these sites have existing development that will likely be adapted to facilitate new development. As a result, some sites have a negative number for net new non‐residential square footage, even though new development is anticipated. 5. Non‐Residential square footage includes land designated neighborhood commercial, services commercial, business park, and manufacturing. 6. Non‐residential square footage in the Airport Area Specific Plan (AASP) includes 605,293 square feet from underutilized land that is likely to redevelop. Remaining capacity in the AASP based on analysis conducted by the City of San Luis Obispo Planning and GIS staff. 7. Does not include projects that fall within the boundaries of the Specific Plan Areas. Only those projects that provided specific unit/square footage numbers were included. 8. Does not include parcels that fall within the boundaries of the Specific Plan Areas or Planned and Approved Projects. Acreages are taken from the vacant land category in the existing land use inventory. Carmel Rio Road Project EIR Section 3.0 Environmental Setting County of Monterey 3-8 This page intentionally left blank. San Luis Ranch Project EIR Section 4.0 Environmental Impact Analysis City of San Luis Obispo 4-1 4.0 ENVIRONMENTAL IMPACT ANALYSIS This section discusses the possible environmental effects of the project for the specific issue areas that were identified through the Notice of Preparation (NOP)/Initial Study Scoping process as having the potential to experience significant impacts. IMPACT CLASSIFICATION “Significant effect” is defined by the State CEQA Guidelines §15382 as “a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. An economic or social change by itself shall not be considered a significant effect on the environment, but may be considered in determining whether the physical change is significant.” The assessment of each issue area begins with a discussion of the environmental setting related to the issue, which is followed by the impact analysis. Within the impact analysis, the first subsection identifies the methodologies used and the “significance thresholds,” which are those criteria adopted by the City, other agencies, universally recognized, or developed specifically for this analysis to determine whether potential effects are significant. The next subsection describes each impact of the proposed project, mitigation measures for significant impacts, and the level of significance after mitigation. Each effect under consideration for an issue area is separately listed in bold text, with the discussion of the effect and its significance following. Each bolded impact listing also contains a statement of the significance determination for the environmental impact as follows: Class I. Significant and Unavoidable: An impact that cannot be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires a Statement of Overriding Considerations to be issued if the project is approved per §15093 of the CEQA Guidelines. Class II. Significant but Mitigable: An impact that can be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires findings to be made under §15091 of the CEQA Guidelines. Class III. Not Significant: An impact that may be adverse, but does not exceed the threshold levels and does not require mitigation measures. However, mitigation measures that could further lessen the environmental effect may be suggested if readily available and easily achievable. Class IV. Beneficial: An effect that would reduce existing environmental problems or hazards. Following each environmental impact discussion is a listing of mitigation measures (if recommended or required) and the residual effects or level of significance remaining after the implementation of the measures. In those cases where the mitigation measure for an impact could have a significant environmental impact in another issue area, this impact is discussed and evaluated as a secondary impact. The impact analysis concludes with a discussion of cumulative effects, which evaluates the impacts associated with the project in conjunction with other future development in the area. San Luis Ranch Project EIR Section 4.0 Environmental Impact Analysis City of San Luis Obispo 4-2 Please also refer to the Executive Summary of this EIR, which clearly summarizes all impacts and mitigation measures that apply to the project. APPROACH TO TIERED ANALYSIS As described in Section 1.0, Introduction, the City’s 2014 Land Use and Circulation Element Update EIR (LUCE Update EIR) provided a program-level environmental analysis that covers the project site. The LUCE Update EIR serves as the basis for the project-specific environmental analysis in the San Luis Ranch Project EIR. The environmental analysis included in this EIR considers and expands upon previous environmental analysis and findings from the LUCE Update EIR. As described in Section 15152 of the State CEQA Guidelines, tiering refers to “using the analysis of general matters in a broader EIR (such as one prepared for a general plan or policy statement) with later EIRs and negative declarations on narrower projects; incorporating by reference the general discussions from the broader EIR; and concentrating the later EIR or negative declaration solely on the issues specific to the later project.” The tiered approach to analysis in this EIR focuses review on project-specific impacts not fully analyzed in the LUCE Update EIR and allows for a more expansive evaluation of environmental effects previously identified. This tiered EIR incorporates by reference the information, analysis, and mitigation measures from the LUCE Update EIR that are relevant to this project. This EIR also incorporates and relies upon relevant analysis from the LUCE EIR related to the evaluation of cumulative impacts and expands upon and refines such information where warranted. This EIR summarizes the LUCE Update EIR environmental analysis in each impact section, including impacts and mitigation measures identified for a particular resource. The environmental impact analysis further evaluates specific details of the project that were assessed only in general terms when the LUCE Updated EIR was prepared. As the majority of mitigation measures in the LUCE Update EIR were included in the 2014 LUCE as policies, these measures are included in the regulatory section of each environmental impact section to inform the reader regarding measures that address and potentially mitigate potential project impacts. Where specific mitigation measures from the LUCE Update EIR are directly relevant, they are summarized in the project analysis to provide a clear linkage with project impacts. APPROACH TO EVALUATION OF PRADO ROAD/U.S. 101 IMPROVEMENTS As described in Section 1.1.3, Relationship of the Project to the Land Use and Circulation Elements, the proposed project does not include any improvements related to a possible Prado Road overpass or interchange with U.S. 101. However, the project recognizes the General Plan, which describes either a full access interchange or overpass at Prado Road (Land Use Element Policy 8.1.4 and Circulation Element Policy 9.2.2). The project proposes to dedicate the necessary right- of-way and financially participate in the overpass or interchange project in accordance with an equitable share analysis. The traffic study conducted for this EIR is, in part, intended to identify if and when implementation of the Prado Road overpass or interchange is necessary to achieve acceptable levels of service on City roadways and intersections, in consideration of vehicle trips generated by the proposed San Luis Ranch Project, in combination with existing and anticipated development in the City. Accordingly, the environmental impacts of improvements at U.S. San Luis Ranch Project EIR Section 4.0 Environmental Impact Analysis City of San Luis Obispo 4-3 101/Prado Road are not evaluated throughout Sections 4.1 through 4.14 as part of the proposed project. Rather, because the project would contribute to the need for the improvements, and the project would provide proportional fair share funding for the improvement as mitigation for its traffic impacts, the environmental impacts of that mitigation are discussed in Section 4.12, Transportation/Traffic. As described in CEQA Guidelines Section 15126.4(D), “If a mitigation measure would cause one or more significant effects in addition to those that would be caused by the project as proposed, the effects of the mitigation measure shall be discussed but in less detail than the significant effects of the project as proposed.” The final design for the improvements has not been selected or approved by the City or Caltrans. As a result, the EIR provides a reasonable worst-case evaluation of the improvements from a physical disturbance perspective, based on the level of detail regarding the improvements that is available at the time of preparation of this EIR. The U.S. 101/Prado Road improvements will require detailed project-level environmental review pursuant to CEQA once designs for the improvement come into greater focus, and that CEQA review will be independent of the EIR for the San Luis Ranch project. San Luis Ranch Project EIR Section 4.0 Environmental Impact Analysis City of San Luis Obispo 4-4 This page intentionally left blank. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-1 4.1 AESTHETICS 4.1.1 Setting a. General Visual Character. The visual character of the area surrounding the City is generally defined by several low hills and ridges formed by the more resistant volcanic rocks of the area such as Bishop Peak and Cerro San Luis Obispo. These peaks are also known as Morros and provide a scenic focal point for much of the City. Along with the Morros, the Santa Lucia Mountains and Irish Hills visually frame the City and are considered the scenic backdrop for much of the City. The surrounding hills have created a hard urban edge for the City where development has remained in the lower elevations. The City itself combines a compact urban form in a rural setting, transitioning from a well- defined urban edge to open space (Section 9, Views, General Plan Conservation and Open Space Element, City of San Luis Obispo, 2006). As reflected in its current General Plan policies, the City has been successful in maintaining an urban or suburban character, separated from a more rural character outside the City by a hard urban edge integral to its development pattern. b. Existing Visual Conditions at the Project Site. The 131-acre San Luis Ranch project site is located in unincorporated San Luis Obispo County, completely surrounded by the corporate boundary of the City of San Luis Obispo, and within the City’s Sphere of Influence. Visually, it is an agricultural “island” surrounded by urban development. The site is located on the south side of Dalidio Road, between Madonna Road and U.S. 101. The property is located within a transition area between the commercial development to the north and the residential development to the west: adjacent land uses include single-family residences to the west; Laguna Lake Park to the northwest, commercial uses to the north, including a post office and the San Luis Promenade shopping center; U.S. 101 to the east; and the SLO City Farm to the south. The project site is characterized primarily by its use as an agricultural property. A single broad swale bisects the western portion of the site, draining toward Prefumo Creek at the site’s southern edge. Prefumo Creek is lined with multiple rows of mature blue gum eucalyptus trees, making that edge of the property visually prominent in the area. The relatively flat topography onsite and the low profile of the row crops provide for expansive views across the property. Views of the site from key viewing corridors, including U.S. 101, Madonna Road, and Prado Road are discussed below. Dominant visual features within the project site are the predominantly flat landform planted with row crops and an existing stand of eucalyptus trees in the southwestern portion of the site. The San Luis Ranch Farm Complex, located in the northwestern portion of the site, consists of a farm house, agricultural outbuildings, and vehicle and materials storage. These existing structures were constructed in the early 20th century and appear to be in a state of disrepair (refer to Section 4.5, Cultural Resources, for a detailed discussion of these structures). Limited views of this complex are available from Madonna Road, although views are partially obscured by the eucalyptus trees. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-2 Figures 2-3a and 2-3b in Section 2.0, Project Description, depict the existing visual condition of the site and surrounding area. Views from key viewing corridors are further described below. Key Viewing Corridors and Scenic Roadways. Several roadways/roadway segments in the vicinity of the project site have been identified in the City’s Land Use Element, Circulation Element, and Conservation and Open Space Element as scenic corridors, either of High or Moderate Value. These roadways include: • U.S. 101 (from the southern City limit to Marsh Street); • South Higuera Street (between Prado Road and the southern City limit); • Prado Road; • Madonna Road; and • Los Osos Valley Road (east of Laguna Lane to U.S. 101). Of these roadways/roadway segments, the project site is largely visible from the stretch of U.S. 101 between the southern City limit and Marsh Street, Madonna Road, and Prado Road. The project site is partially visible from Los Osos Valley Road where it crosses U.S. 101, and is not visible from South Higuera Street. Views of the site from these roadways are described below, and are characterized in terms of foreground, middle-ground, and background views. Foreground views are those immediately presented to the viewer, and include objects at close range. Middle-ground views occupy the center of the viewshed, and tend to include objects that dominate the viewshed in normal circumstances. Background views include distant objects and other objects that make up the horizon. • U.S. 101. Views for northbound travelers on U.S. 101 include expansive, flat agricultural row crops in the foreground; commercial shopping centers in the middle-ground; and Cerro San Luis and Bishop Peak in the background. For southbound travelers, views from U.S. 101 include the same expansive, flat agricultural row crops in the foreground; stands of eucalyptus trees in middle- ground; and the Irish Hills in background. • Madonna Road. Views from Madonna Road travelling in both directions are largely obstructed by the stands of eucalyptus trees. Intermittent views of the San Luis Ranch Farm Complex, including an existing farmhouse and agricultural outbuildings, are briefly available through breaks in the trees. • Prado Road. The project site is only visible from Prado Road when facing westbound at the western terminus of Prado Road at the on-ramp for U.S. 101. Views of the site from this location are generally similar to those from northbound U.S. 101. • Los Osos Valley Road. Views northward from Los Osos Valley Road are largely obstructed by residential and commercial development and stands of trees north of the roadway. The project site is only visible for westbound travelers from the bridge where this roadway crosses U.S. 101. Views of the site are distant and provide only limited visibility of the portion of the site nearest U.S. 101. The General Plan includes policies related to development criteria to protect viewsheds associated with these roadways (see 4.4.4(c), Regulatory Setting, below). San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-3 The site’s historic agricultural character is highly visible from U.S. 101. Due in part to the site’s visually prominent location at a southern gateway to the City, the Land Use Element includes a requirement that the City preserve half of the agriculture and open space on-site, to maintain the City’s agricultural heritage. Scenic Vistas. A scenic vista is a view of natural environmental, historic, and/or architectural features possessing visual and aesthetic qualities of value to the community. The term “vista” generally implies an expansive view, usually from an elevated point or open area. The Conservation and Open Space Element identifies one scenic vista adjacent to the project site. As shown in Figure 11 (Scenic Roadways and Vistas) of the Conservation and Open Space Element, there are two identified “cones of view” near the project site. One “cone of view” is located on Madonna Road directly adjacent to the project site, looking northwest toward Laguna Lake. Because the site is southeast of Madonna Road, it is not included in this cone of view. A second “cone of view” is located on the KSBY station hilltop at the southern edge of town, looking north. The project site is highly visible from this point and, therefore, is located within a City-designated scenic vista. Scenic Highways. The California Scenic Highway Program, maintained by the California Department of Transportation (Caltrans) protects State scenic highway corridors from changes that would diminish the aesthetic value of lands adjacent to highways. According to the California State Scenic Highway Program, the section of U.S. 101 in the project vicinity is eligible for State Scenic Highway designation, but currently is not officially designated (Caltrans 2015). In addition, the City’s General Plan Conservation and Open Space Element and Circulation Element assign scenic value ratings of ‘moderate’ and ‘high’ to several roadways in the City, based on the availability of views of scenic resources from these public viewpoints. According to the General Plan the segment of U.S. 101 along the eastern project site boundary is identified as having moderate scenic value (City of San Luis Obispo 2014a). Madonna Road immediately adjacent to the project site is also identified as having a moderate scenic value by the Conservation and Open Space Element (City of San Luis Obispo 2006) and as having a medium scenic value in the Circulation Element (City of San Luis Obispo 2014a). Light and Glare. Nighttime lighting conditions vary throughout the City, from heavily lit areas of commercial development to more rural areas with little night lighting. There is no street lighting or lighted nighttime activity on the project site other than that associated with the San Luis Ranch Farm Complex. The San Luis Ranch Farm Complex currently provides minimal nighttime lighting. However, lighting and glare levels in the project vicinity (i.e., surrounding the site) are typical of urban areas. The majority of light and glare in the project vicinity is generated by commercial and industrial uses to the north, south, and east of the site, residential uses to the west of the site, and U.S. 101 immediately to the east of the site. Vehicle headlights, street lighting at intersections and along the streets, and building lighting, contribute to the existing light setting to the north, south, and east of the project site. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-4 c. Regulatory Setting. State. State Streets and Highways Code, Section 260, et. seq. A California highway may be designated as scenic depending on how much of the natural landscape can be seen by travelers, the scenic quality of the landscape, and the extent to which development intrudes on the traveler’s enjoyment of the view. When a city or county nominates an eligible scenic highway for official designation, it must identify and define the scenic corridor of the highway, defined by the motorist’s line of vision (a reasonable boundary is selected when the view extends to a distant horizon). A city or county must also adopt ordinances to preserve the scenic quality of the corridor, including: 1) regulation of land use and density of development; 2) detailed land and site planning; 3) control of outdoor advertising (including a ban on billboards); 4) careful attention to and control of earthmoving and landscaping; and 5) careful attention to design and appearance of structures and equipment. Senate Bill (SB) 743. Governor Brown signed SB 743 in September 2013, which made several changes applicable to CEQA for projects located in areas served by transit (Public Resources Code Section 21099). Under SB 743, a project’s aesthetic impacts are not considered significant impacts on the environment if: 1) the project is a residential, mixed-use residential, or employment center project, and 2) the project is located on an infill site within a transit priority area. A transit priority area is an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in an adopted Transportation Improvement Program. A major transit stop is defined in Section 21064.3 of the California Public Resource Code as a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. This provision for aesthetic impacts does not include impacts to historic or cultural resources. The project is an open space, residential, and commercial use development project, which is located on land currently identified as a Specific Plan Area by the City and would include a transit center, bike trials, and walking paths., but However, the project site is not considered to be a transit priority area, and the proposed transit center is not designated as a “major transit stop” since the number of routes serviced by the stop and frequency of service intervals are unknown at this time. and tTherefore, the project is not exempt from consideration for aesthetic impacts under the CEQA process. Local. City of San Luis Obispo General Plan. The City of San Luis Obispo regulates aesthetics of buildings and public spaces through implementation of the General Plan Land Use Element, Circulation Element, Conservation and Open Space Element, and the implementing statutes of the Municipal Code, Community Design Guidelines and Historic Preservation Guidelines. Land Use and Circulation Elements. The Land Use Element and Circulation Element provide policies and programs for maintenance of public views during urbanization along viewing corridors and scenic roadways throughout the City, and additionally provides specific guidance for future development of the project site. As stated in Chapter 8, Section 8.1.4, the site San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-5 “should be developed as a mixed use project that maintains the agricultural heritage of the site,” with consideration given to the following land use and design issues relevant to visual resources: e. Maintain agricultural views along Highway 101 by maintaining active agricultural uses on the site, and maintain viewshed of Bishop Peak and Cerro San Luis. f. Maintain significant agricultural and open space resources on site. Land dedicated to Agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. h. Integrate agricultural open space with adjacent SLO City Farm and development on property. j. Commercial and office uses shall have parking placed behind and to side of buildings so as to not be a prominent feature. The following additional Land Use Element and Circulation Element policies define the local regulatory setting related to the protection of visual resources: Land Use Element Policies. Policy 1.4. Urban Edges Character. The City must maintain a boundary between urban development and surrounding open land, including measures to prevent a stark-appearing edge such as groves of trees, hills to set the edge of development, or providing open space and agricultural transitional buffers. Policy 1.8.1. Open Space Protection. Within the City’s planning area and outside the Urban Reserve Line, undeveloped land should be kept open. Prime agricultural land, productive agricultural land, and potentially productive agricultural land shall be protected for farming. Scenic lands, sensitive wildlife habitat, and undeveloped prime agricultural land shall be permanently protected as open space. Policy 1.13.8. Open Space. Future development on the San Luis Ranch property shall dedicate one half of the total land or easements for open space use. Policy 2.2.10. Site Constraints. Residential developments will respect site constraints including property size and shape, ground slope, access, creeks and wetlands, wildlife habitats, wildlife corridors, native vegetation, and significant trees. Policy 2.3.3. Residential Next to Non-residential. In designing development at the boundary between residential and non-residential uses, the City shall make protection of a residential atmosphere the first priority. Policy 2.3.5. Neighborhood Pattern. The City shall require that all new residential development be integrated with existing neighborhoods. Where physical features make this impossible, the new development should create new neighborhoods. Policy 2.3.7. Natural Features. The City shall require residential developments to preserve and incorporate as amenities natural site features, such as land forms, views, creeks, wetlands, wildlife habitats, wildlife corridors, and plants. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-6 Policy 2.3.9. Compatible Development. The City shall require that new housing built within an existing neighborhood be sited and designed to be compatible with the character of the neighborhood. Policy 2.3.11. Residential Project Objectives. Residential projects should provide: A Privacy, for occupants and neighbors of the project; B Adequate usable outdoor area, sheltered from noise and prevailing winds, and oriented to receive light and sunshine; C Use of natural ventilation, sunlight, and shade to make indoor and outdoor spaces comfortable with minimum mechanical support; D Pleasant views from and toward the project; E Security and safety; F Bicycle facilities consistent with the City’s Bicycle Plan; G Adequate parking and storage space; H Noise and visual separation from adjacent roads and commercial uses (Barrier walls, isolating a project, are not desirable. Noise mitigation walls may be used only when there is no practicable alternative. Where walls are used, they should help create an attractive pedestrian, residential setting through features such as setbacks, changes in alignment, detail and texture, places for people to walk through them at regular intervals, and planting.) I Design elements that facilitate neighborhood interaction, such as front porches, front yards along streets, and entryways facing public walkways; J Buffers from hazardous materials transport routes, as recommended by the City Fire Department. Circulation Element Policies. Policy 15.1.2. Development Along Scenic Routes. Development along scenic roadways should not block views or detract from the quality of views. Projects in the viewshed of a scenic roadshed will be considered “sensitive,” will not wall off scenic roadways and block views, signs will not clutter vistas or views, street lights will be low scale and focus at the intersections where it is most needed, and lighting will not degrade the nighttime visual environment. (City of San Luis Obispo, 2014a). Conservation and Open Space Element. The Conservation and Open Space Element (adopted in 2006) also lists policies and programs that protect public viewsheds. The following Conservation and Open Space Element policies influence the local visual resources regulatory setting: Policy 8.3.2 Open Space Buffers. Buffers shall be required in the following situations: • Between urban development -- including parks and public facilities -- and natural habitats such as creeks, wetlands, hillsides and ridgelines, Morros, scenic rock outcrops and other significant geological features, and grassland communities, to address noise, lighting, storm runoff, spread of invasive, non-native species, and access by people and pets. • Between urban development and agricultural operations, to address dust, noise, odors, chemical use, and access by people and pets. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-7 • Between new development and scenic resources or the greenbelt, to address view blockage, lighting and noise, and visual transition from urban character to rural character. • Urban development or uses located adjacent to the Urban Reserve Line to provide a transition to open space or greenbelt areas. Transition areas should add to the preservation of open space lands or resources. At a minimum, a 50-foot transition area (preserved in essentially a natural state) shall be provided within the project along the project boundary with the Urban Reserve Line, unless the transition area is defined elsewhere in this Element. Policy 8.6.3 (G). Required Mitigation. Any development that is allowed on a site designated as Open Space or Agriculture, or containing open space resources, shall be designed to minimize its impact on open space values on the site and on neighboring land. Policy 9.1.1. Preserve Natural and Agricultural Landscapes. Any development that is permitted in natural or agricultural landscapes shall be visually subordinate to and compatible with the landscape features. Development shall avoid visually prominent locations such as ridgelines, avoid unnecessary grading, vegetation removal, and site lighting, incorporate building forms, architectural materials, and landscaping that respects the setting and historical pattern of development, and preserve scenic or unique landforms. The City’s construction of projects in highly visible locations shall be subject to at least “minor or incidental” architectural review. Policy 9.1.2. Urban Development. Urban development should reflect its architectural context. This does not necessarily prescribe a specific style, but requires deliberate design choices that acknowledge human scale, natural site features, and neighboring urban development, and that are compatible with historical and architectural resources. Plans for sub-areas of the City may require certain architectural styles. Policy 9.1.3. Utilities and Signs. Features that clutter, degrade, intrude on, or obstruct views should be avoided. Necessary equipment including utility, communication, and traffic equipment should be designed and placed as to no impinge upon or degrade scenic view of the Morros or surrounding hillsides and farmland. Policy 9.1.4. Streetscapes and Major Roadways. In the acquisition, design, construction, or significant modification of major roadways the city promotes the creation of “streetscapes” and linear scenic parkways or corridors that promote the City’s visual quality and character, enhances adjacent uses, and integrates the roadway with surrounding districts. Policy 9.1.5. View Protection in New Development. The City will include in all environmental review and carefully consider effects of new development, streets, and road construction on views and visual quality by applying the Community Design Guidelines, height restrictions, hillside standards, Historical Preservation Program Guidelines, and the California Environmental Quality Act and Guidelines. Policy 9.2.1. Views To and From Public Places, Including Scenic Roadways. The City will preserve and improve views of important scenic resources from public places and encourage other agencies with jurisdiction to do so. Public places include parks, plazas, the grounds of civic buildings, streets and roads, and publicly accessible open space. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-8 1. Development projects shall not wall-off scenic roadways and block views. 2. Utilities, traffic signals, and public and private signs and lights shall not intrude on or clutter views, consistent with safety needs. 3. Where important vistas of distant landscape features occur along streets, street trees shall be clustered to facilitate viewing of the distant features. 4. Development projects, including signs, in the viewshed of a scenic roadway shall be considered “sensitive” and require architectural review. Policy 9.2.2. Views To and From Private Development. Projects should incorporate as amenities views from and within private development sites. Private development designs should cause the least view blockage for neighboring property that allows project objectives to be met. Policy 9.2.3. Outdoor Lighting. Outdoor lighting shall avoid: operating at unnecessary locations, levels, and times; spillage to areas not needing or wanting illumination; glare (intense line-of-site contrast); and frequencies (colors) that interfere with astronomical viewing. Policy 9.3.6. View blockage Along Scenic Highways. Determine that view blockage along scenic roadways is a significant impact. City of San Luis Obispo Zoning Ordinance. The Zoning Ordinance of the City’s Municipal Code was developed in conformance with the General Plan (City of San Luis Obispo 2015a). Zoning is intended to promote and enforce broad General Plan policies related to land use, physical development, and construction. The following ordinance concerns the visual impact of lighting. 17.18.030. Illumination. No lighting or illuminated device shall be operated so as to create glare which creates a hazard or nuisance on other property. (Ord. 941 – 1[part], 1982: prior code - 9202.6[C]). 17.23. Night Sky Preservation. Establishes lighting regulations that encourage lighting practices and systems that will: a. Permit reasonable uses of outdoor lighting for nighttime safety, utility, security, and enjoyment while preserving the ambience of night; b. Curtail and reverse any degradation of the nighttime visual environment and the night sky; c. Minimize glare and obtrusive light by limiting outdoor lighting that is misdirected, excessive, or unnecessary; d. Help protect the natural environment from the damaging effects of night lighting; and e. Meet the minimum requirements of the California Code of Regulations for Outdoor Lighting and Signs (Title 24, Chapter 6). Architectural Review Commission. The City’s Architectural Review Commission (ARC) reviews and approves the design for proposed buildings within the City. Architectural review is a process whereby the City’s ARC examines a proposed project’s layout, building design, its relationship to the neighborhood in which it would be located, landscaping, parking, signage, San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-9 lighting, and other features affecting the project’s appearance. This process would be applied to proposed development within the project area, and may result in conditions or design modifications that expand on mitigation measures that may be included in this EIR. The ARC is charged with administering architectural review in a way that creates a pleasant environment, maintains property values, preserves the City’s natural beauty and visual character, and ensures orderly and harmonious development. The ARC uses the City’s Community Design Guidelines as a basis for evaluating the suitability and appropriateness of individual project design to help achieve attractive and environmentally sensitive development. Refer to Section 4.5, Cultural Resources, for the regulatory oversight and requirements associated with the designation and management of historic resources. City of San Luis Obispo Community Design Guidelines. San Luis Obispo’s Community Design Guidelines were developed to communicate the City’s expectations relating to the quality and character of site and building design. Many of the guidelines specifically target the reduction of visual impacts and the promotion of visual harmony with surrounding context (City of San Luis Obispo 2010). The following chapters and sections from the Community Design Guidelines are applicable to the analysis in this section: Chapter 2 – General Design Principles: This chapter includes general principles that should be considered in design of all development. Certain guidelines within this chapter apply only to certain types of projects (e.g., residential or non-residential). Site design considerations include designing each project with careful consideration of site character and constraints, designing projects to fit with the best examples of appropriate site design and architecture in the vicinity of the site, keeping building elements in proportion, and selecting exterior treatments carefully. Chapter 3 – Commercial and Industrial Project Design: This chapter provides guidelines for new and renovated commercial and industrial structures outside of the Downtown. Overall design objectives for commercial projects include consideration of the City’s small down scale and sensitivity to the design context of the surrounding area; avoiding boxy structures; providing landscaping as a project amenity; and locating outdoor equipment, trash receptacles, storage, and loading areas in the least conspicuous part of the site. Section 3.2 includes specific guidelines for large-scale retail projects to create projects that are pedestrian-orientation and that avoid monolithic “big-box” structures surrounded by extensive parking lots. Specific considerations for site planning; the location, design, and landscaping of parking areas; and pedestrian circulation and amenities are included. Chapter 5 – Residential Project Design: This chapter includes guidelines relating to the goals for residential project design, subdivision design and general residential project principles, infill development, multi-family and clustered housing design, and single-family housing design, all of which apply to this proposed Project. Qualities examined include protection of scenic roadways; visually-pleasing parking design and location; consideration of neighboring development; quality landscaping and lighting; and site-specific building design. Chapter 6 – Site Planning and Other Design Details: This chapter details qualities such as energy and resource conservation, lighting, storage, trash/recycling enclosures, landscaping, parking, and public art, among other items. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-10 Section 7.1 Creekside Development: The City’s Design Guidelines focus partially on development near creeks and riparian corridors. Guidelines for such development outline the City’s expectations concerning necessary setbacks from creek banks and the maintenance of public visual access to scenic creeks and corridors. 4.1.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) previously analyzed overall Citywide impacts to aesthetics and visual resources, including those associated with development of the project site, related to the adoption of the Lane Use and Circulation Elements, including planned future land use development and proposed goals, policies, and programs. The LUCE Update EIR identified potentially significant program-level impacts to aesthetic resources due to increased urbanization of the existing viewshed along the U.S. 101 corridor, obstruction of existing public views, and an increase in nighttime lighting from development of the project site with residential, commercial, and agriculture uses. However, the LUCE Update EIR concluded that implementation of the proposed Land Use and Circulation Element policies and existing City policies would reduce program-level impacts to a less than significant level. 4.1.3 Impact Analysis a. Methodology and Significance Thresholds. The assessment of aesthetic impacts involves qualitative analysis that is inherently subjective in nature. Different viewers react to viewsheds and aesthetic conditions differently. This discussion evaluates the existing visual environment against the anticipated level of development with implementation of the proposed San Luis Ranch project. The project site was observed and photographically documented in its surrounding context. The LUCE Update EIR served as a basis of evaluation, and analysis of aesthetic resources was built upon the conclusions of the LUCE Update EIR. The following criteria are based on Appendix G of the State CEQA Guidelines. An impact is considered significant if the project would result in one or more of the following conditions: 1. Have a substantial adverse effect on a scenic vista; 2. Substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway; 3. Substantially degrade the existing visual character or quality of the site and its surroundings; and/or 4. Create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. The potential for lighting and glare at the project site to affect airport operations and/or aircraft flights from the San Luis Obispo Airport, would be addressed by the Airport Land Use Commission (ALUC) in their review of the project. A discussion of potential hazards that may result from the proximity of the project site to the San Luis Obispo County Regional Airport can be found in Section 4.7, Hazards and Hazardous Materials. San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-11 b. Impacts and Mitigation Measures. Threshold 1 Would the project have a substantial adverse effect on a scenic vista? Threshold 2 Would the project substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Impact AES-1 Although there are potentially adverse impacts to scenic viewsheds, the project would implement the open space and agricultural preservation and design elements included in the proposed Specific Plan. Therefore, potential impacts to scenic vistas and scenic resources within a state scenic highway would be Class III, less than significant. The project would convert 131 acres of agricultural landscape, farm structures, and open space to a mix of more urban uses, including 43.3 acres of mixed-density residential uses, 16.8 acres of commercial, office, and hotel development, and 3.4 acres of developed parkland. However, 60.3 acres of the site (approximately 47 percent) would remain in agriculture and open space. Proposed project landscaping and development would modify existing background views of the Santa Lucia Mountains to the east, Irish Hills to the west, and Cerro San Luis and Bishop Peak to the northwest, which are currently visible across the site. The obstruction of views would be most noticeable to travelers along U.S. 101 as the effects on view blockage from the project would be most pronounced to travelers in close proximity to the site. Development of the project would result in the partial loss of the large and uninterrupted agricultural landscape that currently occupies the site, which is the prominent visual feature in the foreground and middle-ground from public viewpoints on U.S. 101 and the western end of Prado Road as well as from the elevated cone of view from the KSBY hilltop. As described in Section 4.1.1(a), the project site is visible from U.S. 101, Madonna Road, and the western end of Prado Road, which are identified in the Land Use and Circulation Elements and the Conservation and Open Space Element as scenic corridors. The portion of the project site nearest U.S. 101 is also briefly visible from the westbound lanes of the Los Osos Valley Road scenic corridor where it crosses U.S. 101. However, the design of the project is intended to preserve the quality of views along U.S. 101 by retaining agricultural uses along the northwest side of the highway and by including height limitations on the low-density residential development that would be primarily visible from U.S. 101, surrounding roadways, and other viewpoints south and east of the project site. Views from U.S. 101. U.S. 101 has been identified by the California Department of Transportation as an eligible state scenic highway, but does not have official designation. With the project, immediate foreground views of the project site from U.S. 101 would be maintained in agricultural use. The northern portion of the project site located closest to U.S. 101 would include commercial structures adjacent to the highway. However, these structures would make up approximately 300 feet of the project site’s approximately 2,500 feet of frontage along U.S. 101. These commercial structures would visually function as an extension of the existing San Luis Obispo Promenade shopping center immediately north of the project site, which also fronts San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-12 on U.S. 101. Residential portions of the proposed development would also be visible in the middle-ground, but would be a minimum of 800 feet from U.S. 101, with agricultural uses remaining in the foreground adjacent to the highway. Neighborhood commercial development would be set back approximately 350 feet from U.S. 101 near the proposed intersection of the extended Prado Road/Dalidio Drive and Froom Ranch Way in the northeastern corner of the site, with agricultural uses remaining in the foreground adjacent to the highway (refer to Figure 2-6 in Section 2.0, Project Description, for relative locations of proposed development and land use types). The commercial components of the project would be consistent in height, scale, and character with the San Luis Obispo Promenade shopping center to the north. The project would be subject to landscaping requirements in the City’s Community Design Guidelines, partially shielding new commercial and residential uses from view along U.S. 101. Development would also be subject to formal Architectural Review, which may result in additional design modifications to improve the visual quality of the development. Due to the proposed building setbacks from U.S. 101, background views of Cerro San Luis, Bishop Peak, and the Irish Hills from U.S. 101 would continue to be visible to the same extent as they are currently, as these features are visible above the existing eucalyptus tree line west of the project site and existing commercial structures north of the project site, and the heights of the proposed structures would not project above the existing tree line to the west or the existing development to the north. Residential development would range from detached single-family units to attached multi-family dwellings, with a maximum height limit for allsingle-family residential land use types of 35 feet and multi-family residential land use types of 40 feet. Proposed architectural styles, massing, and building heights are described in the Specific Plan. Commercial structures would be constructed at a maximum height of 50 feet. Mature eucalyptus trees at the site range from 80 to 100 feet in height. Views from Madonna Road. Views of the site from Madonna Road are dominated by stands of eucalyptus trees. In the short term, portions of the proposed residences constructed under Phase 1 (near the center of the site) would continue to be shielded from views from Madonna Road and the residences to the southwest by the eucalyptus trees, the existing structures on-site, and the post office. In Phase 3 of development of the project site, the eucalyptus trees and existing on-site structures would be removed to accommodate high density multi-family residences adjacent to Madonna Road. Removal of the eucalyptus trees and construction of new high density multi-family residential units would alter existing foreground views from Madonna Road to a more developed condition. Background views from Madonna Road would not be affected, as existing views through the site are substantially blocked by eucalyptus trees, the San Luis Ranch Farm Complex, the post office, and commercial structures. Future views through the site would be similarly blocked by proposed multi-family residences. Views from Prado Road. Views of the site from the western terminus of Prado Road are generally similar to those from U.S. 101, with agricultural row crops in the foreground, stands of eucalyptus trees and commercial shopping centers in the middle-ground, and Cerro San Luis San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-13 and the Irish Hills in the background. As a result, the potential change in scenic views from this location would be similar to those from U.S. 101. Views from Los Osos Valley Road. Views of the site from Los Osos Valley Road where it crosses U.S. 101 are distant with residential and commercial development, stands of trees and other vegetation, and U.S. 101 in the foreground, limited visibility of the on-site agricultural row crops nearest U.S. 101 in the middle-ground, and Cerro San Luis and the SLO Promenade commercial buildings in the distant background. The project would retain the existing agricultural designation along the western side of the project side, adjacent to U.S. 101, which is the portion of the site most visible from Los Osos Valley Road. As a result, the limited view of the project site from Los Osos Valley Road would not be substantially altered by the project. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan proposes programs and policies intended to protect scenic resources. Proposed Specific Plan Policy 2.2 requires the preservation of the site’s visual prominence as a gateway to the City. Proposed Specific Plan Policy 2.3 requires that Specific Plan buildout protect scenic vistas from the site. The proposed Specific Plan proposes to maintain agriculture and open space along U.S. 101, reducing the visual change from this high scenic value corridor. The proposed commercial and residential development would be visually consistent with adjacent land uses to the north and west. Views from Madonna Road would change substantially with the replacement of the existing eucalyptus trees with multi-family residential development. However, based on surrounding development on the south side of Madonna Road, viewer expectations along this roadway are generally of suburban and commercial uses. The proposed multi-family residential development along this approximately 800-foot segment of Madonna Road would be consistent with the surrounding development along the south side of the roadway, and would provide a visual transition from suburban residential uses west of the project site frontage to commercial uses east of the project site frontage. In addition, as stated in the LUCE Update EIR, proposed development would be subject to review by the Architectural Review Committee to ensure compliance with the City’s applicable design guidelines, compliance with which would ensure that the project would result in minimal impacts to scenic resources. Therefore, consistent with the conclusion of the LUCE Update EIR, adherence to City policies and regulations would ensure that impacts associated to scenic resources would be less than significant. Mitigation Measures. No mitigation measures would be required. Residual Impacts. This impact would be less than significant without mitigation. Threshold 3 Would the project substantially degrade the existing visual character or quality of the site and its surroundings? Impact AES-2 The project would alter the existing visual character of the site by converting over half of the agricultural site into a predominantly residential and commercial use site. Due to the project’s visual compatibility with surrounding development, preservation of on-site open space and agricultural land, and compliance with design guidelines, San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-14 the project’s impact on the visual character and quality of the site would be Class III, less than significant. The project would convert over half of the 131-acre site from agricultural uses to residential, commercial, and developed parks, while maintaining 52.7 acres of the project site along U.S. 101 in agriculture. As previously described, the project vicinity is primarily characterized by residential and commercial development to the north, south, and west. U.S. 101 borders the site to the east. Project development would substantially alter the visual character of the majority of the site from rural-agricultural to suburban/urban development. Although this would be a major visual transformation of much of the site, the project would maintain agriculture and open space along the project site’s eastern boundary, as described in Impact AES-1. Proposed commercial and residential development in the northern portion of the site would be visually consistent with adjacent land uses to the north and west, and would provide a visual transition from suburban residential uses west of the project site to commercial uses east of the project site. The eastern 52.7 acres of the project site along U.S. 101 would be maintained in agricultural use. The San Luis Ranch Specific Plan development standards include building height maximums for each of the development types proposed on the project site. In general, low-medium density residential (NG-10) would have a maximum height of 35 feet. Medium- and high-density residential (NG-23 and NG-30) would have a maximum height of 40 feet., and cCommercial, office, and hotel uses, would have a maximum height of 50 feet. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan contains policies and guidelines intended to preserve the visual character and quality of the project site and surroundings. Proposed Specific Plan Policies 1.3, 2.4, 2.8, and 7.1 require the encouragement of an attractive and relevant streetscape design to provide appropriate options for street development depending on the adjacent land use, monitoring of the conversion of active agriculture to non-agricultural uses and consideration of the possible effects of new development on character of the community as a whole, the promotion of building architectural styles that are consistent with agricultural history of the community, and that buildings be designed in a manner consistent with the character of the Specific Plan Area. Furthermore, the Specific Plan design guidelines establish that residential development would include primarily Modern Agrarian and Craftsman architectural styles. Other styles that may be used include Farmhouse, Modern Dutch, Traditional, Cottage, French Country, and Spanish/Spanish Revival, and modern. The Specific Plan includes minimum feasible hardscaping, consistent with the circulation, connectivity, and water quality goals of the City’s General Plan. The Specific Plan also includes specific landscaping requirements, such as drought-tolerant, native plantings. The Specific Plan design guidelines are generally consistent with San Luis Obispo Community Design Guidelines (refer to Appendix A: General Plan Consistency of the Specific Plan [Appendix B of this EIR]), which are intended to ensure that future development is consistent with the City’s expectations relating to the quality and character of site and building design, and to protect scenic resources and views, from public rights-of-way. However, it should be noted that a final determination of project consistency with the Community Design Guidelines would be made by the ARC and City Council. As described above, the LUCE Update EIR analyzed potential impacts to visual character from buildout of the San Luis Ranch Specific Plan Area and determined that program-level visual San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-15 impacts would be less than significant. As discussed in Impact AES-1, the project includes a similar extent of overall development to that which would be permitted under the General Plan performance standards. Neither the General Plan nor the LUCE Update EIR includes an assumption for how development under the General Plan performance standards would be configured on the project site. However, with the San Luis Ranch Specific Plan, agriculture and open space would be maintained along U.S. 101, preserving the visual character of the site as seen from U.S. 101. The project would also be visually compatible with surrounding development. In addition, as described above, the Specific Plan has been prepared by the project applicant to represent the agricultural heritage associated with San Luis Ranch as well as architectural styles typically found within the City to be consistent with the City’s Community Design Guidelines and would undergo consistency review by the ARC and City Council. Therefore, consistent with the conclusion of the LUCE Update EIR, adherence to City policies and regulations would ensure that the project would not substantially degrade the existing visual character or quality of the site and its surroundings, and this impact would be less than significant. Mitigation Measures. No mitigation measures would be required. Residual Impacts. This impact would be less than significant without mitigation. Threshold 4 Would the project create a new source of substantial light or glare that would adversely affect day or nighttime views in the area? Impact AES-3 The project would introduce a new source of nighttime lighting and daytime glare, which could increase ambient light and affect the quality of the nighttime sky. However, project compliance with existing City requirements and design guidelines would limit the magnitude of these effects. This would be a Class III, less than significant impact. The project would result in the replacement of existing agricultural lands that do not currently include any substantial sources of artificial light with residential and commercial uses. There are existing sources of nighttime lighting in the vicinity of the site, provided by the streetlights along Madonna Road, spillover lighting from surrounding development, light from the headlights of vehicles traveling along U.S. 101, and the San Luis Ranch Farm Complex. All of these contribute to the existing urban environment, and degrade the quality of the nighttime sky. Development of the project site would result in an increase in ambient nighttime lighting through the addition of residential and commercial uses and associated exterior lighting. This would include parking lot and security/safety lighting, and fixtures associated with the proposed structural development. The project would be required to conform to the Night Sky Preservation Ordinance (Zoning Regulations Chapter 17.23), which sets operation standards and requirements for lighting installations. These include limits on outdoor lighting that is misdirected, excess, or unnecessary, and meeting the minimum requirements of the California Code of Regulations for Outdoor Lighting and Signs (Title 24, Chapter 6). The project would also be required to comply with City General Plan policies pertaining to lighting and glare (refer to Section 4.1.1[c]), as well San Luis Ranch Project EIR Section 4.1 Aesthetics City of San Luis Obispo 4.1-16 as the City’s Community Design Guidelines and the City’s Night-Sky Preservation Ordinance. The project applicant would also be required to provide an overall lighting plan that demonstrates that the project complies with the requirements of City of San Luis Obispo Ordinance No. 17.18.030, which prohibits lighting or illuminated devices that would create glare which results in a hazard or nuisance on other properties (City of San Luis Obispo, Zoning Regulations). This plan would be reviewed and approved by the ARC prior to issuance of building permits. In addition, exterior building materials, windows, and surface paving materials may cause glare that could affect nearby residences and other glare sensitive land uses. Future development within the Specific Plan Area would be required to provide an overall lighting plan that demonstrates that the project complies with the requirements of City of San Luis Obispo Ordinance No. 17.18.030, which prohibits lighting or illuminated devices that would create glare which results in a hazard or nuisance on other properties (City of San Luis Obispo, Zoning Regulations). Mitigative Components of the Specific Plan and Impact Conclusion. Proposed development under the San Luis Ranch Specific Plan would be required to comply with City General Plan policies pertaining to lighting and glare (refer to Section 4.1.1[c]), Community Design Guidelines, and the Night-Sky Preservation Ordinance. As identified by the LUCE Update EIR, adhering to the existing regulations and ordinances, as well as the City’s Community Design Guidelines, would ensure that exterior lighting and glare is designed to minimize impacts on neighboring properties and other light and glare sensitive uses. Therefore, impacts associated with the creation of new sources of exterior lighting and glare would be less than significant. Mitigation Measures. No mitigation measures would be required. Residual Impacts. This impact would be less than significant without mitigation. c. Cumulative Impacts. The project, in combination with approved, pending, and proposed development in San Luis Obispo, would contribute to increasing urbanization of the southern portion of the City. Consistent with long-term buildout under the General Plan, the project would be required to adhere to the design standards of the City General Plan and City Building Standards and would be subject to discretionary review by the Planning Commission and/or City Council, as well as final design review by the Architectural Review Committee. As determined in the LUCE Update EIR, all development that adheres to the General Plan policies would result in less than significant aesthetic impacts. Therefore, although the visual character of the southern portion of the City could incrementally change as development intensity increases, this change is consistent with the General Plan vision for the urban environment and impacts to visual quality would not be cumulatively considerable. The overall aesthetic impact of cumulative development in the project vicinity would be less than significant. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-1 4.2 AGRICULTURAL RESOURCES 4.2.1 Setting a.Regional Agriculture Production. California agriculture ranks first in the nation, and its 77,900 farms and ranches received a record $46.4 billion for their products in 2013. California produces over 400 commodities and nearly half of all U.S. grown fruits, nuts, and vegetables on 25.5 million acres of farmland (United States Department of Agriculture [USDA], 2015). San Luis Obispo County and the Central Coast region are important key agricultural centers within the State. Wine grapes and strawberries lead a list of high value specialty crops grown in the County’s fertile soils and Mediterranean climate. The region’s agricultural industry is a crucial part of the local economy. It provides employment and income directly for those in agriculture, and it helps drive growth in the tourism industry, which in turn generates further economic activity and consumer spending. As shown in Table 4.2-1, agricultural production has risen steadily over the last 10 years from $594 million in 2005 to over $921 million in 2013. Production decreased to nearly $829 million in 2015, representing a 10 percent decline from 2013 due to ongoing, severe drought conditions. Strawberries, wine grapes, and cattle produced the most revenue, bringing in approximately $223 million, $146 million, and $66 million, respectively. Other crops in the County’s top ten agricultural producers include broccoli, vegetable transplants, cut flowers, avocados, head lettuce, leaf lettuce, and lemons (San Luis Obispo County Department of Agriculture Weights and Measures, 2015). Agricultural operations in the County provide 20,645 jobs. Table 4.2-2 summarizes agricultural productivity by crop type in San Luis Obispo County in 2015, including harvested acreage and total gross values. Table 4.2-1 San Luis Obispo County Comparative Agricultural Values Year Value 2005 $593,632,000 2006 $630,614,000 2007 $638,095,000 2008 $602,922,000 2009 $623,095,000 2010 $712,808,000 2011 $732,413,000 2012 $861,820,000 2013 $921,132,000 2014 $900,070,000 2015 $828,800,000 Source: San Luis Obispo County Department of Agriculture Weights and Measures, 2015. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-2 Table 4.2-2 San Luis Obispo County Agricultural Summary Crop Types Harvested Acres Total Gross Values Animal Industry N/A $70,659,000 Field Crops 1,042,521 $15,600,000 Fruit and Nut Crops 52,369 $428,344,000 Vegetable Crops 27,340 $214,059,000 Nursery Products N/A $100,138,000 Total 1,122,230 $828,800,000 Source: San Luis Obispo County Department of Agriculture Weights and Measures, 2015. The City of San Luis Obispo is an urban area of the County and by its nature, does not contain large-scale agricultural activities. These activities are typically found surrounding the City in unincorporated areas. The site is located in unincorporated San Luis Obispo County, but is completely surrounded by the corporate boundary of San Luis Obispo, and would be annexed to the City under the project. Because of the City’s location within a rural and agricultural region, the City functions as an important location for agricultural commerce, both locally and beyond. b. City Land in Agricultural Production. There are no large tracts of land in the City currently in commercial agricultural production with the exception of the SLO City Farm. The SLO City Farm occupies approximately 25 acres and is located off of U.S. Highway 101 (U.S. 101) and Calle Joaquin Road, southwest of and adjacent to the project site. The goal of SLO City Farm is to work with local farmers who will cultivate lands, provide demonstrations, and work in partnership with educational programs and facilities that will help sustain City agricultural production. The 131-acre project site is one of the largest pieces of productive agricultural land adjacent to the City and would be annexed to the City as part of the project. c. San Luis Ranch Agricultural Resources. Historical Agricultural Uses. Agricultural operations such as grain crop farming and small dairy operations on the San Luis Ranch project site date back to approximately 1900. In approximately 1921, the site was purchased by the Dalidio family and was converted to row crop farming of onion, artichoke, garbanzo beans, and flowers for seed. The Dalidio family continued row crop farming on the property throughout the 1900s and in the early 1980s their agricultural business became known as Zapata Farms. The Dalidio family sold the property in 2014, but the site has remained in use for row crop production. Current Agricultural Uses. Approximately 109 acres of the 131-acre project site are currently used for the production of irrigated row crops including celery, broccoli, lettuce, Asian vegetables, and peas. A vegetable packing facility, storage areas, Prefumo Creek watershed drainages, and eucalyptus trees occupy about 22 acres that have little or no agricultural production value. The packing facility is used to process locally grown crops and the storage areas primarily store agricultural equipment. Crops grown on the site are packed in the field. On any given year various combinations of row crops may be grown on the site. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-3 The current crop production areas are typically separated by at least 100- to 300-foot wide buffers from adjacent residential, commercial, and post office uses; however, these buffers were not planned and are not regulated by the City, but simply a coincidental separation from agricultural uses. Existing residential areas to the west are separated from the cropland by a riparian and eucalyptus corridor, a barbed wire fence, and a farm access road along Prefumo Creek. The shopping center and hotel north of the site are separated from the cropland area by a farm access road, Dalidio Drive, and a parking lot. The postal facility building to the northwest is separated from the cropland area by a farm access road, a drainage swale, and parking lot. Soils and Crop Production. Two soils types are found on the project site: Cropley clay, which comprises about 83 acres in current agricultural production; and Salinas silty clay loam, which occupies about 26 acres of crop production land. Both soil types are designated as prime agricultural soils by the California Department of Conservation (DOC). Total irrigated crop production is about 109 acres. The soils meet criteria that further designate these areas as Prime Farmland by DOC Farmland Mapping and Monitoring Program (FMMP). Figure 4.2-1 shows the soil types on the project site. The FMMP is discussed further in Section 4.2.1(e). The Cropley clay soil is constrained by seasonal wetness due to the slow surface runoff, which reduces the ability to farm when the ground is wet. The Salinas silty clay loam soil has no constraints related to crop production. The remaining three acres of Salinas silty clay loam are within the creek and bank area of Prefumo Creek and have limited agricultural production value. The 19 acres of Cropley clay that are presently used for the packing facility, storage areas, eucalyptus groves, and drainage areas, have little or no agricultural production value. Characteristics of the soil types found on the project site are described in Table 4.2-3. As shown in Table 4.2-3, 112 acres of the project site are Cropley clay with 0 to 2 percent slopes, and Salinas silty clay loam with 0 to 2 percent slopes, which may be categorized as Prime Farmland by the FMMP. As described above and shown in Table 4.2-3, the area described as Salinas silty clay loam with 0 to 2 percent slopes includes three acres within the creek and bank area of Prefumo Creek that have limited agricultural production value and are categorized as Other Lands. Therefore, approximately 109 acres of the project site meet the FMMP criteria for Prime Farmland (refer to in Section 4.2.1[e] for a detailed discussion of the FMMP and associated category criteria). d. Soil Quality. The USDA’s Natural Resources Conservation Service (NRCS) developed a system to generally classify soil types. The land capability classification describes soils types, their physical characteristics and limitations, and their suitability for agriculture and other uses. The NRCS groups soils according to their general suitability for most kinds of field crops. The capability class is designated by Roman numerals I through VIII. The numbers indicate progressively greater limitations and narrower choices for practical use: • Classes I and II – Soils with few limitations that restrict their use for agriculture; almost all crops can be grown successfully on these soils. • Class III and IV – Soils with agricultural limitations, which would affect management or choice of crop. • Class V – There are no soils of Class V in the County. • Class VI and VII – Soils that fall into these classes are suited primarily for rangeland. • Class VIII – Soils and landforms that are unsuitable for agricultural use. 127 197 128 197 Soils on the Project Site Figure 4.2-1 City of San Luis Obispo San Luis Ranch Project EIRSection 4.2 Agricultural Resources 0 800400 Scale in Feet ±Imagery provided by Google and its licensors © 2016.Soil data provided by U.S. Department of Agriculture, NaturalResources Conservation Service SSURGO, 2014. Site Boundary 127: Cropley clay, 0 to2% slopes, MLRA 14 128: Cropley clay, 2 to9% slopes, MLRA 14 197: Salinas silty clayloam, 0 to 2% slopes,MLRA 14 4.2-4 San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-5 Table 4.2-3 Project Site Soil Characteristics Soil Name Texture Slope % Capability Class Storie Index Site Area (acres) Soil Constraints Regional Cropland Uses Site Agricultural Uses FMMP Designation Cropley clay 0 to 2 II 60 83 wetness row crops, pasture, dryland farming row crops Prime Farmland Cropley clay 2 to 9 II 54 19 wetness dryland, hay/grain packing, watershed Urban and Built-up Land and Other Land Salinas silty clay loam 0 to 2 I 86 29 none row crops, hay (26 acres) creek/bank of Prefumo Creek (3 acres) row crops Prime Farmland and Other Land Source: USDA Web Soil Survey, 2015; Department of Conservation, 2014. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-6 The project site soils and their associated acreages and capability classifications are shown in Table 4.2-13 (only the irrigated capability class is shown because irrigation water is available and in active use at the site). e. Farmland Mapping and Monitoring Program. The FMMP is implemented by the DOC’s Division of Land Resource Protection, and recognizes the suitability of land for agricultural production. The FMMP is non-regulatory and was developed to inventory land and provide categorical definitions of Important Farmlands and consistent and impartial data to decision-makers for use in assessing present status, reviewing trends, and planning for the future of California’s agricultural land resources. The program does not necessarily reflect local General Plan actions, urban needs, changing economic conditions, proximity to market, and other factors, which may be taken into consideration when government considers agricultural land use policies. FMMP produces Important Farmland Maps, which account for both resource quality (soils) and land use information. FMMP data is also released in the biennial California Farmland Conversion Report. Designated categories of FMMP Important Farmland include the following: • Prime Farmland has the most favorable combination of physical and chemical features, enabling it to sustain long-term production of agricultural crops. This land possesses the soil quality, growing season, and moisture supply needed to produce sustained high yields. In order to qualify for this classification, the land must have produced irrigated crops at some point during the two update cycles prior to National Resource Conservation Service (NRCS) mapping. • Farmland of Statewide Importance possesses minor shortcomings when compared to Prime Farmland, such as greater slopes and/or less ability to store moisture. In order to qualify for this classification, the land must have produced irrigated crops at some point during the two update cycles prior to NRCS mapping. • Unique Farmland is of lesser quality soils used for the production of the state’s leading agricultural crops. Unique Farmland includes areas that do not meet the above stated criteria for Prime Farmland or Farmland of Statewide Importance, but that have been used for the production of specific high economic value crops during the two update cycles prior to the mapping date. It has the special combination of soil quality, location, growing season, and moisture supply needed to produce sustained high quality and/or high yields of a specific crop when treated and managed according to current farming methods. • Farmland of Local Importance is important to the local agricultural economy, as determined by the County Board of Supervisors and a local advisory committee. • Grazing Land contains existing vegetation that is suited to the grazing of livestock. • Urban and Built-up Land is occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. This land is used for residential, industrial, commercial, construction, institutional, public administration, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes. • Other Land is land not included in any other mapping category. Common examples include low density rural developments; brush, timber, wetland, and riparian areas San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-7 not suitable for livestock grazing; confined livestock, poultry or aquaculture facilities; strip mines, borrow pits; and water bodies smaller than 40 acres. Vacant and nonagricultural land surrounded on all sides by urban development and greater than 40 acres is mapped as Other Land. According to Appendix G of the State CEQA Guidelines, Important Farmland includes Prime Farmland, Farmland of Statewide Importance, and Unique Farmland. The best quality land is Prime Farmland. The remaining categories are used for reporting changes in land use as required for the FMMP biennial farmland conversion report. Figure 4.2-2, below, shows the FMMP designations within the project site. As shown therein, the majority of the project site (approximately 112 acres, or 85 percent) consists of Prime Farmland. f. Agricultural Water Supply. Existing agricultural operations on the project site currently use water drawn from on-site wells from the underlying aquifer. As described in Section 2.0, Project Description, water for continuing agricultural operations under the project would continue to be supplied by the existing wells. Refer to Section 4.13, Water Resources, for further discussion of water resources available to supply the proposed on-site uses. g. Regulatory Setting. State. Public Resources Code (PRC) Section 21060.1. PRC Section 21060.1 defines agricultural land for the purposes of assessing environmental impacts under the FMMP. As stated earlier, the FMMP inventories agricultural land use and land use changes throughout California. Land Conservation Act (Williamson Act). Preservation of agricultural, recreational, and open space lands through agricultural preserve contracts between the County and property owners is a technique encouraged by the State to implement general plan policy. Agricultural preserve contracts are executed through procedures enabled by the California Land Conservation Act of 1965, also known as the Williamson Act. A contract may be entered into for property with agricultural, recreational, and open space uses in return for decreased property taxes. The County Agricultural Preserve Rules of Procedure require certain minimum parcel sizes and land use restrictions applicable to agricultural preserve lands under their respective contracts. The Rules of Procedure additionally outline agricultural and compatible uses for lands subject to land conservation contracts. Land Conservation Act contracts preserve agriculture and open space over a rolling term 10 year contract. The inclusion of a parcel in a Williamson Act contract is entirely voluntary and must have the consent of the property owner. No lands within the project site or City of San Luis Obispo are enrolled in a Williamson Act contract (City of San Luis Obispo, 2014). Local Agency Formation Commission. Local Agency Formation Commissions (LAFCos) are state agencies that were created in 1963 to help organize, manage, and regulate the provision of public services to development at the local level. San Luis Obispo LAFCo must approve any annexation or Sphere of Influence adjustment request made by the City, based on policies that discourage sprawl, preserve prime agriculture, and ensure the provision of public services. £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r 56 acres 11 acres 11 acres 53 acres Important Farmland on the Project Site Figure 4.2-2 City of San Luis Obispo Section 4.2 Agricultural ResourcesSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016.Additional data provided by Department of Conservation FMMP, 2015. ±0 500250 Feet Site Boundary Prime Farmland Urban and Built-Up Land Other Land Proposed Development Area 4.2-8 San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-9 LAFCo must consider the effect that any annexation proposal may produce on existing agricultural lands. By guiding development toward vacant urban land and away from agricultural land, LAFCo assists with the preservation of valuable agricultural resources. The Cortese‐Knox‐Hertzberg (CKH) Act of 2000, which provides LAFCo with its authority, strongly discourages the use of prime agriculture land for development. In 2008 San Luis Obispo LAFCo adopted Agricultural Goals‐Policies‐Guidelines developed to help preserve agricultural resources. LAFCo Agricultural Policy 12 applies to projects that propose annexation of land containing prime agricultural soils. This policy requires that such projects include mitigation requiring a substitution ratio of at least 1:1 for the prime land to be converted from agricultural use. Local. County of San Luis Obispo General Plan Agriculture Element. Although not binding relative to the City of San Luis Obispo, the County’s Agriculture Element includes policies and programs that may affect the City’s ability to annex and develop unincorporated lands that may either be designated as Agriculture, contain prime soils, or be in agricultural production. LAFCo will also consider these policies when considering any annexation request, or adjustment to the City’s existing Sphere of Influence. The following policies are most relevant in this regard. Note that while County policies AGP22 and AGP23 apply to development in the County (and not the City), they have the potential to allow higher density clustered development adjacent to the City, which could be considered potentially inconsistent with the City’s policies with respect to maintaining a hard urban edge. For this reason, these policies are described below. Policy AG2. Conserve agricultural resources. a. Maintain the agricultural land base of the county by clearly defining and identifying productive agricultural lands for long-term protection. b. Conserve the soil and water that are the vital components necessary for a successful agricultural industry in this county. c. Establish land-use policies in this element that support the needs of agriculture without impeding its long-term viability. Policy AG3. Protect Agricultural Lands. a. Establish criteria in this element for agricultural land divisions that will promote the long‐ term viability of agriculture. b. Maintain and protect agricultural lands from inappropriate conversion to non‐agricultural uses. Establish criteria in this element and corresponding changes in the Land Use Element and Land Use Ordinance for when it is appropriate to convert land from agricultural to non‐ agricultural designations. Policy AGP24. Conversion of Agricultural Land. a. Discourage the conversion of agricultural lands to non-agricultural uses through the following actions: San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-10 1. Work in cooperation with the incorporated cities, service districts, school districts, the County Department of Agriculture, the Agricultural Advisory Liaison Board, Farm Bureau, and affected community advisory groups to establish urban service and urban reserve lines and village reserve lines that will protect agricultural land and will stabilize agriculture at the urban fringe. 2. Establish clear criteria in this plan and the Land Use Element for changing the designation of land from Agriculture to non‐agricultural designations. 3. Avoid land redesignation (rezoning) that would create new rural residential development outside the urban and village reserve lines. 4. Avoid locating new public facilities outside urban and village reserve lines unless they serve a rural function or there is no feasible alternative location within the urban and village reserve lines. City of San Luis Obispo General Plan. The City of San Luis Obispo addresses agricultural uses and compatibility with urban development through implementation of adopted policies and programs in the General Plan Land Use Element and Conservation and Open Space Element. The current General Plan policies and programs seek to maintain agricultural resources within and outside of the urban reserve line. Policies protect prime agricultural land by maintaining a strict urban growth boundary and promotion of compact residential clusters in agricultural land outside the City limits. The City has a designated Greenbelt, which is an important tool for open space protection in the City. The City seeks to maintain the greenbelt by way of agricultural easements or acquisition land around the urban reserve line. The project site does not fall within the City’s designated greenbelt. Land Use Element. The following policies included in the Land Use Element define the local regulatory setting relative to agricultural resources on the project site: Policy 1.7.1. Urban Reserve. The City shall maintain an urban reserve line containing the area around the City where urban development might occur. Policy 1.7.3. Interim Uses. Expansion areas should be kept in agriculture, compatible with agricultural support services or open-space uses until urban development occurs, unless a City-approved specific plan provides for other interim uses. Policy 1.8.1. Open Space Protection. Within the City's planning area and outside the urban reserve line, undeveloped land should be kept open. Prime agricultural land, productive agricultural land, and potentially productive agricultural land shall be protected for farming. Scenic lands, sensitive wildlife habitat, and undeveloped prime agricultural land shall be permanently protected as open space. Policy 1.9.1. Agricultural Protection. The City shall support preservation of economically viable agricultural operations and land within the urban reserve and City limits. The City should provide for the continuation of farming through steps such as provision of appropriate general plan designations and zoning. Policy 1.9.2. Prime Agricultural Land. The City may allow development on prime agricultural land if the development contributes to the protection of agricultural land in the urban reserve or greenbelt by one or more of the following methods, or an equally effective method: acting as a receiver site for transfer of development credit from prime agricultural land of equal quantity; securing for the City or for San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-11 a suitable land conservation organization open space or agricultural easements or fee ownership with deed restrictions; helping to directly fund the acquisition of fee ownership or open space easements by the City or a suitable land conservation organization. Development of small parcels which are essentially surrounded by urbanization need not contribute to agricultural land protection. Policy 1.10.3. Public Access. Areas preserved for open space should include public trail access, controlled to protect the natural resources, to assure reasonable security and privacy of dwellings, and to allow continuing agricultural operations. Public access through production agricultural land will not be considered, unless the owner agrees. Policy 1.10.4. Design Standards. The City shall require cluster development to: A Be screened from public views by land forms or vegetation, but not at the expense of habitat. If the visually screened locations contain sensitive habitats or unique resources as defined in the Conservation and Open Space Element, development should be avoided in those areas and instead designed to cluster in the form of vernacular farm building complexes, to blend into the traditional agricultural working landscape. B Be located on other than prime agricultural land and be situated to allow continued agricultural use. C Prohibit building sites and roads within stream corridors and other wetlands, on ridge lines, rock outcrops, or visually prominent or steep hillsides, or other sensitive habitats or unique resources as defined in the Conservation and Open Space Element. D Preserve historic or archeological resources. Policy 1.13.8. Open Space. Future development on the San Luis Ranch property shall dedicate one half of the total land or easements for open space use. Policy 8.1.4. SP-2, San Luis Ranch (Dalidio) Specific Plan Area. Purpose: This project site should be developed as a mixed use project that maintains the agricultural heritage of the site, provides a commercial/office transition to the existing commercial center to the north, and provides a diverse housing experience. Protection of the adjacent creek and a well-planned integration into the existing circulation system will be required. The specific plan for this area should consider and address the following land use and design issues. A Provide land and appropriate financial support for development of a Prado Road connection. Appropriate land to support road infrastructure identified in the Final Project EIR (overpass or interchange) at this location shall be dedicated as part of any proposal and any area in excess of the project’s fair share of this facility shall not be included as part of the project site area used to calculate the required 50% open space. B Circulation connections to integrate property with surrounding circulation network for all modes of travel. C Connection to Froom Ranch and Calle Joaquin, if proposed, shall not bifurcate on- site or neighboring agricultural lands. Any connection to Calle Joaquin shall be principally a secondary / emergency access by design. D Development shall include a transit hub. Developer shall work with transit officials to provide express connections to Downtown area. E Maintain agricultural views along Highway 101 by maintaining active agricultural uses on the site, and maintain viewshed of Bishop Peak and Cerro San Luis. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-12 F Maintain significant agricultural and open space resources on site (see Policy 1.13.8.B). Land dedicated to Agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. G Where buffering or transitions to agricultural uses are needed to support viability of the agricultural use, these shall be provided on lands not counted towards the minimum size for the agriculture / open space component. Provide appropriate transition to agricultural uses on-site. H Integrate agricultural open space with adjacent SLO City Farm and development on property. I Site should include walkable retail and pedestrian and bicycle connections to surrounding commercial and residential areas. J Commercial and office uses shall have parking placed behind and to side of buildings so as to not be a prominent feature. K Neighborhood Commercial uses for proposed residential development shall be provided. L Potential flooding issues along Prefumo Creek need to be studied and addressed without impacting off-site uses. M All land uses proposed shall be in keeping with safety parameters described in this General Plan or other applicable regulations relative to the San Luis Obispo Regional Airport. N Historic evaluation of the existing farm house and associated structures shall be included. Conservation and Open Space Element. The Conservation and Open Space Element includes policies designed to protect agricultural resources and prime agricultural land, as well as offset the development of agricultural areas. The following policies influence the local regulatory setting relative to project agricultural resources: Policy 8.2.1. Open Space Preserved. The City will preserve as open space or agriculture the undeveloped and agricultural land outside the urban reserve line, including the designated Greenbelt as shown in Figure 5 [of the Conservation and Open Space Element], and will encourage individuals, organizations and other agencies to do likewise. Policy 8.2.2. Goal: Open space within the urban area [Relevant Portion]. Within the urban area, the City will secure and maintain a diverse network of open land encompassing particularly valuable natural and agricultural resources, connected with the landscape around the urban area. Particularly valuable resources include: • Undeveloped land within the Urban Reserve not intended for urban uses. • Prime agricultural soils and economically viable farmland. Policy 8.3.2. Open Space Buffers. [Relevant Portion]. When activities close to open space resources within or outside the urban area could harm them, the City will require buffers between the activities and the resources. The City will actively encourage individuals, organizations and other agencies to follow this policy. Buffers associated with new development shall be on the site of the development, rather than on neighboring land containing the open space resource. Buffers provide distance in the form of setbacks, within which certain features or activities are not allowed or conditionally allowed. Buffers shall also use techniques such as planting and wildlife-compatible fencing. Buffers shall be adequate for the most sensitive species in the protected area, as determined by a qualified professional and shall complement the protected area’s habitat values. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-13 Buffers shall be required in the following situations: • Between urban development and agricultural operations, to address dust, noise, odors, chemical use, and access by people and pets. • Between agricultural operations and natural habitat, to address noise, chemical use, sediment transport, and livestock access. Policy 8.5.1. Public Access. Public access to open space resources, with interpretive information, should be provided when doing so is consistent with protection of the resources, and with the security and privacy of affected landowners and occupants. Access will generally be limited to non- vehicular movement, and may be visually or physically restricted in sensitive areas. Public access to or through production agricultural land, or through developed residential lots, will be considered only if the owner agrees. The City shall also designate open space areas that are not intended for human presence or activity. Policy 8.6.3. Required Mitigation. [Relevant Portion]. Loss or harm shall be mitigated to the maximum extent feasible. Mitigation must at least comply with Federal and State requirements. Mitigation shall be implemented and monitored in compliance with State and Federal requirements, by qualified professionals, and shall be funded by the project applicant. • For a widespread habitat type or for farmland, mitigation shall consist of permanently protecting an equal area of equal quality, which does not already have permanent protection, within the San Luis Obispo Planning Area. 4.2.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update Environmental Impact Report (LUCE Update EIR) previously analyzed agricultural impacts of development planned under the General Plan Land Use and Circulation Elements, including planned development on the project site. The LUCE Update EIR noted that the project site is currently in use for the production of irrigated row crops. The LUCE Update EIR also noted that the 109 acres of irrigated row crops on the site are considered prime agricultural land, although the project site is not currently under a Williamson Act or agricultural preserve contract. The LUCE Update EIR identified significant impacts to agricultural resources due to the conversion of prime farmland from development of the project site. However, the EIR concluded that implementation of the updated General Plan policies and amendments to existing City policies would reduce impacts to a less than significant level. In particular, the LUCE Update EIR incorporated program-level Mitigation Measure AG-1, which amended Land Use Element Policy 1.8.1, Open Space Protection to state that “productive agricultural land shall be protected for farming.” The LUCE Update EIR also incorporates Conservation and Open Space Element Policy 8.6.3, which requires the loss of agricultural land to be mitigated to the maximum extent feasible (City of San Luis Obispo 2014). San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-14 4.2.3 Impact Analysis a. Methodology and Significance Thresholds. The following thresholds are based on the City’s Initial Study and Appendix G of the State CEQA Guidelines. Impacts would be significant if the San Luis Ranch Project would result in any of the following: 1. Conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use; 2 Conflict with existing zoning for agricultural use or a Williamson Act contract; 3 Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)); 4 Result in the loss of forest land or conversion of forest land to non-forest use; and/or 5 Result in changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use. The project Initial Study (refer to Appendix A) determined that the project would not conflict with a Williamson Act Contract. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of this issue. In addition, the project site does not contain any designated forest land, timberland, or timberland zoned Timberland Production. Therefore, the project would not conflict with zoning for these resources and would not result in the loss or conversion of forest land. Impacts would be less than significant and Thresholds 3 and 4 are not discussed further herein. This analysis builds upon the conclusions identified in the LUCE Update EIR. The LUCE Update EIR analyzed the potential for development of the San Luis Ranch Specific Plan area to convert agricultural resources to developed uses, and concluded that impacts would be less than significant with the incorporation of program-level mitigation measures, including dedication of off-site agricultural lands or in-lieu fees (consistent with Land Use Element Policies 1.8.1 and 1.9.2 and Conservation and Open Space Element Policy 8.6.3). To evaluate the significance of impacts from the conversion of farmland to non-agricultural use, this analysis relies on the acreages of Prime Farmland, Unique Farmland, and Farmland of Statewide Importance mapped by the FMMP. In addition, this analysis uses the California Agricultural Land Evaluation and Site Assessment (LESA) Model as a basis to help determine if the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses would create significant agricultural resource impacts. The LESA Model was developed as an amendment to Appendix G of the State CEQA Guidelines concerning agricultural lands. It is intended “to provide lead agencies with an optional methodology to ensure that significant effects on the environment of agricultural land conversions are quantitatively and consistently considered in the environmental review process” (Public Resources Code Section 21095). LESA is a method used to define an approach for rating the relative quality of land resources based upon specific measurable features. The LESA Model is composed of six different factors: two Land Evaluation (LE) factors are based upon measures of soil resource quality, and four Site Assessment (SA) San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-15 factors provide measures of a given project’s size, water resource availability, surrounding agricultural lands, and surrounding protected resource lands. The factors are then weighted relative to one another and combined, resulting in a single project score that becomes the basis for making a determination of a project’s potential significance, based upon a range of established scoring thresholds. • If the total LESA score is from 0 to 39 points, the scoring decision is “not considered significant.” • If the score is from 40 to 59 points, it is “considered significant only if LE and SA subscores are each greater than or equal to 20 points.” • If the score is from 60 to 79 points, it is “considered significant unless either LE or SA subscore is less than 20 points.” • If the score is from 80 to 100 points, it is “considered significant” (California Department of Conservation 1997). The methodologies for analyzing the project’s potential impacts to agricultural resources are based on the guidelines, policies, and procedures identified in the City’s General Plan, the FMMP, and the California Agricultural LESA Model. The California Department of Conservation provided mapping data used to assess project site soil characteristics. FMMP data utilized for the LESA Model are dated 2014. As the project site is not under Williamson Act contract, the project would not conflict with a Williamson Act contract. b. Impacts and Mitigation Measures. Threshold 1: Would the project result in conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? Impact AG-1 The project would result in the direct conversion of 59.3 56 acres of Prime Farmland, as mapped by the FMMP, to non- agricultural uses. Therefore, impacts would be Class II, significant but mitigable. Approximately 109 acres of the 131-acre project site are currently used for the production of irrigated row crops including celery, broccoli, lettuce, Asian vegetables, and peas. As shown in Figure 4.2-2 and Table 4.2-3, the project site contains 112 109 acres of Prime Farmland, as designated by the FMMP, with 109 acres in agricultural production. This Prime Farmland comprises approximately 83 85 percent of the site, with non-Prime Farmland located along the western and northwestern fringes of the site. The project would preserve approximately 52.7 53 acres in agriculture adjacent the San Luis Obispo City Farm and along the project site frontage with U.S. 101, all of which is designated Prime Farmland. The remaining agricultural area represents (approximately 40.7 43 percent) of the net site acreage and 40 percent of the gross site acreage (when major roadways and right of way for the Prado Road interchange are discounted) in agriculture, primarily adjacent the San Luis Obispo City Farm and along the project site frontage with U.S. 101, all of which is designated Prime Farmland. Approximately 59.3 56 acres of on-site Prime Farmland would be converted to non-agricultural use. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-16 Table 4.2-4 summarizes the LESA Model score for the project site. Table 4.2-4 LESA Analysis Summary for Project Site Factor Rating (0-100 points) Factor Weighting (Total = 1.00) Weighted Factor Rating Land Evaluation (LE) 1. Land Capability Classification 92.1 0.25 23.1 2. Storie Index Rating 64.9 0.25 16.2 Site Assessment (SA) 1. Project Size 100 0.15 15.0 2. Water Resource Availability 83 0.15 12.5 3. Surrounding Agricultural Lands 0 0.15 0.0 4. Protected Resource Lands 0 0.05 0.0 Total LESA Score (sum of weighted factor ratings) 66.8 Significance Determination Significant (because both LE and SA sub-scores are each greater than 20 points). See Appendix C for complete LESA Model Worksheets for the project site. Utilizing the FMMP map and NRCS soil map, the estimated LESA score for the project site was found to be 66.8 (see Appendix C for complete LESA Model worksheets). This score indicates that agricultural resources within the project site are significant because both the LE and SA scores are each greater than 20 points. The reason for the resulting sub-score is that the project site is a relatively large site, contains soils with Prime Farmland designations, and includes onsite wells that serve as a reliable water source for irrigation. Because the project would convert Prime Farmland to non-agricultural use on a site with a LESA Model score which indicates that the agricultural resources within the site are significant, this impact would be potentially significant. As a result, the project would potentially conflict with Land Use Element Policy 1.8.1, which states that prime agricultural land, productive agricultural land, and potentially productive agricultural land shall be protected for farming (refer to Section 4.9, Land Use, for a detailed discussion of the project’s consistency with applicable General Plan policies). Mitigative Components of the Specific Plan and Impact Conclusion. San Luis Ranch Specific Plan Goal 2 establishes a goal to provide a community that maintains and promotes the land’s agricultural heritage. San Luis Ranch Specific Plan Policy 2.4, which requires strict monitoring of the conversion of active agriculture to non-agricultural uses and consider the possible effects of new development on character of the community as a whole, is intended to help achieve Specific Plan Goal 2. Nevertheless, the project would convert Prime Farmland to non- agricultural 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. In addition, Conservation and Open Space Element Policy 8.6.3 would require the applicant to permanently protect land of equal area and quality which does not already have permanent protection (through an San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-17 agricultural conservation easement or in-lieu fees to a fund dedicated to acquiring and preserving agricultural land). The project also includes a commitment, to be included in the Development Agreement, to procure an off-site agricultural conservation easement/deed restriction to comply with the Land Use Element Policy 8.1.4.f, which requires that future development on the San Luis Ranch property dedicate one half of the total land or easements for open space use, and that land dedicated to agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. Land Use Element Policy 8.1.4 includes a performance standards table, which states that “a substantial multiplier for the amount of open space is provided for the off-site property exchanged to meet the on-site requirement.” The project applicant has an existing option-to-purchase agreement on a parcel located within the City’s Greenbelt, and the City has provided the applicant with preliminary approval for this site as an off-site agricultural conservation easement/deed restriction to satisfy Land Use Element Policy 8.1.4.f. However, the specific location of potential off-site agricultural conservation easement land has not been formally identified through a final approval. The “substantial multiplier” required by the City for the San Luis Ranch Specific Plan would be determined by the City at the time that final approval for off-site property exchanged to meet the on-site requirement is considered. To ensure that the final off-site agricultural conservation easement/deed restriction satisfies the requirements of Land Use Element Policy 8.1.4, the project applicant would be required to establish performance measures for the off-site agricultural conservation easement/deed restriction. Therefore, impacts associated with the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), pursuant to the FMMP, to non-agricultural use are identified as potentially significant. Mitigation Measures. The following mitigation measures would be required to ensure that impacts associated with the conversion of Prime Farmland are mitigated to the maximum extent feasible: AG-1 Agricultural Conservation. Prior to issuance of any grading permits, the project proponent shall provide that for every one (1) acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to non-agricultural use as a result of project development, one (1) acre of land of comparable agricultural productivity shall be preserved in perpetuity. The land dedicated to agriculture pursuant to this measure shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. The acreage required to meet the 1:1 ratio may be met by the off-site agricultural conservation easement/deed restriction proposed by the project applicant, as long as this land meets the conditions outlined in this measure. Said mitigation shall be satisfied by the applicant through: 1) Granting a perpetual conservation easement(s), deed restriction(s), or other farmland conservation mechanism(s) to the City or qualifying entity which has been approved by the San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-18 City, such as the Land Conservancy of San Luis Obispo, for the purpose of permanently preserving agricultural land. The required easement(s) area or deed restriction(s) shall therefore total a minimum of 59.3 56 acres of Prime Farmland. The land covered by said on- and/or off-site easement(s) or deed restriction(s) shall be located within or contiguous to the City’s Urban Reserve Line or Greenbelt subject to review and approval of the City’s Natural Resources Manager; or 2) Making an in-lieu payment to a qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, to be applied toward the future purchase of a minimum of 59.3 56 acres of Prime Farmland in San Luis Obispo County, together with an endowment amount as may be required. The payment amount shall be determined by the qualifying entity or a licensed appraiser; or 3) Making an in-lieu payment to a qualifying entity which has been approved by the City and that is organized for conservation purposes, to be applied toward a future perpetual conservation easement, deed restriction, or other farmland conservation mechanism to preserve a minimum of 59.3 56 acres of Prime Farmland in San Luis Obispo County. The amount of the payment shall be determined by the qualifying entity or a licensed appraiser; or 4) Any combination of the above. Prior to issuance of any grading permits for the project, the applicant shall provide evidence of the recorded easement(s), deed restriction(s), or evidence of payment to the City Planning Department or qualifying entity for approval to demonstrate compliance with this measure. Plan Requirements and Timing. Notices, payment of in-lieu fees, and/or dedication of agricultural conservation easements shall be completed by the applicant prior to development plan approval. Monitoring. The City shall ensure compliance with Land Use Element Policy 8.6.3. The City shall make the final decision on the specific requirements for agricultural mitigation prior to development plan approval. 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 56 acres of land of comparable agricultural productivity to be preserved in perpetuity on- or off-site to satisfy the requirement of Mitigation Measure AG-1 that impacts to Prime Farmland be mitigated at a 1:1 ratio (acres of Prime Farmland converted to acres of Prime Farmland preserved in perpetuity). San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-19 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 56 acres of Prime Farmland offsite as required by Mitigation Measure AG-1 would result in a minimum of 3 acres of Prime Farmland required to be preserved off-site (56 total acres required to be preserved minus 53 acres proposed to be preserved on-site) mitigation ratio of approximately 10:1 (acres preserved off-site to acres required on-site), which would appear to satisfy the intent of the “substantial multiplier” clause. However the final determination of the project’s consistency with City policy rests with City Council. Therefore, for the purposes of CEQA, implementation of Mitigation Measure AG-1 would ensure that the project would be potentially consistent with the intent of Land Use Element Policy 8.1.4.f and 1.13.8, as well as Conservation and Open Space Element Policy 8.6.3 (refer to Section 4.9, Land Use/Policy Consistency, for a detailed discussion of the project’s consistency with applicable City policies). However, the final determination of the project’s consistency with City policy, including the degree to which the project satisfies the “substantial multiplier” clause, rests with City Council. Therefore, with implementation of Mitigation Measure AG-1, this impact would be reduced to a less than significant level. Threshold 2: Would the project conflict with existing zoning for agricultural use? Impact AG-2 The project would alter the existing land use and zoning on the project site. However, these alterations would be consistent with the General Plan’s identification of the San Luis Ranch Specific Plan for a mix of urban, agricultural, and open space use. Therefore, this impact would be Class III, less than significant. The 131-acre project site is an unincorporated area completely surrounded by the City of San Luis Obispo, and is within the City’s Sphere of Influence. Under the County’s jurisdiction, the project site has a Multi-Land Use category with Flood Hazard and Airport Review Area (AR) combining designation overlays. Refer to Section 2.0, Project Description, for a detailed discussion of the pre-zoning and annexation required for the project. Under the City’s General Plan, the project site has a land use designation of San Luis Ranch Specific Plan and is intended for the future adoption of a specific plan. Land Use Element Policy 8.1.4 provides requirements and guidance for the future development of a mixed-use project on the San Luis Ranch property that maintains the agricultural heritage of the site. The City’s Zoning Regulations, which implement the General Plan, do not currently apply to the project site because it is currently outside of the incorporated City. No zoning districts in the City have been designated for the project site. Mitigative Components of the Specific Plan and Impact Conclusion. San Luis Ranch Specific Plan Goal 1 establishes a goal to provide a mixed-use development that fosters a sense of community. San Luis Ranch Specific Plan Policy 1.1, which requires that the Specific Plan support multiple land uses that work to enhance the surrounding residential, open space, agriculture, and commercial uses, is intended to help achieve this goal. The Specific Plan area would be annexed to the City of San Luis Obispo as part of the project, and would be rezoned consistent with the associated land use plan included in the Specific Plan. Future development of the site would be consistent with the underlying zoning. Approximately 109 acres of the 131- acre site are currently used for irrigated row crop production. The project would result in a mix San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-20 of residential and commercial development on the site and preservation of approximately 52.7 acres for agricultural purposes. Therefore, the Specific Plan would be consistent with the intended uses of the site and would not conflict with existing zoning. This impact would be less than significant. Mitigation Measures. No mitigation measure would be required. Residual Impacts. Impacts would be less than significant without mitigation. Threshold 5: Would the project result in changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? Impact AG-3 The project would include development of commercial and residential uses adjacent to agricultural uses on the project site. This may result in conflict with existing or future urban and agricultural zoning and uses and adversely affect the long-term viability of the remaining agricultural uses onsite and at the adjacent SLO City Farm. However, with implementation of agricultural buffers, and compliance with standard SLOAPCD dust control measures and City policies, this impact would be Class II, significant but mitigable. Approximately 109 acres of the 131-acre site are currently used for irrigated row crop production. The project site is generally bounded by residential uses and Madonna Road to the west, commercial uses and Dalidio Drive to the north, U.S. 101 to the east, and the San Luis Obispo City Farm to the south. Prefumo Creek is located west of the site. As development occurs on the project site, conflicts could occur between continuing on-site agricultural operations and existing and future adjacent non-agricultural uses. Typical land use conflicts between active agricultural operations and other land uses are described below. Short-Term Conflicts with Agricultural Uses. As described in Section 2.0, Project Description, the project would be constructed in six phases, resulting in a construction period that may last for up to six years. Each phase of construction would require extensive earthwork, which would result in fugitive dust that could impact on-site and off-site crops and other agricultural activities. Implementation of standard dust control measures required by the San Luis Obispo Air Pollution Control District (SLOAPCD), such as watering dirt to dampen and prevent or alleviate dust nuisance and covering stockpiles to prevent dust leaving the site, during each phase would ensure adjacent agricultural operations are not impacted by ongoing construction. Section 4.3, Air Quality, describes standard dust control measures required by SLOAPCD that would be applicable during project construction and would incrementally reduce potential impacts to the productivity of on-site and neighboring agricultural uses. Compliance with standard SLOAPCD dust control measures and City policies to provide buffers between urban and agricultural uses on the project site would ensure that impacts from short-term conflicts with agricultural uses during project construction would remain less than significant. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-21 Earthwork during project construction would also require stockpiling of soil on-site, as areas of the site are graded to their final elevations. Potential impacts associated with siltation into local streams during construction activities are described in Section 4.8, Hydrology and Water Quality. Long-Term Conflicts with Agricultural Uses. Urban development adjacent to farmland can create conflicts with agricultural operations in adjacent areas. The increase in the number of residents in the area and new accessible pathways, bike paths, and roadways would increase public access near existing agricultural areas, increasing the potential for conflicts, such as vandalism to farm equipment or fencing, and theft of crops at on-site agricultural lands and the adjacent SLO City Farm. These effects can result in direct economic impacts to agricultural operations, potentially impacting the overall economic viability of continued agricultural operations. Long-Term Conflicts with Residential and Commercial Uses. Development of the project would add an estimated 1,293 residents to the City (546 new single family and multi-family dwelling units x 2.29 people/unit and 34 new affordable units x 1.25 people/unit)1 near lands under agricultural cultivation. Residents living adjacent to agricultural operations commonly cite odor nuisance impacts, noise from farm equipment, dust, and pesticide spraying as typical sources of conflict. Conservation and Open Space Element Policy 8.3.2, Open Space Buffers, requires that buffers be placed between urban development and agricultural operations. In compliance with the City’s Open Space Buffers policy, the project would include a 72-foot buffer between agricultural operations and urban development to reduce and/ or avoid noise, dust, light impacts, odors, chemical use, access by people and pets, pilferage, and pesticide drift to new residential and commercial land uses on the project site. The 72-foot buffers allow for 60 feet of multimodal right-of-way beyond 12-foot residential rear yard space. The prevailing winds in the region are generally from the northwest, directing agricultural dust away from adjacent residential areas when wind blows from that direction. Compliance with Conservation and Open Space Element Policy 8.3.2 would ensure that land use conflicts between agriculture and adjacent residential and commercial land would be minimized. Mitigative Components of the Specific Plan and Impact Conclusion. San Luis Ranch Specific Plan Goal 2 establishes a goal to provide a community that maintains and promotes the land’s agricultural heritage. San Luis Ranch Specific Plan Policy 2.1 requires that the Specific Plan encourage open space and agricultural uses that support a green buffer surrounding residential and commercial neighborhoods in the Specific Plan area. Specific Plan Policy 2.4 requires strict monitoring of the conversion of active agriculture to non-agricultural uses and considers the possible effects of new development on character of the community as a whole. Specific Plan Policy 2.7 requires incorporation of appropriate agricultural uses in public places and neighborhoods. These policies are intended to help achieve Specific Plan Goal 2. Compliance with Conservation and Open Space Element Policy 8.3.2 would ensure that land use conflicts between agriculture and adjacent residential and commercial land would be minimized. As described above, the Specific Plan includes a 72-foot buffer between agricultural operations and urban development to reduce and/ or avoid noise, dust, light impacts, odors, chemical use, 1 Population growth rate from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-22 access by people and pets, pilferage, and pesticide drift to new residential and commercial land uses on the project site. The proposed agricultural buffer includes berm and bioswale configurations limits on production hours and machinery use for adjacent agricultural operations. In addition, the Specific Plan proposes that on-site agricultural operations would include transition to organic farming, which would not involve pesticide or chemical fertilizer use on the site. However, the increase in the number of residents in the area and new accessible pathways, bike paths, and roadways would increase the potential for conflicts at on-site agricultural lands and the adjacent SLO City Farm which can result in direct economic impacts to agricultural operations, potentially impacting the overall economic viability of continued agricultural operations. Therefore, impacts associated with conversion of Farmland to non- agricultural use would be potentially significant. Mitigation Measures. The following mitigation measure would be required. AG-3(a) Agricultural Conflict Avoidance Measures. The following language shall be added to Section 4.2.1, Agricultural Buffer, of the San Luis Ranch Specific Plan: Agricultural buffers will include City-approved measures to reduce availability of public access to agricultural cultivation areas adjacent to the project site (e.g., fencing, signs, etc.). Future residents will be notified of agricultural buffers as part of purchase or lease agreements. AG-3(b) Agricultural Fencing. The project applicant shall coordinate with the City to fund installation of fencing and signs along Froom Ranch Way and Dalidio Drive/Prado Road to minimize potential for increases in trespass and vandalism of adjacent agricultural areas. AG-3(c) Buffer Landscaping. To reduce the potential for noise, dust, and pesticide drift to affect future residents on the project site, the project applicant shall ensure that project landscape plans include planting of a windrow of trees and shrubs within the agricultural buffer along Froom Ranch Way at a sufficient density to buffer the site from surrounding agricultural operations. Plan Requirements and Timing. The applicant shall clearly identify measures such as fencing, landscaping, etc. within the development plan and tract map. Monitoring. The City Natural Resources Manager shall make the final decision on the specific requirements for agricultural conflict avoidance measures prior to development plan approval for the project, and shall ensure that agricultural conflict avoidance measures are implemented in compliance with applicable General Plan policies. The City Natural Resources Manager shall review the development plan and VTTM to ensure that design includes installation of fencing and signs as required under Mitigation Measures AG-3(b) and AG- San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-23 3(c). The City Natural Resources Manager shall also review the final landscape plan to ensure that the species mix and density of proposed plantings would provide an adequate landscape buffer. Field inspections at appropriate phases of project construction shall confirm installation and compliance with Mitigation Measures AG-3(b) and AG-3(c). Residual Impacts. Impacts associated with potential long-term conflicts with agricultural uses would be less than significant levels with implementation of Mitigation Measures AG-3(a) through AG-3(c). Agricultural fencing would not interfere substantially with the movement of any resident or migratory fish or wildlife species or with established resident or migratory wildlife corridors within the Specific Plan Area (for a detailed discussion of potential project impacts to wildlife movement, refer to Impact BIO-4 in Section 4.4, Biological Resources). Threshold 5: Would the project result in changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? Impact AG-4 Re-grading of the project site would not result in significant degradation of viability of on-site agricultural land. Therefore, this impact would be Class III, less than significant. The project site is relatively level, with a gentle slope to the south and southwest. Two soils types are found on the project site: Cropley clay, which comprises about 83 acres in current agricultural production; and Salinas silty clay loam, which occupies about 26 acres of crop production land (refer to Figure 4.2-1). As described above, both soil types are designated as prime agricultural soils by DOC, and both soils meet criteria that designate these areas as Prime Farmland by the FMMP. The proposed grading and drainage plan for the site would require grading of topsoils to offset the diverted flows from adjacent areas, such that no change in flood water depths or flows would occur on surrounding properties. Grading in the Agricultural Heritage Facilities & Learning Center area would include the placement of fill to protect the proposed structures from flooding. In November 2016, Althouse and Meade, Inc. (Althouse and Meade) prepared a Grading Plan Review for Continued Agricultural Suitability in Floodway memorandum (Agricultural Suitability memorandum; refer to Appendix C) for the project, which summarize the results of an analysis of on-site soils and grading plans, and the agricultural viability of on-soils following project grading activities. The Agricultural Suitability memorandum reviewed the project grading/drainage plans, a June 30, 2015 agricultural suitability analysis letter prepared by Althouse & Meade, and results from soil sampling conducted in July 2015 (both of which are appended to the memorandum; refer to Appendix C). This analysis identified that the on-site Cropley clay and Salinas silty clay loam topsoils are generally over five feet in depth. The proposed flood improvements may remove up to two feet of soil at the north end of the area proposed to be retained in agricultural use. The project grading plan indicates that stormwater would drain from the project site on the same slope and aspect as the current condition. Refer to San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-24 Section 2.5.3, Infrastructure, for a detailed discussion of grading associated with buildout of the project site. The Agricultural Suitability memorandum determined that on-site farmland would continue to be viable for crops in the remaining deep topsoil even if up to 2.5 feet of topsoil were removed and that that post-project stormwater would continue to drain from the site on the same slope and aspect as the current condition. In addition, this analysis determined that the 24.4 acres of Salinas silty clay loam and 28.3 acres of Cropley clay affected by project grading would retain prime agricultural soils status following the proposed re-grading of the project site. Mitigative Components of the Specific Plan and Impact Conclusion. As discussed under Impact AG-3, San Luis Ranch Specific Plan Policy 2.4 requires strict monitoring of the conversion of active agriculture to non-agricultural uses and considers the possible effects of new development on character of the community as a whole. Project grading activities may remove up to two feet of soil at the north end of the agricultural area proposed to be retained with the project. However, on-site farmland would remain viable even if up to 2.5 feet of topsoil were removed, on-site soils will retain prime agricultural soils status, and stormwater will drain from the site on the same slope and aspect as the current condition following project implementation. As such, agricultural viability will be retained after removal of topsoil resulting from implementation of the proposed grading and drainage plan for the project site. Therefore, potential impacts to the agricultural viability of on-site soils would be less than significant. Mitigation Measures. No mitigation measure would be required. Residual Impacts. Impacts would be less than significant without mitigation. c. Cumulative Impacts. Planned buildout of the City of San Luis Obispo under the General Plan, including buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans, would result in conversion of agricultural land to non-agricultural uses. The conversion of agricultural land within the City would potentially result in incompatibilities with agricultural uses and decrease in Prime Farmland, Unique Farmland, and/or Farmland of Statewide Importance. However, as described in the LUCE Update EIR, adherence to General Plan policies and applicable state and federal regulatory requirements would reduce any cumulative agricultural impacts resulting from buildout of the City under the General Plan, including buildout of the San Luis Ranch Specific Plan, to a less than significant level. Implementation of the project would contribute incrementally to the loss of agricultural land within the City and in San Luis Obispo County by converting approximately 59.3 56 acres of Prime Farmland to non- agricultural use. Although agricultural resources in the project vicinity are mainly in areas outside of City limits, agriculture is a major industry in San Luis Obispo County. Development of Prime Farmland and Farmland of Local or Statewide Importance would contribute to cumulative impacts to regional agricultural resources. Such impacts would result in incompatibilities with agricultural uses and a decrease in Prime Farmland, Unique Farmland, and/or Farmland of Statewide Importance. San Luis Obispo County has experienced the trend of conversion of agricultural resources to developed uses; between 2010 and 2012, the FMMP recorded a net loss of 3,601 acres of Important Farmland, and between 2008 and 2010, the San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-25 FMMP recorded a net loss of 810 acres (Department of Conservation 2012; Department of Conservation 2010). Consistent with the LUCE Update EIR, the project would implement mitigation measures to ensure compliance with the goals and policies of the General Plan. As with the project, other cumulative development within the City that would result in the conversion of agricultural resources would be subject to Land Use Element Policies 1.8.1 and 1.9.2, and Conservation and Open Space Element Policy 8.6.3. As a result, cumulative impacts would be less than significant. San Luis Ranch Project EIR Section 4.2 Agricultural Resources City of San Luis Obispo 4.2-26 This page intentionally left blank. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-1 AIR QUALITY 4.3 4.3.1 Setting a. Climate and Topography. The project site is in the South Central Coast Air Basin (SCCAB), which includes all of San Luis Obispo, Santa Barbara, and Ventura Counties. The 2001 Clean Air Plan (2001 CAP) for San Luis Obispo County describes the air quality setting for the County in detail, including the local climate and meteorology, current and projected air quality, and the regulatory framework for the management of air quality. The climate of the SCCAB is strongly influenced by its proximity to the Pacific Ocean and the location of the semi-permanent high-pressure cell in the northeastern Pacific. The Mediterranean climate of the region produces moderate average temperatures, although extreme temperatures can be reached in the winter and summer. The warmest month of the year is September with an average maximum temperature of 69.8 degrees Fahrenheit (°F), while the coldest month of the year is January with an average minimum temperature of 46.7°F. Rainfall is concentrated in the winter months. Local climate conditions are shown in Table 4.3-1. Table 4.3-1 San Luis Obispo Climate Conditions Average annual rainfall 22.4 inches Average maximum temperature (Annual) 69.8°F Average minimum temperature (Annual) 46.7°F Warmest Month September Coolest Month January Annual mean temperature 58.3°F Source: Western Regional Climate Center 2016. Note averages are based on the period of record, February 2, 1893 to June 10, 2016. The region is subject to seasonal Santa Ana winds. Santa Ana winds are strong northerly to northeasterly winds that originate from high-pressure areas centered over the desert of the Great Basin. These winds are usually warm, dry, northerly winds which blow offshore at 15 to 20 miles per hour (mph), but can reach speeds in excess of 60 mph. Santa Ana winds are particularly strong in the mountain passes and at the mouths of canyons. However, seasonal and local topographic conditions may alter the winds experienced in San Luis Obispo. Two types of temperature inversions (warmer air on top of cooler air) are created in the area: subsidence and radiational. The subsidence inversion is a regional effect created by the Pacific high in which air is heated when it flows from the high-pressure area to the low-pressure areas inland and is compressed. This type of inversion generally forms at about 1,000 to 2,000 feet and can occur throughout the year, but it is most evident during the summer months. Radiational, or surface, inversions are formed by the more rapid cooling of air near the ground at night, especially during winter. This type of inversion is typically lower and is generally accompanied by stable air. Both types of inversions limit the dispersal of air pollutants within the regional airshed as the more stable the air (low wind speeds, uniform temperatures), the lower the amount of pollutant dispersion. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-2 b. Air Pollutants of Primary Concern. The State and Federal Clean Air Acts mandate the control and reduction of certain air pollutants. Under these acts, the United States Environmental Protection Agency (U.S. EPA) and the California Air Resources Board (ARB) have established ambient air quality standards for certain “criteria” pollutants. Ambient air pollutant concentrations are affected by the rates and distributions of corresponding air pollutant emissions, as well as by the climactic and topographic influences discussed above. The primary determinant of concentrations of non-reactive pollutants (such as carbon monoxide [CO] and fine particulates [PM2.5 and PM10]) is proximity to major sources. Ambient CO levels usually closely follow the spatial and temporal distributions of vehicular traffic. Federal and state standards have been established for ozone, CO, nitrogen dioxide (NO2), sulfur dioxide (SO2), lead, and PM10 and PM2.5. Standards have been set at levels intended to be protective of public health. California standards are more restrictive than federal standards for each of these pollutants except lead and the eight-hour average for CO. Table 4.3-2 illustrates the current Federal and State Ambient Air Quality Standards. Table 4.3-2 Current Federal and State Ambient Air Quality Standards Pollutant Averaging Time Federal Primary Standards California Standard Ozone 1-Hour --- 0.09 ppm 8-Hour 0.070 ppm 0.070 ppm Carbon Monoxide 8-Hour 9.0 ppm 9.0 ppm 1-Hour 35.0 ppm 20.0 ppm Nitrogen Dioxide Annual 0.053 ppm 0.030 ppm 1-Hour 100 ppb 0.18 ppm Sulfur Dioxide Annual 0.030 ppm --- 24-Hour 0.14 ppm 0.04 ppm 1-Hour 75 ppb 0.25 ppm PM10 Annual --- 20 µg/m3 24-Hour 150 µg/m3 50 µg/m3 PM2.5 Annual 12 µg/m3 12 µg/m3 24-Hour 35 µg/m3 --- Lead 30-Day Average --- 1.5 µg/m3 Rolling 3-Month Average 0.15 µg/m3 --- Calendar Quarter 1.5 µg/m3 --- Source: ARB 2016. ppm = parts per million ppb = parts per billion µg/m3 = micrograms per cubic meter The SLOAPCD monitors criteria pollutant levels to ensure that air quality standards are met, and if they are not met, develops strategies to meet the standards. Depending on whether or not the standards are met or exceeded, the air basin is classified as being in “attainment” or “non- attainment.” As of August 2013 (the last date that SLOAPCD’s attainment status was updated), San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-3 San Luis Obispo County is in non-attainment for the 1-hour and 8-hour State standards for ozone and the 24-hour State standard for PM10 (SLOAPCD 2013). Table 4.3-3 summarizes the annual air quality data for the local airshed. The ARB maintains over 60 air quality monitoring stations throughout California, including tentwo stations in San Luis Obispo County. The remaining stations in San Luis Obispo County are maintained by SLOAPCD. The nearest monitoring station to the project site is the San Luis Obispo station, located at 3220 South Higuera Street and approximately 1,500 feet east of the project site. The San Luis Obispo station collects data on both ozone and PM concentrations. The data collected at this station is considered to be generally representative of the baseline air quality experienced at the project site. Table 4.3-3 Ambient Air Quality Data at the San Luis Obispo Station Pollutant 2013 2014 2015 Ozone, ppm – Hourly Maximum 0.067 0.080 0.066 Number of days of State exceedances (>0.090 ppm) 0 0 0 Number of days of Federal exceedances 0 0 0 Ozone, ppm – Eight Hour (State) 0.061 0.074 0.062 Number of days of State exceedances (>0.070 ppm) 0 1 0 Number of days of Nation exceedances (>0.070 ppm) 0 0 0 Particulate Matter <10 microns, µg/m3 Worst 24 Hours 75.6 43.2 43.1 Number of samples of State exceedances (>50 µg/m3 ) 3 0 0 Number of samples of Federal exceedances (>150 µg/m3 ) 0 0 0 Particulate Matter <2.5 microns, µg/m3 Worst 24 Hours 19.5 15.6 16.4 Number of samples of Federal exceedances (>35 µg/m3 ) 0 0 0 Source: ARB, Top 4 Summary, 2016b The primary pollutants of concern in San Luis Obispo are ozone and particulate matter (PM10). Table 4.3-3 provides the number of days of State or federal exceedance in a given year. As shown, pollutant concentrations have not exceeded State or federal standards since 2013 for hourly ozone and PM2.5. The State eight hour ozone standard was exceeded once in 2014 and the PM10 24 Hour standard was exceeded three times in 2013. The major local sources for PM10 in the region are agricultural operations, vehicle dust, grading, and dust produced by high winds. Ozone is a secondary pollutant that is not produced directly by a source, but rather is formed by a reaction between nitrogen oxides (NOX) and reactive organic gases (ROG) in the presence of sunlight. Reductions in ozone concentrations are dependent on reducing the amount of these precursors. In San Luis Obispo County, the major sources of ROG are motor vehicles, organic solvents, the petroleum industry, and pesticides; and the major sources of NOX are motor vehicles, public utility power generation, and fuel combustion by various industrial sources (SLOAPCD 2001). c. Regulatory Setting. Air quality is regulated by the U.S. EPA, ARB, and SLOAPCD. Each of these agencies develops rules, regulations, policies, and/or goals to comply with San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-4 applicable legislation. Although U.S. EPA regulations may not be superseded, state and local regulations may be more stringent. The Federal Clean Air Act (CAA) required U.S. EPA to establish national ambient air quality standards (NAAQS) (Table 4.3-2). The CAA also required each state to prepare an air quality control plan referred to as a State Implementation Plan (SIP). The Federal CAA Amendments of 1990 added requirements for states with nonattainment areas to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is modified periodically to reflect the latest emissions inventories, planning documents, and rules and regulations of the air basins as reported by their jurisdictional agencies. EPA is responsible for reviewing all SIPs to determine whether they conform to the mandates of the CAA and its amendments and whether implementation will achieve air quality goals. If the EPA determines a SIP to be inadequate, a federal implementation plan that imposes additional control measures may be prepared for the nonattainment area. If an approvable SIP is not submitted or implemented within the mandated time frame, sanctions may be applied to transportation funding and stationary air pollution sources in the air basin. The ARB is responsible for preparing and enforcing the federally‐required SIP to achieve and maintain NAAQS, as well as the California Ambient Air Quality Standards (CAAQS), which were developed as part of the California Clean Air Act (1988) (Table 4.3-2). The State standards for criteria pollutants are equivalent to or more stringent than the national standards, and include other pollutants for which there are no national standards. The ARB is also responsible for assigning air basin attainment and nonattainment designations in California. The ARB is the oversight agency responsible for regulating statewide air quality, but implementation and administration of the CAAQS is delegated to several regional air pollution control districts and air quality management districts. These districts have been created for specific air basins and have principal responsibility for: developing plans to comply with the NAAQS and CAAQS; developing control measures for non‐vehicular sources of air pollution necessary to achieve and maintain NAAQS and CAAQS; implementing permit programs established for the construction, modification, and operation of air pollution sources; enforcing air pollution statutes and regulations governing non‐vehicular sources; and developing employer‐based trip reduction programs. With regards to toxic air contaminants (TACs), the Tanner Air Toxics Act (Assembly Bill [AB] 1807, Chapter 1047, Statutes of 1983) sets forth a formal procedure for ARB to designate substances and develop control measures. The Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588, Chapter 1252, Statutes of 1987) requires stationary sources to report the types and quantities of certain substances routinely released into the air. The SLOAPCD, the lead air quality regulatory agency for San Luis Obispo County, maintains air quality comprehensive programs for planning, regulation, enforcement, technical innovation, and promotion of the understanding of air quality issues. The clean‐air strategy of SLOAPCD involves the preparation of plans and programs for the attainment of CAAQS and NAAQS, adoption and enforcement of rules and regulations, and issuance of permits for stationary sources. The 2001 Clean Air Plan for San Luis Obispo County, prepared by SLOAPCD, contains a comprehensive set of control measures and a regulatory framework designed to reduce criteria air pollutants and precursors from both stationary and mobile San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-5 sources. The SLOAPCD also inspects stationary sources to ensure they abide by permit requirements, responds to citizen complaints, monitors ambient air quality and meteorological conditions, and implements other programs and regulations required by the Federal and State Clean Air Acts. In 2009, SLOAPCD adopted guidelines for assessment and mitigation of air quality impacts under the California Environmental Quality Act (CEQA). The CEQA Air Quality Handbook, which was updated in 2012 (SLOAPCD 2012), is an advisory document that provides lead agencies, consultants, and project applicants with uniform procedures for addressing air quality issues in environmental documents. The CEQA Air Quality Handbook also includes standard construction and operational mitigation measures that may be applied to projects that exceed SLOAPCD thresholds. d. Sensitive Receptors. Ambient air quality standards have been established to represent the levels of air quality considered sufficient, with an adequate margin of safety, to protect public health and welfare. Standards are designed to protect that segment of the public most susceptible to respiratory distress, such as children under 14; the elderly over 65; persons engaged in strenuous work or exercise; and people with cardiovascular and chronic respiratory diseases. Therefore, the majority of sensitive receptor locations are residences, schools, and hospitals. Sensitive receptors near the project site include the residential areas to the southwest and west. The nearest schools are Pacific Beach High School, located approximately 750 feet west of the project site and C.L. Smith Elementary School, located approximately 1,500 feet north of the project site. The nearest hospitals to the project site include French Hospital Medical Center, located approximately two miles northeast at 1911 Johnson Avenue, and Sierra Vista Regional Medical Center, located approximately 2.5 miles north at 1010 Murray Avenue. Therefore, the nearest sensitive receptors to the project site are the residences located approximately 75 feet to the west, separated from the project site by Prefumo Creek. The project’s proposed residential uses would also be considered sensitive receptors. e. Odors. The SLOAPCD CEQA Air Quality Handbook identifies multiple sources that may cause odors including, but not limited to, wastewater treatment plants, landfills, composting facilities, petroleum refineries, and chemical manufacturing. The main objectionable odor released from wastewater treatment plants is associated with hydrogen sulfide (H2S), which emits an odor similar to rotten eggs. The nearest existing source of odor in the vicinity of the project site is the San Luis Obispo Water Resource Recovery Facility (WRRF) located approximately 500 feet east of the project site boundary, across U.S. 101. 4.3.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) analyzed air quality impacts for the City of San Luis Obispo related to the adoption of the updated General Plan Land Use and Circulation Elements. However, the LUCE Update EIR did not include a site-specific analysis of air quality impacts for the San Luis Ranch Specific Plan Area. The LUCE Update EIR identified significant but mitigable short-term construction-related air quality impacts associated with buildout of the General Plan. Mitigation measures required in the LUCE Update EIR to reduce this impact included implementation of the most current San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-6 SLOAPCD‐recommended emissions reduction measures to reduce construction‐generated emissions to less‐significant levels at the project-specific level. The LUCE Update EIR identified significant and unavoidable long-term air quality impacts due to operational emissions from development under the General Plan and inconsistency with the 2001 CAP because the growth rate in vehicle miles travelled (VMT) under the updated Land Use and Circulation Elements would exceed the rate of population growth. However, the LUCE Update EIR concluded that implementation of the updated General Plan policies, and amendments to existing City policies, as well as the establishment of project-specific mitigation measures, where appropriate, would reduce cumulative air quality impacts to a less than significant level. 4.3.3 Impact Analysis a. Methodology and Significance Thresholds. Procedures and guidance regarding the evaluation of air quality impacts associated with land development projects are provided by SLOAPCD’s CEQA Air Quality Handbook (2012). Methodology. The California Emissions Estimator Model (CalEEMod) version 2016.3.1 was utilized to estimate regional air pollutant emissions associated with project construction and operation. Proposed construction would occur in six phases between 2017 and 2023. Phases 1, 2, and 3 – which include the proposed residential build out – would be constructed between 2017 and 2020. Phases 4 and 5 – which include office and hotel build out – would be constructed between 2018 and 2023. Phase 6 – which includes commercial build out – would be constructed between 2017 and 2020. Each year of construction was modeled separately in CalEEMod based on the phasing plan described in Section 2.0, Project Description, and Section 7.7 of the Specific Plan (Appendix B) to account for multiple operational years. To provide a conservative estimate, it was assumed that office construction would be concentrated between 2018 and 2021. CalEEMod construction schedule defaults were used, except in the case of architectural coating. Architectural coating was extended to overlap with half of the default building construction phase because painting is generally completed as buildings within a phase are completed, rather than subsequent all building construction. Construction phasing assumptions are detailed in the CalEEMod output files (refer to Appendix D). Grading of the project site would require approximately 248,000 cubic yards (cy) of import. Off- site hauling of import materials was included in the emissions modeling. This analysis assumes that soil would be imported to the site during each phase and, as exact import volumes per phase are unknown, total import was divided between phases proportionally by phase acreage. CalEEMod’s default trip length of 20 miles per one-way trip was used for hauling. Existing buildings in the northern area of the project site were estimated to total approximately 17,500 square feet of building area. Demolition of these buildings was included in the modeling for Phase 3. Estimates of vehicle trips associated with the proposed development were based on peak hour trip generation rates from the project Traffic Impact Study (refer to Section 4.12, Transportation/Traffic and Appendix L). The trip generation rates in the TIS are based on the Institute of Transportation Engineers 9th Edition Trip Generation Manual, and also account for reductions expected from the mixed use and pedestrian-oriented characteristics of the project (see Appendix L), including internal capture and pass-by trips. In addition, the open space and San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-7 park areas’ use of reclaimed water was included in the emissions modeling. All other values utilized in the emissions modeling were based on applicable SLOAPCD defaults for the SCCAB. Existing agricultural operations on the project site generate emissions from agricultural equipment, such as tractors, and vehicles accessing the site. The active agricultural area would be reduced from approximately 109 acres (refer to Section 4.2, Agricultural Resources) to 53 acres, a 50 percent decrease, which would result in a proportionate reduction in emissions from agricultural operations. The existing agricultural uses of the site are substantially less energy, water, and fuel intensive than the proposed residential and commercial land uses for the site. To provide a conservative estimate of the project’s operational emissions, the analysis does not include the net reduction in emissions that would result from reducing to area of active agricultural operations on the project site. Significance Thresholds. The following thresholds are based on Appendix G of the State CEQA Guidelines. Impacts would be significant if the project would: 1. Conflict with or obstruct implementation of the applicable air quality plan; 2. Violate any air quality standard or contribute substantially to an existing or projected air quality violation; 3. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative guidelines for ozone precursors); 4. Expose sensitive receptors to substantial pollutant concentrations; or 5. Create objectionable odors affecting a substantial number of people. The Initial Study (Appendix A) determined that the project would not create objectionable odors that would affect a substantial number of people, nor would the project expose people to objectionable odors. Therefore, Threshold 5 is not discussed further in this section. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of this issue. As stated in the State CEQA Guidelines, the significance criteria established by the regional air quality management or air quality pollution control district may be relied upon to make determinations. SLOAPCD’s recommended significance criteria are described in its CEQA Air Quality Handbook (2012) and included below. Consistency with the 2001 CAP. Projects and programs requiring an analysis of consistency with the CAP include: General Plan updates and amendments, Community Plans, Specific Plans, Area Plans, large residential developments and large commercial/industrial developments. Therefore, the proposed San Luis Ranch Specific Plan Area is evaluated for impacts related to CAP consistency. The CEQA Air Quality Handbook (2012) indicates that if a project is consistent with the land use and transportation control measures and strategies outlined in the 2001 CAP, then the project is considered consistent with the 2001 CAP. The 2001 CAP guidance for project consistency analysis states that the following questions should be evaluated: San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-8 1. Are the population projections used in the plan or project equal to or less than those used in the most recent CAP for the same area? 2. Is rate of increase in vehicle trips and miles traveled less than or equal to the rate of population growth for the same area? 3. Have all applicable land use and transportation control measures from the CAP been included in the plan or project to the maximum extent feasible? According to the 2001 CAP, if the answer to all of the above questions is yes, then the project is consistent with the CAP. If the answer to any of the above questions is no, the project is inconsistent with the CAP. Construction Emissions Thresholds. The SLOAPCD has developed specific daily and quarterly numeric thresholds that apply to projects within the SCCAB. Daily thresholds are for projects that would be completed in less than one quarter (90 days). The SLOAPCD’s quarterly construction thresholds are applicable to the proposed project because construction would last for more than one quarter. These include: ROG and NOX Emissions • Quarterly – Tier 1: For construction projects lasting more than one quarter, exceedance of the 2.5 tons per quarter threshold requires Standard Mitigation Measures and Best Available Control Technology (BACT) for construction equipment. If implementation of the Standard Mitigation and BACT measures cannot bring the project below the threshold, off-site mitigation may be necessary; and, • Quarterly – Tier 2: For construction projects lasting more than one quarter, exceedance of the 6.3 tons per quarter threshold requires Standard Mitigation Measures, BACT, implementation of a Construction Activity Management Plan (CAMP), and off-site mitigation. Diesel Particulate Matter (DPM) Emissions • Quarterly - Tier 1: For construction projects lasting more than one quarter, exceedance of the 0.13 tons per quarter threshold requires Standard Mitigation Measures, BACT for construction equipment; and, • Quarterly - Tier 2: For construction projects lasting more than one quarter, exceedance of the 0.32 ton per quarter threshold requires Standard Mitigation Measures, BACT, implementation of a CAMP, and off-site mitigation. Fugitive Particulate Matter (PM10), Dust Emissions • Quarterly: Exceedance of the 2.5 tons per quarter threshold requires Fugitive PM10 Mitigation Measures and may require the implementation of a CAMP. Operational Emissions Thresholds. SLOAPCD‘s long-term operational emission thresholds are summarized in Table 4.3-4. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-9 Table 4.3-4 SLOAPCD Operational Emissions Significance Thresholds Pollutant Threshold Daily Annual ROG + NOX (combined)1 25 lbs/day 25 tons/year Diesel Particulate Matter (DPM)1 1.25 lbs/day --- Fugitive Particulate Matter (PM10), Dust 25 lbs/day 25 tons/year CO 550 lbs/day --- Source: SLOAPCD 2012 1. SLOAPCD specifies that CalEEMod winter emission outputs should be compared to operational thresholds for these pollutants (2012). b. Project Impacts and Mitigation Measures. Threshold 1: Would the project conflict with or obstruct implementation of the applicable air quality plan? Impact AQ-1 The project would be inconsistent with the SLOAPCD 2001 Clean Air Plan because it would result in an increase in vehicle miles traveled (VMT) that would exceed the rate of population growth. This impact would be Class I, significant and unavoidable. As described in Section 4.3.3(a), Methodology and Thresholds, significant impacts related to consistency with the 2001 CAP are identified by determining whether the project would exceed the population projections used in the CAP for the same area, whether the vehicle trips and vehicle miles traveled generated by the project would exceed the rate of population growth for the same area, and whether all applicable land use management strategies and transportation control measures from the CAP have been included in the project to the maximum extent feasible. The consistency of the project with each of these criteria is discussed in the following paragraphs. Population Growth Consistency. Development of the project would add an estimated 1,293 residents to the City (546 new single family and multi-family dwelling units x 2.29 people/unit and 34 new affordable units x 1.25 people/unit).1 When added to the existing population within the City of approximately 46,117 (California Department of Finance 2016), buildout of the Specific Plan Area would increase the City’s total population to an estimated 47,410 residents, an increase of 2.8 percent. The 2001 CAP’s population estimate for the City is 48,499 by 2015, which represents growth of 22 percent over the 20-year period from 1995 to 2015. Because the project would not cause the City’s population to exceed the 2001 CAP’s 2015 population estimate for the City of 48,499, the project would not result in an exceedance of the population projections contained in the 2001 CAP. 1 Population growth rate from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-10 Vehicle Trip Rate Increase and Miles Traveled. The Traffic Impact Study determined that the project would add a total of 662 vehicle trips in the AM peak hour and 899 vehicles in the PM peak hour to local roadways under existing and short-term conditions (Appendix L; also refer to Section 4.12, Transportation/Traffic). Under 2035 conditions, the project would add a total of 648 vehicle trips in the AM peak hour and 879 vehicles trips in the PM peak hour. The LUCE Update EIR determined that buildout under the updated General Plan would result in 1,356,310 daily VMT in 2035. Based on the CalEEMod analysis (see Appendix D), the project would result in annual VMT of 14,737,087, or a daily VMT of 40,376 (annual VMT divided by 365 days per year). Buildout of the Specific Plan Area would increase the City’s daily VMT to 1,396,686, an increase of approximately 3.0 percent. The LUCE Update EIR determined that the City’s population in 2035 would be 48,550, assuming a moderate growth rate. Buildout of the Specific Plan Area would increase the City’s total population in 2035 to an estimated 49,795 49,843, an increase of 2.6 2.7 percent. The project’s increase in total vehicle miles traveled (3.0 percent) would exceed the project’s increase to population (2.6 2.7 percent); therefore the project would be inconsistent with the CAP assumptions for VMT. Implementation of Land Use and Transportation Control Measures. Five of the transportation control measures (TCMs) and four of the land use planning strategies contained in the CAP are applicable to the proposed project. The project’s consistency with the CAP’s applicable land use and transportation control measures is assessed in Table 4.3-5. Table 4.3-5 Project Consistency with Applicable 2001 CAP Land Use and Transportation Control Measures 2001 CAP Control Measure Project Consistency Land Use Planning Strategies L-1 Planning Compact Communities. Maintaining compact city and village areas reduces reliance on the automobile by enhancing the viability of public transit and maximizing the potential for walking and bicycling to work, shopping, and other destinations. Consistent The project’s internal circulation would include an emphasis on pedestrian and bicycle circulation. Proposed neighborhoods would be connected with a local street and trail system, and would contain recreational areas. Furthermore, the project would utilize the surrounding developed areas, streets, and bike path to connect to the existing urban pattern. The project would incorporate multimodal access to the site, including transit stops and bike staging areas. See Figure 2-8 Multimodal Circulation Plan in Section 2.0, Project Description. The project includes Class I bike paths on the main streets throughout the project site and Class II paths on local streets. The bicycle circulation network would connect single- and multi-family residential areas with the Bob Jones Trail and a series of loops that join the various project land uses. L-2 Providing for Mixed Land Use. Communities should allow a mixture of land uses that enables people to walk or bicycle to work or to purchase necessary household items or service, at locations convenient to their neighborhood. Consistent The project is a mixed-use project and includes residential, commercial, office, hotel, agriculture and open space. This mix of land uses combined with a walkable-bikeable neighborhood design would enable people to utilize alternative modes of transportation to go to work or purchase goods. Figure 6.8 of the Specific Plan (Appendix B) shows a five and ten minute walk from the center of the neighborhood to nearby commercial areas where residents would have access to a wide variety of goods and services. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-11 Table 4.3-5 Project Consistency with Applicable 2001 CAP Land Use and Transportation Control Measures 2001 CAP Control Measure Project Consistency L-3 Balancing Jobs and Housing. Within cities and unincorporated communities, the gap between the availability of jobs and housing should be narrowed and should not be allowed to expand. Consistent An objective of the project is to create entry-level, workforce housing opportunities within the city. The project also includes 34 units of affordable housing. The proposed project is a mixed use development that would locate housing near existing and proposed job opportunities. L-4 Circulation Management. The primary goal of the recommended Circulation Management Policies and Programs is to encourage the design and construction of the county’s transportation system in a manner that supports alternative travel modes and decreases reliance on single occupant motor vehicles. Policies include: • Promoting accessibility in the transportation system • Promoting walking and bicycling • Parking management • Transportation demand management Consistent See discussion of strategy L-1. The project would also provide a fair-share financial contribution towards public circulation improvements, which could be used towards design and construction of the County’s transportation system in a manner that supports alternative travel modes and decreases reliance on single occupant motor vehicles. Transportation Control Measures T-2A Local Transit System Improvements. The focus of this measure is on improving local transit service and infrastructure to increase ridership by enhancing the convenience and overall viability of the system. Consistent The project would improve local transit service by creating a new transit center that would connect the project to downtown San Luis Obispo. As discussed in Section 6.3.1 of the Specific Plan, revised bus routes and the creation and maintenance of transit facilities would be coordinated with the City of San Luis Obispo based on an analysis of expected demand. Access to SLO Transit would also provide San Luis Ranch residents a connection to the Regional Transit Authority (RTA) bus routes. If transit ridership meets specified demand thresholds, direct Regional Transit Authority access will be considered at this future transit center. T-2B Regional Public Transit Improvements. San Luis Obispo Regional Transit Authority (SLORTA) operates the regional fixed route system, Central Coast Area Transit (CCAT). The focus of this measure is to improve regional transit service and infrastructure with the goal of increasing ridership rates in excess of countywide population growth rates. Consistent See discussion of strategy T-2A. T-3 Bicycling and Bikeway Enhancements. To effectively encourage the modal shift to bicycles, a comprehensive program to promote bicycle use was adopted in the 1991 Clean Air Plan. Consistent The project’s internal circulation would include an emphasis on pedestrian and bicycle circulation. Proposed neighborhoods would be connected with a local street and trail system, and would contain recreational areas. T-6 Traffic Flow Improvements. This control measure focuses on traffic flow improvements and “traffic-calming” to improve the flow of all transportation modes. Traffic-calming refers to a full range of methods designed to improve the flow of nonmotorized transportation by Consistent The project’s Neighborhood Traffic Management program would incorporate strategies outlined in the City’s Neighborhood Traffic Management program. A key component of the program would be the slowing of traffic speeds and reduction of traffic volumes. As described in the Specific Plan, the project includes a range of San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-12 Table 4.3-5 Project Consistency with Applicable 2001 CAP Land Use and Transportation Control Measures 2001 CAP Control Measure Project Consistency slowing down the speed of motorized traffic. Traffic-calming is generally used in residential areas on non-arterial local streets and roads. traffic control strategies, including narrow drive lanes, speed and warning signs, turn restriction signs, roundabouts, and speed humps. T-8 Teleworking, Teleconferencing, and Telelearning. This control measure seeks to reduce emissions by promoting telecommuting for any employee whose job can accommodate working from home. Inconsistent The project includes commercial and office development. The project would not preclude employees of businesses within the future development from telecommuting. However, the project does not include promotion of telecommuting. Three transportation control measures are not applicable to the project, T-1B Campus Trip Reduction Program; T-4 Park and Ride Lots; T-5 Motor Vehicle Inspection and Control Programs, because the project does not include a college campus, park and ride lots, or smog check program. As shown in Table 4.3-5, the project does not include provisions for future employers on the site to encourage telecommuting (TCM T-8). Therefore, the project is inconsistent with the CAP and mitigation would be required. Mitigative Components of the Specific Plan and Impact Conclusion. As shown in Table 4.3-5, the Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The project also emphasizes bikeways and pedestrian connections, all of which contribute to reduced VMT and air pollutant emissions. However, the Specific Plan would increase VMT in the Specific Plan Area at a rate greater than population growth and does not include specific policies to require future employers to encourage telecommuting (TCM T-8). Therefore, impacts would be potentially significant. Mitigation Measures. The following mitigation measure is required to reduce the project’s impacts related to inconsistency with the CAP. AQ-1 Encourage Telecommuting. The project applicant or developers of individual projects within the Specific Plan Area shall include provisions to encourage employers within the proposed commercial, office, and hotel components of the project to implement telecommuting programs and include teleconferencing capabilities, such as web cams or satellite linkage, which will allow employees to attend meetings remotely without requiring them to travel out of the area. Plan Requirements and Timing. The project applicant or developers of individual projects within the Specific Plan Area shall submit proof that employers within the proposed commercial, office, and hotel components of the project have either implemented telecommuting programs or include teleconferencing capabilities, or proof that such a program is infeasible. Monitoring. The Commercial Community Development Department shall verify teleconferencing capabilities, if feasible, are included in tenant improvements prior to issuance of occupancy permits. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-13 Significance After Mitigation. Implementation of the above mitigation measure, as well as Mitigation Measure AQ-3(a) and AQ-3(b) described below, would reduce regional air pollutant emissions and ensure that the project would be consistent with the CAP transportation control measures and land use strategies. However, mitigation is not available that would reduce projected VMT such that the project’s vehicle trip rate increase would not exceed population growth in the region. Therefore, impacts related to consistency with the 2001 CAP would remain significant and unavoidable (Class I). Threshold 2: Would the project violate any air quality standard or contribute substantially to an existing or projected air quality violation? Impact AQ-2 Construction of the project would generate temporary increases in localized air pollutant emissions. Construction emissions of ROG, NOX, and DPM would exceed SLOAPCD construction thresholds. Impacts would be Class II, less than significant with mitigation incorporated. Construction of the project would generate temporary emissions of air pollutants. Ozone precursors, NOX and ROG, as well as DPM (exhaust PM2.5 and PM10) would be emitted by the operation of construction equipment, while fugitive dust (PM10) would be emitted by activities that disturb the soil, such as grading and excavation, road construction, and building construction. The project’s maximum quarterly emissions are shown in Table 4.3-6. As shown in Table 4.3-6, the project’s combined ROG and NOX emissions would exceed SLOAPCD’s Quarterly Tier 1 and Tier 2 thresholds, and the project’s DPM emissions would exceed SLOAPCD’s Quarterly Tier 1 thresholds, but would not exceed Tier 2 thresholds. The project’s dust emissions would not exceed Tier 1 or 2 thresholds. Nonetheless, SLOAPCD requires any project with grading areas greater than 4.0 acres or that are within 1,000 feet of any sensitive receptor to implement standard fugitive dust mitigation measures. Mitigative Components of the Specific Plan and Impact Conclusion. The Specific Plan does not contain any mitigative components that would reduce impacts from construction emissions; therefore, construction emissions would exceed SLOAPCD thresholds and impacts would be potentially significant. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-14 Table 4.3-6 Estimated Construction Maximum Quarterly Air Pollutant Emissions (tons/quarter)1 Construction Year Maximum Quarter Per Year (tons/quarter)2 ROG + NOX DPM Dust 2017 2.9 0.14 0.1 2018 6.1 0.20 0.2 2019 6.9 0.17 0.3 2020 4.6 0.12 0.2 2021 4.2 0.16 0.2 Maximum tons/quarter 6.9 0.20 0.3 SLOAPCD Quarterly Tier 1 Thresholds (tons/quarter) 2.5 0.13 2.5 Threshold Exceeded? Yes Yes No SLOAPCD Quarterly Tier 2 Thresholds (tons/quarter) 6.3 0.32 2.5 Threshold Exceeded? Yes No No Notes: All calculations were made using CalEEMod. See Appendix D for model results. DPM equal to combined exhaust PM10 and PM2.5 and dust equal to fugitive PM10 from CalEEMod. 1 Maximum daily emissions include on-site and off-site emissions. 2 CalEEMod calculates quarterly emissions of ROG+NOX, but does not generate quarterly emissions for DPM and dust; therefore, maximum annual construction emissions of DPM and dust were divided by the number of quarters undergoing construction in a year to estimate maximum quarterly emissions. Mitigation Measures. The following mitigation measures are required to reduce construction emissions of ROG, NOX, and DPM. Although the project’s dust emissions would not exceed Tier 1 or 2 thresholds, SLOAPCD requires any project with grading areas greater than 4.0 acres or that are within 1,000 feet of any sensitive receptor to implement standard fugitive dust mitigation measures. Therefore, Mitigation Measure AQ-2(a) is also required. AQ-2(a) Fugitive Dust Control Measures. Construction projects shall implement the following dust control measures so as to reduce PM10 emissions in accordance with SLOAPCD requirements. • Reduce the amount of the disturbed area where possible; • Water trucks or sprinkler systems shall be used during construction in sufficient quantities to prevent airborne dust from leaving the site. Increased watering frequency shall be required whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water or a SLOAPCD-approved dust suppressant shall be used whenever possible;, to reduce the amount of potable water used for dust control; • All dirt stock pile areas shall be sprayed daily as needed; • Permanent dust control measures identified in the approved project revegetation and landscape plans shall be San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-15 implemented as soon as possible following completion of any soil disturbing activities; • Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading shall be sown with a fast germinating, non-invasive grass seed and watered until vegetation is established; • All disturbed soil areas not subject to revegetation shall be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the SLOAPCD; • All roadways, driveways, sidewalks, etc. to be paved shall be completed as soon as possible after grading unless seeding or soil binders are used; • Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site; • All trucks hauling dirt, sand, soil, or other loose materials are to be covered or shall maintain at least two feet of freeboard (minimum vertical distance between top of load and top of trailer) in accordance with California Vehicle Code Section 23114; • Install wheel washers where vehicles enter and exit unpaved roads onto streets, or wash off trucks and equipment leaving the site; • Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers with reclaimed water shall be used where feasible; • All of these fugitive dust mitigation measures shall be shown on grading and building plans; and • The contractor or builder shall designate a person or persons to monitor the fugitive dust emissions and enhance the implementation of the measures as necessary to minimize dust complaints, reduce visible emissions below 20 percent opacity, and to prevent transport of dust offsite. Their duties shall include holidays and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the SLOAPCD Compliance Division prior to the start of any grading, earthwork or demolition. AQ-2(b) Standard Control Measures for Construction Equipment. The following standard air quality mitigation measures shall be implemented during construction activities at the project site: • Maintain all construction equipment in proper tune according to manufacturer’s specifications; • Fuel all off-road and portable diesel powered equipment with ARB certified motor vehicle diesel fuel (non-taxed version suitable for sue off-road); San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-16 • Use diesel construction equipment meeting ARB’s Tier 2 certified engines or cleaner off-road heavy-duty diesel engines, and comply with the State Off-Road Regulation; • Use on-road heavy-duty trucks that meet the ARB’s 2007 or cleaner certification standard for on-road heavy-duty diesel engines, and comply with the State On-Road Regulation; • Construction or trucking companies with fleets that do not have engines in their fleet that meet the engine standards identified in the above two measures (e.g. captive or NOX exempt area fleets) may be eligible by proving alternative compliance; • On-road diesel vehicles shall comply with Section 2485 of Title 13 of the California Code of Regulations. This regulation limits idling from diesel-fueled commercial motor vehicles with gross vehicular weight ratings of more than 10,000 pounds and licensed for operation on highways. It applies to California and non-California based vehicles. In general, the regulation specifies that drivers of said vehicles: 1. Shall not idle the vehicle's primary diesel engine for greater than 5-minutes at any location, except as noted in Subsection (d) of the regulation; and, 2. Shall not operate a diesel-fueled auxiliary power system (APS) to power a heater, air conditioner, or any ancillary equipment on that vehicle during sleeping or resting in a sleeper berth for greater than 5.0 minutes at any location when within 1,000 feet of a restricted area, except as noted in Subsection (d) of the regulation. • Off-road diesel equipment shall comply with the 5-minute idling restriction identified in Section 2449(d)(2) of the California Air Resources Board's In-Use Off-Road Diesel regulation. • All on and off-road diesel equipment shall not idle for more than 5 minutes. Signs shall be posted in the designated queuing areas and or job sites to remind drivers and operators of the 5 minute idling limit; • In addition to the state required diesel idling requirements, the project applicant shall comply with these more restrictive requirements to minimize impacts to nearby sensitive receptors: 1. Signs that specify the no idling areas shall be posted and enforced at the site. 2. Diesel idling within 1,000 feet of sensitive receptors is not permitted; 3. Staging and queuing areas shall not be located within 1,000 feet of sensitive receptors; 4. Use of alternative fueled equipment is recommended; San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-17 • Electrify equipment when feasible; • Substitute gasoline-powered in place of diesel-powered equipment, where feasible; and • Use alternatively fueled construction equipment on-site where feasible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel. AQ-2(c) Best Available Control Technology (BACT) for Construction Equipment. The following BACT for diesel-fueled construction equipment shall be implemented during construction activities at the project site, where feasible: • Further reducing emissions by expanding use of Tier 3 and Tier 4 off-road and 2010 on-road compliant engines where feasible; • Repowering equipment with the cleanest engines available; and • Installing California Verified Diesel Emission Control Strategies, such as level 2 diesel particulate filters. These strategies are listed at: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm AQ-2(d) Architectural Coating. To reduce ROG and NOX levels during the architectural coating phase, low or no VOC-emission paint shall be used with levels of 50 g/L or less. AQ-2(e) Construction Activity Management Plan. Emissions reduction measures and construction practices required to comply with Mitigation Measures AQ-2(a) through AQ-2(d) shall be documented in a Construction Activity Management Plan (CAMP) and submitted to SLOAPCD for review and approval at least three months before the start of construction. The CAMP shall include a Dust Control Management Plan, tabulation of on and off-road construction equipment (age, horse-power and miles and/or hours of operation), construction truck trip schedule, construction work-day period, and construction phasing. If implementation of the Standard Mitigation and Best Available Control Technology measures cannot bring the project below the Tier 1 threshold (2.5 tons of NOX+ROG per quarter), off-site mitigation shall be implemented in coordination with SLOAPCD to reduce NOX and ROG emissions to below the Tier 1 threshold. Significance After Mitigation. According to the SLOAPCD CEQA Air Quality Handbook, if estimated construction emissions are expected to exceed either of the SLOAPCD Quarterly Tier 2 thresholds of significance after the standard and BACT measures are factored into the estimation, then an SLOAPCD approved Construction Activity Management Plan (CAMP) and offsite mitigation need to be implemented in order to reduce potential air quality impacts to a San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-18 less than significant level. If construction emissions do not exceed Tier 2 thresholds with implementation of standard and BACT measures, SLOAPCD considers emissions less than significant, even if Tier 1 thresholds continue to be exceeded. Table 4.3-7 shows mitigated construction emissions with implementation of Tier 3 off-road engine compliance and level 2 diesel particulate filters required by Mitigation Measure AQ-2(c), as well as low VOC-emission paint required by Mitigation Measure AQ-2(d). As shown therein, with implementation of Mitigation Measures AQ-2(c) and AQ-2(d) construction emissions would not exceed either of the SLOAPCD Quarterly Tier 2 thresholds of significance. Therefore, implementation of a CAMP and offsite mitigation is not required and impacts would be less than significant with mitigation. Table 4.3-7 Estimated Mitigated Construction Maximum Quarterly Air Pollutant Emissions (tons/quarter)a Construction Year Maximum Quarter Per Year (tons/quarter) ROG + NOX DPM Dust 2017 1.9 0.04 0.1 2018 3.9 0.08 0.2 2019 3.0 0.07 0.3 2020 2.4 0.06 0.2 2021 2.1 0.07 0.2 Maximum tons/quarter 3.9 0.08 0.3 SLOAPCD Quarterly Tier 1 Thresholds (tons/quarter) 2.5 0.13 2.5 Threshold Exceeded? Yes No No SLOAPCD Quarterly Tier 2 Thresholds (tons/quarter) 6.3 0.32 2.5 Threshold Exceeded? No No No Notes: All calculations were made using CalEEMod. See Appendix D for model results. DPM equal to combined exhaust PM10 and PM2.5 and dust equal to fugitive PM10 from CalEEMod. 1 Maximum daily emissions include on-site and off-site emissions. 2 CalEEMod calculates quarterly emissions of ROG+NOX, but does not generate quarterly emissions for DPM and dust; therefore, maximum annual construction emissions of DPM and dust were divided by the number of quarters undergoing construction in a year to estimate maximum quarterly emissions. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-19 Threshold 2: Would the project violate any air quality standard or contribute substantially to an existing or projected air quality violation? Threshold 3: Would project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative guidelines for ozone precursors)? Impact AQ-3 Operation of the project would generate air pollutant emissions on an ongoing daily and annual basis. The project’s daily emissions would exceed SLOAPCD daily emissions thresholds, but would not exceed annual thresholds. Implementation of SLOAPCD’s standard mitigation measures and off-site mitigation would reduce emissions to a less than significant level. Impacts would be Class II, less than significant with mitigation incorporated. Operation of the project would result in ongoing emissions associated with vehicle trips, natural gas use, and area sources, such as landscaping, consumption of consumer products, and off- gassing from architectural coatings. Daily and annual operational emissions associated with the proposed project are shown in Table 4.3-8 and Table 4.3-9 (see Appendix D for complete CalEEMod results), and compared to the applicable SLOAPCD operational emissions thresholds. Table 4.3-8 Estimated Operational Daily Air Pollutant Emissions a Source Emissions (lbs/day) ROG + NOX DPM Dust CO Total Daily Emissions 115.9 2.49 30.9 188.6 SLOAPCD Daily Thresholds 25 1.25 25 550 Threshold Exceeded? Yes Yes Yes No Notes: All calculations were made using CalEEMod. See Appendix D for calculations. DPM equal to combined exhaust PM10 and PM2.5 from CalEEMod. Dust equal to fugitive PM10 from CalEEMod. a Maximum emissions include on-site and off-site emissions. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-20 Table 4.3-9 Estimated Operational Annual Air Pollutant Emissions a Source Emissions (tons/year) ROG + NOX Dust Total Emissions 19.9 4.9 SLOAPCD Annual Thresholds 25 25 Threshold Exceeded? No No Notes: All calculations were made using CalEEMod. See Appendix D for calculations. DPM equal to combined exhaust PM10 and PM2.5 from CalEEMod. Dust equal to fugitive PM10 from CalEEMod. a Maximum emissions include on-site and off-site emissions. As shown in Table 4.3-8, the project’s operational emissions would exceed SLOAPCD’s daily operational emissions thresholds. However, as shown in Table 4.3-9, the operational emissions would not exceed SLOAPCD’s annual operational emissions thresholds. Mitigative Components of the Specific Plan and Impact Conclusion. The Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing intended to balance jobs and housing. The project also emphasizes bikeways and pedestrian connections, all of which contribute to reduced VMT and air pollutant emissions. However, as shown in Table 4.3-8, buildout of the Specific Plan would result in daily ROG and NOX emissions above SLOAPCD’s daily operational thresholds. The Specific Plan’s consistency with SLOACPD’s standard operational mitigation measures is described in Table 4.3-10. As shown in Table 4.3-10, the Specific Plan includes mitigative components that would reduce operational emissions. However, according to SLOAPCD’s CEQA Air Quality Handbook, if a project generates 50 pounds per day or more of combined ROG and NOX, then the project should be required to implement all feasible operational mitigation measures listed in the CEQA Air Quality Handbook. As the Specific Plan would not implement all applicable measures identified in Table 4.3-10, impacts from operational emissions would be potentially significant and mitigation is required. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-21 Table 4.3-10 Applicable Mitigation Measures from SLOAPCD CEQA Air Quality Handbook # Measure Type Mitigation Measure Pollutant Reduced1 Specific Plan Consistency 1 Site design, Transportation Improve job/housing balance opportunities within communities. Ozone, Particulate, Greenhouse Gases Consistent The project includes 34 units of affordable housing. The proposed project is a mixed use development that would locate housing near existing and proposed job opportunities. 2 Site design Orient buildings toward streets with automobile parking in the rear to promote a pedestrian-friendly environment. Ozone, Particulate, Greenhouse Gases Consistent As described in Chapter 3 of the Specific Plan, garage entries, carports, and parking areas would be internalized in building groups or oriented away from street frontages. 3 Site design Provide a pedestrian-friendly and interconnected streetscape to make walking more convenient, comfortable and safe (including appropriate signalization and signage). Ozone, Particulate, Greenhouse Gases Consistent The project would establish links in the City’s Bicycle Transportation Plan. The project would construct a segment of the Bob Jones Bike Trail and provide a connection from Laguna Lake area neighborhoods and businesses along Madonna Road to the southern portion of the City Limit at Froom Ranch Way. 4 Site design Provide good access to/from the development for pedestrians, bicyclists, and transit users. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measure #3. In addition, the project would create interior bicycle trails and lanes, including a Class I Bike Trail and Class II Bike lanes. These facilities are consistent with the goals established by San Luis Obispo’s 2013 Bicycle Transportation Plan. The project also includes a transit stop. 5 Site design Incorporate outdoor electrical outlets to encourage the use of electric appliances and tools. Ozone, Particulate, Greenhouse Gases Consistent These are provided per City code and are optional on all houses. 6 Site design Provide shade tree planting in parking lots to reduce evaporative emissions from parked vehicles. Design should provide 50% tree coverage within 10 years of construction using low ROG emitting, low maintenance native drought resistant trees. Ozone, Particulate, Greenhouse Gases Consistent Per City requirement for tree planting in parking lots. 7 Site design Pave and maintain the roads and parking areas Particulate Consistent Roads and parking areas would be paved and on-going maintenance would be required. 8 Site design Driveway design standards (e.g., speed bumps, curved driveway) for self-enforcing of reduced speed limits for unpaved driveways. Particulate Consistent City has a requirement that the design speeds in local and collector roads not exceed 25 mph. Additionally, there are no unpaved roads or driveways proposed in the Specific Plan Area. 9 Site design Use of an SLOAPCD-approved suppressant on private unpaved roads leading to the site, unpaved driveways and parking areas; applied at a rate and frequency that ensures Particulate Consistent There are no unpaved roads, private or otherwise proposed in the Specific Plan Area. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-22 Table 4.3-10 Applicable Mitigation Measures from SLOAPCD CEQA Air Quality Handbook # Measure Type Mitigation Measure Pollutant Reduced1 Specific Plan Consistency compliance with SLOAPCD Rule 401, visible emissions and ensures offsite nuisance impacts do not occur. 10 Site design Development is within 1/4 mile of transit centers and transit corridors. Ozone, Particulate, Greenhouse Gases Consistent The project includes a transit stop in the Specific Plan Area. 11 Site design Design and build compact communities in the urban core to prevent sprawl. Ozone, Particulate, Greenhouse Gases Consistent The project is infill development near existing residential and commercial uses. The proposed compact, mixed use development would utilize the surrounding developed areas, streets, and bike path to connect to the existing urban pattern. 12 Site design Increase density within the urban core and urban reserve lines. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measure #11. 13 Site design No residential wood burning appliances. Ozone, Particulate, Greenhouse Gases Inconsistent Although the project does not specifically propose wood burning appliances, the Specific Plan does not include provisions restricting the installation of wood burning devices in proposed development. 14 Site design; transportation Incorporate traffic calming modifications to project roads, such as narrower streets, speed platforms, bulb-outs and intersection designs that reduce vehicles speeds and encourage pedestrian and bicycle travel. Ozone, Particulate, Greenhouse Gases Consistent City has a requirement that the design speeds in local and collector roads not exceed 25 mph. The project includes a range of traffic control strategies, including narrow drive lanes, speed and warning signs, turn restriction signs, roundabouts, and speed humps. 15 Site design; transportation Increase number of connected bicycle routes/lanes in the vicinity of the project. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measures #3 and #4. 16 Site design; transportation Provide easements or land dedications and construct bikeways and pedestrian walkways. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measures #3 and #4. 17 Site design; transportation Link cul-de-sacs and dead-end streets to encourage pedestrian and bicycle travel to adjacent land uses. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measures #3 and #4. 18 Site design; transportation Project is located within one-half mile of a ‘Park and Ride’ lot or project installs a ‘Park and Ride’ lot with bike lockers in a location of need defined by SLOCOG. Ozone, Particulate, Greenhouse Gases InconsistentConsistent The project is not within one-half mile of a Park and Ride lot, but the project would include a Transit Center with parking for commuters and bike lockersnor would it include development of a Park and Ride lot with bike lockers. 19 Site design Tract maps resulting in parcels of one-half acre or less shall orient at least 75% of all lot lines to create easy due south orientation of future structures. Greenhouse Gases Consistent Most proposed streets run east-west, which provide future structures with solar access. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-23 Table 4.3-10 Applicable Mitigation Measures from SLOAPCD CEQA Air Quality Handbook # Measure Type Mitigation Measure Pollutant Reduced1 Specific Plan Consistency 20 Site design Trusses for south-facing portions of roofs shall be designed to handle dead weight loads of standard solar-heated water and photovoltaic panels. Roof design shall include sufficient south facing roof surface, based on structures size and use, to accommodate adequate solar panels. For south facing roof pitches, the closest standard roof pitch to the ideal average solar exposure shall be used. Ozone, Greenhouse Gases Inconsistent The Specific Plan does not include standards requiring roof trusses for solar panels or solar-heated water. 21 Energy efficiency Increase the building energy rating by 20% above Title 24 requirements. Measures used to reach the 20% rating cannot be double counted. Ozone, Greenhouse Gases Inconsistent Although the Specific Plan includes the goal of “Meeting or Exceeding Title 24 Standards,” the Specific Plan does not include standards requiring building development to exceed Title 24 requirements by 20 percent. 22 Energy efficiency Plant drought tolerant, native shade trees along southern exposures of buildings to reduce energy used to cool buildings in summer. Ozone, Greenhouse Gases Consistent As described in Chapter 7 of the Specific Plan, water conservation measures require all landscaped areas to include drought-tolerant landscape to the maximum extent possible. 23 Energy efficiency Utilize green building materials (materials which are resource efficient, recycled, and sustainable) available locally if possible. Ozone, Diesel Particulate Matter, Greenhouse Gases Consistent Per Specific Plan Program 7.2.1, the Specific Plan would maximize use of building materials that are locally resourced, require minimal mineral extraction and production, and area easily salvaged and recycled. 24 Energy efficiency Install high efficiency heating and cooling systems. Ozone, Greenhouse Gases Consistent As described in Chapter 5 of the Specific Plan, the project would install energy efficient HVAC systems.. 25 Energy efficiency Orient 75% or more of homes and/or buildings to be aligned north/south to reduce energy used to cool buildings in summer. Ozone, Greenhouse Gases Consistent See consistency discussion for Measure #19. 26 Energy efficiency Design building to include roof overhangs that are sufficient to block the high summer sun, but not the lower winter sun, from penetrating south facing windows (passive solar design). Ozone, Greenhouse Gases Inconsistent The Specific Plan does not include development standards that require passive solar design. 27 Energy efficiency Utilize high efficiency gas or solar water heaters. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include standards requiring installation of high efficiency gas or solar water heaters. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-24 Table 4.3-10 Applicable Mitigation Measures from SLOAPCD CEQA Air Quality Handbook # Measure Type Mitigation Measure Pollutant Reduced1 Specific Plan Consistency 28 Energy efficiency Utilize built-in energy efficient appliances (i.e. Energy Star®). Ozone, Particulate, Greenhouse Gases Consistent The Specific Plan would require installation of energy efficient appliances. 29 Energy efficiency Utilize double-paned windows. Ozone, Particulate, Greenhouse Gases Consistent City standard. 30 Energy efficiency Utilize low energy street lights (i.e. sodium). Ozone, Particulate, Greenhouse Gases Consistent City uses LED street lights. 31 Energy efficiency Utilize energy efficient interior lighting. Ozone, Particulate, Greenhouse Gases Consistent This measure is required by CalGreen; therefore, the Project would include energy efficient interior lighting. 32 Energy efficiency Utilize low energy traffic signals (i.e. light emitting diode). Ozone, Particulate, Greenhouse Gases Consistent The project does not include traffic signals onsite. Nonetheless, the City uses LED traffic lights. 33 Energy efficiency Install door sweeps and weather stripping (if more efficient doors and windows are not available). Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include development standards requiring the installation of door sweeps or weather stripping. 34 Energy efficiency Install energy-reducing programmable thermostats. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include development standards requiring the installation of energy-reducing programmable thermostats. 35 Energy efficiency Participate in and implement available energy-efficient rebate programs including air conditioning, gas heating, refrigeration, and lighting programs. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include development standards requiring participating in energy-efficient rebate programs. 36 Energy efficiency Use roofing material with a solar reflectance values meeting the EPA/DOE Energy Star® rating to reduce summer cooling needs. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include development standards requiring the use of roofing materials with solar reflectance to reduce summer cooling needs. 37 Energy efficiency Utilize onsite renewable energy systems (e.g., solar, wind, geothermal, low-impact hydro, biomass and bio-gas). Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include onsite renewable energy systems. 38 Energy efficiency Eliminate high water consumption landscape (e.g., plants and lawns) in residential design. Use native plants that do not require watering and are low ROG emitting. Ozone, Greenhouse Gases Consistent See consistency discussion for Measure #22. 39 Energy efficiency Provide and require the use of battery powered or electric landscape maintenance equipment for new development. Ozone, Greenhouse Gases Inconsistent The Specific Plan does not include standards requiring use of battery powered or electric landscape maintenance equipment. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-25 Table 4.3-10 Applicable Mitigation Measures from SLOAPCD CEQA Air Quality Handbook # Measure Type Mitigation Measure Pollutant Reduced1 Specific Plan Consistency 40 Transportation Develop recreational facility (e.g., parks, gym, pool, etc.) within one-quarter of a mile from site. Ozone, Particulate, Greenhouse Gases Consistent Parks are provided within walking distance of each residence. 41 Transportation If the project is located on an established transit route, provide improved public transit amenities (i.e., covered transit turnouts, direct pedestrian access, covered bench, smart signage, route information displays, lighting etc.). Ozone, Particulate, Greenhouse Gases Consistent The project includes a transit stop in the Specific Plan Area. 42 Transportation Project provides a display case or kiosk displaying transportation information in a prominent area accessible to employees or residents. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include the provision of transportation information in a display case. 43 Transportation Provide electrical charging station for electric vehicles. Ozone, Particulate, Greenhouse Gases Consistent As described in Chapter 5 of the Specific Plan, electrical vehicle charging stations would be provided at some parking spaces within the Specific Plan Area. Spaces would be prioritized for electrical vehicles. 44 Transportation Provide neighborhood electric vehicles / car share program for the development. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include a neighborhood electric vehicle/car share program. 45 Transportation Provide bicycle-share program for development. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include a bicycle share program. 46 Transportation Provide preferential parking / no parking fee for alternative fueled vehicles or vanpools. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measure #43. 47 Transportation Provide bicycle lockers for existing ‘Park and Ride’ lots where absent or insufficient. Ozone, Particulate, Greenhouse Gases InconsistentConsistent See consistency discussion for Measure #18. 48 Transportation Provide vanpool, shuttle, mini bus service (alternative fueled preferred). Ozone, Particulate, Diesel Particulate Matter, Greenhouse Gases Inconsistent The Specific Plan does not provide for vanpool, shuttle, or minibus service. 49 Transportation Provide storage space in garage for bicycle and bicycle trailers, or covered racks / lockers to service the residential units. Ozone, Particulate, Greenhouse Gases Consistent The Specific Plan includes garages for residential areas where bicycles or bicycle trailers could be stored. The Specific Plan also includes bicycle racks. 50 Transportation Provide free-access telework terminals and/or wi-fi access in multi-family projects. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not provide free-access telework terminals or wi-fi access in multi-family projects. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-26 Mitigation Measures. Implementation of the following mitigation measures would be required to reduce operational emissions. All feasible on-site mitigation (Mitigation Measure AQ-3(a) shall be implemented prior to implementation of off-site mitigation (Mitigation Measure AQ-3[b]). AQ-3(a) Standard Operational Mitigation Measures. Prior to issuance of grading permits, the applicant shall define and incorporate into the San Luis Ranch Specific Plan standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook to reduce emissions to below daily threshold levels. Emission reduction measures mayshall include, but would not be limited to: • Prohibit residential wood burning appliances; • Install a ‘Park and Ride’ lot with bike lockers in a location of need defined by SLOCOG; • Trusses for south-facing portions of roofs shall be designed to handle dead weight loads of standard solar-heated water and photovoltaic panels. Roof design shall include sufficient south facing roof surface, based on structures size and use, to accommodate adequate solar panels. For south facing roof pitches, the closest standard roof pitch to the ideal average solar exposure shall be used; • Increase the building energy rating by 20 percent above 2013 Title 24 requirements (used in the California Emissions Estimator Model) or consistent with 2016 Title 24 requirements, whichever is stricter. Measures used to reach the 20 percent rating cannot be double counted; • Design building to include roof overhangs that are sufficient to block the high summer sun, but not the lower winter sun, from penetrating south facing windows (passive solar design); • Utilize high efficiency gas or solar water heaters; • Install door sweeps and weather stripping (if more efficient doors and windows are not available); • Install energy-reducing programmable thermostats; • Participate in and implement available energy-efficient rebate programs including air conditioning, gas heating, refrigeration, and lighting programs; • Use roofing material with a solar reflectance values meeting the U.S. EPA/DOE Energy Star® rating to reduce summer cooling needs. • Utilize onsite renewable energy systems (e.g., solar, wind, geothermal, low-impact hydro, biomass and bio-gas); and • Provide and require the use of battery powered or electric landscape maintenance equipment for new development; • Provide a display case or kiosk displaying transportation information in a prominent area accessible to employees or residents; • Provide neighborhood electric vehicles/ car share program; • Provide bicycle-share program;. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-27 • Provide bicycle lockers for ‘Park and Ride’ lots; • Provide vanpool, shuttle, mini bus service (alternative fueled preferred); • Provide free-access telework terminals and/or wi-fi access in multi- family projects. In addition, the proposed hotel component of the Specific Plan shall participate in the SLO Car Free Program, provide incentives to car-free travelers, and promote the program in their communication tools. Plan Requirements and Timing. Future development shall incorporate the listed provisions into development plans and submit proof that emissions have been reduced to below daily threshold levels through a combination of these measures and off-site mitigation (described in Mitigation Measure AQ- 3[b]) prior to issuance of grading permits. Monitoring. The Commercial Community Development Department shall verify compliance prior to issuance of grading permits. The Commercial Community Development Department shall site inspect to ensure development is in accordance with approved plans prior to occupancy clearance. Commercial Community Development staff shall verify installation in accordance with approved building plans. AQ-3(b) Off-Site Mitigation. If implementation of standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook described in Mitigation Measure AQ-3(a) is insufficient to reduce emissions to below daily threshold levels, then the applicant shall coordinate with SLOAPCD to provide funding for off-site emission reduction measures to reduce emissions to below daily threshold levels. In accordance with SLOAPCD methodology, the excess emissions shall be multiplied by the cost effectiveness of mitigation as defined in the State’s current Carl Moyer Incentive Program Guidelines to determine the annual off-site mitigation amount. This amount shall then be extrapolated over the life of the project to determine total off-site mitigation. Off-site emission reduction measures may include, but would not be limited to: • Developing or improving park-and-ride lots; • Retrofitting existing homes in the project area with SLOAPCD- approved wood combustion devices; • Retrofitting existing homes in the project area with energy-efficient devices; • Constructing satellite worksites; • Funding a program to buy and scrap older, higher emission passenger and heavy-duty vehicles; • Replacing/re-powering transit buses; San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-28 • Replacing/re-powering heavy-duty diesel school vehicles (i.e. bus, passenger or maintenance vehicles); • Funding an electric lawn and garden equipment exchange program; • Retrofitting or re-powering heavy-duty construction equipment, or on-road vehicles; • Re-powering marine vessels; • Re-powering or contributing to funding clean diesel locomotive main or auxiliary engines; • Installing bicycle racks on transit buses; • Purchasing particulate filters or oxidation catalysts for local school buses, transit buses or construction fleets; • Installing or contributing to funding alternative fueling infrastructure (i.e. fueling stations for CNG, LPG, conductive and inductive electric vehicle charging, etc.); • Funding expansion of existing transit services; • Funding public transit bus shelters; • Subsidizing vanpool programs; • Subsidizing transportation alternative incentive programs; • Contributing to funding of new bike lanes; • Installing bicycle storage facilities; and • Providing assistance in the implementation of projects that are identified in City or County Bicycle Master Plans. Plan Requirements and Timing. The applicant shall coordinate with SLOAPCD to provide funding for off-site emissions reduction measures prior to issuance of grading permits. The project applicant or developers of individual projects within the Specific Plan Area shall submit proof that emissions have been reduced to below daily threshold levels to the Commercial Community Development Department. Monitoring. The Commercial Community Development Department shall verify compliance prior to issuance of grading permits. Significance After Mitigation. Implementation of the measures identified in Mitigation Measure AQ-3(a) and AQ-3(b) would reduce impacts to regional air quality. For informational purposes, Table 4.3-11 and Table 4.3-12 show anticipated project emissions with incorporation of measures achieving a 20 percent exceedance of Title 24 requirements and a prohibition on residential wood burning devices, which are quantifiable in CalEEMod. As shown in Table 4.3- 11 and Table 4.3-12, implementation of these measures alone would not reduce daily operational emissions of ROG, NOX, DPM, or dust to below SLOAPCD’s daily significance thresholds. However, with implementation of Mitigation Measures AQ-3(a), Standard Operational Mitigation Measures, and AQ-3(b), Off-Site Mitigation, annual emissions would be reduced below SLOAPCD’s annual operational thresholds. Therefore, long-term operational impacts would be less than significant. San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-29 Table 4.3-11 Estimated Mitigated Operational Daily Air Pollutant Emissions a Source Emissions (lbs/day) ROG + NOX DPM Dust CO Total Daily Emissions 114.4 2.31 30.9 187.7 SLOAPCD Daily Thresholds 25 1.25 25 550 Threshold Exceeded? Yes Yes Yes No Notes: All calculations were made using CalEEMod. See Appendix D for calculations. DPM equal to combined exhaust PM10 and PM2.5 from CalEEMod. Dust equal to fugitive PM10 from CalEEMod. a Maximum emissions include on-site and off-site emissions. Table 4.3-12 Estimated Mitigated Operational Annual Air Pollutant Emissions a Source Emissions (tons/year) ROG + NOX Dust Total Emissions 19.6 4.9 SLOAPCD Annual Thresholds 25 25 Threshold Exceeded? No No Notes: All calculations were made using CalEEMod. See Appendix D for calculations. DPM equal to combined exhaust PM10 and PM2.5 from CalEEMod. Dust equal to fugitive PM10 from CalEEMod. a Maximum emissions include on-site and off-site emissions. Threshold 4: Would the project expose sensitive receptors to substantial pollutant concentrations? Impact AQ-4 The project would not expose sensitive receptors to substantial pollutant concentrations. This impact would be Class III, less than significant. The primary sources of toxic air contaminant emissions in urbanized and suburban areas include vehicle trips on area roadways and industrial uses. There are no major industrial uses near the project site, and the project does not include any industrial uses. Vehicle exhaust emissions include diesel exhaust from heavy duty trucks, which is considered a toxic air contaminant. Future land uses within the immediate vicinity of U.S. 101 would be exposed to the highest concentrations of localized vehicle exhaust emissions. ARB currently recommends that local agencies avoid siting new sensitive land uses within 500 feet of freeways or urban roads with 100,000 vehicles per day (ARB, Air Quality and Land Use Handbook, April 2005). As shown in Figure 2-6, Project Site Plan, proposed new residences on the project site would be located over 500 feet from U.S. Highway 101. In addition, based on traffic volumes from the Caltrans Traffic Data Branch (Caltrans, 2015), annual average daily traffic along U.S. Highway San Luis Ranch Project EIR Section 4.3 Air Quality City of San Luis Obispo 4.3-30 101 next to the project site is approximately 61,100 vehicles per day, less than the 100,000 vehicles per day threshold recommended by ARB for urban roadways (ARB 2005). Therefore, potential impacts from exposure of sensitive receptors to substantial pollutant concentrations would be less than significant. Naturally occurring asbestos (NOA) has been identified by the State Air Resources Board as a toxic air contaminant. Serpentine and ultramafic rocks are common in San Luis Obispo County and may contain naturally occurring asbestos. According to the SLOAPCD NOA Map for San Luis Obispo County, the project site is located in an area that is known to contain naturally occurring asbestos (SLOAPCD 2016). The project would result in excavation and grading and therefore may encounter naturally occurring asbestos. Under ARB’s Air Toxics Control Measure (NOA ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations, prior to any grading activities at a site within the green “buffer” areas on SLOAPCD’s NOA map, the Owner or Operator would be required to comply with the NOA ATCM. The NOA ATCM requires submittal of a geologic evaluation determining whether serpentine rock is present on a project site, and if so, to what extent (less or more than one acre). Depending on the results of the geologic evaluation, a project would be required to file an exemption request form (if on serpentine is present), a Mini Dust Control Measure Plan (if less than one acre of serpentine is present), or an Asbestos Dust Control Measure Plan (if more than one acre of serpentine is present). A Soil Engineering Report prepared for the project by GeoSolutions, Inc. in 2015 (Appendix E) indicates that the nearest serpentine formation is located approximately 1,000 feet northeast of the project site (see Figure 4 of the Soil Engineering Report, Appendix E). Furthermore, only clay soils were found in the soil borings taken on the project site. The project would be required to submit a geologic evaluation and exemption request to SLOAPCD for approval. Therefore, with compliance to ARB’s NOA ATCM, impacts associated with naturally occurring asbestos would be less than significant. Mitigation Measures. No mitigation measures would be required. Significance After Mitigation. The project’s potential to expose sensitive receptors to substantial pollutant concentrations is less than significant. c. Cumulative Impacts. A project that does not exceed applicable SLOAPCD thresholds and is consistent with the 2001 CAP would have a less than significant cumulative impact on the airshed. Conversely, a project that exceeds applicable SLOAPCD significance thresholds or is found to be inconsistent with the CAP would result in significant cumulative impacts. As discussed under Impacts AQ-1 through and AQ-3(b), the project is inconsistent with the 2001 CAP and would exceed SLOAPCD construction and operational thresholds. As such, cumulative impacts on air quality would be Class I, significant and unavoidable. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-1 4.4 BIOLOGICAL RESOURCES 4.4.1 Setting The analysis of biological resources within the 131-acre San Luis Ranch Specific Plan Area is based on a search of available biological databases, review of aerial photographs and topographic maps, review of multiple literature resources, and site visits. Wildlife and botanical surveys were conducted on the project site in April, May, and June 2014 by Althouse and Meade, Inc. Additional site visits were conducted by Rincon Consultants, Inc. (Rincon) in April and May 2016. Discussion of existing conditions on the project site is based on peer reviews of the Biological Constraints Report, California Red-legged Frog Protocol Survey Site Assessment, and Delineation of Potential Jurisdictional Wetlands and Waters, San Luis Ranch Monarch Trees Inspection Memo, Results of 2015 and 2016 San Luis Ranch Heron Rookery Surveys Memo, and San Luis Ranch – Prefumo Creek Widening Biological Constraints Memo prepared by Althouse and Meade (refer to Appendix F). A biological resource investigation was conducted by Rincon in April and May 2016 to confirm the accuracy of the applicant studies and to supplement the applicant-provided findings with an independent evaluation of biological resources. a. Regional Setting. The project site is located in unincorporated San Luis Obispo County, California, completely surrounded by the corporate boundary of San Luis Obispo. The project site is generally bounded by residential uses and Madonna Road to the west, commercial uses and Dalidio Drive to the north, U.S. 101 to the east and the San Luis Obispo City Farm to the south (see Figure 2-1 in Section 2.0, Project Description). The project site is within the South Coast Ranges (SCoR) geographic subregion of California. The SCoR subregion is a component of the larger Central Western California Region, which occurs within the even larger California Floristic Province (Baldwin et al., 2012). Floristic provinces within California are typically dictated by climate, and have distinctive flora. b. Project Site Setting. The project site is located in unincorporated San Luis Obispo County and is generally bounded by Madonna Road to the west, Dalidio Drive to the north, United States Highway 101 (U.S. 101) to the east and the San Luis Obispo City Farm to the south. Although the project site is generally surrounded by urban and active agricultural uses, the Laguna Lake open space is located northwest of the site, and the Prefumo Creek corridor is located along the western edge of the site. Prefumo Creek flows out of Laguna Lake, under Madonna Road, along the western edge of the property, and drains into San Luis Obispo Creek approximately half a mile to the south. In addition, a shallow ephemeral drainage named Cerro San Luis Channel runs southwest across the property into Prefumo Creek. The approximate center of the project site occurs at latitude 35°15’23”N and longitude 120°40’46”W (WGS-84 datum). The project site occurs within the San Luis Obispo, California United States Geological Survey (USGS) 7.5-minute topographic quadrangle in Meridian Mt. Diablo, Township 31S, Range 12E and Section 03. The project site boundary encompasses roughly 131 acres (refer to Figure 2-2 in Section 2.0, Project Description). In addition to the proposed on-site project components outlined in Section 2.0, Project Description, the project includes an off-site connection of Froom Ranch Way across Prefumo Creek. These components collectively comprise the potential disturbance area for the project. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-2 Approximately 109 acres of the 131-acre site support continuously planted and plowed farmland. The remainder of the site consists primarily of blue gum eucalyptus (Eucalyptus globulus) groves; developed residences, barns, and outbuildings; non-native annual grassland; disturbed ruderal habitat; and riparian vegetation associated with Cerro San Luis Channel and Prefumo Creek. The topography of the project site is generally flat with onsite elevations ranging from approximately 120 to 140 feet above mean sea level. Habitat Types. Six terrestrial vegetation communities or land cover types occur within the project site: Agriculture, Eucalyptus Grove, Ruderal/Developed, Willow-Riparian, Riverine, and Non-native Annual Grassland. Vegetation was classified and mapped during botanical resources surveys conducted in May 2014 by Althouse and Meade to characterize the site. Vegetation classification and mapping was field-verified by Rincon in April and May 2016, and is discussed in more detail below. A summary of vegetation/land cover types identified in the project site is presented in Table 4.4-1 and Figure 4.4-1 provides a map of these features. Habitat characterizations were based on the classification systems presented in A Manual of California Vegetation, Second Edition (MCV2; Sawyer et al., 2009) and Preliminary Description of Terrestrial Natural Communities of California (Holland, 1986); but have been modified slightly to most accurately reflect the existing site conditions. California Vegetation (Holland and Keil, 1995) and California Wildlife Habitat Relationships (CWHR) were also referenced for describing the habitat types within the project site. Plant species nomenclature and taxonomy used for the project site follow treatments within Baldwin et al. (2012). Table 4.4-1 Summary of Vegetation/Land Cover Types within the Project Site Habitat Type Approximate Acreage Approximate Percentage of Total Area Agriculture 111.5 84.9% Eucalyptus Grove 10.1 7.7% Ruderal/Developed 7.0 5.3% Willow Riparian 0.5 0.4% Riverine 0.1 0.1% Non-native Annual Grassland 2.1 1.6% TOTAL 131.3 100% Agriculture. Agricultural is the predominant habitat type within the project site, covering approximately 111.7 acres. Agriculture is an anthropogenic, frequently disturbed habitat and includes irrigated row crops that are usually monotypic. This habitat type occurs within and adjacent to the project site. The 20-acre San Luis Obispo City Farm is adjacent to the project site on the south, creating a contiguous 151-acre agricultural area. During the site visit, lettuce (Lactuca sativa) and cruciferous vegetables, such as broccoli (Brassica oleracea), were in production. Regular cultivation and other agricultural practices generally eliminate habitat for burrowing animals such as small mammals, and many amphibian and reptile species that utilize small mammal burrows or construct their own burrows. Given that this community type is not naturally occurring, it is not described in either the Holland (1986) or Sawyer et al. (2009) classification systems. £¤101 L o s O s o s V a ll e y Rd£¤101 Madonna Rd Dal i d i o Dr AutoPark WayEl M e r c a d o Vegetation Communities and Jurisdictional Features Figure 4.4-1 City of San Luis Obispo Imagery provided by Google and its licensors © 2016. San Luis Ranch Project EIR Project Site Potential Jurisdictional Features CWA Sec 404 Federal Wetland(0.14acres) CWA Sec 404 Other Waters ofthe US(0.69acres) CWA Sec 401 (RWQCB), andCDFG Code 1600 (2.17acres) Vegetation Community Agriculture Eucalyptus grove Non-native annual grassland Red willow thicket Riverine Ruderal/Developed Willow riparian±0 500250 Feet Inset MapPrefumoCreekSection 4.4 Biological Resources CerroSanLuisChannelInset Map Inset MapExtent 4.4-3 San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-4 Eucalyptus Grove. Blue gum eucalyptus groves cover approximately 10.2 acres of the project site. The trees range in size from sapling to mature trees 80 to 100 feet tall. The understory beneath the eucalyptus grove southwest of the U.S. Post Office consists primarily of non-native grasses, goose grass (Galium aparine) and periwinkle (Vinca major). Southwest of the farm buildings and east of Prefumo Creek there is an approximately six-acre blue gum eucalyptus grove, which has an understory of non-native grasses and non-native ruderal forbs. On the western edge of this eucalyptus grove, near Prefumo Creek, the understory also consists of native shrubs including toyon (Heteromeles arbutifolia), coast live oak (Quercus agrifolia), and coffeeberry (Frangula californica). In other places, there is little understory due to the build-up of fallen eucalyptus leaves and woody debris. The eucalyptus grove provides nesting habitat for raptors, great blue herons, and a variety of songbirds, and roosting habitat for owls and turkey vultures. It also provides foraging habitat for birds and small mammals. The largest eucalyptus grove in the project site is a historic monarch butterfly overwintering site. The overall health of the eucalyptus trees onsite is degraded, likely due to several years of drought conditions and overall age of the stands. Eucalyptus Grove habitat type within the project site is not described by Holland (1986) but most closely corresponds with the Eucalyptus groves Semi-Natural Woodland Stands (Eucalyptus [globulus, camaldulensis] Semi-Natural Stands) described in MCV2 (Sawyer et al., 2009). Ruderal/Developed. Anthropogenic manipulated and maintained ruderal and developed habitat covers approximately 7.0 acres of the project site. Vegetation can vary depending on the degree of disturbance or development. This land cover type consists of two houses, three barns, sheds, small outbuildings, parking areas, access areas, and storage areas surrounded by ornamental trees and shrubs in the northwestern portion of the project site. In less developed areas, ruderal species dominate, including slender wild oat (Avena barbata), ripgut brome (Bromus diandrus), Italian thistle (Carduus pycnocephalus) and poison hemlock (Conium maculatum). Cover by plant species is generally low due to disturbance, and there is a high percentage of bare soil. Ruderal areas provide poor habitat for animal species; however, these areas can be used during dispersal and for movement during foraging in adjacent habitats. In addition, the structures have suitable nesting habitat for birds and may house roosting colonies of bats. Ruderal/Developed areas are not classified in the MCV2 classification system (Sawyer et al., 2009) or the Holland classification system (Holland, 1986); however, developed areas but are included in the California Department of Fish and Wildlife (CDFW) CWHR as Urban (Mayer and Laudenslayer, 1988). Red Willow Thicket. Within the project site, red willow thicket occurs on both the eastern and western banks of Prefumo Creek where the Froom Ranch Way bridge crossing is proposed. The upper canopy is dominated by red willow (Salix laevigata) with intermittent arroyo willow (Salix lasiolepis), Fremont cottonwood (Populus fremontii) and non-native trees such as Canary Island date palm (Phoenix canariensis) which have encroached from residential yards on the west side of the creek. The red willow thicket vegetation community surrounding Prefumo Creek may be considered a sensitive habitat community by CDFW because it is a riparian vegetation community that has been known to host sensitive species. The red willow thicket vegetation community within the project area most closely corresponds to element #61210 San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-5 Central Coast Cottonwood-Sycamore Riparian Forest (Holland, 1986) and to Salix laevigata Shrubland Alliance in the Manual of California Vegetation system (Sawyer et al., 2009). Willow Riparian. Willow-dominated riparian scrub and riparian woodlands are present in the eastern portion of Cerro San Luis Channel for a distance of approximately 400 linear feet, from Dalidio Drive to the southwest corner of the U.S. Post Office parking lot. The riparian vegetation in this portion of the drainage is dominated by mature arroyo willow, red ironbark (Eucalyptus sideroxylon), umbrella sedge (Cyperus eragrostis), poison hemlock, and Harding grass (Phalaris aquatica). Willow riparian vegetation units are consistent with Arroyo Willow Thickets Alliance in A Manual of California Vegetation, Second Edition (Sawyer et al., 2009) and Central Coast arroyo willow riparian forest in the Holland classification (Holland, 1986). Riverine. Running alongside the western edge of the property is the Prefumo Creek streambed. The streambed traverses the project site at the proposed Froom Ranch Way bridge crossing location in the southwest corner of the site. The majority of the streambed contains gravel; however, intermittent portions of the streambed also consist of vegetative litter and woody debris. This land cover type was also documented within the Cerro San Luis Channel which runs across the northwest portion of the project site and connects to Prefumo Creek on the western boundary of the site. The bed is vegetated with ruderal and invasive forbs such as periwinkle, bristly ox-tongue (Helminthotheca echioides), red-stem filaree (Erodium cicutarium), and Italian thistle that recruit after the water recedes in the early summer. Patches of wetland species such as tule (Schoenoplectus sp.) are also present. The streambed and surrounding habitat on its banks provides excellent nesting and foraging habitat for nesting birds and a variety of common and special status species. This community type is also not described in either the Holland (1986) or Sawyer et al. (2009) classification systems. However, riverine is described in the Cowardin (1979) and U.S. Fish and Wildlife Service (USFWS) (2015) classification systems. Non-native Annual Grassland. Non-native annual grassland was mapped in the northwest section of the project site where non-native grasses predominate. Vegetation composition is variable and patchy within this community. Slender wild oat, ripgut brome, Harding grass, and foxtail (Hordeum murinum) are dominant in patches; mustards (Brassica nigra; Hirschfeldia incana) are also common. This habitat type is currently of low botanical value, as no native grass species were found during surveys. This area could provide habitat for a variety of small mammals, including pocket gopher (Thomomys sp.) and California ground squirrel (Otospermophilus beecheyi) and therefore could be suitable foraging habitat for raptors. This vegetation type most closely corresponds to non-native grassland type (Element Code #42200) described by Holland (1986) and includes areas that are consistent with two semi- natural herbaceous stands described in the MCV2: Avena (barbata, fatua) semi-natural stands and Bromus (diandrus, hordeaceus)-Brachypodium distachyon semi-natural stands (Sawyer et al., 2009). Natural Drainages and Wetlands. The project site is located within the Central Coastal Watershed (Hydrologic Unit Code [HUC] 18060006) and contains two aquatic features: Prefumo Creek and Cerro San Luis Channel. Prefumo Creek runs just outside the majority of the western boundary of the project site, but does occur within the project site at the proposed Froom Ranch Way bridge crossing and flows north to south. Cerro San Luis Channel runs San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-6 across the northwest portion of the project site and connects to Prefumo Creek on the western boundary of the site. These drainage features are visible on aerial photography. The extents of these drainages within the project site are presented in Figure 4.4-1 and are discussed in greater detail below. Prefumo Creek. Prefumo Creek is a named tributary to San Luis Obispo Creek that conveys water from the Irish Hills and farm fields, to Laguna Lake, and then to a box culvert under Madonna Road and flows along the western edge of the property. Prefumo Creek flows into San Luis Obispo Creek approximately half a mile south of the project site. Prefumo Creek has been managed by adjacent farmers and homeowners with evidence of concrete structures to prevent scour and occasional wooden structures installed by homeowners southwest of the project site. The eastern bank is dominated by blue gum eucalyptus and the western bank is dominated by red willow, with intermittent arroyo willow, Fremont cottonwood and non- native trees. The bed contains gravel; however, intermittent portions also consist of vegetative litter and woody debris. The bed is vegetated with ruderal and invasive forbs such as periwinkle, bristly ox-tongue, red-stem filaree, and Italian thistle. On May 26, 2016 Rincon observed two large pools with standing water in the portion of Prefumo Creek where the Froom Ranch Way bridge crossing is proposed The pools were approximately 35 feet wide, 45 feet long, and 2 to 3 feet deep. Both pools contained a sufficient amount of cover, emergent vegetation, and water depth to support California red-legged frog (Rana draytonii; CRLF) breeding. The California Natural Diversity Database (CNDDB) documents an occurrence of CRLF just north of the confluence of Prefumo Creek and San Luis Obispo Creek approximately one half mile downstream from the project site. In addition, Prefumo Creek is federally designated critical habitat for the south-central California Coast distinct population segment (DPS) steelhead (steelhead; Oncorhyncus mykiss irideus) (Figure 4.4-2). Special status species are discussed in greater detail below. Cerro San Luis Channel. As previously mentioned, the project site contains an ephemeral drainage named Cerro San Luis Channel, which runs southwest across the site into Prefumo Creek. The drainage carries run off from Cerro San Luis Obispo , through shopping centers, to a culvert under Dalidio Road. The drainage feature daylights east of the U.S. Post Office, on the west side of an active farm field. The drainage is actively maintained for adjacent agricultural purposes and is degraded, with chunks of asphalt in the drainage from an old road. The eastern portion of the drainage, which runs along the east side of the U.S. Post Office, is dominated by mature arroyo willow and red ironbark. The western portion of the drainage lacks large shrubs and is dominated by non-native annual grassland and ruderal vegetation. No flowing or pooled water was observed within Cerro San Luis Channel during the site visits. Wetlands. Wetlands occur in nutrient-rich mineral soils that are saturated to the surface throughout part or all of the year. These habitats are best developed in locations with slow- moving or stagnant shallow water such as drainage corridors, seeps or in areas with adequate water sources. These features occur where high water tables and seeps create conditions that support hydrophytic (i.e., water-tolerant) vegetation. Within the project site, wetlands that have been identified by the USFWS National Wetlands Inventory (NWI) include Freshwater Forested/ Shrub Wetland and Riverine along Prefumo Creek. Within the project site, Prefumo Creek and the Cerro San Luis Channel contain riparian and wetland habitats and jurisdictional drainages. All wetlands observed within the project site contain a hydrologic connection to a waterway, no isolated wetlands were observed. 12 49 49 16 17 33 13 3 3135 3534 4718 7 1 42 27 27 27 3050 45 39 4519 21 48 47 54 8 11 45 27 35 45 21 25 45 48 4845 39 8 48 45 17 48 5 21 8 7 48 17 21 34 34 35 13 17 21 24 30 47 2821 8 39 42 3545 42 45 27 25 42 42 21 21 35 43 8 8 38 8 45 24 20 26 34 17 3534 39 8 35 35 2735 44 45 45 42 44 48 17 42 45 27 8 50 17 45 43 42 42 1 42 6 8 44 35 1 44 45 8 8 8 8 8 1 8 8 6 44 35 8 45 42 44 11 8 11 35 45 35 7 35 11 11 17 44 42 3939 34 45 45 34 44 35 45 45 44 39 48 17 35 8 45 42 35 35 45 42 25 44 4445 25 45 45 45 17 17 42 44 45 11 45 17 42 34 17 45 17 7 44 42 17 1 1 42 7 17 7 17 17 7 7 45 48 17 11 11 17 17 44 44 17 40 457 5956 60 32 22 15 51 10 15 23 15 51 52 58 9 10 10 53 10 58 58 32 51 58 55 46 32 3232 10 10 51 58 58 55 37 10 2 2 2 53 10 5110 10 10 58 22 32 51 58 51 14 58 10 58 Sensitive Elements Reported in theCalifornia Natural Diversity Database and FederallyDesignated Critical Habitats Located within 5 miles Figure 4.4-2 City of San Luis Obispo Section 4.4 Biological ResourcesSan Luis Ranch Project EIR Imagery provided by ESRI and its licensors © 2016. Special status species data source: California Natural Diversity Database, May, 2016. Additional suppressed records reported by the CNDDB known to occur or potentially occur within this search radius include: prairie falcon, black legless lizard. For more information please contact the Department of Fish and Game. Critical habitat data source: U.S. Fish and Wildlife Service, January, 2016. Final critical habitat acquired via the USFWS Critical Habitat Portal. It is only a general representation of the data and does not include all designated critical habitat. Contact USFWS for more specific data. Project Location 5-Mile Buffer CNDDB Animals Plants Natural Communities Final Critical Habitat Steelhead California red-legged frog 0 1.80.9 Miles ± 1 - adobe sanicle2 - American badger3 - Arroyo de la Cruz manzanita4 - Atascadero June beetle5 - Betty's dudleya6 - black-flowered figwort7 - Blochman's dudleya8 - Brewer's spineflower9 - California horned lark10 - California red-legged frog11 - Cambria morning-glory12 - Central Maritime Chaparral13 - chaparral ragwort14 - coast horned lizard15 - Coast Range newt16 - Coastal and Valley Freshwater Marsh17 - Congdon's tarplant18 - Cuesta Ridge thistle19 - dune larkspur20 - dwarf soaproot 21 - Eastwood's larkspur22 - ferruginous hawk23 - foothill yellow-legged frog24 - Hoover's bent grass25 - Hoover's button-celery26 - Indian Knob mountainbalm27 - Jones' layia28 - La Panza mariposa-lily29 - loggerhead shrike30 - mesa horkelia31 - Miles' milk-vetch32 - monarch - California overwintering population33 - Morro manzanita34 - most beautiful jewelflower35 - mouse-gray dudleya36 - Ojai fritillary37 - pallid bat38 - Palmer's monardella39 - Pecho manzanita40 - Pismo clarkia 41 - saline clover42 - San Luis mariposa-lily43 - San Luis Obispo County lupine44 - San Luis Obispo fountain thistle45 - San Luis Obispo owl's-clover46 - San Luis Obispo pyrg47 - San Luis Obispo sedge48 - Santa Margarita manzanita49 - Serpentine Bunchgrass50 - southern curly-leaved monardella51 - steelhead - south-central California coast DPS52 - tidewater goby53 - Townsend's big-eared bat54 - umbrella larkspur55 - vernal pool fairy shrimp56 - western bumble bee57 - western mastiff bat58 - western pond turtle59 - western yellow-billed cuckoo60 - white-tailed kite 4.4-7 San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-8 c.Special Status Species and Plant Communities. Several species protected by federal and State agencies occur within San Luis Obispo County. The CNDDB (CDFW, 2015a), California Native Plant Society (CNPS) (2015), and USFWS ECOS (2015b) together list seventy- two (72) special status plants, forty-three (43) special status animals, and nine sensitive plant communities within the San Luis Obispo, California USGS 7.5-minute topographic quadrangle and the surrounding eight quadrangles. For the purpose of this analysis, special status species are those plants and animals listed, proposed for listing, or candidates for listing as threatened or endangered by the USFWS and National Marine Fisheries Service (NMFS) under the federal Endangered Species Act (FESA); those listed or proposed for listing as rare, threatened, or endangered by the CDFW under the California Endangered Species Act (CESA); animals designated as “Species of Special Concern,” “Fully Protected,” or “Watch List” by the CDFW; “Special Animals” designated by the CDFW with potential nesting and/or overwintering habitat on site; and plants with a California Rare Plant Rank (CRPR) of 1, 2, 3, and 4, which are defined as: •List 1A = Plants presumed extinct in California; •List 1B.1 = Rare or endangered in California and elsewhere; seriously endangered in California (over 80% of occurrences threatened/high degree and immediacy of threat); •List 1B.2 = Rare or endangered in California and elsewhere; fairly endangered in California (20- 80% occurrences threatened); •List 1B.3 = Rare or endangered in California and elsewhere, not very endangered in California (<20% of occurrences threatened or no current threats known); •List 2 = Rare, threatened or endangered in California, but more common elsewhere; •List 3 = Plants needing more information (most are species that are taxonomically unresolved; some species on this list meet the definitions of rarity under CRPR and CESA); •List 4.2 = Plants of limited distribution (watch list), fairly endangered in California (20-80% occurrences threatened); and •List 4.3 = Plants of limited distribution (watch list), not very endangered in California (<20% occurrences threatened or no current threats known). Rincon staff determined that the project site contains suitable habitat for sixteen (16) special status animal species, but no special status plant species (Tables 4.4-2 and 4.4-3). In addition, the project site contains designated critical habitat for steelhead within Prefumo Creek. Species marked with an asterisk (*) are special status species added to the list because they were either directly observed onsite or have the potential occur based on our knowledge of the area. The CNDDB occurrences of special status plants, wildlife, sensitive plant communities and federally designated critical habitats within five miles of the project site are illustrated on Figure 4.2-2. The evaluation of potential to occur for each species identified in the records search is presented in Tables 4.4-2 and 4.4-3 and is based on the presence of the habitat types occurring within the project site and each respective species range. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-9 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Agrostis hooveri Hoover’s bent grass Poaceae --/-- 1B.2 Santa Barbara and San Luis Obispo Counties Usually occurs on sandy substrates within closed- cone coniferous forest, chaparral, cismontane woodland, and valley and foothill grassland. Elevations range: 6-610 meters. Blooms April-July No Potential Not detected in project site during bloom period. Oak woodland is not found on site. Arctostaphylos cruzensis Arroyo de la Cruz manzanita Ericaceae --/-- 1B.2 San Luis Obispo County Perennial evergreen shrub. Blooms Dec-Mar. Chaparral. On shale outcrops, on slopes, in chaparral. Elevations 350- 850m. Blooms December- March No Potential Not detected in project site. Appropriate bluff habitat is not found on site. Arctostaphylos luciana Santa Lucia manzanita Ericaceae --/-- 1B.2 San Luis Obispo County Shale substrates within chaparral and cismontane woodland. Elevations range: 350-850 meters. Blooms December- March No Potential Not detected in project site. Appropriate habitat is not found on site. Arctostaphylos morroensis Morro manzanita Ericaceae FT/-- 1B.1 San Luis Obispo County Baywood fine sand substrates within maritime chaparral, cismontane woodland, coastal dunes and coastal scrub. Elevations: 5-205 meters. Blooms December- March No Potential Not detected in project site. Dune habitat is not found on site. Arctostaphylos osoensis Oso manzanita --/-- 1B.2 San Luis Obispo County Perennial evergreen shrub. Blooms Feb-Mar. Occurs within chaparral and cismontane woodland. Elevations: 95-500 meters. No Potential Not detected in project site. Appropriate habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-10 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Arctostaphylos pechoensis Pecho manzanita Ericaceae --/-- 1B.2 Santa Barbara and San Luis Obispo Counties Siliceous shale substrates within closed-cone coniferous forest, chaparral, and coastal scrub. Elevations range: 125-850 meters. Blooms November- March No Potential Not detected in project site. Appropriate habitat is not found on site. Arctostaphylos pilosula Santa Margarita manzanita Ericaceae --/-- 1B.2 Monterey and San Luis Obispo Counties Broadleaf upland forest, closed-cone coniferous forest, chaparral, and cismontane woodland, reported growing on decomposed granite or sandstone. Elevations range: 170-1100 meters. Blooms December-May No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Arctostaphylos rudis sand mesa manzanita --/-- 1B.2 Santa Barbara and San Luis Obispo Counties Perennial evergreen shrub. Sandy, chaparral (maritime), and coastal scrub. Elevation: 25-322 meters Blooms November-February No Potential Not detected in project site. Appropriate sandy soils and habitat are not found on site. Arctostaphylos tomentosa ssp. daciticola Dacite manzanita Ericaceae --/-- 1B.1 San Luis Obispo County Perennial evergreen shrub. Blooms Mar-May. Chaparral, cismontane woodland. Only known from one site in San Luis Obispo County on dacite porphyry buttes. Elevation about 120m. Blooms March -May No Potential Not detected in project site during bloom period. Chaparral is not present on site. Arenaria paludicola marsh sandwort Caryophyllaceae FE/SE 1B.1 Los Angeles, San Bernardino*, Santa Cruz*, San Francisco*, and San Luis Obispo Counties Sandy openings within freshwater marshes and swamps. Elevations range: 3-170 meters. Blooms May- August. No Potential Not detected in project site during bloom period. Appropriate wetland habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-11 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Astragalus didymocarpus var. milesianus Miles’ milk-vetch Fabaceae --/-- 1B.2 Santa Barbara, San Luis Obispo, and Ventura Counties Clay substrates within coastal scrub and native grasslands. Elevations range: 20-90 meters. Blooms March-June No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Atriplex coulteri Coulter’s saltbush Chenopodiaceae --/-- 1B.2 Channel Islands; Southern California Coastal bluff scrub, coastal dunes, coastal scrub, valley and foothill grassland. Ocean bluffs, ridgetops, as well as alkaline low places. Elevations 10-440 m. Blooms March - October No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Bryoria spiralifera Twisted horsehair lichen Parmeliaceae --/-- 1B.1 Del Norte, Humboldt, Monterey, San Luis Obispo, and Sonoma Counties Fruticose lichen (epiphytic). Usually on conifers. North Coast coniferous forest (immediate coast). Elevations 0-30m. No Potential Not detected in project site. Coniferous forest habitat is not found on site. California macrophylla Round-leaved filaree Geraniaceae --/-- 1B.2 Widely distributed in California Annual herb. Cismontane woodland, valley and foothill grassland. Clay soils. Elevations 15-1200 m. Blooms March-May No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Calochortus obispoensis San Luis mariposa-lily Liliaceae --/-- 1B.2 San Luis Obispo County Often on serpentinite substrates within chaparral, coastal scrub, and valley and foothill grassland. Elevations range: 50-730 meters. Blooms May-July No Potential Not detected in project site during bloom period. Appropriate heavy soils are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-12 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Calochortus simulans La Panza mariposa-lily Liliaceae --/-- 1B.3 Santa Barbara and San Luis Obispo Counties Sandy, granitic or serpentine within chaparral, cismontane woodland, lower montane coniferous forest, and valley and foothill grassland. Elevations range: 395-1100 meters. Blooms April-June No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. Calycadenia villosa dwarf calycadenia --/-- 1B.1 Fresno, Monterey, Santa Barbara, and San Luis Obispo Counties Annual herb. Rocky, fine soils. Chaparral, cismontane woodland, meadows and seeps, and valley and foothill grassland. Elevation: 240-1350 meters Blooms May-October No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Camissoniopsis hardhamiae Hardham’s evening- primrose Onagraceae --/-- 1B.2 Monterey and San Luis Obispo Counties Annual herb. Chaparral, cismontane woodland. Decomposed carbonate. Elevations 330-500 meters. Blooms March-May No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. Carex obispoensis San Luis Obispo sedge Cyperaceae --/-- 1B.2 Monterey, San Diego, and San Luis Obispo Counties Often serpentinite seeps and clay soils, occasionally gabbro substrates within closed-cone coniferous forest, chaparral, coastal prairie, coastal scrub, and valley and foothill grassland. Elevations range: 10-820 meters. Blooms April-June No Potential Not detected in project site during bloom period. Appropriate serpentine soils and habitat are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-13 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Castilleja densiflora ssp. obispoensis San Luis Obispo owl’s- clover Orobanchaceae --/-- 1B.2 San Luis Obispo County Occasionally serpentinite substrates; found within meadows and seeps and valley and foothill grassland. Elevations range: 10-400 meters. Blooms March-May No Potential Not detected in project site during bloom period. Appropriate grassland habitat is not found on site. Centromadia parryi ssp. congdonii Congdon’s tarplant Asteraceae --/-- 1B.1 Alameda, Contra Costa, Monterey, Santa Clara, Santa Cruz*, San Luis Obispo, San Mateo, and Solano* Counties Alkaline valley and foothill grassland. Elevations range: 0-230 meters. Blooms May-November No Potential Not detected in project site during bloom period. Appropriate vernal moist soils not found on site. Chenopodium littoreum Coastal goosefoot Chenopodiaceae --/-- 1B.2 Los Angeles, Santa Barbara, and San Luis Obispo Counties Annual herb. Coastal dunes. Elevations 10-30 meters. Blooms April- August No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not sound on site. Chlorogalum pomeridianum var. minus dwarf soaproot Agavaceae --/-- 1B.2 Colusa, Lake, San Luis Obispo, Sonoma, and Tehama Counties Serpentinite substrates within chaparral. Elevations range: 305-1000 meters. Blooms from May to August No Potential Not detected in project site during bloom period. Appropriate serpentine soils and chaparral habitat are not found on site. Chloropyron maritimum ssp. maritimum Salt marsh bird’s-beak Orobanchaceae FE/SE 1B.2 Los Angeles, Orange, Santa Barbara, San Bernardino, San Diego, San Luis Obispo, and Ventura Counties Annual herb (hemiparasitic). Coastal salt marsh, coastal dunes. Limited to the higher zones of the salt marsh habitat. Elevations 0-30 meters. Blooms May- October No Potential Not detected in project site during bloom period. Salt marsh habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-14 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Chorizanthe breweri Brewer’s spineflower Polygonaceae --/-- 1B.3 Monterey and San Luis Obispo Counties Serpentinite, rocky or gravelly substrates within closed-cone coniferous forest, chaparral, cismontane woodland, and coastal scrub. Elevations range: 45-800 meters. Blooms April-August No Potential Not detected in project site during bloom period. Appropriate serpentine soils and habitat are not found on site. Chorizanthe rectispina Straight-awned spineflower Polygonaceae --/-- 1B.3 Monterey, Santa Barbara, and San Luis Obispo Counties Annual herb. Chaparral, cismontane woodland, coastal scrub. Often on granite in chaparral. Elevations 85-1035 meters. Blooms April – July No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not found on site. Cirsium fontinale var. obispoense Chorro Creek Bog thistle (San Luis Obispo fountain thistle) Asteraceae FE/SE 1B.2 San Luis Obispo County Serpentinite seeps and drainages within chaparral, cismontane woodland, coastal scrub, and valley and foothill grassland. Elevations range: 35-380 meters. Blooms February – September No Potential Not detected in project site during bloom period. Serpentine soils are not found on site. Cirsium occidentale var. lucianum Cuesta Ridge thistle Asteraceae --/-- 1B.2 San Luis Obispo County Serpentinite substrates and often on steep rocky slopes and disturbed roadsides within openings in chaparral. Elevations range: 500-750 meters. Blooms April-June No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. Cirsium rhothophilum Surf thistle Asteraceae --/ST 1B.2 Santa Barbara and San Luis Obispo Counties Perennial herb. Coastal dunes, coastal bluff scrub. Open areas in central dune scrub; usually in coastal dunes. Elevations 3-60 meters. Blooms April - June No Potential Not detected in project site during bloom period. Appropriate dune habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-15 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Cirsium scariosum var. loncholepis La Graciosa thistle FE/ST 1B.1 Monterey, Santa Barbara, and San Luis Obispo Counties Perennial herb. Mesic, sandy. Cismontane woodland, coastal dunes, coastal scrub, marshes and swamps (brackish), and valley and foothill grassland. Elevation: 4-220 meters Blooms May-August No Potential Not detected in project site during bloom period. Appropriate wetland habitat is not found on site. Cladonia firma popcorn lichen Cladoniaceae --/-- 2B.1 San Luis Obispo County Maritime habitats in Europe and North America. Stabilized sand dunes on the coast. On soil and detritus on stabilized sand dunes, in pure stands or intermixed with other lichens and mosses forming biotic soil crusts, covering areas up to several meters. No Potential Not detected in project site. Appropriate soils and habitat are not found on site. Clarkia speciosa ssp. immaculata Pismo clarkia Onagraceae FE/SR 1B.1 southern San Luis Obispo County Sandy substrates, margins and openings within chaparral, cismontane woodland, and valley and foothill grassland. Elevations range: 25-185 meters. Blooms April - July No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not found on site. Delphinium parryi ssp. blochmaniae dune larkspur Ranunculaceae --/-- 1B.2 Santa Barbara, San Luis Obispo, and Ventura Counties Maritime chaparral and coastal dunes. Elevations range: 0-200 meters. Blooms April-June No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-16 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Delphinium parryi ssp. eastwoodiae Eastwood’s larkspur Ranunculaceae --/-- 1B.2 San Luis Obispo County Coastal serpentinite substrates within openings in chaparral and valley and foothill grassland. Elevations range: 75-500 meters. Blooms February – March No Potential Not detected in project site during bloom period. Serpentine soils are not found on site. Delphinium umbraculorum Umbrella larkspur Ranunculaceae --/-- 1B.3 San Luis Obispo County Perennial herb. Chaparral, cismontane woodland. Mesic sites. Elevations 400- 1600 meters. Blooms April- June No Potential Not detected in project site during bloom period. Project site is outside of the known elevation range for this species. Dithyrea maritima Beach spectaclepod Brassicaceae --/ST 1B.1 Los Angeles, Ventura, Santa Barbara, San Luis Obispo Counties; Channel Islands Perennial rhizomatous herb. Coastal dunes, coastal scrub. Formerly more widespread in coastal habitats in So. Calif. Sea shores, on sand dunes, and sandy places near the shore. Elevations 3-50 meters. Blooms March-May No Potential Not detected in project site during bloom period. Dune habitat is not found on site. Dudleya abramsii ssp. bettinae Betty’s dudleya Crassulaceae --/-- 1B.2 San Luis Obispo County Perennial herb. Coastal scrub, valley and foothill grassland, chaparral. On rocky, barren exposures of serpentine within scrub vegetation. Elevations 20- 180 meters. Blooms May - July No Potential Not detected in project site during bloom period. Serpentine soils are not found on site. Dudleya abramsii ssp. murina mouse-gray dudleya Crassulaceae --/-- 1B.3 San Luis Obispo County Serpentinite outcrops within chaparral, cismontane woodland, and valley and foothill grassland. Elevations range: 90-440 meters. Blooms May - June No Potential Not detected in project site during bloom period. Serpentine soils are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-17 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Dudleya blochmaniae ssp. blochmaniae Blochman’s dudleya Crassulaceae --/-- 1B.1 Los Angeles, Orange, Santa Barbara, San Diego, San Luis Obispo, and Ventura Counties Rocky, often clay or serpentinite substrates within coastal bluff scrub, chaparral, coastal scrub, and valley and foothill grassland. Elevations range: 5-450 meters. Blooms April - June No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Eriastrum luteum Yellow-flowered eriastrum Polemoniaceae --/-- 1B.2 Monterey and San Luis Obispo Counties Annual herb. Broadleaved upland forest, cismontane woodland, chaparral. On bare sandy decomposed granite slopes. Elevations 360-1000 meters. Blooms May - June No Potential Not detected in project site during bloom period. Appropriate habitat and sandy soils are not found on site. Erigeron blochmaniae Blochman's leafy daisy Asteraceae --/-- 1B.2 Santa Barbara and San Luis Obispo Counties Perennial rhizomatous herb. Coastal dunes. Sand dunes and hills. Elevations 3-185 meters. Blooms June - August No Potential Not detected in project site during bloom period. Sandy soils are not found on site. Eriodictyon altissimum Indian Knob mountainbalm Boraginaceae FE/SE 1B.1 San Luis Obispo County Perennial evergreen shrub. Chaparral (maritime), cismontane woodland, coastal scrub. Ridges in open, disturbed areas within chaparral on Pismo sandstone. Also occurs on Baywood sands. Elevations 80-270 meters. Blooms March – June No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. Eryngium aristulatum var. hooveri Hoover’s button-celery Apiaceae --/-- 1B.1 Alameda, San Benito, Santa Clara, San Diego, and San Luis Obispo Counties Vernal pools and serpentine seeps in mesic grasslands. Elevations range: 3-45 meters. Blooms in July- August. No Potential Not detected in project site during bloom period. Appropriate vernal pool habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-18 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Extriplex [=Atriplex] joaquiniana San Joaquin spear scale Chenopodiaceae --/-- 1B.2 Southern and Central California and the Great Valley Annual herb. Alkaline, chenopod scrub, meadows and seeps, playas, valley and foothill grassland. Elevations 1-835 meters. Blooms April-October No Potential Not detected in project site during bloom period. Alkaline soils are not found on site. Fritillaria ojaiensis Ojai fritillary Liliaceae --/-- 1B.2 Monterey, Santa Barbara, San Luis Obispo, and Ventura Counties Perennial bulbiferous herb. Broadleaved upland forest (mesic), chaparral, lower montane coniferous forest. Rocky sites; one reported as "moist shale talus." Elevations 300-670 meters. Blooms February-May No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Fritillaria viridea San Benito fritillary Liliaceae --/-- 1B.2 Fresno, Monterey, San Benito, and San Luis Obispo Counties Perennial bulbiferous herb. Chaparral. Serpentine slopes. Elevations 200- 1525 meters. Blooms March-May No Potential Not detected in project site during bloom period. Serpentine soil is not found on site. Horkelia cuneata var. puberula mesa horkelia Rosaceae --/-- 1B.1 Los Angeles, Orange, Riverside*, San ta Barbara, San Bernardino, San Diego*, San Luis Obispo, and Ventura Counties Sandy or gravelly substrates within maritime chaparral, cismontane woodland, and coastal scrub. Elevations: 70-810 meters. Blooms February- September No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not found on site. Lasthenia glabrata ssp. coulteri Coulter’s goldfields Asteraceae --/-- 1B.1 Colusa, Kern, Los Angeles, Merced, Orange, Riverside, Santa Barbara, San Bernardino, San Diego, San Luis Obispo, Santa Rosa Island, Tehama, Tulare, Venture, and Yolo Counties Annual herb. Coastal salt marshes, playas, valley and foothill grassland, vernal pools. Usually found on alkaline soils in playas, sinks, and grasslands. Elevations 1-1400 meters. Blooms February-June No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-19 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Layia heterotricha Pale-yellow layia Asteraceae --/-- 1B.1 Fresno, Kings, Kern, Los Angeles, Monterey, Santa Barbara, San Benito, San Luis Obispo, and Ventura Counties Annual herb. Cismontane woodland, pinyon-juniper woodland, valley and foothill grassland. Alkaline or clay soils; open areas. Elevations 270-1365 meters. Blooms March - June No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Layia jonesii Jones’ layia Asteraceae --/-- 1B.2 San Luis Obispo County Clay or serpentinite substrates within chaparral and valley and foothill grassland. Elevations range: 5-400 meters. Blooms March-May No Potential Not detected in project site during bloom period. Clay soils present on site, but heavily disturbed. Lupinus ludovicianus San Luis Obispo County lupine Fabaceae --/-- 1B.2 San Luis Obispo County Sandstone or sandy substrates within chaparral and cismontane woodland. Elevations range: 50-525 meters. Blooms April-July No Potential Not detected in project site during bloom period. Oak woodland habitat is not found on site. Malacothamnus gracilis Slender bush-mallow Malvaceae --/-- 1B.1 Santa Barbara and San Luis Obispo Counties Perennial deciduous shrub. Usually rocky chaparral. Dry, rocky slopes. Elevations 190-575 meters. Blooms May-October No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Malacothamnus palmeri var. Involucratus Carmel Valley bush- mallow --/-- 1B.2 Monterey and San Luis Obispo Counties. Perennial deciduous shrub. Chaparral, cismontane woodland, coastal scrub. Elevation: 30-1100 meters Blooms April-October No Potential Not detected in project site during bloom period Appropriate habitat is not found on site. Malacothamnus palmeri var. palmeri Santa Lucia bush-mallow Malvaceae --/-- 1B.2 Monterey and San Luis Obispo Counties Perennial deciduous shrub. Chaparral. Dry rocky slopes, mostly near summits, but occasionally extending down canyons to the sea. Elevations 60-365 meters. Blooms May – July No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-20 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Monardella palmeri Palmer’s monardella Lamiaceae --/-- 1B.2 Monterey and San Luis Obispo Counties Serpentinite substrates within chaparral and cismontane woodland. Elevations range: 200-800 meters. Blooms June- August No Potential Not detected on site during bloom period. Serpentine soils are not found on site. Monardella sinuata ssp. sinuata Southern curly-leaved monardella Lamiaceae --/-- 1B.2 Santa Barbara, San Luis Obispo, and Ventura Counties Coastal dunes, coastal scrub, chaparral, cismontane woodlands. Sandy soils. Elevations 0- 300 meters. Blooms April- September No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not found on site. Monardella undulata ssp. undulata San Luis Obispo monardella --/-- 1B.2 Santa Barbara and San Luis Obispo Counties Perennial rhizomatous herb. Coastal dunes and coastal scrub (sandy). Elevation: 10-200 meters. Blooms: May-September No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not found on site. Monolopia gracilens Woodland woolythreads Asteraceae --/-- 1B.2 Alameda, Contra Costa, Monterey, San Benito, Santa Clara, Santa Cruz, San Luis Obispo, and San Mateo Counties Annual herb. Chaparral, valley and foothill grasslands (serpentine), cismontane woodland, broadleafed upland forests, north coast coniferous forest. Grassy sites, in openings; sandy to rocky soils. Often seen on serpentine after burns but may have only weak affinity to serpentine. Elevations 100-1200 meters. Blooms February-July No Potential Not detected in project site during bloom period. Appropriate sandy soils and habitat are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-21 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Navarretia fossalis Spreading Navarretia FT / -- 1B.1 Los Angeles, Riverside, San Diego, San Luis Obispo, and Ventura Counties Annual herb. Occurs in vernal pools, ditches, and other areas that are wet or flooded during the rainy season and dry during the rest of the year, and in areas with alkali soils. No Potential Not detected in project site. Species has not been documented by CNDDB within 5 miles of the project site. Appropriate alkali soils not present. Not expected to occur. Navarretia nigelliformis ssp. radians Shining navarretia Polemoniaceae --/-- 1B.2 Alameda, Contra Costa, Colusa, Fresno, Madera, Merced, Monterey, San Benito, San Joaquin, and San Luis Obispo Counties Annual herb. Cismontane woodland, valley and foothill grassland, vernal pools. Apparently in grassland, and not necessarily in vernal pools. Elevations 200-100 meters. Blooms April - July No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. Nemacaulis denudata var. denudata Coast woolly-heads Polygonaceae --/-- 1B.2 Los Angeles, Orange, Santa Catalina Island, San Diego, and San Luis Obispo Counties Annual herb. Coast dunes. Elevations 0-100 meters. Blooms April-September No Potential Not detected in project site during bloom period. Dune habitat is not found on site. Plagiobothrys uncinatus Hooked popcorn flower Boraginaceae --/-- 1B.2 Monterey, San Benito, Santa Clara, San Luis Obispo, and Stanislaus Counties Annual herb. Chaparral, cismontane woodland, valley and foothill grassland. Sandstone outcrops and canyon sides; often in burned or disturbed areas. Elevations 300-760 meters. Blooms April-May No Potential Not detected in project site during bloom period. Appropriate sandstone substrate is not found on site. Poa diabolic Diablo Canyon blue-grass Poaceae --/-- 1B.2 San Luis Obispo County Perennial rhizomatous herb. Shale; sometimes burned areas. Closed-cone coniferous forest, chaparral (mesic), cismontane woodland, coastal scrub. Elevations 120-400 meters. Blooms March-April No Potential Not detected in project site during bloom period. Appropriate habitat is not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-22 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Sanicula maritima adobe sanicle Apiaceae --/SR 1B.1 Alameda*, Monterey, San Francisco*, and San Luis Obispo Counties Clay and serpentinite substrates within chaparral, coastal prairie, meadows and seeps, and valley and foothill grassland. Elevations range: 30-240 meters. Blooms February – May No Potential Not detected in project site during bloom period. Appropriate wet meadow habitat is not found on site. Scrophularia atrata black-flowered figwort Scrophulariaceae --/-- 1B.2 Santa Barbara and San Luis Obispo Counties Closed-cone coniferous forest, chaparral, coastal dunes, coastal scrub, and riparian scrub. Elevations range: 10-500 meters. Blooms March-July. No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. Senecio aphanactis chaparral ragwort Asteraceae --/-- 2B.2 Alameda, Contra Costa, Fresno, Los Angeles, Merced, Monterey, Orange, Riverside, Santa Barbara, San Benito, Santa Clara, Santa Cruz, Santa Catalina Island, San Diego, San Luis Obispo, Solano, Santa Rosa Island, and Ventura Counties Occasionally alkaline substrates within chaparral, cismontane woodland, and coastal scrub. Elevations range: 15-800 meters. Blooms January – April. No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. Sidalcea hickmanii ssp. anomala Cuesta Pass checkerbloom Malvaceae --/SR 1B.2 San Luis Obispo County Perennial herb. Closed- cone coniferous forest. Rocky serpentine soil; associated with Sargent cypress forest. Elevations 600-800 meters. Blooms May-June No Potential Not detected in project site during bloom period. Appropriate serpentine soils and coniferous forest habitat are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-23 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Streptanthus albidus ssp. peramoenus most beautiful jewel-flower Brassicaceae --/-- 1B.2 Alameda, Contra Costa, Monterey, Santa Clara, and San Luis Obispo Counties Serpentinite substrates within chaparral, cismontane woodland, and valley and foothill grassland. Elevations range: 94-1000 meters. The Jepson eFLora does not recognize S. albidus ssp. peramoenus reported from SLO County as distinct from the common Streptanthus glandulosus ssp. glandulosus. Blooms March - October No Potential Not detected in project site during bloom period. Serpentine soils are not found on site. Suaeda californica California seablite Chenopodiaceae FE/-- 1B.1 Alameda, Contra Costa, Santa Clara, San Francisco, and San Luis Obispo Counties Perennial evergreen subshrub. Found on the margins of coastal salt marshes and swamps. Elevations 0-15 meters. Blooms July-October No Potential Not detected in project site. Salt marsh habitat is not found on site. Sulcaria isidiifera Splitting yarn lichen Alectoriaceae --/-- 1B.1 San Luis Obispo County Chaparral, cismontane woodland. On branches of oaks and shrubs. Elevations 20-30 meters. No Potential Not detected in project site. Appropriate habitat is not found on site. Trifolium hydrophilum saline clover Fabaceae --/-- 1B.2 Alameda, Contra Costa, Colusa, Lake, Monterey, Napa, Sacramento, San Benito, Santa Clara, Santa Cruz, San Luis Obispo, San Mateo, Solano, Sonoma, and Yolo Counties Marshes and swamps, mesic and alkaline areas within valley and foothill grassland, and vernal pools. Elevations range: 0-300 meters. Blooms April-June No Potential Not detected in project site during bloom period. Appropriate soils and habitat are not found on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-24 Table 4.4-2 Special Status Plant Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Family Status Fed/State ESA CRPR Distribution Habitat Requirements Potential to Occur Rationale Tropidocarpum capparideum Caper-fruited tropidocarpum --/-- 1B.1 Alameda, Contra Costa, Fresno, Glenn, Monterey, Santa Clara, San Joaquin, San Luis Obispo Counties Annual herb. Valley and foothill grassland (alkaline hills). Elevation: 1-455 meters. Blooms: March- April No Potential Not detected in project site during bloom period. Alkaline clay soil is not found on site. Sources: CNDDB (CDFW, 2016); USFWS IPaC (2016), CDFW Special Plants List (2013), and CNPS Rare Plant Inventory (2016). FE = Federally Endangered, FT = Federally Threatened, DL = Delisted SE = State Endangered, ST = State Threatened, SR = State Rare G-Rank/S-Rank = Global Rank and State Rank as per NatureServe and CDFW’s CNDDB RareFind3. CRPR (California Rare Plant Rank): 1A=Presumed Extinct in California 1B=Rare, Threatened, or Endangered in California and elsewhere 2=Rare, Threatened, or Endangered in California, but more common elsewhere 3=Need more information (a Review List) 4=Plants of Limited Distribution (a Watch List) CRPR Threat Code Extension: .1=Seriously endangered in California (over 80% of occurrences threatened / high degree and immediacy of threat) .2=Fairly endangered in California (20-80% occurrences threatened) .3=Not very endangered in California (<20% of occurrences threatened) San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-25 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Invertebrates Branchinecta lynchi vernal pool fairy shrimp FT/-- Endemic to the grasslands of the Central Valley, and Central Coast and the South Coast mountains of San Luis Obispo County. Rain-filled pools; small, clear- water sandstone-depression pools and grassland swale, earth slump, or basalt-flow depression pools. Adults: wet season, approximately December-April; Cysts: dry season, approximately June-October No Potential Not detected in project site. Appropriate habitat is not present on site. Helminthoglypta walkeriana Morro shoulderband snail FE/-- Restricted to the coastal strand in the immediate vicinity of Morro Bay. Coastal dunes and scrub. Inhabits the duff beneath Haplopappus, Salvia, Dudleya, and Mesembryanthemum as well as iceplant. Can be detected year round. No Potential Not detected in project site. Appropriate habitat is not present on site; project site is outside known range of species. Fish Eucyclogobius newberryi tidewater goby FE/-- SSC Coastal California from Del Norte County to San Diego County. Occurs in brackish and freshwater shallow lagoons and slow-moving lower stream reaches. Requires fairly calm and still waters, but not stagnant. Avoids open areas with strong currents or wave action. Typically July-October (occasionally outside this period with agency consultation) No Potential Not detected in project site. Appropriate habitat is not present on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-26 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Oncorhynchus mykiss irideus steelhead – south/central California coast DPS FT/-- -- All naturally spawned populations that occur in coastal streams from the Pajaro River south to, but excluding the Santa Maria River. The major watersheds include the Pajaro, Salinas, and Carmel, as well as the smaller rivers along the Big Sur Coast and south. Occurs in perennial water within riparian, emergent, and palustrine habitats. Spawning and rearing occurs in cool, clear fast-flowing streams with abundant gravel or cobble and riffles. Feeds and forages in open waters within estuarine subtidal and riverine habitats. Connectivity to the Pacific Ocean is required to complete its life cycle. Can be detected year round. High Potential Not detected in project site. However, Prefumo Creek is historic habitat. Amphibians Ambystoma californiense California tiger salamander FT/ST SSC Sonoma and Santa Barbara Counties and Central California. Restricted to vernal pools and seasonal ponds, including constructed stock ponds, in grassland and oak savannah plant communities, predominantly from sea level to 2,000 feet, in Central California. No Potential Species has not been documented by CNDDB within 5 miles of the BSA. No vernal pools or ponds have been documented on-site. Not expected to occur. Rana boylii Foothill yellow-legged frog --/-- SSC Occurs along the coast of California and east of the Central Valley. Partly-shaded, shallow streams and riffles with a rocky substrate in a variety of habitats. Need at least some cobble-sized substrate for egg-laying. Need at least 15 weeks to attain metamorphosis. No Potential Not detected in project site. Prefumo creek does not have suitable substrate for this species. Not expected to occur. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-27 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Rana draytonii California red-legged frog FT/-- SSC Coastal drainages of central California, from Marin County, south to San Diego County Found in permanent and temporary pools of deep water in streams, marshes, and ponds with dense grassy, shrubby, or emergent vegetation. Requires 11-20 weeks of permanent water for larval development. Must have access to upland aestivation habitat. The Survey period is typically between November and June. High Potential Not detected in project site. However, appropriate creek habitat is present on site and, project site is 0.5 mile from the confluence of Prefumo and San Luis Obispo Creek and a documented occurrence of CRLF. Spea hammondii Western spadefoot -- / -- SSC Occurs in Central Valley and bordering foothills of California and along the coast ranges in the USA south of San Francisco Bay. Open areas with sandy or gravelly soils, including mixed woodlands, grasslands, coastal sage scrub, chaparral, sandy washes, lowlands, river floodplains, alluvial fans, playas, alkali flats, foothills, and mountains. Rain pools that do not support bullfrogs, fish, or crayfish are required for breeding. Breeding season: January-August Moderate Potential Wetland depressions that hold water for several weeks were observed onsite that may be suitable for Western spadefoot to breed. Taricha torosa Coast Range newt --/-- SSC Coastal drainages from Mendocino County to San Diego County. Prefers wooded rocky streamsides in forested and wooded areas and will migrate over 1 kilometer to breed in slow water. Moderate Potential Pools within Prefumo Creek where some tree canopy is available may be suitable for breeding. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-28 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Reptiles Emys marmorata western pond turtle --/-- SSC Western portion of California, including the coast ranges and the central valley, west of the crest of Cascades and Sierra Nevadas. Occurs in river/streams w/deep pools and irrigation canals with moderate amounts of riparian and emergent vegetation. Slow moving waters, perm aquatics. Note that taxonomy of pond turtles in southern California has been revised multiple times in recent years. Detection is most likely between March-October High Potential Not detected in project site. However, appropriate creek habitat is present on site, and project site is nearby confluence with San Luis Obispo Creek, which has documented occurrences of this species. Anniella pulchra nigra black legless lizard -- / -- SSC Occurs from southern edge of the San Joaquin River in northern Contra Costa County south to Ventura County. Also occurs in coastal dunes from Morro Bay south to the mouth of the Santa Maria River in San Luis Obispo County. Sand dunes and sandy soils in the Monterey Bay and Morro Bay regions. Inhabit sandy soil/dune areas with bush lupine and mock heather as dominant plants. Moist soil is essential. Detectable year round. No Potential Not detected in project site. Appropriate habitat is not present on site. Anniella pulchra pulchra silvery legless lizard --/-- SSC Contra Costa County south through the Coast, Transverse, and Peninsular Ranges, along the western edge of the Sierra Nevada Mountains and parts of the San Joaquin Valley and Mojave Desert. Requires dune scrub, coastal scrub, chaparral, pine-oak woodland, oak woodland, and riparian woodland. Utilizes loose sandy or loamy soils for burrowing, moisture, warmth, and adequate vegetative cover. Detectable year round. No Potential Not detected in project site. Appropriate habitat is not present on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-29 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Gambelia silus blunt-nosed leopard lizard FE / SE FP Fresno, Kern, Kings, Los Angeles, Madera, Mariposa, Merced, Monterey, San Benito, San Luis Obispo, Santa Barbara, Santa Clara, Stanislaus, Tulare, and Ventura Counties. Occur in semiarid grasslands, alkali flats, and washes. Prefer flat areas with open space for running, avoiding densely vegetated areas. Elevation: 30- 730 meters. No Potential Not expected to occur on site. No suitable habitat occurs on site and no observations were made during the surveys. Phrynosoma blainvillii coast horned lizard --/-- SSC Fragmented distribution that includes the Pacific coast from the Baja California border west of the deserts and the Sierra Nevada, north to the Bay Area, and inland as far north as Shasta Reservoir, and south into Baja California. Coastal sage, chaparral, grassland, conifer forests and other woodlands, riparian, with open areas and patches of loose soil. Peak detection is between May and September. No Potential Not detected in project site. Appropriate habitat is not present on site. Thamnophis hammondii* two-striped garter snake --/-- SSC Coastal California from vicinity of Salinas to northwest Baja California. From sea to about 7,000 feet. elevation. Highly aquatic, found in or near permanent fresh water. Often along streams with rocky beds and riparian growth. Moderate Potential Suitable riparian habitat is present onsite adjacent to Prefumo Creek. Birds Accipiter cooperii Cooper's hawk (nesting) --/-- WL Breeding resident throughout most of the wooded portion of the state. Breeds in southern Sierra Nevada foothills, New York Mts., Owens Valley, and other local areas in southern California. Forages and nests in open woodlands and wood margins, riparian forests. Can be detected year round. High Potential Detected in project site (not nesting). Foraging habitat is present, may nest in eucalyptus. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-30 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Agelaius tricolor tricolored blackbird (nesting colony) --/-- SSC Common locally throughout Central Valley and in coastal districts from Sonoma County to southern California Counties. Grassland and cropland habitats with emergent wetland with tall, dense cattails and/or tules. Also occurs in thickets of willow, blackberry, and tall herbs. Can be detected Year Round. No Potential Not detected in project site. Appropriate nesting and foraging habitat is not present on site. Ammodramus savannarum grasshopper sparrow --/-- SSC Coastal districts from Humboldt County to San Diego County as well as east to the Great Plains. Dense grasslands on rolling hills, lowland plains, in valleys and on hillsides on lower mountain slopes. Favors native grasslands with a mix of grasses, forbs and scattered shrubs. Loosely colonial when nesting. Detection during Summer. No Potential Not detected in project site. Appropriate grassland habitat in not present on site. Aquila chrysaetos golden eagle (nesting & wintering) --/-- FP Extensive range throughout California. Known to occur in San Luis Obispo. Nests on cliffs, rocks, and large trees and forages in open country, grasslands. Can be detected year round. No Potential Not detected in project site. Appropriate woodland habitat is not present on site. Ardea Herodias* great blue heron (rookery) --/-- SSA (rookery) Extensive range from the Americas to Canada. Known to occur in San Luis Obispo. Rookeries located in tall trees near foraging areas. High Potential A great blue heron rookery consisting of six nests is present in a stand of blue gum eucalyptus located between the Post Office and the farm buildings. At least three nests contained nestlings during biological surveys. Athene cunicularia burrowing owl --/-- SSC Central Valley, the Modoc Plateau and northeastern California, and the southeastern portions of the state. Occurs in open dry grasslands and desert habitats. Also occurs in open areas within pinyon- juniper habitat. Can be detected year round. No Potential Small isolated patches of grassland habitat on-site are highly disturbed and not suitable for nesting burrowing owl. Not detected in project site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-31 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Buteo regalis ferruginous hawk --/-- WL Uncommon winter resident and migrant at lower elevations and open grasslands in the Modoc Plateau, Central Valley, and Coast Ranges. Open grasslands, sagebrush flats, desert scrub, low foothills surrounding valleys, and fringes of pinyon-juniper habitat. Detection during Winter. No Potential Not detected in project site. Appropriate grassland habitat is not present on site. Charadrius alexandrinus nivosus western snowy plover FT/-- SSC Range is largely restricted to coastal California. Also occurs in a few inland alkaline lakes, the Salton Sea. and Mono Lake. Requires dune-backed beaches, barrier beaches, and salt- evaporated ponds. Uses sandy, gravelly, or friable soils for nesting. Occasionally uses agricultural waste ponds of the Central Valley. Can be detected year round. No Potential Not detected in project site. Appropriate habitat is not present on site. Contopus cooperi* olive-sided flycatcher --/-- SSC Nests in mixed conifer, montane hardwood- conifer forests in California and elsewhere in North America. Nesting habitats are mixed conifer, montane hardwood- conifer, Douglas-fir, redwood, red fir and lodge-pole pine. Most numerous in montane conifer forests where tall trees overlook canyons, meadows, lakes or other open terrain. High Potential Eucalyptus in project site contains moderately suitable nesting habitat. Site contains ample foraging habitat. One olive-sided flycatcher was detected during the April 29 survey, most likely a migratory individual. No other individuals were detected during later surveys. Coccyzus americanus occidentalis western yellow-billed cuckoo FT/SE -- Coastal valleys from the Mexican border to Sebastopol, Sonoma County and the Central Valley from Bakersfield and Weldon, Kern County, north to Redding, Shasta County. Riparian plants, prefers willows, cottonwoods, aspens, sycamores and alders for resting and foraging. Year Round. No Potential Not detected in project site. Appropriate dense riparian habitat is not present on the site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-32 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Elanus leucurus white-tailed kite --/-- FP California’s coastal and valley regions excluding the Cascades, Sierra Nevadas, Mojave Desert, and Peninsular Ranges. Grasslands, dry farmed agricultural fields, savannahs and relatively open oak woodlands, and other relatively open lowland scrublands. Year Round Moderate Potential Not detected in project site. Suitable habitat onsite for foraging and nesting. No nests were documented in the project site, but white tailed kites could nest in eucalyptus. Empidonax traillii extimus southwestern willow flycatcher FE/SE -- Alpine, Fresno, Imperial, Inyo, Kern, Los Angeles, Madera, Mono, Monterey, Orange, Riverside, San Benito, San Bernardino, San Diego, San Luis Obispo, Santa Barbara, Santa Cruz, Tulare, Tuolumne, and Ventura Counties. Breeds in relatively dense riparian tree and shrub communities associated with rivers, swamps, lakes and reservoirs. Nests in non-native, mixed-native, and native vegetation including willow, seepwillow, boxelder, buttonbrush, and cottonwood. No Potential There are no documented occurrences by CNDDB within 5 miles of the project site. Not known to occur in area. Eremophila alpestris actia California horned lark --/-- WL A common resident throughout California, and known populations in San Luis Obispo County. Grasslands, open coastal plains, and alkali flats. Prefers low, sparse vegetation. Year Round No Potential Not detected in project site. Appropriate habitat is not present on site. Falco columbarius merlin --/-- WL Extensive range throughout California. Known to occur in San Luis Obispo. Forages over coastlines, open grasslands, savannahs, woodlands, and wetlands. Winter High Potential Not detected in project site. However, appropriate wintering habitat is present on site. Falco mexicanus prairie falcon --/-- WL Southeastern deserts northwest throughout the Central Valley and along the inner Coast Ranges and Sierra Nevada. Dry, open terrain, flat or hilly with breeding sites located on cliffs. February-September No Potential Not detected in project site. Appropriate habitat is not present on site. Gymnogyps californianus California condor FE / SE FP Fresno, Inyo, Kern, Kings, Los Angeles, Merced, Mono, Monterey, San Benito, San Bernardino, San Luis Obispo, Santa Require large areas of remote country for foraging, roosting, and nesting. Roost on large trees or snags, or on isolated rocky outcrops and cliffs. Nests are located in shallow caves and No Potential Extremely unlikely to occur. Marginal foraging habitat. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-33 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Barbara, Santa Clara, Tulare, and Ventura Counties. rock crevices on cliffs where there is minimal disturbance. Foraging habitat includes open grasslands and oak savanna foothills that support populations of large mammals such as deer and cattle. Lanius ludovicianus loggerhead shrike --/-- SSC Extensive range throughout California. Known to occur in San Luis Obispo. Coastal sage scrub, grasslands. Year Round High Potential Not detected in project site. Appropriate nesting and foraging habitat is present on site. Known to occur in vicinity. Laterallys jamaicensis coturniculus California black rail --/ST FP Placer County, San Joaquin County, the San Francisco Bay area, Marin County, and Morro Bay in San Luis Obispo County. Populations have also been found in Yuba, Butte, and Nevada Counties. Inhabits freshwater marshes, wet meadows and shallow margins of saltwater marshes bordering larger bays. Needs water depths of about one inch that does not fluctuate during the year and dense vegetation for nesting habitat. Year Round No Potential Not detected in project site. Appropriate salt marsh habitat is not present on site. Progne subis purple martin --/-- SSC San Luis Obispo County. Inhabits woodlands including sycamores, low elevation coniferous forest of Douglas fir, ponderosa pine, and Monterey pine. Primarily nests in old woodpecker cavities. Summer No Potential Not detected in project site. Sycamores are not present on site. Rallus longirostris obsoletus California clapper rail FE/SE FP Humbolt County, Monterey County, and in Morro Bay in San Luis Obispo County. Salt-water and brackish marshes traversed by tidal sloughs in the vicinity of San Francisco Bay. Associated with abundant growths of pickle weed, but feeds away from cover on invertebrates from mud-bottomed sloughs. Year Round No Potential Not detected in project site. Appropriate habitat is not present on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-34 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Setophaga petechia brewsteri* yellow warbler --/-- SSC Found throughout much of North America and southern Canada in habitats briefly categorized as wet, deciduous thickets Riparian plant associations. Prefers willows, cottonwoods, aspens, sycamores, and alders for nesting and foraging. Also nests in montane shrubbery in open conifer forests. High Potential The riparian habitat in Prefumo Creek is marginally suitable nesting habitat. Multiple yellow warblers were seen foraging in the willows south of the Post Office in the seasonal drainage during spring surveys. Sterna antillarum browni California least tern FE/SE -- Alameda, Contra Costa, Los Angeles, Marin, Monterey, Napa, Orange, Sacramento, San Diego, San Francisco, San Luis Obispo, San Mateo, Santa Barbara, Santa Clara, Santa Cruz, Solano, Sonoma, and Ventura Counties. Nests along the coast from San Francisco Bay south to northern Baja California. Colonial breeder on bare or sparsely vegetated, flat substrates: sand beaches, alkali flats, landfills, or paved areas. No Potential No suitable habitat occurs within the project site for this species. Not expected to occur. Vireo bellii pusillus least Bell’s vireo FE/SE -- Imperial, Inyo, Kern, Los Angeles, Monterey, Orange, Riverside, Sacramento, San Benito, San Bernardino, San Diego, San Joaquin, San Luis Obispo, Santa Barbara, Santa Clara, Santa Cruz, Stanislaus, Tulare, Ventura, and Yolo Counties. Inhabits structurally diverse woodlands along watercourse, including cottonwood-willow forests, oak woodlands, and mule fat scrub. No Potential Species is not known to occur in this area and there are no documented occurrences by CNDDB within 5 miles of the project site. No suitable nesting habitat present within the project site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-35 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Mammals Antrozous pallidus pallid bat --/-- SSC Throughout California except for the high Sierra Nevada from Shasta to Kern Cos., and the northwestern corner of the state from Del Norte and western Siskiyou Cos. to northern Mendocino Co. Rock crevices, tree hollow, mines, caves, structures. Open, lowland areas. Year Round High Potential Not detected in project site. However, appropriate old buildings are present on site for habitat. Corynorhinus townsendii Townsend’s big-eared bat --/SCT SSC Extensive range throughout California. Known to occur in San Luis Obispo. Requires caves, mines, tunnels, buildings, or other human-made structures for roosting. Year Round High Potential Not detected in project site. However, appropriate old buildings are present on site for habitat. Dipodomys heermanni morroensis Morro Bay kangaroo rat FE/SE FP Coast range along Morro Bay and between Spooner Cover and Hazards Canyon in Montano de Oro in San Luis Obispo County. Commonly associated with stabilized sand dune, coastal dune, and coastal sage scrub, and maritime chaparral communities. Year Round No Potential Not detected in project site. Appropriate dune habitat is not present on site. Dipodomys ingens giant kangaroo rat FE / SE -- Fresno, Kern, Kings, Madera, Merced, Monterey, San Benito, San Luis Obispo, Tulare, and Ventura Counties. Occur in annual grassland communities with few or no shrubs, well drained, sandy-loam soils located on gentle slopes (less than 11 percent) in areas with about 6.3 inches or less of annual precipitation. No Potential Not expected to occur on site. No suitable habitat occurs on site and no observations were made during the survey. Eumops perotis californicus western mastiff bat --/-- SSC Coast ranges from Monterey County southward through Southern California, from the coast eastward to the Colorado desert. Many open, semi-arid to arid habitats, including conifer and deciduous woodlands, coastal scrub, grasslands, chaparral, etc. Roosts in crevices in cliff faces, high buildings, trees and tunnels. Year Round No Potential Not detected in project site. Appropriate roosting habitat is not present on site. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-36 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Neotoma lepida intermedia San Diego desert woodrat --/-- SSC Found throughout central and southern California from San Luis Obispo south through the Transverse and Peninsula Ranges in Baja California. Commonly inhabit Joshua tree woodlands, pinyon-juniper woodlands, mixed chaparral, sagebrush, and desert habitats. Known to construct dens in the cracks between boulders using sticks, yucca leaves, and tin cans. No Potential Not detected in project site. Appropriate habitat is not present on site. Nyctinomops macrotis big free-tailed bat --/-- SSC Rare in California, from urban areas of San Diego and Alameda County. Low-lying arid areas in Southern California. Need high cliffs or rocky outcrops for roosting sites. Feeds principally on large moths. No Potential Not detected in project site. Appropriate habitat is not present on site. Taxidea taxus American badger --/-- SSC Extensive range throughout California. Known to occur in San Luis Obispo. Requires open, arid habitats, but are most commonly associated with grasslands, savannahs, mountain meadows, and open areas of desert scrub. Soils must be friable for burrow excavation. Year Round No Potential Not detected in project site. Soils in the Study Area are not ideal for badger and grassland habitat onsite is highly disturbed and not suitable for burrowing. Vulpes macrotis mutica San Joaquin kit fox FE/ST -- Extensive range throughout California. Known to occur in San Luis Obispo County. Occurs in annual grasslands or open stages with scattered shrubby vegetation. Requires loose sandy textured soils for burrowing. No Potential No CNDDB documented occurrences within 5 miles of the project site., no SJKF or associated burrows were observed within the project site during the survey. Not expected to occur. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-37 Table 4.4-3 Special Status Animal Species in the Regional Vicinity of the Project Site Scientific Name/ Common Name Status Federal/State ESA CDFW Status- Distribution Habitat Requirements; Detection Periods Potential to Occur Rationale Insects Danaus plexippus* Monarch butterfly --/-- SSA (overwintering) Winter roost sites extend along the coast from northern Mendocino to Baja California, Mexico. Roosts located in wind- protected tree groves (eucalyptus, Monterey pine, cypress), with nectar and water sources nearby. Roosts located in wind protected tree groves with nectar and water nearby. High Potential Overwintering individuals were observed on-site by Althouse and Meade during the winter of 2016. Euproserpinus euterpe Kern primrose sphinx moth FT/-- -- Kern, Kings, San Luis Obispo, Santa Barbara, and Ventura Counties. Occurs in gently sloping sandy washes consisting of coarse to fine textured, decomposed granite soil, and dominant vegetation that includes red- stemmed stork’s beak (Erodium cicutarium), baby blue-eyes (Nemophila menziesii), rabbit brush (Chyysothamnus nausseosus), gold fields (Lasthenia chrysostoma), and brome grass (Bromus arenarius). Essential to the survival of the Kern primrose sphinx moth is the presence of its primary food plant, the sun cup or evening primrose Camissonia contorta No Potential Not expected to occur on site. No suitable habitat occurs on site and no observations were made during the survey. Host plant (Camissonia contorta epilobiodes) was not detected on the site. Sources: CNDDB (CDFW, 2016); USFWS IPaC (2016), CDFW Special Animals List (2016). FT = Federally Threatened SE = State Endangered FC = Federal Candidate Species ST = State Threatened FE = Federally Endangered SR = State Rare FS = Federally Sensitive SS = State Sensitive WL=Watch List SSA = State Special Animal DL = Delisted SCT = State Candidate Threatened G-Rank/S-Rank = Global Rank and State Rank as per NatureServe and CDFW’s CNDDB RareFind3. SCC = CDFW Species of Special Concern FP = Fully Protected San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-38 Special Status Plant Species. Based on the database and literature review of records from the San Luis Obispo, California USGS 7.5-minute topographic quadrangle and surrounding eight quadrangles as well as the USFWS IPaC list of federally listed species, seventy-two (72) special status plant species are known to or have the potential to occur within the vicinity of the project site (Table 4.4-2). A number of special status plant species were eliminated based on known restrictions in range and/or known extirpation. None of the special status plant species with potential to occur were detected during the field surveys. Surveys were seasonally timed to correspond with the blooming periods for the sensitive plant species that have potential to occur onsite. Based on the negative survey results or lack of suitable habitat, no special status plant species are expected to occur within the project site. Special Status Animal Species. Forty-three special status animal species were identified within the San Luis Obispo, California USGS 7.5-minute topographic quadrangle and surrounding eight quadrangles as well as the USFWS IPaC list of federally listed species. Five additional special status species were added to the list because they were either directly observed onsite or have the potential occur based on our knowledge of the area. These five species have been marked with an asterisk (*). Potential habitat for sixteen (16) special status animal species occurs within the project site based on the presence of their general habitat requirements and each species geographic range. These species include: • Western Pond Turtle (Emys marmorata), State Species of Special Concern (SSC) • California Red-legged Frog (Rana draytonii), Federally Threatened (FT), SSC • Western Spadefoot (Spea hammondii), SSC • Coast Range Newt (Taricha torosa torosa), SSC • Two-striped Garter Snake* (Thamnophis hammondii), SSC • Steelhead – South/Central California Coast DPS (Oncorhynchus mykiss), FT • Pallid Bat (Antrozous pallidus), SSC • Townsend’s Big-eared Bat (Corynorhinus townsendii) – State Candidate Threatened (SCT), SSC • Cooper's Hawk (Accipiter cooperii), Watch List (WL) • Merlin (Falco columbarius), WL • White-tailed Kite (Elanus leucurus), Fully Protected (FP) • Yellow Warbler* (Setophaga petechial brewsteri), SSC • Olive-sided Flycatcher* (Contopus cooperi), SSC • Loggerhead Shrike (Lanius ludovicianus), SSC • Great Blue Heron* (Ardea herodias), State Special Animal (SSA), (rookery site) • Monarch Butterfly* (Danaus plexippus), SSA, (overwintering) The special status animal species listed above are all those that are known to occur in the habitats previously described within the project site. Some of the species listed above can also be found in association with human development, such as the pallid bat and Townsend’s big- eared bat, which can utilize structures as roosting areas. Structures that occur within the project site that can be utilized by special status bats include abandoned barns, sheds, and small outbuildings. Prefumo Creek within the project site is also designated Critical Habitat for steelhead, a federal Threatened and state Species of Special Concern. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-39 Special Status Plant Communities. Nine special status plant communities were identified by the CNDDB as occurring in the vicinity of the project site (Table 4.4-4). None of these communities occur within the project site. Table 4.4-4 Sensitive Plant Communities within the Regional Vicinity of the Project Site Plant Community Global/State Rank Habitat Presence/ Absence Central dune scrub G2/S2.2 Not present Central foredunes G1/S1.2 Not present Central maritime chaparral G2/S2.2 Not present Coastal and valley freshwater marsh G3/S2.1 Not present Coastal brackish marsh G2/S2.1 Not present Northern coastal salt marsh G3/S3.2 Not present Northern interior cypress forest G2/S2.2 Not present Serpentine bunchgrass G2/S2.2 Not present Valley needlegrass grassland G3/S2.1 Not present Source: CDFW’s CNDDB RareFind5 d. Wildlife Corridors. Wildlife movement corridors, or habitat linkages, are generally defined as connections between habitat patches that allow for physical and genetic exchange between otherwise isolated animal populations. Such linkages may serve a local purpose, such as providing a linkage between foraging and denning areas, or they may be regional in nature. Some habitat linkages may serve as migration corridors, wherein animals periodically move away from an area and then subsequently return. Others may be important as dispersal corridors for young animals. A group of habitat linkages in an area can form a wildlife corridor network. The habitats within the link do not necessarily need to be the same as the habitats that are being linked. Rather, the link merely needs to contain sufficient cover and forage to allow temporary inhabitation by ground-dwelling species. Typically, habitat linkages are contiguous strips of natural areas, though dense plantings of landscape vegetation can be used by certain disturbance-tolerant species. Depending upon the species using a corridor, specific physical resources (such as rock outcroppings, vernal pools, or oak trees) may need to be located within the habitat link at certain intervals to allow slower-moving species to traverse the link. For highly mobile or aerial species, habitat linkages may be discontinuous patches of suitable resources spaced sufficiently close together to permit travel along a route in a short period of time. Wildlife movement corridors can be both large and small scale. Regionally, the project site is not located within an Essential Connectivity Area (ECA) as mapped in the report California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California (2010). ECAs represent principle connections between Natural Landscape Blocks. ECAs are regions in which land conservation and management actions should be prioritized to maintain and enhance ecological connectivity. ECAs are mapped based on coarse ecological condition indicators, rather than the needs of particular species and thus serve the majority of species in each region. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-40 Small-scale habitat corridors are present on site and include drainages and other topographic features that facilitate movement. Prefumo Creek and its associated riparian vegetation border the western boundary of the project site. The creek and ephemeral drainage provide a suitable small-scale corridor for sensitive and common wildlife to travel locally. Riparian corridors found within the project site may serve as movement corridors particularly where upland habitat occurs adjacent to them. e. Jurisdictional Features. All potentially jurisdictional features within the project site were inspected to record existing conditions and determine limits of U.S. Army Corps of Engineers (USACE), Regional Water Quality Control Board (RWQCB), and CDFW jurisdictions. A summary of potentially jurisdictional features identified within the project site is presented in Table 4.4-5 and Figure 4.4-1 provides a map of these features. Based upon the analysis of Althouse and Meade’s jurisdictional delineation, the site contains Prefumo Creek and Cerro San Luis Channel, which are subject to CDFW, RWQCB, and USACE jurisdictions. Prefumo Creek and Cerro San Luis Channel within the project site contain federal Waters of the U.S. which include wetlands that meet the three criteria of hydrology, hydric soils, and hydrophytic vegetation within and adjacent to the OHWM boundary. However, both features are primarily categorized as “Other Waters”, which include areas within the OHWM lacking either hydric soils and/or hydrophytic vegetation. Within the project site, Prefumo Creek and Cerro San Luis Channel consist of approximately 0.14 acre of wetlands and 0.69 acre of other waters. In addition, both features exhibit defined bed and banks in portions of their extents within the project site and are hydrologically connected San Luis Obispo Creek and the Pacific Ocean, which is a Traditional Navigable Water (TNW). Furthermore, both features are of value to special status wildlife species such as CRLF and steelhead. Therefore, these waterways would likely be considered Waters of U.S. as well as Waters of the State pursuant to the Porter- Cologne Water Quality Control Act and would be subject to regulation by the USACE as well as the SWRCB and Central Coast RWQCB. The riparian and eucalyptus grove habitats within the top of bank and immediately adjacent to the top of bank bordering these waterways would likely fall under the jurisdiction of the Central Coast RWQCB. In addition, both features and their associated riparian and eucalyptus grove habitats would likely fall under the jurisdiction of the CDFW. Within the project site, both waterways and supporting riparian and eucalyptus grove habitat account for 2.17 acres of RWQCB and CDFW jurisdiction. The final jurisdictional determinations of the boundaries of wetlands, waters, and riparian habitat are made by each agency, typically at the time that authorizations to impact such features are requested. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-41 Table 4.4-5 Summary of Potentially Jurisdictional Wetlands, Waters and Riparian Habitats Jurisdictional Features Jurisdictional Type Area (acres) Length (feet) Prefumo Creek and Cerro San Luis Channel CWA Sections 404/401 (USACE/RWQCB) Other Waters of the U.S. 0.69 1,748 Prefumo Creek and Cerro San Luis Channel CWA Sections 404/401 (USACE/RWQCB) Wetland Waters of the U.S. 0.14 629 Prefumo Creek and Cerro San Luis Channel Porter-Cologne (RWQCB) & CFGC Section 1602 (CDFW) Waters of the State 2.17 2,487 f. Regulatory Setting. The following is a summary of the regulatory context under which biological resources are managed at the federal, state, and local level. Agencies with responsibility for protection of biological resources within the project site include: • U.S. Fish and Wildlife Service and National Marine Fisheries Service (federally listed species, candidate and proposed species for federal listing, and migratory birds); • U.S. Army Corps of Engineers (waters of the United States, including wetlands); • California Department Fish and Wildlife (state listed and fully-protected species, and other special status plants, wildlife and habitats, including streams, rivers, lakes and riparian vegetation); • Central Coast Regional Water Quality Control Board (waters of the State); and • County of San Luis Obispo (special status plants, wildlife, and habitats). A number of federal and/or State statutes provide a regulatory structure that guides the protection of biological resources. The following discussion provides a summary of those laws that are most relevant to biological resources in the project site. Federal. Federal agencies with jurisdiction within the project site include the USFWS, NMFS, and USACE. United States Fish and Wildlife Service and National Marine Fisheries Service. The USFWS implements the Migratory Bird Treaty Act (16 United States Code [USC] Section 703-711) and the Bald and Golden Eagle Protection Act (16 USC Section 668). The USFWS and NMFS share responsibility for implementing the Federal Endangered Species Act (FESA) (16 USC § 153 et seq.). The USFWS generally implements the FESA for terrestrial and freshwater species, while the NMFS implements the FESA for marine and anadromous species. Projects that would result in take of any federally listed threatened or endangered species are required to obtain permits from the USFWS or NMFS through either Section 7 (interagency consultation with a federal nexus) or Section 10 (Habitat Conservation Plan) of FESA, depending on the involvement by the federal government in permitting and/or funding of the project. The permitting process is used to determine if a project would jeopardize the continued existence of a listed species and what measures would be required to avoid jeopardizing the species. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-42 “Take” under federal definition means to harass, harm (which includes habitat modification), pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct. Proposed or candidate species do not have the full protection of FESA; however, the USFWS and NMFS advise project applicants that they could be elevated to listed status at any time. U.S. Army Corps of Engineers. Under Section 404 of the Clean Water Act (CWA) and Section 10 of the Rivers and Harbors Act (RHA), the USACE has authority to regulate activities resulting in the discharge of dredged or fill material into waters of the United States, including wetlands. The USACE administers the federal policy embodied in Executive Order 11990, which, when implemented, is intended to result in no-net-loss of wetland functions, values or area. In achieving the goals of the CWA and RHA, the USACE seeks to avoid adverse impacts and to offset unavoidable adverse impacts on existing aquatic resources. Any fill or adverse modification of waters of the U.S. and/or associated wetlands would require a permit from the USACE prior to the start of work. Typically, permits issued by the USACE include as a condition of the project prescribed mitigation to offset unavoidable impacts to wetlands in a manner that achieves the goal of no-net-loss of wetlands. State. State agencies with jurisdiction within the project site include the RWQCB and CDFW. Regional Water Quality Control Board. The SWRCB and the local Central Coast RWQCB have jurisdiction over “waters of the State,” pursuant to the Porter-Cologne Water Quality Control Act, which are defined as any surface water or groundwater, including saline waters, within the boundaries of the State. The SWRCB has issued general Waste Discharge Requirements regarding discharges to “isolated” waters of the State (Water Quality Order No. 2004-0004-DWQ, Statewide General Waste Discharge Requirements for Dredged or Fill Discharges to Waters Deemed by the U.S. Army Corps of Engineers to be Outside of Federal Jurisdiction). The Central Coast RWQCB enforces actions under this general order for isolated waters not subject to Federal jurisdiction, and is also responsible for the issuance of water quality certifications pursuant to Section 401 of the Clean Water Act for waters subject to Federal jurisdiction. California Department of Fish and Wildlife. The CDFW derives its authority from the Fish and Game Code of California and the California Endangered Species Act (CESA; Fish and Game Code Section 2050 et seq.), which prohibits take of state listed as threatened or endangered species. Take under CESA is restricted to the direct killing of a listed species and does not prohibit indirect harm by way of habitat modification. California Fish and Game Code Sections 3503, 3503.5, and 3511 describe unlawful take, possession, or needless destruction of birds, nests, and eggs. Fully protected birds (Section 3511) may not be taken or possessed except under specific permit. Section 3503.5 of the Code protects all birds-of-prey and their eggs and nests against take, possession, or destruction of nests or eggs. Species of Special Concern (SSC) is a category used by the CDFW for those species that are considered to be indicators of regional habitat changes or are considered to be potential future protected species. Species of Special Concern do not have any special legal status except that which may be afforded by the Fish and Game Code as noted above. The SSC category is San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-43 intended by the CDFW for use as a management tool to include these species into special consideration when decisions are made concerning the development of natural lands. The CDFW also has authority to administer the Native Plant Protection Act (NPPA) (Fish and Game Code Section 1900 et seq.). The NPPA requires the CDFW to establish criteria for determining if a species, subspecies, or variety of native plant is endangered or rare. Under Section 1913(c) of the NPPA, the owner of land where a rare or endangered native plant is growing is required to notify the department at least 10 days in advance of changing the land use to allow for salvage of plant. Perennial and intermittent streams and associated riparian vegetation, when present, also fall under the jurisdiction of the CDFW. Section 1600 et seq. of the Fish and Game Code (Lake and Streambed Alteration Agreements) gives the CDFW regulatory authority over work within the stream zone (which could extend to the 100-year flood plain) consisting of, but not limited to, the diversion or obstruction of the natural flow or changes in the channel, bed, or bank of any river, stream or lake. Local. Local agencies with jurisdiction within the project site include the City of San Luis Obispo (City) and County of San Luis Obispo. City of San Luis Obispo General Plan. The City of San Luis Obispo General Plan addresses biological resources and compatibility with urban development through implementation of adopted policies and programs in the City’s updated General Plan Land Use Element and Conservation and Open Space Element (COSE). The Land Use Element and COSE include policies require protection of special-status plant and animal species and associated habitat and biological resources, including open spaces, creeks and wetlands, trees, ecotones, and wildlife corridors. These local policy requirements pertaining to biological resources will be implemented in the San Luis Ranch Specific Plan Area through incorporation of the mitigation measures presented in this document. Land Use Element. The following Land Use Element policies define the local regulatory setting for biological resources in the San Luis Ranch Specific Plan Area: Policy 1.8.6. Wildlife Habitat. The City shall ensure that continuous wildlife habitat – including corridors free of human disruption - are preserved, and, where necessary, created. Policy 1.8.7. Trees Outside City Limits. The City shall preserve significant trees, particularly native species, outside its limits and in the greenbelt on lands owned or leased by the City or for which the City has an easement. For other areas in the greenbelt, the City will work with the County, Cal Poly, and other public agencies to protect these trees. Policy 2.3.7. Natural Features. The City shall require residential developments to preserve and incorporate as amenities natural site features, such as land forms, views, creeks, wetlands, wildlife habitats, wildlife corridors, and plants. Policy 6.3.1. Open Space and Greenbelt Designations. The City shall designate the following types of land as open space: A Upland and valley sensitive habitats or unique resources, as defined in the Conservation and Open Space Element, including corridors which connect habitats. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-44 B Undeveloped prime agricultural soils which are to remain in agricultural use as provided in Policy 1.9.2. C Those areas which are best suited to non-urban uses due to: infeasibility of providing proper access or utilities; excessive slope or slope instability; wildland fire hazard; noise exposure; flood hazard; scenic value; wildlife habitat value, including sensitive habitats or unique resources as defined in the Conservation and Open Space Element; agricultural value; and value for passive recreation. D A greenbelt, outside the urban reserve, that surrounds the ultimate boundaries of the urban area, and which should connect with wildlife corridors that cross the urbanized area. E Sufficient area of each habitat type to ensure the ecological integrity of that habitat type within the urban reserve and the greenbelt, including connections between habitats for wildlife movement and dispersal; these habitat types will be as identified in the natural resource inventory, as discussed in the “Background to this Land Use Element Update” and in Community Goal #8. Public lands suited for active recreation will be designated Park on the General Plan Land Use Element Map. The City may establish an agricultural designation. (See the Conservation and Open Space Element for refinements of these policies.) Policy 6.3.2. Open Space Uses. Lands designated Open Space should be used for purposes which do not need urban services, major structures, or extensive landform changes. Such uses include: watershed protection; wildlife and native plant habitat; grazing; cultivated crops; and passive recreation. The City shall require that buildings, lighting, paving, use of vehicles, and alterations to the landforms and native or cultural landscapes on open space lands are minimized, so rural character and resources are maintained. Buildings and paved surfaces, such as parking or roads, shall not exceed the following: where a parcel smaller than ten acres already exists, five percent of the site area; on a parcel of ten acres or more, three percent. (As explained in the Conservation and Open Space Element, the characteristics of an open space area may result in it being suitable for some open space uses, but not the full range.) Parcels within Open Space areas should not be further subdivided. Policy 6.4.3: Amenities and Access. New public or private developments adjacent to the lake, creeks, and wetlands must respect the natural environment and incorporate the natural features as project amenities, provided doing so does not diminish natural values. Developments along creeks should include public access across the development site to the creek and along the creek, provided that wildlife habitat, public safety, and reasonable privacy and security of the development can be maintained, consistent with the Conservation and Open Space Element. Policy 6.6.1. Creek and Wetlands Management Objectives. The City should manage its lake, creeks, wetlands, floodplains, and associated wetlands to achieve the multiple objectives of: A Maintaining and restoring natural conditions, and fish and wildlife habitat; B Preventing loss of life and minimizing property damage from flooding; C Providing recreational opportunities which are compatible with fish and wildlife habitat, flood protection and use of adjacent private properties; and D Recognizing and distinguishing between those sections of creeks and Laguna Lake which are in previously urbanized areas, such as the downtown core and sections which are in largely natural areas. Those sections already heavily impacted by urban San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-45 development and activity may be appropriate for multiple use whereas creeks and lakeshore in a more natural state shall be managed for maximized ecological value. Policy 6.6.2. Citywide Network. The City shall include the lake, creeks, and wetlands as part of a citywide and regional network of open space, parks, and – where appropriate – trails, all fostering understanding, enjoyment, and protection of the natural landscape and wildlife. Policy 6.6.3. Amenities and Access. New public or private developments adjacent to the lake, creeks and wetlands must respect the natural environment and incorporate the natural features as project amenities, provided doing so does not diminish natural values. Developments along creeks should include public access across the development site to the creek and along the creek, provided that wildlife habitat, public safety, and reasonable privacy and security of the development can be maintained, consistent with the Conservation and Open Space Element. Conservation and Open Space Element. The COSE includes goals that address biological resources, including Goal 7.2 Sustainable Natural Populations which includes Policies 7.3.1 through 7.3.3, Goal 7.4 Trees and other Plants which includes Policies 7.5.1 through 7.5.6, and Goal 7.7 Program which includes policies 7.7.1 through 7.7.9. The following COSE policies define the local regulatory setting for biological resources in the San Luis Ranch Specific Plan Area: Policy 7.3.1.A-D. Protect Listed Species. The City will comply with state and federal requirements; the City will protect listed species through its actions on: land-use designations; development standards; development applications; location, design, construction and maintenance of creeks, City roads and facilities; and on land that the City owns or manages. Additionally, the City may approve a project where mitigation requires relocation of a species if there is no practicable alternative. Policy 7.3.2. Species of Local Concern. The City will: • Maintain healthy populations of native species in the long term, even though they are not listed for protection under State or Federal laws. These “species of local concern” are at the limit of their range in San Luis Obispo, or threats to their habitat are increasing. • Identify the location, habitat and buffer needs of species of local concern. This information will be developed by qualified people early in the planning and development review process. • Protect species of local concern through: its actions on land use designations, development standards, development applications; the location, design, construction and maintenance of City facilities; land that the City owns or manages. • Encourage individuals, organizations and other agencies to protect species of local concern within their areas of responsibility and jurisdiction. • Protect sensitive habitat, including creeks, from encroachment by livestock and human activities Policy 7.3.3. Wildlife Habitat and Corridors. Continuous wildlife habitat, including corridors free of human disruption, shall be preserved and where necessary, created by interconnecting open spaces, wildlife habitat and corridors. To accomplish this, the City will: San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-46 • Require public and private developments, including public works projects, to evaluate animal species and their movements within and through development sites and create habitats and corridors appropriate for wildlife. • Plan for connectivity of open spaces and wildlife habitat and corridors using specific area plans, neighborhood plans, subdivision maps or other applicable planning processes, consistent with Open Space Guidelines. • Coordinate with San Luis Obispo County and adjoining jurisdictions, federal and state agencies such as Caltrans to assure regional connectivity of open space and wildlife corridors. • Preserve and expand links between open spaces and creek corridors. Policy 7.5.1. Protection of Significant Trees. Significant trees, as determined by the City Council upon the recommendation of the Tree Committee, Planning or Architectural Review Committee, are those making substantial contributions to natural habitat or to the urban landscape due to their species, size, or rarity. Significant trees, particularly native species, shall be protected. Removal of significant trees shall be subject to the criteria and mitigation requirements in Chapter 8.6.3. Oak Woodland communities in the Greenbelt and in open space areas shall be protected. Policy 7.5.2. Use of Native California Plants in Urban Landscaping. Landscaping should incorporate native plant species, with selection appropriate for location Policy 7.5.3. Heritage Tree Program. The City will continue a program to designate and help protect “heritage trees.” Policy 7.5.4. Preservation of grassland communities and other habitat types. Grassland communities and other habitat types in the Greenbelt and in designated open space areas shall be preserved. Policy 7.5.5. Soil Conservation and Landform modification. Public and private development projects shall be designed to prevent soil erosion, minimize landform modifications to avoid habitat disturbance and conserve and reuse onsite soils. Policy 7.7.6. Replace Invasive, Non-Native Vegetation with Native Vegetation. The City and private development will protect and enhance habitat by removing invasive, non- native vegetation that detracts from habitat values and by replanting it with native California plant species. The Natural Resources Manager will prioritize projects and enlist the help of properly trained volunteers to assist in non-native vegetation removal and replanting when appropriate. Policy 7.7.7. Preserve Ecotones. Condition or modify development approvals to ensure that “ecotones,” or natural transitions along the edges of different habitat types, are preserved and enhanced because of their importance to wildlife. Natural ecotones of particular concern include those along the margins of riparian corridors, marshlands, vernal pools and oak woodlands where they transition to grasslands and other habitat types. Policy 7.7.8. Protect Wildlife Corridors. Condition development permits in accordance with applicable mitigation measures to ensure that important corridors for wildlife movement and dispersal are protected. Features of particular importance to wildlife include San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-47 riparian corridors, wetlands, lake shorelines, and protected natural areas with cover and water. Linkages and corridors shall be provided to maintain connections between habitat areas. Policy 7.7.9. Creek Setbacks. As further described in the zoning regulations (Section 17.16.025), the City will maintain creek setbacks to include: an appropriate separation from the physical top of bank, the appropriate floodway as identified in the Flood Management Policy, native riparian plants or wildlife habitat and space for paths called for by any city-adopted plan. In addition, creek setbacks should be consistent with the following: • The following items should be no closer to the wetland or creek than the setback line: buildings, streets, driveways, parking lots, aboveground utilities, and outdoor commercial storage or work areas. • Development approvals should respect the separation from creek banks and protection of floodways and natural features identified in Part A above, whether or not the setback line has been established. • Features which normally would be outside the creek setback may be permitted to encroach where there is no practical alternative, to allow reasonable development of a parcel, consistent with the Conservation and Open Space Element. • Existing bridges may be replaced or widened, consistent with policies in this Element. Removal of any existing bridge or restoration of a channel to more natural conditions will provide for wildlife corridors, traffic circulation, access, utilities and reasonable use of adjacent properties. Policy 8.3.1. Open Space within an Urban Area. The City will preserve the areas listed in Goal 8.2.2 (creek corridors, including open channel with natural banks and vegetation, wetlands and vernal pools, grassland communities and woodlands, wildlife habitat corridors, habitat of listed species, and unique plant and animal communities including “species of local concern”) and will encourage individuals, organizations, and other agencies to do likewise. The City will designate these areas as Open Space or Agriculture in the General Plan. Policy 8.3.2. Open Space Buffers. When activities close to open space resources within or outside the urban area could harm them, the City will require buffers between the activities and the resources. The City will actively encourage individuals, organizations and other agencies to follow this policy. Buffers associated with new development shall be on the site of the development, rather than on neighboring land containing the open space resource. Buffers provide distance in the form of setbacks, within which certain features or activities are not allowed or conditionally allowed. Buffers shall also use techniques such as planting and wildlife- compatible fencing. Buffers shall be adequate for the most sensitive species in the protected area, as determined by a qualified professional and shall complement the protected area’s habitat values. Buffers shall be required in the following situations (one of the five noted here, see COS Policy 8.3.2 for the remainder): • Between urban development -- including parks and public facilities-- and natural habitats such as creeks, wetlands, hillsides and ridgelines, Morros, scenic rock outcrops and other significant geological features, and grassland communities, to address noise, lighting, storm runoff, spread of invasive, non-native species, and access by people and pets (see also the Safety Element for “defensible space” next to wildland fire areas). San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-48 Policy 8.6.3.G. Required Mitigation. Any development that is allowed on a site designated as Open Space or Agriculture, or containing open-space resources, shall be designed to minimize its impacts on open space values on the site and on neighboring land. • Creek corridors, wetlands, grassland communities, other valuable habitat areas, archaeological resources, agricultural land, and necessary buffers should be within their own parcel, rather than divided among newly created parcels. Where creation of a separate parcel is not practical, the resources shall be within an easement. The easement must clearly establish allowed uses and maintenance responsibilities in furtherance of resource protection. Policy 8.7.2.C. Enhance and Restore Open Space. Remove invasive, non-native species in natural habitat areas, and prevent the introduction or spread of invasive, non-native species and pathogens. City of San Luis Obispo Zoning Regulations. Section 17.16.025. Creek Setbacks. As stated in the zoning regulations, creek setbacks apply to all creeks defined in the COSE (refer to Figure 9 of the COSE), and are measured from the existing top of bank or from the outside edge of the predominant riparian vegetation, whichever is farther from the creek flow line. The zoning regulations specify different setback dimensions for different classes of covered waterways such as whether the creek was within the 1996 City limits or annexed after 1996. Tank Farm Creek qualifies under the zoning regulations for a twenty-foot setback from the top of the bank or outside edge of riparian vegetation; however, the City may require larger setbacks for discretionary projects in order to avoid environmental impacts. 4.4.2 Previous Program-Level Environmental Review In 2014, the update of the City’s Land Use and Circulation Elements included some minor revisions to the COSE. The City’s 2014 Land Use and Circulation Element Update EIR (LUCE Update EIR) provided a programmatic assessment of City-wide biological resource impacts related to the Land Use and Circulation Element update, including a brief discussion of those related to development of the San Luis Ranch Specific Plan Area. The LUCE Update EIR noted that implementation of a Specific Plan on the site could result in impacts to: Coastal and Valley Freshwater Marsh habitat associated in particular with Prefumo Creek; special‐status plant species associated with Prefumo Creek and associated riparian habitats; and special‐status wildlife species associated with Prefumo Creek and with the existing on-site eucalyptus groves. However, the LUCE Update EIR concluded that implementation of the proposed Land Use Element policies and amendments to existing City policies would reduce program-level impacts to a less than significant level. In particular, incorporation of COSE Policies 7.3.1 through 7.3.3, which require protection of species and sensitive habitats and also require areas containing sensitive resources to undergo individual project environmental review, and Land Use Element Policies 6.6.1 and 6.6.2, which provide management guidelines for the protection of creeks, wetlands, and other open spaces, were found to reduce program-level impacts associated with the development of the San Luis Ranch Specific Plan Area to a less than significant level. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-49 4.4.3 Impact Analysis a. Methodology and Significance Thresholds. This impact analysis is based on site reconnaissance conducted in April, May, and June 2014 by Althouse and Meade, and in April and May 2016 by Rincon, as well as review of aerial photography and topographic maps and available literature regarding the existing biological resources within the project site in the Biological Constraints Report, California Red-legged Frog Protocol Survey Site Assessment and Delineation of Potential Jurisdictional Wetlands and Waters prepared by Althouse and Meade (refer to Appendix F). Construction impacts are assessed based on information provided within the Specific Plan and preliminary development plan, which include the approximate size, location, and grade of building pads, location and area of disturbance associated with roadways, bicycle and pedestrian paths, culvert crossing proposed over the Cerro San Luis Drainage Swale, Froom Ranch Way bridge crossing, and location and size of utility and drainage infrastructure (refer to Section 2.0, Project Description). This was used to determine the area of disturbance to vegetative communities and associated species. CEQA, Chapter 1, Section 21001(c) states that it is the policy of the State of California to “prevent the elimination of fish and wildlife species due to man’s activities, ensure that fish and wildlife populations do not drop below self-perpetuating levels, and preserve for future generations representations of all plant and animal communities.” Environmental impacts relative to biological resources may be assessed using impact significance criteria encompassing CEQA guidelines and federal, state and local plans, regulations, and ordinances. The following thresholds are based on the City’s Initial Study and Appendix G of the State CEQA Guidelines. Impacts would be significant if the San Luis Ranch Project would result in any of the following: 1. A substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; 2. A substantial adverse effect, on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; 3. A substantial adverse effect on federally protected wetlands as defined in Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; 4. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; 5. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or 6. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. The project is not reasonably expected to conflict with local policies or ordinances protecting biological resources. Refer to Section 4.10, Land Use and Policy Consistency, for detailed discussions of the Specific Plan’s compliance with applicable local policies. In addition, as San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-50 described in the project Initial Study (refer to Appendix A), the San Luis Ranch Specific Plan Area is not part of any adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Refer to Section 4.14, Issues Addressed in the Initial Study, for a discussion of these issues. Therefore, Thresholds 5 and 6 are not discussed further in this section. b. Impact Statements and Mitigation. Threshold 1: Would the project have a substantial adverse impact, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. Impact BIO-1 Implementation of the project could have a substantial adverse effect on candidate, sensitive, or special status species that may occur on the project site. Impacts would be Class II, potentially significant but mitigable. The San Luis Ranch Specific Plan Area would be developed over six phases, beginning in 2017. Construction is planned to be completed in 2023. Project construction would entail the clearing of approximately 69.2 acres of development (including area for residential and commercial development, parks, and roadways) as well as within much of the planned 7.6 acres of open space bike paths, utilities, drainage facilities, culvert crossing proposed over the Cerro San Luis Drainage Swale, and habitat restoration. As a project requirement, construction would also occur offsite at the proposed Froom Ranch Way bridge crossing location in the southwest corner of the project site (depicted on the western side of the site in Figure 4.4-1). Project construction would include the ongoing operation of heavy construction equipment, vehicles, and presence of construction crews within or near sensitive biological habitats, such as wetland and riparian corridors within Prefumo Creek and Cerro San Luis Channel, and would have the potential to affect sensitive species within those habitats. Construction crews and heavy equipment would potentially be operating within and adjacent to riparian corridors in order to conduct site preparation, grading, tree removal, trenching, and paving activities for bicycle paths, roadway infrastructure, the Froom Ranch Way bridge crossing, and utilities over several phases extended over several years. Construction work within riparian corridors would consist of activities associated with the Froom Ranch Way bridge crossing, bench widening along Prefumo Creek, and channel improvements to the eastern portion of Cerro San Luis Channel (refer to Impact BIO-2 for a specific discussion of impacts to riparian habitat). Construction activity could temporarily impact habitat by generating noise, dust, petro- chemical pollutants, liquid sediments, and other waste that contaminate wildlife habitat. Contamination of water sources and food supplies, and the related reduction in available forage would cause direct effects to sensitive wildlife. Prolonged construction activities and exposure of large areas of disturbed soils in the vicinity of Prefumo Creek and Cerro San Luis Channel could result in potential for substantial erosion and sediment flows into these waterways and downstream habitats during grading and site preparation activities. Potential for large volumes of sediment input could compromise aquatic habitat in Prefumo Creek and San Luis Obispo Creek downstream. Changes to the creek flow and hydrology as well as San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-51 potential for release of contaminants into aquatic habitats could directly affect species within these creeks by reducing the quality of existing habitat and causing mortality of individuals. Based on the CNDDB query and review of the USFWS and CNPS species lists, several special status species and habitats occur within the region. Because the plant and animal lists are regional, an analysis of the range and habitat preferences of those species was conducted to identify which sensitive plant and wildlife species have the potential to occur within the project site. In addition, as noted above, wildlife and botanical surveys were conducted on the project site in April, May, and June 2014 by Althouse and Meade, and in April and May 2016 by Rincon. Special Status Plants. No State or federally listed, proposed, candidate or other special status plant species were observed within the project site during the botanical inventories that were conducted for the project. The surveys were seasonally timed to correspond with the blooming periods for the sensitive plant species that have potential to occur onsite. State Special Status Animals (Species of Special Concern, Special Animal, Watch List). Pallid Bat. No pallid bats were detected and no evidence of bats (e.g., guano) was observed within the project site during the field surveys. The CNDDB records pallid bat in the San Luis Obispo area, the nearest documented occurrence of which was less than two miles northeast of the project site (CNDDB #77). The barns, sheds, and small outbuildings onsite are marginally suitable habitat for the pallid bat to roost during the day. The project site does, however, provide suitable foraging habitat and there are water sources within the project site. Potential direct impacts to pallid bats within the project site include removal of roosting habitat and harassment or injury if they are foraging within the project area during implementation. Townsend’s Big-eared Bat. No Townsend’s big-eared bats were detected and no evidence of bat guano was observed within the project site during the field surveys. There are two records of Townsend’s big-eared bat in the CNDDB, the nearest of which is approximately 10 miles northeast of the project site (CNDDB #119). Townsend's big-eared bat has potential to roost during the day in the barns, sheds, and small outbuildings onsite. Potential direct impacts to Townsend’s big-eared within the site include removal of roosting habitat and harassment or injury if they are foraging within the project area during implementation. Monarch Butterfly (overwintering). The project site contains a historic monarch butterfly overwintering site located in the large stand of eucalyptus trees east of Prefumo Creek and south of the farm buildings. Records in the CNDDB indicate that this site has not been occupied by overwintering monarchs since 1998, when only 100 monarchs were observed in clusters. However, surveys conducted by Althouse and Meade in the winter of 2016 documented monarch butterflies overwintering on the project site in the stand of eucalyptus east of Prefumo Creek. Nine trees were identified as monarch aggregation trees within the project site. Direct impacts to this species may occur due to removal of eucalyptus trees if the species are present at the time of removal. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Great Blue Heron (roosting). Great blue herons have been nesting in the project site since at least 1979, though not always in the same trees (Envicom, 1982; Rincon Consultants, Inc., 2004). There is currently an active great blue heron rookery in the northern end of the site, located in the stand of blue gum eucalyptus between the U.S. Post Office and the farm San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-52 buildings. The rookery consists of six nests, at least three of which contained nestlings during the April 2016 survey. The nearby cropland and adjacent Laguna Lake may provide foraging habitat for this species. Direct impacts to this species may occur due to removal of eucalyptus trees that may contain active nests. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Ongoing, increased human presence may also result in indirect impacts once construction is complete. Olive-sided Flycatcher. Olive-sided flycatcher has been known to nest in tall trees (including eucalyptus), near the coast in California. The blue gum eucalyptus trees within the project site contain moderately suitable nesting habitat for this species. One olive-sided flycatcher was detected during the April 29, 2014 survey, most likely a migratory individual. No other individuals were detected during later surveys. Direct impacts to this species may occur due to removal of trees and shrubs that may contain active nests. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Yellow Warbler. There are no breeding records in the CNDDB for yellow warbler in San Luis Obispo County; however, yellow warbler is a regular spring and fall migrant that has been known to breed in the vicinity. The riparian habitat in Prefumo Creek is moderately suitable nesting habitat for this species. Multiple yellow warblers were seen foraging in the willows south of the U.S. Post Office in Cerro San Luis Channel during spring 2014 surveys. The habitat surrounding Cerro San Luis Channel is not suitable nesting habitat for yellow warbler. Direct impacts to this species may occur due to removal of trees and shrubs that may contain active nests. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Loggerhead Shrike. Loggerhead shrike has been documented by the CNDDB within five miles of the project site and is known to occur within the general vicinity. The annual grassland and ornamental trees and shrubs within the ruderal/developed habitats provide suitable nesting and foraging habitat for this species. Direct impacts to this species may occur due to removal of trees and shrubs that may contain active nests. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Merlin. Merlin has been known to winter in various habitats in San Luis Obispo County. Appropriate roosting habitat is present in the eucalyptus grove within the project site. There is low quality foraging habitat in the site; however, appropriate foraging habitat is present nearby at Laguna Lake. Merlin may use habitats on the property seasonally for roosting; however, they are not known to breed on site. No merlins were detected in the project site during the surveys. Direct impacts to this species may occur due to removal of eucalyptus trees that may contain roosting habitat. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Cooper’s Hawk. Cooper’s hawk has been documented by the CNDDB within five miles of the project site and is known to occur regularly in San Luis Obispo County during the winter months and during spring and fall migration. Cooper’s hawks frequent oak and riparian woodland habitats, and increasingly urban areas, where they prey primarily upon small birds. The red willow thicket and eucalyptus grove habitat communities within the project site San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-53 contain suitable nesting habitat for this species. In addition, the site contains suitable foraging habitat in the form of small passerines. A Cooper’s hawk was observed within the project site during the April 29, 2014 survey. The bird was flushed from its perch in a large eucalyptus tree next to Prefumo Creek. Direct impacts to this species may occur due to removal of trees and shrubs that may contain nesting habitat. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. Two-striped Garter Snake. This species has not been previously documented within the San Luis Obispo area in the CNDDB; however, suitable riparian habitat exists in San Luis Obispo Creek half a mile south of the project site, and moderate quality riparian habitat exists in Prefumo Creek. No two-striped garter snakes were observed within the site during the field surveys. Although two-striped garter snakes were not observed during the field surveys, if present during construction potential direct impacts to this species include harassment, injury, as well as destruction of nocturnal retreats. Western Pond Turtle. CNDDB contains numerous reports within the project vicinity, including a record of pond turtles at the confluence of San Luis Obispo Creek and Prefumo Creek approximately half a mile south of the project site (CNDDB #1162). Pond turtles have a low to moderate potential to occur in upland habitat adjacent to Prefumo Creek; however, the potential to occur is high where the Froom Ranch Way crossing is proposed across Prefumo Creek due to sufficient pooling. No pond turtles were detected during the field surveys. Potential direct impacts to western pond turtle include harassment or injury of active as well as overwintering individuals and potential destruction of nests located in upland habitat if they are present within the project area during implementation. Western spadefoot. This species is reported from the general vicinity but has not been documented by the CNDDB within 5-miles of the project site. Therefore, there is low potential for this species to occur onsite. Spadefoots are almost completely terrestrial as adults, but require water to breed. Spadefoots inhabit hot dry environments by burrowing underground using hardened spades on its hind feet. This species spends most of its life underground in earth-filled burrows, and is active above ground typically between October and May, depending on rainfall. Spadefoots typically breed in ephemeral to seasonal pools and ponds with limited vegetation cover. Potentially suitable ephemeral ponding was observed within the Prefumo Creek channel. Implementation of the project may result in loss and/or fragmentation of western spadefoot habitat or breeding habitat. Potential direct impacts to this species may occur if it is foraging or burrowing onsite during construction activities. Coast Range Newt. No evidence of Coast Range newt was found on site; however, suitable habitat is located within portions of the project site. The Prefumo Creek riparian corridor provides suitable habitat for this species and the pooling at the proposed Froom Ranch Way crossing may provide suitable breeding habitat for this species. There are three records in the CNDDB of occurrences within five miles of the project site (northeast of project site). Implementation of the project may result in loss and/or fragmentation of Coast Range newt habitat or breeding sites. Direct impacts to this species could occur if it is foraging or aestivating onsite during construction activities. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-54 Special Status Animals (Fully Protected and Federal/State Listed Species). White-tailed Kite. White-tailed kite has been recorded by the CNDDB within five miles of the project site (Figure 4.4-2) at El Chorro Regional Park (CNDDB #103). The habitats onsite provide poor foraging habitat for this species; however, suitable foraging habitat is present across Madonna Road and around Laguna Lake. The eucalyptus trees bordering Prefumo Creek may provide suitable nest sites for white-tailed kite. No white-tailed kites were detected during surveys. Direct impacts to this species may occur due to removal of trees that may contain active nests. Construction within the project site may result in indirect impacts should this species be present in the vicinity of areas of disturbance at the time of construction. California Red-legged Frog. Implementation of the project will not result in loss or fragmentation of any federally designated critical habitat for CRLF. The majority of the upland habitat within the project site is poor habitat for CRLF; however, the wetland and riparian corridor surrounding Prefumo Creek and Cerro San Luis Channel is suitable dispersal and foraging habitat for this species. The majority of dispersing individuals through the site are expected to occur within and around these two features. Potential direct impacts to CRLF individuals include harassment or injury if they are present within the project area during implementation. Direct permanent impacts to upland habitat that could be used by CRLF are expected to occur within the riparian corridor and wetland habitat surrounding Prefumo Creek and Cerro San Luis Channel. Direct permanent impacts to aquatic habitat within the Prefumo Creek streambed may occur as a result of the construction associated with the Froom Ranch Way bridge crossing and bench widening along Prefumo Creek. Indirect impacts to CRLF could result from general project-related disturbance and noise if individuals are foraging or aestivating within the project site. Indirect impacts may also occur as a result of water quality issues associated with the construction of the Froom Ranch Way crossing and bench widening along Prefumo Creek. Steelhead. Construction of the proposed Froom Ranch Way bridge crossing and bench widening along Prefumo Creek may result in direct impacts to in-stream steelhead critical habitat. Potential direct impacts to individuals include harassment or injury if they are present within the project area during implementation. Indirect impacts may also occur as a result of water quality issues associated with the construction of the bridge and bench widening along Prefumo Creek, and other site runoff. Mitigative Components of the Specific Plan and Impact Conclusion. No special status plant species were observed within the project site during the botanical inventories that were conducted for the project. Therefore, no impacts to sensitive botanical resources are expected to occur and avoidance, minimization, or mitigation measures are not required for project implementation. Special status animal species, including nesting birds and roosting bats, have potential to occur in the habitats on the project site. COSE Policies 7.3.1, Protect Listed Species, and 7.3.2, Species of Local Concern, describe state and federal requirements for the protection of special status species and additional City commitments to protecting species of local concern. Additionally, the San Luis Ranch Specific Plan includes requirements intended to protect and enhances the natural habitats and species onsite. Specific Plan Policy 5.3 and Program 5.3.1 require attention be given to the preservation of biological and habitat resources through the identification of San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-55 sensitive habitats and species early in the development process. Nevertheless, impacts to special status animal species would be potentially significant; therefore, project-specific mitigation is required. Implementation of Mitigation Measures BIO-1(a) through BIO-1(h) would reduce these impacts to a less than significant level. Mitigation Measures. The following measures would reduce impacts to special status animal species to a less than significant level. BIO-1(a) Best Management Practices. The applicant shall ensure the following general wildlife Best Management Practices (BMPs) are required for construction activity within the San Luis Ranch Specific Plan Area: • No pets or firearms shall be allowed at the project site during construction activities. • All trash that may attract predators must be properly contained and removed from the work site. All such debris and waste shall be picked up daily and properly disposed of at an appropriate site. • All refueling, maintenance, and staging of equipment and vehicles shall occur at least 100 feet from Prefumo Creek and in a location where a spill would not drain toward aquatic habitat. A plan must be in place for prompt and effective response to any accidental spills prior to the onset of work activities. All workers shall be informed of the appropriate measures to take should an accidental spill occur. • Pallets or secondary containment areas for chemicals, drums, or bagged materials shall be provided. Should material spills occur, materials and/or contaminants shall be cleaned from the project site and recycled or disposed of to the satisfaction of the Regional Water Quality Control Board (RWQCB). • Prior to construction activities in areas adjacent to Prefumo Creek and Cerro San Luis Channel, the drainage features shall be fenced with orange construction fencing and signed to prohibit entry of construction equipment and personnel unless authorized by the City. Fencing should be located a minimum of 20 feet from the edge of the riparian canopy or top of bank and shall be maintained throughout the construction period for each phase of development. Once all phases of construction in this area are complete, the fencing may be removed. • To control sedimentation during and after project implementation, appropriate erosion control BMPs (e.g., use of coir rolls, jute netting, etc.) shall be implemented to minimize adverse effects on Prefumo Creek. No plastic monofilament netting shall be utilized on site. • Construction equipment shall be inspected at the beginning of each day to ensure that wildlife species have not climbed into wheel wells or under tracks since the equipment was last parked. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-56 Any sensitive wildlife species found during inspections shall be gently encouraged to leave the area by a qualified biological monitor or otherwise trained personnel. • All vehicles and equipment shall be in good working condition and free of leaks. • Environmentally Sensitive Areas shall be delineated by a qualified biologist prior to construction to confine access routes and construction areas. • Construction work shall be restricted to daylight hours (7:00 AM to 7:00 PM) to avoid impacts to nocturnal and crepuscular (dawn and dusk activity period) species. No construction night lighting shall be permitted within 100 yards of the top of the Prefumo Creek bank. • Concrete truck and tool washout shall be limited to locations designated by a qualified biologist such that no runoff will reach Prefumo Creek or Cerro San Luis Channel. • All open trenches shall be constructed with appropriate exit ramps to allow species that accidentally fall into a trench to escape. Trenches will remain open for the shortest period necessary to complete required work. • Existing facilities and disturbed areas shall be used to the extent possible to minimize the amount of disturbance and all new access roads other than the Froom Ranch Way Bridge shall be cited to avoid high quality habitat and minimize habitat fragmentation. • In the event that construction must occur within the creek or creek setback, a biological monitor shall be present during all such activities with the authority to stop or redirect work as needed to protect biological resources. BIO-1(b) Worker Environmental Awareness Program Training. Prior to the initiation of construction activities (including staging and mobilization), the applicant shall ensure all personnel associated with project construction attend a Worker Environmental Awareness Program (WEAP) training. • The training shall be conducted by a qualified biologist, to aid workers in recognizing special status resources that may occur in the project area. The specifics of this program shall include identification of the sensitive species and habitats, a description of the regulatory status and general ecological characteristics of sensitive resources, and review of the limits of construction and avoidance measures required to reduce impacts to biological resources within the work area. A fact sheet conveying this information shall also be prepared for distribution to all contractors, their employers, and other personnel involved with construction of the project. All employees shall sign a form San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-57 provided by the trainer documenting they have attended the WEAP and understand the information presented to them. BIO-1(c) Western Pond Turtle and Two-Striped Garter Snake Impact Avoidance and Minimization. The applicant shall ensure the following actions are implemented to avoid and minimize potential impacts to western pond turtle and two-striped garter snake (these reptiles utilize similar habitats; therefore, implementation of the proposed measures for western pond turtle are also suitable and appropriate for two-striped garter snake): • A qualified biologist(s) shall conduct a pre-construction survey within 24 hours prior to the onset of work activities within and around areas that may serve as potential western pond turtle habitat. If this species is found and the individuals are likely to be injured or killed by work activities, the approved biologist shall be allowed sufficient time to move them from the project site before work activities begin. The biologist(s) must relocate the any western pond turtle the shortest distance possible to a location that contains suitable habitat that is not likely to be affected by activities associated with the project. • Access routes, staging, and construction areas shall be limited to the minimum area necessary to achieve the project goal and minimize potential impacts to western pond turtle habitat including locating access routes and construction staging areas outside of wetlands and riparian areas to the maximum extent practicable. BIO-1(d) California Red-legged Frog, Western spadefoot, and Coast Range Newt Impact Avoidance and Minimization. The applicant shall implement the following to avoid and minimize potential impacts to CRLF. Because coast range newt and western spadefoot are amphibians that utilize similar habitats to CRLF, implementation of the following measures provided for CRLF shall be implemented for these species as well. • Only USFWS-approved biologists shall participate in activities associated with the capture, handling, and monitoring of CRLF. • Ground disturbance shall not begin until written approval is received from the USFWS that the biologist is qualified to conduct the work. If the USFWS does not authorize the relocation of CRLF occurring within the project site, CRLF found within the project site shall be avoided with a 100-foot buffer and no activities shall occur within that buffer until the CRLF has left the project site on its own. • Areas of the project site that lie within 100 feet upland from riparian or jurisdictional areas shall be surrounded by a solid temporary exclusion fence (such as silt fencing) that shall extend at least three feet above the ground and be buried into the ground San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-58 at least 6 inches to exclude CRLF from the project site. Plastic monofilament netting or other similar material will not be used. The location of the fencing shall be determined by a qualified biologist. The fence shall remain in place throughout construction activities. Installation of the exclusion fencing shall be monitored by a qualified biologist to ensure that it is installed correctly. • During new grading activities in habitats within 100 feet upland from riparian or jurisdictional areas, a qualified biologist shall be on-site to recover any spadefoot toads that may be excavated/unearthed with native material or found under vegetation. If the animals are in good health, they shall be immediately relocated to a designated release area. If they are injured, the animals shall be turned over to an approved wildlife rehabilitator until they are in a condition to be released into the designated release area. • To ensure that diseases are not conveyed between work sites by the approved biologist, the fieldwork code of practice developed by the Declining Amphibian Populations Task Force shall be followed at all times. BIO-1(e) Steelhead Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to steelhead: • Before any activities begin on the project, a qualified biologist will conduct a training session for all construction personnel. At a minimum, the training will include a description of the steelhead and its habitat, the specific measures that are being implemented to conserve this species for the project, and the boundaries within which the project may be accomplished. Brochures, books, and briefings may be used in the training session, provided that a qualified person is on hand to answer any questions. • During the duration of project activities, all trash that may attract predators will be properly contained and secured, promptly removed from the work site, and disposed of regularly. Following construction, all trash and construction debris will be removed from the work areas. • All refueling, maintenance, and staging of equipment and vehicles will occur at least 100 feet from riparian habitat or bodies of water and in a location where a potential spill would not drain directly toward aquatic habitat (e.g., on a slope that drains away from the water source). The monitor shall ensure that contamination of suitable habitat does not occur during such operations. Prior to the onset of work activities, a plan must be in place for prompt and effective response to any accidental spills. All workers shall be informed of the importance of preventing spills and of the appropriate measures to take should an accidental spill occur. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-59 • The number of access routes, size of staging areas, and the total area used for construction activities shall be limited to the minimum area necessary to achieve the project goals. • The City will only permit work within the immediate vicinity of Prefumo Creek for times of the year when potential impacts to steelhead would be minimal. Work shall be restricted during the wet season (October 15 through April 30) and should ideally occur during the late summer and early fall during the driest portion of the year; however, water may still be present during construction. If work is proposed in the streambed and water is present during construction, a diversion will be required to dewater the work area and the following avoidance and minimization measures will apply: 1. Upstream and downstream passage for fish, including juvenile steelhead, shall be provided through or around the construction site at all times construction is occurring within the Prefumo Creek streambed. 2. A qualified biologist shall conduct a pre-construction survey and be present onsite during the diversion installation and dewatering process to capture and relocate any trapped steelhead and/or other fish. Upon approval from the NMFS, the biologist(s) must relocate these individuals the shortest distance possible to a location that contains suitable habitat that is not likely to be affected by activities associated with the project. 3. Dewatering operations shall employ a five millimeter mesh screen fastened to the intake hose to exclude fish and other wildlife species from the pump. 4. Steelhead shall be excluded from the construction zone with block nets installed upstream and downstream the of the bridge construction zone. The distance upstream and downstream for block net installation will depend on the type of construction activities occurring in the streambed. • To control sedimentation during and after project implementation, the following BMPs shall be implemented. If the BMPs are somehow ineffective, consultation with the City and appropriate resource agencies will be undertaken, and all attempts to remedy the situation will commence immediately. 1. It shall be the owner’s/contractor’s responsibility to maintain control of the entire construction operations and to keep the entire site in compliance. 2. The owner/contractor shall be responsible for monitoring erosion and sediment control measures (including but not limited to fiber rolls, inlet protections, silt fences, and gravel bags) prior, during and after storm events, monitoring includes maintaining a file documenting onsite inspections, problems encountered, corrective actions, and notes and a map of remedial implementation measures. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-60 3. Erosion shall be controlled by covering stockpiled construction materials (i.e. soil, spoils, aggregate, fly-ash, stucco, hydrated lime, etc.) All earth stockpiles over 2.0 cubic yards that are not actively being used, shall be covered with a tarp consistent with the applicable construction general permit, or through other means of erosion control approved by the City (e.g., and ringedsurrounding with straw bales or silt fencing). The site shall be maintained to minimize sediment-laden runoff to any storm drainage system including existing drainage swales and/or sand watercourses. a. Construction operations shall be carried out in such a manner that erosion and water pollution will be minimized. b. State and local laws concerning pollution abatement shall be complied with. c. If grading operations are expected to denude slopes, the slopes shall be protected with erosion control measures immediately following grading on the slopes. 4. Specifically, in order to prevent sedimentation and debris from entering Prefumo Creek during construction, silt fencing shall be installed along the top of the banks on the west side of the channel prior to the onset of construction activities. • The project biologist will monitor construction activities, in stream habitat, and overall performance of BMPs and sediment controls for the purpose of identifying and reconciling any condition that could adversely affect steelhead or their habitat. The biologist will halt work if necessary and will recommend site- specific measures to avoid adverse effects to steelhead and their habitat. • Equipment will be checked daily for leaks prior to the initiation of construction activities. A spill kit will be placed near the creek and will remain readily available during construction in the event that any contaminant is accidentally released. • In addition to these avoidance and minimization measures, Mitigation Measure BIO-2(a) would also ensure that potential temporary and permanent indirect impacts to steelhead from the project are reduced as much as practicable. BIO-1(f) Great Blue Heron and Monarch Butterfly Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to overwintering monarch butterflies and nesting great blue herons. • Tree trimming/removal and construction activities that affect eucalyptus trees near or within the monarch overwintering grove or active great blue heron nests identified in the San Luis Ranch Monarch Trees Inspection Memo, Results of 2015 and 2016 San Luis San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-61 Ranch Heron Rookery Surveys Memo, and San Luis Ranch – Prefumo Creek Widening Biological Constraints Memo prepared by Althouse and Meade (Appendix F), shall not be conducted during the monarch butterfly overwintering season from October 1 through March 31 if monarch butterflies are present, or while great blue heron nests are active from February 1 to August 31. If construction activities must be conducted during these periods, a qualified biologist shall conduct overwintering monarch surveys and/or nesting great blue heron surveys within one week of habitat disturbance. If surveys do not locate clustering monarchs or nesting great blue herons, construction activities may be conducted. If clustering monarchs and/or nesting great blue herons are located, no construction activities shall occur within 100 feet of the edge of the overwintering grove and/or active nest(s) until the qualified biologist determines that no more monarchs are overwintering in the grove or the nest(s) are no longer active. • A qualified biologist shall prepare and implement a habitat enhancement plan prior to issuance of grading permits to enhance and restore overwintering and nesting habitat that is to be preserved. The habitat enhancement plan shall include native shrubs and trees such as Monterey Cypress (Hesperocyparis macrocarpa) that may support heron roosting and monarch butterfly overwintering. As eucalyptus trees senesce, they shall be replaced with native species. Native trees and shrubs shall also be used to supplement gaps in canopy or act as windbreaks. • Create new offsite nesting habitat for great blue herons to mitigate for removal of onsite nesting habitat. With a qualified biologist present, the current rookery may be moved to a suitable offsite location where the same great blue herons can resume nesting, following methods detailed in Crouch et al. (2002). It should be noted that creating offsite nesting habitat for great blue herons is experimental and that the relocation techniques described in Crouch et al. (2002) were used to relocate black-crowned night heron (Nycticorax nycticorax). In addition, an agreement with the City will be required prior to implementation of the offsite strategy on their property. The methods detailed in Crouch et al. (2002) include: a. This entails at least one year of pre-construction monitoring of the rookery, where the timing of rookery activities will be noted: arrival of breeding adults, egg laying, hatching, and fledging. During this time, audio recordings of adults and juveniles shall be made. b. Following the completion of the nesting season in late summer, a certified arborist specializing in the translocation of trees will examine the mature trees San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-62 onsite and work with the City’s Natural Resources Manager to determine whether or not it is feasible to relocate the mature trees containing nests the mature trees containing nests shall be boxed and moved across Madonna Road to a suitable location at Laguna Lake Open Space. c. Prior to the start of the next nesting season (based on timing of adult arrival in previous years), nesting adults will be recruited to the new location via decoys and playback of vocalizations. The new location will be monitored regularly by a qualified biologist for the following three breeding seasons. BIO-1(g) Nesting Birds Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to nesting birds: • For construction activities occurring during the nesting season (generally February 1 to September 15), surveys for nesting birds covered by the California Fish and Game Code and the Migratory Bird Treaty Act shall be conducted by a qualified biologist no more than 14 days prior to vegetation removal. The surveys shall include the disturbance area plus a 500-foot buffer around the site. If active nests are located, all construction work shall be conducted outside a buffer zone from the nest to be determined by the qualified biologist. The buffer shall be a minimum of 50 feet for non-raptor bird species and at least 300 feet for raptor species. Larger buffers may be required depending upon the status of the nest and the construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and young have fledged the nest prior to removal of the buffer. • If feasible, removal of vegetation within suitable nesting bird habitats will be scheduled to occur in the fall and winter (between September 1 and February 14), after fledging and before the initiation of the nesting season. BIO-1(h) Roosting Bats Impact Avoidance and Minimization. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to roosting bats: • Prior to issuance of grading permits, a qualified biologist shall conduct a survey of existing structures within the project site to determine if roosting bats are present. The survey shall be conducted during the non-breeding season (November through March). The biologist shall have access to all interior attics, as needed. If a colony of bats is found roosting in any structure, San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-63 further surveys shall be conducted sufficient to determine the species present and the type of roost (day, night, maternity, etc.) If the bats are not part of an active maternity colony, passive exclusion measures may be implemented in close coordination with CDFW. These exclusion measures must include one-way valves that allow bats to exit the structure but are designed so that the bats may not re-enter the structure. • If a bat colony is excluded from the project site, appropriate alternate bat habitat as determined by a qualified biologist shall be installed on the project site or at an approved location offsite. • Prior to removal of any trees over 20 inches diameter-at-breast- height (DBH), a survey shall be conducted by a qualified biologist to determine if any of the trees proposed for removal or trimming harbor sensitive bat species or maternal bat colonies. If a non- maternal roost is found, the qualified biologist, in close coordination with CDFW shall install one-way valves or other appropriate passive relocation method. For each occupied roost removed, one bat box shall be installed in similar habitat and should have similar cavity or crevices properties to those which are removed, including access, ventilation, dimensions, height above ground, and thermal conditions. Maternal bat colonies may not be disturbed. Plan Requirements and Timing. Special status species protection plans and surveys shall be prepared by the applicant and shall be submitted to for review and approval by the City prior to the approval of grading and construction permits. Any required permits shall be obtained from the state and federal agencies prior to issuance of grading permits. Monitoring. The Environmental Monitor shall monitor environmental compliance of the construction activities throughout the construction period or as stipulated in the species- or resource-specific mitigation measure and provide monitoring reports to the City. Residual Impacts. Implementation of BIO-1(a) through BIO-1(h) would reduce impacts to listed, candidate or special-status plant and wildlife species to a less than significant level and ensure that the project would comply with COSE Policies 7.3.1, Protect Listed Species, and 7.3.2, Species of Local Concern. Threshold 2: Would the project have a substantial adverse impact on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or US Fish and Wildlife Service. Impact BIO-2 Implementation of the project would have a substantial adverse effect on sensitive habitats, including riparian areas. Impacts would be Class II, potentially significant but mitigable. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-64 Development of the San Luis Ranch Specific Plan area would impact suitable nesting and foraging habitat for migratory birds, including raptors, in riparian, wetland, and agricultural habitats as well as habitat for sensitive amphibians, reptiles, roosting bats and for rare plants (refer to Section 4.4.1(c), Special Status Species and Plan Communities). Potentially impacted riparian habitat would include the banks of Prefumo Creek and the associated riparian habitat, as well as Cerro San Luis Channel and associated riparian habitat, which may be under CDFW jurisdiction pursuant to Section 1600 et seq. of the California Fish and Game Code. Project implementation would result in the permanent removal of approximately 0.6 acre of willow riparian habitat, and 0.1 acre of riverine habitat (refer to Table 4.4-1 and Table 2-3 in Section 2.0, Project Description). Removal of habitat occupied by sensitive species would create potentially significant adverse impacts to the species, regardless of whether direct mortality or harm to individual plants or animals occurs. In addition, the Specific Plan would dedicate approximately 7.6 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to riparian habitat along these corridors. Those impacts occurring within Prefumo Creek’s riparian corridor would include activities associated with the Froom Ranch Way bridge crossing and bench widening along Prefumo Creek. Several red willows are expected to be trimmed and/or removed as a result of the project. Proposed channel improvements to the eastern portion of Cerro San Luis Channel may entail removal of native willows and riparian vegetation. Land Use Element Policies 1.8.6, Wildlife Habitat; 1.8.7, Trees Outside City Limits; 2.3.7, Natural Features; and 6.6.1, Creek and Wetlands Management Objectives describe the City’s commitments to protecting and managing significant habitat and other biological resources, including creeks, wetlands, and trees. COSE Policies 7.5.1, Protection of Significant Trees; 7.7.9, Creek Setbacks; 8.6.3, Required Mitigation; and 8.7.2 Enhance and Restore Open Space, describe the City’s commitments to protecting natural habitat areas, such as creek corridors, wetlands, and trees. Mitigative Components of the Specific Plan and Impact Conclusion. Indirect impacts which may occur as a result of implementation of the project would include impacts to water quality from earth moving activities and operational site runoff. Direct impacts which may occur as a result of the project would include permanent removal of riparian habitat. As discussed under Impact BIO-1, San Luis Ranch Specific Plan Policy 5.3 and Program 5.3.1 would be required for the project and are intended to protect and enhances the natural habitats onsite. In addition, Specific Plan Policy 5.1 would require support of restoration efforts for the creek and associated habitat. Nevertheless, project related impacts to sensitive habitats would be potentially significant and would require a Streambed Alteration Agreement from the CDFW. Mitigation Measures. The following mitigation measure would be required to address impacts related to sensitive habitats. BIO-2(a) Habitat Mitigation and Monitoring Plan. A Habitat Mitigation and Monitoring Plan (HMMP) shall be prepared which will provide a minimum 2:1 ratio (replaced: removed) for temporary and permanent impacts to riparian habitat. The HMMP will identify the specific mitigation sites and it will be implemented San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-65 immediately following project completion. The HMMP shall include, at a minimum, the following components: • Description of the project/impact site (i.e. location, responsible parties, areas to be impacted by habitat type); • Goal(s) of the compensatory mitigation project [type(s) and area(s) of habitat to be established, restored, enhanced, and/or preserved; specific functions and values of habitat type(s) to be established, restored, enhanced, and/or preserved]; • Description of the proposed compensatory mitigation site (location and size, ownership status, existing functions and values of the compensatory mitigation site); • Implementation plan for the compensatory mitigation site (rationale for expecting implementation success, responsible parties, schedule, site preparation, planting plan [including plant species to be used, container sizes, seeding rates, etc.]); • Maintenance activities during the monitoring period, including weed removal and irrigation as appropriate (activities, responsible parties, schedule); • Monitoring plan for the compensatory mitigation site, including no less than quarterly monitoring for the first year (performance standards, target functions and values, target acreages to be established, restored, enhanced, and/or preserved, annual monitoring reports); • Success criteria based on the goals and measurable objectives; said criteria to be, at a minimum, at least 80 percent survival of container plants and 80 percent relative cover by vegetation type; • An adaptive management program and remedial measures to address negative impacts to restoration efforts; • Notification of completion of compensatory mitigation and agency confirmation; and • Contingency measures (initiating procedures, alternative locations for contingency compensatory mitigation, funding mechanism). BIO-2(b) Tree Replacement. Riparian trees four inches or greater measured at diameter-at-breast-height (DBH) shall be replaced in-kind at a minimum ratio of 3:1 (replaced: removed). Trees 24 inches or greater inches DBH shall be replaced in-kind at a minimum ratio of 10:1. Willows and cottonwoods may be planted from live stakes following guidelines provided in the California Salmonid Stream Habitat Restoration Manual for planting dormant cuttings and container stock (CDFW 2010). • Tree replacement shall be conducted in accordance with a Natural Habitat Restoration and Enhancement Plan to be approved by the City’s Natural Resource Manager. • The Natural Habitat Restoration and Enhancement Plan shall prioritize the planting of replacement trees on-site where feasible, San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-66 but shall allow that replacement trees may be planted off-site with approval of the City’s Natural Resource Manager. • Replacement trees may be planted in the fall or winter of the year in which trees were removed. All replacement trees will be planted no more than one year following the date upon which the native trees were removed. BIO-2(c) Froom Ranch Way Bridge Design to Avoid Riparian Areas. The Froom Ranch Way Bridge crossing footings shall be placed outside mapped riparian areas. The placement of the bridge and footings shall be indicated on the Development Plan, VTM, and HMMP, and shall show the bridge’s placement in relation to existing vegetation and the bed and bank of Prefumo Creek. Plan Requirements and Timing. The HMMP required by Mitigation Measure BIO-2(a) shall specify the location, timing, species composition, and maintenance of all restored, enhanced, and newly established riparian and wetland areas, and tree replacement. The applicant shall submit the HMMP to the City for approval prior to recordation of the VTM, and shall update and resubmit to the City prior to each phase of construction. Tree and vegetation replacement shall occur within the same construction phase as tree and vegetation removal. Tree and vegetation removal associated with the construction of the Froom Ranch Way Bridge crossing shall be replaced during or immediately subsequent to completion of that project component. Monitoring. The City shall review and approve the HMMP (and associated tree replacement requirements) for compliance prior to issuance of grading permits and the onset of construction for each phase, as well as the onset of construction of the Froom Ranch Way Bridge crossing. The applicant shall submit annual documentation to the City and appropriate agencies demonstrating compliance with HMMP requirements. The City shall review and approve the final Froom Ranch Way Bridge crossing design for compliance prior to issuance of grading permits. Replacement plants shall be monitored by a qualified biologist for 5 years with a goal of at least 70 percent survival at the end of the 5- year period. Supplemental irrigation may be provided during years 1 to 3; however, supplemental watering shall not be provided during the final two years of monitoring. Furthermore, Mitigation Measure BIO-1(a) requires implementation of construction best management practices that would reduce impact to riparian habitat during construction activity. Mitigation Measure BIO-3, below, for Jurisdictional Waters and Wetlands would also be required to ensure that project impacts to red willow thicket/riparian habitat would be minimized to the maximum extent feasible. Residual Impacts. Implementation of Mitigation Measures BIO-1(a), BIO-2(a), BIO-2(b), BIO-2(c), and BIO-3 would reduce direct impacts to sensitive habitats, including riparian areas, by implementing construction BMPs, including containing construction activities, debris, and sediment in appropriate locations outside of sensitive habitat to the maximum extent practicable, and by providing compensatory mitigation for permanently impacted riparian San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-67 habitat. In addition Mitigation Measures HWQ-1(a) and HWQ-1(b) include construction management practices that would reduce construction related impacts to water quality. When combined with standard regulatory measures (including required permitting from USACE, CDFW, and RWQCB), and regulatory oversight during construction by the Environmental Monitor, implementation of required mitigation measures would reduce impacts to a less than significant level and ensure that the project would comply with applicable General Plan policies for the protection of habitat and other biological resources. Threshold 3: Would the project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. Impact BIO-3 Construction of the project could have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act. Impacts would be Class II, potentially significant but mitigable. Development under the San Luis Ranch Specific Plan would have the potential to result in direct impacts to jurisdictional areas, including wetlands, other waters and riparian habitats. Approximately 0.14 acre of wetlands, 0.69 acre of other waters and 2.17 acres of streambed/ riparian/associated eucalyptus grove habitat were delineated onsite. Approximately 0.05 acre of wetlands, 0.1 acre of other waters, and 0.3 acres of streambed/riparian/associated eucalyptus grove habitats would be impacted as a result of construction activities associated with the Froom Ranch Way bridge crossing, bench widening along Prefumo Creek, and channel improvements to the eastern portion of Cerro San Luis Channel. Note the final jurisdictional determinations of the boundaries of wetlands, waters, and riparian habitat are made by each agency, typically at the time that authorizations to impact such features are requested. The Specific Plan would dedicate approximately 7.6 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to wetlands along these corridors. The project site contains features that would fall under jurisdiction of the SWRCB and Central Coast RWQCB, which has jurisdiction over “Waters of the State” pursuant to the Porter- Cologne Water Quality Control Act. Therefore, a Waste Discharge Requirements permit may also be required. In addition, the project is anticipated to require a Section 404 Nationwide Permit from the USACE and a Section 401 Water Quality Certification from the RWQCB, under the Clean Water Act. COSE Policy 7.5.5, Soil Conservation and Landform modification, describes the City’s requirement that private development projects be designed to prevent soil erosion and minimize landform modifications to avoid habitat disturbance. Mitigative Components of the Specific Plan and Impact Conclusion. San Luis Ranch Specific Plan Goal 5 establishes a goal to provide a community that protects and enhances the adjacent creek and habitat. Specific Plan Policy 5.1 and Program 5.3.1, as described in Impact BIO-1 and BIO-2 above, would be required of the project and are intended to help achieve this goal through protection of the creek. However, project-level impacts to jurisdictional areas would San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-68 remain potentially significant, and Mitigation Measures BIO-1(a) and BIO-2(a) are required to reduce this impact and ensure consistency with COSE Policy 7.5.5. Mitigation Measures. Implementation of Mitigation Measures BIO-1(a) and BIO-2(a) would reduce impacts to a less than significant level. No additional mitigation is required. Residual Impacts. Implementation of Mitigation Measures BIO-1(a) and BIO-2(a would reduce potential impacts to federally protected wetlands, any riparian habitat, or other sensitive natural communities to a less than significant level and ensure that the project would be consistent with COSE Policy 7.5.5. Threshold 4: Would the project interfere substantially with the movement of any resident or migratory fish or wildlife species or with established resident or migratory wildlife corridors, or impede the use of wildlife nursery sites. Impact BIO-4 Development of the San Luis Ranch Specific Plan Area would not permanently interfere with the movement of resident or migratory fish or wildlife species or with established resident or migratory wildlife corridors along Prefumo Creek and through open agricultural lands on the project site. This impact would be Class II, potentially significant but mitigable. Extensive site alteration and construction of new homes, roadways, pedestrian and bicycle pathways, utility and drainage infrastructure, and increased noise, lighting, and glare along Prefumo Creek could disrupt the movement of special status birds, great blue heron rookeries, amphibians, and reptiles such as the western pond turtle, and potentially California red-legged frog, coast range newt, and steelhead trout, nesting birds, as well as more common wildlife species. Temporary Disturbances to Wildlife Corridors. Direct construction-related disturbances within and adjacent to Prefumo Creek, including removal of and damage to habitat, increased noise, activity, sedimentation and potential for releases of toxic materials to be introduced to the Creek would occur for several years over multiple project phases. Disturbance of the Creek and open land movement areas during construction could interfere with wildlife movement through the site. These disruptions could temporarily affect both common and sensitive species that use Prefumo Creek for movement, including migratory birds and raptors. Over the long term, such species would return to the migratory corridor after completion of restoration. Implementation of the Froom Ranch Way bridge crossing may result in a temporary barrier during potential dewatering; however, upon completion of construction activities, any diversions or barriers to flow would be removed in a manner that would allow flow to resume. Cerro San Luis Channel would be widened to improve form and function, and the majority of the construction would occur on agricultural land. Due to constant maintenance activities, the function of the agricultural land within the project site as a wildlife corridor is extremely limited. None of these activities are expected to permanently interfere with the movement of resident or migratory wildlife. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-69 Permanent Disturbances to Wildlife Corridors. Development of the San Luis Ranch Specific Plan Area would result in residential development in proximity to riparian areas along Prefumo Creek, including an open space corridor along the Creek. In a number of locations pedestrian and bicycle pathways within the open space corridor would be located in closely proximity to the creek, with the potential to be located near the top of the creek bank and within existing riparian canopy. Thus, while the planned open space corridor would help preserve the habitat value and wildlife corridor function of Prefumo Creek, inadequate development setbacks could adversely affect this wildlife utilization and movement along this corridor. Long-term impacts to wildlife movement and special status species could occur due to increased human presence onsite including lighting located on buildings and along residential streets, increased noise from automobiles, human activity, domesticated pets, and other similar activities. Solid waste and polluted runoff from parks, residential streets, and roads could enter Prefumo Creek through wind or the drainage system during storm events. Outdoor night lighting and noise associated with development of new residential units could create glare offsite and light spillage, degrading the quality of Prefumo Creek and the associated riparian area. Project impacts associated with nighttime lighting and daytime glare are discussed in detail in Section 4.1, Aesthetics (refer to Impact AES-3), and were found to be less than significant based on compliance with applicable City General Plan policies pertaining to lighting and glare. The proximity of bicycle and pedestrian pathways to Prefumo Creek would lead to increased human interaction within the riparian area. This includes increased foot traffic in and around Prefumo Creek and more post-consumer waste entering the sensitive habitat. Increased runoff from paved surfaces and buildings could lead to increased long-term sedimentation, water turbidity, and water quality degradation. Collectively, these planned improvements could reduce the habitat value of Prefumo Creek and the associated riparian habitat and restrict or inhibit wildlife movement and utilization. The project would be required to comply with Section 17.16.025 of the City Zoning Regulations, Creek Setbacks, which establishes setback distances for different classes of creeks. For creeks in areas annexed after 1996, including Prefumo Creek, the required setback is 35 feet. Zoning Regulations setbacks are defined in terms of the distances from the top of bank or edge of riparian drip line, which-ever is farther from the creek, that development is permitted to occur. The City Zoning Regulations prohibits the following activities from occurring within a set-back area: paving, parking lots; and, in nonresidential zones, areas used for storing or working on vehicles, equipment, or materials. Compliance with the creek setback requirements in the Zoning Regulations would ensure consistency with the intent of COSE Policy 7.7.9, Creek Setbacks. Overall, long-term impacts to the habitat value of Prefumo Creek and its functioning as a wildlife corridor would be less than significant. Because the open agricultural lands on the project site do not provide a connection or corridor between other non-disturbed habitat, and because impacts to Prefumo Creek would be temporary in nature, and this existing wildlife corridor would not be removed or narrowed, no permanent impacts to wildlife movement are expected. As a result, the project would be consistent with the applicable Land Use Element Policies 1.8.6, Wildlife Habitat, and 6.6.2, Citywide Network, and COSE Policies 7.3.3, Wildlife Habitat and Corridors, 7.7.8, Protect Wildlife Corridors, and 7.7.9, Creek Setbacks, which require the City to preserve and maintain continuous stretches of wildlife habitat consisting of open space, lakes, creeks, and wetlands. In San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-70 addition, the project would be consistent with Section 17.16.025 of the City Zoning Regulations, Creek Setbacks. Prefumo Creek is not defined in the City’s COSE as a wildlife corridor (refer to COSE Figure 3, Wildlife Corridors); however, Prefumo creek is defined as a “perennial creek with good riparian corridor (refer to COSE Figure 9, Creeks and Wetlands). Mitigative Components of the Specific Plan and Impact Conclusion. As discussed under Impacts BIO-1 through BIO-3 above, the San Luis Ranch Specific Plan contains various goals, policies, and programs intended to protect biological and habitat resources on the project site. However, because the project would result in temporary impacts to species that use Prefumo Creek for movement, including migratory birds and raptors, this impact would be potentially significant. Mitigation Measures. Implementation of BIO-1(a) requires construction BMPs that would reduce potential impacts to riparian habitat within the Prefumo Creek corridor. Implementation of Mitigation Measures BIO-1(c), BIO-1(d), and BIO-1(e), would reduce impacts to western pond turtle, CRLF, coast range newt, and steelhead by requiring pre- construction surveys by qualified biological staff and construction worker training to ensure individuals of these species are not impacts during project construction activity within or adjacent to riparian and riverine habitat. Implementation of Mitigation Measure BIO-1(f) would reduce impacts to heron rookeries by requiring preconstruction surveys, mapping, exclusionary fencing, and offsite compensatory mitigation. Implementation of Mitigation Measure BIO-1(h) would reduce impacts to birds by requiring construction monitoring for nesting birds, and requiring appropriate buffers for construction activity in proximity to active nests. Implementation of Mitigation Measure BIO-1(h) would reduce impacts to bats roosting in trees by requiring trees that may provide habitat for roosting bats to be surveyed by a qualified biologist prior to removal. Implementation of Mitigation Measures BIO-2(a) would reduce potential impacts to federally protected wetlands, any riparian habitat, or other sensitive natural community to a less than significant level. Residual Impacts. Implementation of Mitigation Measures BIO-1(a), BIO-1(c), BIO-1(d), BIO-1(e), BIO-1(f), BIO-1-(h), and BIO-2(a) would reduce potential impacts to wildlife species, wildlife nursery sites, riparian corridors, and other sensitive natural communities to a less than significant level. c. Cumulative Impacts. Planned buildout of the City of San Luis Obispo under the General Plan, including buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans, would incrementally contribute to the trend of conversion of the City from undeveloped to developed uses, with resultant loss of open space and habitat, and City-wide increases in impervious surfaces and pollutant loading in the San Luis Obispo Creek watershed, night light, noise, and traffic associated with such development. These changes would both directly and indirectly affect sensitive habitats and wildlife species. However, as described in the LUCE Update EIR, incorporation of required project-level mitigation measures to implement program-level mitigation and compliance with applicable General Plan policies and applicable state and federal regulatory requirements, cumulative impacts to biological resources resulting from buildout of the City under the General Plan, including buildout of the San Luis Ranch Specific Plan, would be significant but mitigable. Buildout of the General Plan would retain Prefumo Creek and associated areas of sensitive wetlands, and would minimize habitat fragmentation and protect wildlife corridors, consistent with City policy. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-71 Consistent with the LUCE Update EIR, the project would implement mitigation measures to ensure compliance with the applicable goals and policies of the General Plan. As with the project, other cumulative development within the City that would result in potential impacts to biological resources would be subject to applicable General Plan goals and policies, and would be required to incorporate project-specific mitigation measures to implement these policies. As a result, the project’s contribution to this cumulative impact would be potentially significant but mitigable. San Luis Ranch Project EIR Section 4.4 Biological Resources City of San Luis Obispo 4.4-72 This page intentionally left blank. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-1 4.5 CULTURAL RESOURCES The information in this section is based on the San Luis Ranch Project Cultural Resources Study prepared by Rincon Consultants, Inc. (Rincon) in August 2016 (Appendix G) and the 2014 LUCE Update EIR. 4.5.1 Setting a. Prehistoric Setting. The project site is located within what is generally described as the Central Coast archaeological region, which one of eight organizational divisions of California (Jones and Klar 2007, Moratto 1984). The Central Coast archaeological region extends from Monterey Bay to Morro Bay, and includes the County of San Luis Obispo. The prehistoric cultural chronology for the Central Coast is generally divided into six periods: Paleo-Indian (ca. 10,000 – 6,000 B.C.), Milling Stone (6,000 - 3,000 B.C.), Early and Early-Middle Transition (3,000 - 600 B.C.), Middle (600 B.C. - A.D. 1000), Middle-Late Transition (A.D. 1000 - A.D. 1250), and Late (A.D. 1250 - historic contact [ca. A.D. 1769]) (Jones and Klar 2007). Several chronological sequences have been devised to understand cultural changes along the Central Coast from the Millingstone Period to contact. Jones (1993) and Jones and Waugh (1995) presented a Central Coast sequence that integrates data from archaeological studies conducted since the 1980s. Three periods, including the Early, Middle, and Late periods, are presented in their prehistoric sequence subsequent to the Millingstone Period. More recently, Jones and Ferneau (2002) updated the sequence following the Millingstone Period as follows: Early, Early- Middle Transition, Middle, Middle-Late Transition, and Late periods. The archaeology of the Central Coast subsequent to the Millingstone Period is distinct from that of the Bay Area to the north and Central Valley to the east. The region has more in common with the Santa Barbara Channel area during the Middle and Middle-Late Transition periods, but few similarities during the Late period (Jones & Ferneau 2002). b. Historical Setting. Post-European contact history for California is generally divided into three periods: the Spanish Period (1769–1822), the Mexican Period (1822–1848), and the American Period (1848–present). The Spanish Period brought the establishment of the California mission system, while the Mexican Period is largely known for the division of the land of California into private land holdings. Following the Mexican-American war, the United States purchased California from Mexico; population of the state subsequently increased, particularly during the Gold Rush. Following the arrival of the first Europeans, Mission San Luis Obispo de Tolosa was founded in 1772 by Padre Junipero Serra. The population of native people at the mission declined rapidly. In 1803, there was a peak of 919 Native Americans residing at the mission, but by 1838 the population had declined to 170. In 1822 California became a Mexican Territory, and the mission lands gradually became private ranchos through Mexican land grants. In 1846, the Bear Flag Rebellion resulted in California’s independence from Mexico, and control of the territory soon fell into the hands of the United States. Beginning in 1873, the County experienced a steady change in land use and recorded more acreage under cultivation each year. The California State Board of Agriculture reported that in 1910 the County had 1,566,660 acres of farmland. Over the following decades, the San Luis Obispo area continued to operate as agricultural and ranching property. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-2 Agriculture in San Luis Obispo. By the early 20th century, the land surrounding Laguna Lake developed into farms, dairies, and ranches (Bertrando 1999a). Wool, flour, and dairy were important income-generating products in the area. Some of the most important agricultural crops in the late 1800s were wheat, barley, and beans. Grain from area ranchos was processed at local mills. Production increased when steam-powered mills were constructed starting in the 1870s. Ranching and agriculture were the region’s main commercial enterprises at one time and thus had an impact on the development of the city (Historic Resources Group [HRG] 2013). Because San Luis Obispo was the largest settlement in the area, some ranchers would travel from up to forty miles away to bring their grains into the city to be milled. As a result, roads were constructed throughout the County in the 1870s, primarily by Chinese laborers, leading to increased mobility in the region. In 1872, Captain John Harford began construction on the Pacific Coast Railway which ran just to the east of the Specific Plan Area. The railway improved shipping methods of local crops and products, advancing the economy (HRG 2013). A dairy industry began developing in San Luis Obispo County in the late 1860s after the drought years of 1862-64. During the 1880s, beans were the primary crop grown south of the city and continued into the early years of the 20th century (Bertrando 1999b). Other significant agricultural crops in the area in the early 20th century included winter peas, celery and flower seed. Japanese farmers in particular were successful with these crops through the 1930s. Horse Racing in San Luis Obispo. Horse racing was documented to be a popular sport in the region since the time of the Mexican ranchos in the first half of the 19th century (Angel 1883). Historical newspaper articles discuss the establishment of horse racing tracks in the San Luis Obispo area from 1874 through 1887. During this period a halfone-mile race track was located in the vicinity of Madonna Plaza, which would be slightly to the northeast of the project site (Bertrando 1999a). After 1901, ownership of the portion of the project site with the spectators’ barn/viewing stand changed hands, and the spectators’ barn/viewing stand was reportedly moved to its current location on the northwest portion of the project site, near Madonna Road. It was reported that when the spectators’ barn/viewing stand was moved into the project site, the track was shortened by a half mile (Froom in Bertrando, 1998). c. Project Site Historic Context. The project site is comprised of several lots that were subdivided in 1875, when the Laguna Rancho was sold off into plots for small family farms. Each property consisted of a farm complex with a home (Bertrando 1999a). A horse race track facility, which included stables and a spectators’ barn/viewing stand, was originally located in the current agricultural area of the site. After 1910, the horse race track facility was moved to its current location on the northwest portion of the project site, near Madonna Road. A kitchen and cocktail lounge that once existed on opposite ends of the viewing stand were removed and utilized for the construction of a small family residence. The stables that had been associated with the race track were removed from the site and the spectators’ barn/viewing stand was further altered by the addition of a dairy, stables and conversion of the spectator seating area to hay storage. In approximately 1921, the Dalidio family purchased the project site and converted the site to farmed crops such as onions, artichokes, and garbanzo beans, as well as flowers for seed (Bertrando 1999a; Stewart 1999). The agricultural business on the project site was known as Zapata Farms starting in the early 1980s (Bertrando 1999a; Stewart 1999). The property changed ownership again in 2014 and it has recently been known as the San Luis Ranch. For a detailed San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-3 history of the region and the San Luis Ranch Specific Plan Area, refer to the Cultural Resources Study in Appendix G to this EIR. The former spectators’ barn/viewing stand, as well as other on-site structures, is described in detail in Section 4.5.1(d). d. Documented Cultural Resources. Previously Documented Archaeological and Historical Resources. On January 25, 2016 Rincon requested a search of the cultural resource records housed at the California Historical Resources Information System (CHRIS) Central Coast Information Center (CCIC) located at University of California, Santa Barbara. The search included a review of the National Register of Historic Places (NRHP), the California Register of Historical Resources (CRHR), the California State Historical Landmarks list, the California Points of Historical Interest list, historic building surveys, the Archaeological Determinations of Eligibility list, and the California Inventory of Historical Resources list. The records search provided information about archaeological resources, historic resources, and reports within the project site as well as within a 0.5-mile radius of the project site. The records search identified 51 reports of studies previously conducted within the project site as well as within a 0.5-mile radius of the project site. Of these records, eight previous studies overlap with or were located within the project site. The National Archaeological Database listing summary for these studies is presented in Appendix B of the Cultural Resources Study prepared for the project by Rincon in August 2016 (refer to Appendix G to this EIR). The previous studies conducted within and in the vicinity of the project site did not identify any archaeological resources on the project site. In addition, the CCIC did not list any historic addresses on the project site, nor does the CCIC possess any historical maps that indicate the presence of historic resources on the project site. However, the CCIC records search identified nine previously recorded archaeological and historical resources located within a 0.5-mile radius of the project site, described in detail in Appendix G to this EIR. Of these resources, one identified historic resource is located on the project site: the San Luis Ranch Complex (P-40- 041000). The San Luis Ranch Complex, formerly known as the Dalidio Ranch Complex, is located on the northwest portion of the project site, near Madonna Road. Singer and Atwood (1988) conducted a cultural resources survey of the project site in 1988, and identified “two wood frame structures, a large, two-story house and a barn” as having potential historical significance. Betsy Bertrando recorded and evaluated the Complex in 1999 and identified eight historic built environment resources including the Dalidio home, a bungalow, a small shed/bunkhouse, a garage, a water tower, the main barn, a large equipment storage building, and the spectators’ barn/viewing stand. The San Luis Ranch Complex presently includes nine structures, described in detail below. The water tower that was recorded on the project site in the 1999 Bertrando analysis was not observed during the investigation for the current project. Archaeological and Historical Resources on the Project Site. Archaeological Resources. Rincon staff conducted a pedestrian field survey of the project site for archaeological resources between March 14, 2016 and March 16, 2016. During this field survey, Rincon identified and recorded three prehistoric archaeological resources on the project site. These resources include one prehistoric archaeological site (SLR-S-01) and two isolated prehistoric artifacts (SLR-I-01 and SLR-I-02). Between August 1, 2016 and August 16, 2016, San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-4 Rincon conducted test excavations, including one test unit, two shovel test pits, and 21 auger tests, of archaeological site SLR-S-01 to evaluate the CRHR eligibility of the site. The three resources identified on the project site include: •SLR-S-01. SLR-S-01 is a prehistoric lithic scatter. The site measures 170 × 315 feet and consists of a surface scatter of lithic artifacts and one fragment of shell, with a subsurface component of redeposited lithic debitage (waste material from stone tool production) extending to 40 centimeters below the surface. During the pedestrian survey, Rincon identified the site as a surface scatter of flaked stone debitage, all composed of cryptocrystalline silicate (CCS) materials including Franciscan and Monterey cherts. •SLR-I-01. SLR-I-01 consists of an isolated prehistoric grayish-brown cortical CCS flake measuring 4.8 x 3.6 x 1 centimeters. The flake exhibits moderate post-depositional damage. •SLR-I-02. SLR-I-02 consists of an isolated prehistoric brownish-red cortical CCS flake measuring 3.0 x 2.3 x 0.7 centimeters. The flake exhibits moderate post-depositional damage. Built Environment Resources. As shown in Figure 4.5-1, the project site currently contains a grouping of nine structures at the northwest end of the property, collectively known as the San Luis Ranch Complex. The San Luis Ranch Complex includes three single-family residences, a garage/shed, a smaller shed, the main barn, a large equipment storage building, a warehouse, and the former spectators’ barn/viewing stand, which was converted to farm use. Figures 4.5- 2a through 4.5-2e provide photographs of each of these structures. The following is a summarized description of each of the structures within the San Luis Ranch Complex: •Main Residence (Residence #1). The main residence is a single-family residence estimated to have been built ca. 1910. It is irregular in plan and built in the Craftsman style. This structure features a high pitched, front-gabled roof, with overhanging eaves and exposed rafter tails. The roof is clad in composition shingles. There is a shed dormer on the northeast side of the roof. On the southwest side a hipped roof extension covers the wrap-around porch and a cantilevered box bay window. The home is clad with shiplap and clapboard siding as well as shingles on the gable face. •Residence #2. This single family home is estimated to have been built ca. 1900-1910. It is rectangular in plan and appears to have a small addition on the east elevation as well as a shed extension on the south. The eastern addition includes a chimney. Both the main portion of the home and the addition feature medium pitched front-gabled roofs and an open eave overhang with fascia boards. The roof is clad with composite shingles. The shed extension features a nearly flat roof partially clad with corrugated panels. Residence #3. This single family home is estimated to have been built in the 1960s. It is roughly square in plan, clad with reverse board and batten and has a side-gabled roof clad with composition shingles. There are horizontally slatted vents under the gable peaks. The home features aluminum sliding windows surrounded by wood framing on the north and east elevations. !> !> !> !> !> !> !> !> !> Main Barn Warehouse Residence #3 Residence #2 Shed #2 Main Residence (Residence #1) Garage/Shed Spectators' Barn/Viewing Stand #9 - Equipment Storage Building Madonna Rd City of San Luis Obispo Built Environment Resources Figure 4.5-1 Imagery provided by Google and its licensors, 2016. San Luis Ranch Project EIRSection 4.5 Cultural Resources ±0 16080 Feet Project Boundary !>San Luis RanchComplex Structures 4.5-5 San Luis Ranch Project EIR Section 4.5 Cultural Resources San Luis Ranch Complex Structure Photographs Figure 4.5-2a City of San Luis Obispo Photo 1: Main Residence (Residence #1), northwest elevation, view to the southeast. Photo 2: Residence #2, view to the east. 4.5-6 San Luis Ranch Project EIR Section 4.5 Cultural Resources San Luis Ranch Complex Structure Photographs Figure 4.5-2b City of San Luis Obispo Photo 3: Residence #3, view to the south. Photo 4: Garage/Shed, northwest elevation, view to the southeast. 4.5-7 San Luis Ranch Project EIR Section 4.5 Cultural Resources San Luis Ranch Complex Structure Photographs Figure 4.5-2c City of San Luis Obispo Photo 5: Shed #2, northwest elevation, view to the southeast. Photo 6: Main barn, north elevation, view to the southwest. 4.5-8 San Luis Ranch Project EIR Section 4.5 Cultural Resources San Luis Ranch Complex Structure Photographs Figure 4.5-2d City of San Luis Obispo Photo 7: Equipment storage building, north elevation, view to the south. Photo 8: Warehouse, east elevation, view to the southwest. 4.5-9 San Luis Ranch Complex Structure PhotographsFigure 4.5-2eCity of San Luis ObispoSan Luis Ranch Project EIRSection 4.5 Cultural ResourcesPhoto 9: Former spectator’s barn/viewing stand, northwest elevation, view to the southeast.4.5-10 San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-11 • Garage/Shed. This garage/shed is the larger of two sheds on the property. Estimated to have been built in the 1930s, it is rectangular in plan and is clad with flush, vertical wooden boards. It is covered with a shed roof that has exposed rafter tails and is clad with corrugated metal panels. • Shed #2. Shed #2 is a small rectangular shed. Estimated to have been built in the 1930s, it is clad with vertical wooden boards and has a shed roof clad with corrugated panels. • Main Barn. The main barn in a raised-center-aisle barn estimated to have been built in 1900. It is clad with vertical wooden boards. The roof is clad with corrugated metal panels. The north elevation has a large centered opening with chamfered corners as well as a sliding barn door. The south elevation has a sliding barn door and a large hinged door, as well as a hay carrier and hay doors under the gable peak. The east elevation features four open bays supported by square wooden posts. • Equipment Storage Building. This large building is estimated to have been built in 1938. It has a rectangular footprint and has four open bays on one side. The building is clad with vertical wooden boards. The shed roof is covered with corrugated aluminum panels and is supported by poles enhanced with Y braces. • Warehouse. The large warehouse is estimated to have been built in the 1960s. It is rectangular in plan and is clad with vertical aluminum panels. It has a very low pitched, gabled roof. The east elevation features a single entry door (possibly metal), as well as a metal roll-up garage door and a rectangular vent with horizontal slats. The south elevation also has a metal roll-up garage door. Across the width of the north elevation is a shed supported by round metal poles. It has a flat roof clad with corrugated metal panels. • Former Spectators’ Barn/Viewing Stand. The former spectators’ barn/viewing stand has been converted to other farm uses. It is estimated to have been built ca. 1887 and is a two-story wood framed building clad with shiplap siding. It has a rectangular plan and a high pitched, side-gabled roof with boxed eaves. The northwest elevation features a strip of angled window openings that indicate the prior use as a race track viewing stand; the slant is likely a result of row seating and the open seating/viewing area was likely enclosed. Beneath this are two window openings which have been boarded over. Under the gable peak is a hay carrier and a pair of hay doors on hinges. A large concrete loading dock wraps around the southeast and southwest sides of the building. Along the southwest side of the building there is an addition that appears to have been constructed at a later date. The structure is clad with vertical wood boards and has a steeply pitched shed roof. e. Regulatory Setting Federal Regulations. The project does not involve federal funding or permitting, and as a result, does not have a federal nexus. Therefore, compliance with reference to the National Historic Preservation Act of 1966 (NHPA) and other federal laws is provided here for informational purposes only. National Register of Historic Places. The NRHP was established by the NHPA to help identify properties that are significant cultural resources at the national, state, and/or local level. To be eligible for listing in the NRHP, a resource must be significant in American history, architecture, archaeology, engineering, or culture. Districts, sites, buildings, structures, and objects of potential significance must also possess integrity of location, design, setting, San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-12 materials, workmanship, feeling, and association. A property is eligible for the NRHP if it meets one or more of the following criteria: A: It is associated with events that have made a significant contribution to the broad patterns of our history; B: It is associated with the lives of persons who are significant in our past; C: It embodies the distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components may lack individual distinction; and/or D: It has yielded, or may be likely to yield, information important in prehistory or history. As described in the Cultural Resources Study (see Appendix G), San Luis Ranch (formerly Dalidio Ranch) began as a family farm and expanded into a larger agribusiness. The property has retained a complex of ranch buildings and cultivated fields for over a century. The property was owned for many decades by the Dalidio family, who has been involved in the regional dairy industry and agribusiness. Their contributions are believed to be of local significance, not statewide or nationwide. Thus, the Dalidio family’s contributions do not make the property or complex eligible for listing in the NRHP. The property and the structures on the property are also not expected to yield important information about prehistory or history and do not demonstrate sufficient historical significance in national, state, or local agricultural development or as a unique property type to warrant listing in the NRHP. State Regulations. Assembly Bill 52. Assembly Bill 52 (AB 52) amends Public Resources Code (PRC) Section 5097.94 (CEQA) and adds eight new sections to the PRC relating to Native Americans. It was passed and signed into law in 2014 and took effect on July 1, 2015. This law establishes a new category of resource called tribal cultural resources (PRC Section 21074) and establishes a process for consulting with Native American tribes and groups regarding those resources. The consultation process must be completed before a CEQA document can be certified. Native American tribes to be included in the process are identified through consultation with the California Native American Heritage Commission (NAHC) (PRC Section 21080.3.1). Tribal cultural resources are “[s]ites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe…” (PRC Section 21074.1). A tribal cultural resource must be on, or eligible for, the CRHR as described above for historical resources, or must be included in a local register of historical resources. Also as discussed above for historical resources, the lead agency can determine that a tribal cultural resource is significant even if it has not been evaluated as eligible for the CRHR or is not on a local register. Assembly Bill 52 establishes that “A project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment” (PRC Section 21084.2). It further states that the lead agency shall establish measures to avoid impacts that would alter the significant characteristics of a tribal cultural resource, when feasible (PRC Section 21084.3). The City conducted Native American consultation consistent with Senate Bill 18 and Assembly Bill 52 for the project, which is described in Section 4.5.3(a), Methodology. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-13 Senate Bill 18. Passed in 2004, Senate Bill 18 (SB 18) requires cities and counties to consult with Native American tribes to help protect traditional tribal cultural places through the land use planning process. Unlike AB 52, SB 18 is not an amendment to, or otherwise associated with, CEQA. Instead, SB 18 requires cities and counties to consult with Native American tribes early during broad land use planning efforts on both public and private lands, prior to site- and project-specific land use decisions. The bill applies to general plan adoption or amendments and to specific plan adoption or amendments. A Native American tribe is defined as “a federally recognized California Native American tribe or a non-federally recognized California Native American tribe that is on the contact list maintained by the Native American Heritage Commission” (Governor’s Office of Planning and Research 2005). Traditional tribal cultural places are defined in PRC Sections 5097.9 and 5097.993 to include sanctified cemeteries, places of worship, religious or ceremonial sites, or sacred shrines, or any historic, cultural, or sacred site that is listed on or eligible for the CRHR including any historic or prehistoric ruins, burial grounds, or archaeological site (Governor’s Office of Planning and Research 2005). Under SB 18, cities and counties must notify the appropriate Native American tribe(s) of intended adoption or amendments to general plans or specific plans, and offer the opportunity for the tribe(s) to consult regarding traditional tribal cultural places within the proposed plan area. Consultation is intended to encourage preservation and protection of traditional tribal cultural places by developing treatment and management plans that might include incorporating the cultural places into designated open spaces (Governor’s Office of Planning and Research 2005). California Environmental Quality Act. CEQA requires a lead agency to determine whether a project may have a significant effect on historical resources (Public Resources Code [PRC], Section 21084.1). A historical resource is a resource listed, or determined to be eligible for listing, in the CRHR; a resource included in a local register of historical resources; or any object, building, structure, site, area, place, record, or manuscript that a lead agency determines to be historically significant (State CEQA Guidelines, Section 15064.5[a][1-3]). A resource may be eligible for inclusion in the CRHR if it meets one or more of the following criteria: 1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; 2. Is associated with the lives of persons important in our past; 3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or 4. Has yielded, or may be likely to yield, information important in prehistory or history. The San Luis Ranch Complex is eligible for listing in the CRHR under Criterion 1 for its association with the early agricultural development of San Luis Obispo. The San Luis Ranch property has retained the complex of ranch buildings and cultivated fields for over a century. The property is also representative of an early 20th century farm with its associated buildings, agricultural fields and ancillary structures. The buildings reflect the distinctive characteristics of the early 20th century vernacular agricultural architecture, making the San Luis Ranch Complex also eligible for listing in the CRHR under Criterion 3. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-14 Individual buildings within the San Luis Ranch Complex also embody distinctive characteristics of a type, period, region, or method of construction. The main residence (Residence # 1) is constructed in a Craftsman style and retains many of its character-defining features such as clapboard and shiplap siding, shingles in the gable face, overhanging eaves and exposed rafter tails, decoratively cut knee braces and rafter tails, a wrap-around porch supported by square pillars, a shed-roofed dormer window, and various original wood windows. The main barn also embodies the raised-center-aisle type of barn. This structure retains its barn doors, hay doors, hay carriers and hardware, thus retaining much of its integrity. Therefore, the main residence and main barn are individually eligible for listing in the CRHR under Criterion 3. In addition, if a project can be demonstrated to cause damage to a unique archaeological resource, the lead agency may require reasonable efforts to permit any or all of these resources to be preserved in place or left in an undisturbed state. To the extent that resources cannot be left undisturbed, mitigation measures are required (PRC, Section 21083.2[a], [b], and [c]). PRC, Section 21083.2(g) defines a unique archaeological resource as an artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: 1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information; or 2. Has a special and particular quality such as being the oldest of its type or the best available example of its type; or 3. Is directly associated with a scientifically recognized important prehistoric or historic event or person. According to CEQA, all buildings constructed over 50 years ago and that possess architectural or historical significance may be considered potential historic resources. Most resources must meet the 50-year threshold for historic significance; however, resources less than 50 years in age may be eligible for listing on the CRHR if it can be demonstrated that sufficient time has passed to understand their historical importance. Codes Governing Human Remains. Section 15064.5 of the CEQA Guidelines also assigns special importance to human remains and specifies procedures to be used when Native American remains are discovered. The disposition of human remains is governed by Health and Safety Code Section 7050.5 and PRC Sections 5097.94 and 5097.98, and falls within the jurisdiction of the NAHC. If human remains are discovered, the County Coroner must be notified within 48 hours and there should be no further disturbance to the site where the remains were found. If the remains are determined by the coroner to be Native American, the coroner is responsible for contacting the NAHC within 24 hours. The NAHC, pursuant to PRC Section 5097.98, will immediately notify those persons it believes to be most likely descended from the deceased Native Americans so they can inspect the burial site and make recommendations for treatment or disposal. Local Regulations. The project is subject to local measures, including the City’s Historic Preservation Ordinance, the City’s General Plan, and the San Luis Obispo Municipal Code. These regulations are discussed below. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-15 Historic Preservation Ordinance. In 2010, the City of San Luis Obispo passed a Historic Preservation Ordinance to identify and protect important historic resources within the city (City of San Luis Obispo 2010). When determining if a property should be designated as a listed Historic or Cultural Resource, the Cultural Heritage Commission and City Council are to consider this ordinance and SHPO standards. To be eligible for designation, the resource shall exhibit a high level of historic integrity, be at least 50 years old (less than 50 if it can be demonstrated that enough time has passed to understand its historical importance) and satisfy at least one of the following criteria: A. Architectural Criteria: Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values. (1) Style: Describes the form of a building, such as size, structural shape and details within that form (e.g. arrangement of windows and doors, ornamentation, etc.). Building style will be evaluated as a measure of: a. The relative purity of a traditional style; b. Rarity of existence at any time in the locale; and/or current rarity although the structure reflects a once popular style; c. Traditional, vernacular and/or eclectic influences that represent a particular social milieu and period of the community; and/or the uniqueness of hybrid styles and how these styles are put together. (2) Design: Describes the architectural concept of a structure and the quality of artistic merit and craftsmanship of the individual parts. Reflects how well a particular style or combination of styles are expressed through compatibility and detailing of elements. Also, suggests degree to which the designer (e.g., carpenter-builder) accurately interpreted and conveyed the style(s). Building design will be evaluated as a measure of: a. Notable attractiveness with aesthetic appeal because of its artistic merit, details and craftsmanship (even if not necessarily unique); b. An expression of interesting details and eclecticism among carpenter-builders, although the craftsmanship and artistic quality may not be superior. (3) Architect: Describes the professional (an individual or firm) directly responsible for the building design and plans of the structure. The architect will be evaluated as a reference to: a. A notable architect (e.g., Wright, Morgan), including architects who made significant contributions to the state or region, or an architect whose work influenced development of the city, state or nation. b. An architect who, in terms of craftsmanship, made significant contributions to San Luis Obispo (e.g., Abrahams who, according to local sources, designed the house at 810 Osos - Frank Avila’s father’s home - built between 1927 – 30). B. Historic Criteria: (1) History – Person: Associated with the lives of persons important to local, California, or national history. Historic person will be evaluated as a measure of the degree to which a person or group was: a. Significant to the community as a public leader (e.g., mayor, congress member, etc.) or for his or her fame and outstanding recognition - locally, regionally, or nationally. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-16 b. Significant to the community as a public servant or person who made early, unique, or outstanding contributions to the community, important local affairs or institutions (e.g., council members, educators, medical professionals, clergymen, railroad officials). (2) History – Event: Associated with events that have made a significant contribution to the broad patterns of local or regional history or the cultural heritage of California or the United States. Historic event will be evaluated as a measure of: a. A landmark, famous, or first-of-its-kind event for the city - regardless of whether the impact of the event spread beyond the city. b. A relatively unique, important or interesting contribution to the city (e.g., the Ah Louis Store as the center for Chinese-American cultural activities in early San Luis Obispo history). (3) History-Context: Associated with and also a prime illustration of predominant patterns of political, social, economic, cultural, medical, educational, governmental, military, industrial, or religious history. Historic context will be evaluated as a measure of the degree to which it reflects: a. Early, first, or major patterns of local history, regardless of whether the historic effects go beyond the city level, that are intimately connected with the building (e.g., County Museum). b. Secondary patterns of local history, but closely associated with the building (e.g., Park Hotel). C. Integrity: Authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance. Integrity will be evaluated by a measure of: (1) Whether or not a structure occupies its original site and/or whether or not the original foundation has been changed, if known. (2) The degree to which the structure has maintained enough of its historic character or appearance to be recognizable as an historic resource and to convey the reason(s) for its significance. (3) The degree to which the resource has retained its design, setting, materials, workmanship, feeling and association. The project site is not currently within the City limit. Therefore, neither the project site nor any structures on the site are currently listed as a Historic or Cultural Resource according to the above criteria. However, the San Luis Ranch property exemplifies an important period of local history, being established as a family farm and developing into a valuable local agribusiness industry. The property is representative of early 20th century agricultural and industrial development. The San Luis Ranch Complex, as well as cultivated fields, has existed on the property for over a century. The San Luis Ranch Complex is a rare remaining and intact example of a farm complex representing the early agricultural history of San Luis Obispo. Therefore, it is eligible for designation as a City of San Luis Obispo historic resource under Criterion B.2 (Event) and Criterion B.3 (Context). The main Craftsman style residence (Residence #1) and the main barn both embody the distinctive characteristics of Craftsman and vernacular agricultural architecture, retaining the majority of their character-defining features and integrity. As such, these two structures are individually eligible for designation as City of San Luis Obispo historic resources under Criterion A.1 (Style). San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-17 City of San Luis Obispo General Plan. The Conservation and Open Space Element of the General Plan addresses historic and architectural Resources within the City. New development is evaluated for consistency with the following adopted goals and policies relating to archaeological and historical resources: Goal 3.2. Historic and Architectural Resources. The City will expand community understanding, appreciation, and support for historic and architectural resource preservation to ensure long-term protection of cultural resources. Policy 3.3.1. Historic Preservation. Significant historic and architectural resources should be identified, preserved, and rehabilitated. Policy 3.3.2. Demolitions. Historically or architecturally significant buildings shall not be demolished or substantially changed in outward appearance, unless doing so is necessary to remove a threat to health and safety and other means to eliminate or reduce the threat to acceptable levels are infeasible. Policy 3.3.3. Historical Documentation. Buildings and other cultural features that are not historically significant but which have historical or architectural value should be preserved or relocated where feasible. Where preservation or relocation is not feasible, the resources shall be documented and the information retained in a secure but publicly accessible location. An acknowledgement of the resources should be incorporated within the site through historic signage and the reuse or display of historic material and artifacts. Goal 3.4. Historic and Architectural Resources. The City will expand community understanding, appreciation, and support for archaeological resource preservation. Policy 3.5.1. Archaeological Resource Protection. The City shall provide for the protection of both known and potential archaeological resources. To avoid significant damage to important archaeological sites, all available measures, including purchase of the property in fee or easement, shall be explored at the time of a development proposal. Where such measures are not feasible and development would adversely affect identified archaeological or paleontological resources, mitigation shall be required pursuant to the Archaeological Resource Preservation Program Guidelines. Policy 3.5.2. Native American Sites. All Native American cultural and archaeological sites shall be protected as open space wherever possible. Policy 3.5.3. Non-Development Activities. Activities other than development which could damage or destroy archaeological sites, including off-road vehicle use on or adjacent to known sites, or unauthorized collection of artifacts, shall be prohibited. Policy 3.5.4. Archaeological Sensitive Areas. Development within an archaeologically sensitive area shall require a preliminary site survey by a qualified archaeologist knowledgeable in Native American cultures, prior to a determination of the potential environmental impacts of the project. Policy 3.5.5. Archaeological Resources Present. Where a preliminary site survey finds substantial archaeological resources, before permitting construction, the City shall require a mitigation plan to protect the resources. Possible mitigation measures include: presence of a San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-18 qualified professional during initial grading or trenching; project redesign; covering with a layer of fill; excavation removal and curation in an appropriate facility under the direction of a qualified professional. Policy 3.5.6. Qualified Archaeologist Present. Where substantial archaeological resources are discovered during construction or grading activities, all such activities in the immediate area of the find shall cease until a qualified archaeologist knowledgeable in Native American cultures can determine the significance of the resource and recommend alternative mitigation measures. Policy 3.5.7. Native American Participation. Native American participation shall be included in the City’s Guidelines for resource assessment and impact mitigation. Native American representatives should be present during archaeological excavation and during construction in an area likely to contain cultural resources. The Native American community shall be consulted as knowledge of cultural resources expands and as the City considered updates or significant changes to its General Plan. Policy 3.6.3. Construction within Historic Districts. The Cultural Heritage Committee and Architectural Review Commission will provide specific guidance on the construction of new buildings within historic districts. Municipal Code. In addition to the City of San Luis Obispo’s requirements to designate a Historic or Cultural Resource, the City Municipal Code contains specific requirements for the demolition and relocation of structures listed in the inventory of historic resources. These requirements are stated in Municipal Code sections 14.01.100 and 14.01.110. The City Municipal Code states that the Cultural Heritage Committee (CHC) shall review and make recommendations to the City Council regarding demolition applications for structures listed in the inventory of historic resources. An application for demolition of a listed historic resource shall be approved only if the proposed demolition is found consistent with the general plan and 1) the historic resource is a hazard to public health of safety, and repair or stabilization is not structurally feasible; or 2) denial of the application will constitute an economic hardship as described in section 14.01.100(J)(1-3) of the municipal code. Additional procedures regarding the timing of the demolition, documentation and acknowledgment of the historic resource are also delineated. Likewise, the relocation of a structure listed on the inventory of historic resources is subject to review by the CHC and Architectural Review Commission (ARC). Relocation shall be permitted only when relocation is consistent with the goals and policies of the general plan, any applicable area or specific plans, and the Historic Preservation Program Guidelines, as well as additional criteria defined in Municipal Code Section 14.01.110(B)(1-6). The timing, plan, procedures and documentation are also delineated. City of San Luis Obispo Archaeological Resource Preservation Guidelines. The Archaeological Resource Preservation Guidelines (part of the City’s Environmental Guidelines) developed by the San Luis Obispo CHC are used to determine whether a project complies with CEQA, as well as the information needed to evaluate a project’s effects on archaeological sites and artifacts. The Guidelines call for a three-step approach to historical resources: preparation of an Archaeological and Architectural Resource Inventory (ARI); Subsurface Archaeological San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-19 Resource Evaluation (SARE); and Archaeological Resource Impact Mitigation (ARIM). These steps parallel the CEQA process. 4.5.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) previously analyzed Citywide impacts to cultural resources, including those associated with development on the San Luis Ranch Specific Plan Area, related to the adoption and implementation of the Land Use and Circulation Element policies and programs. The LUCE Update EIR cultural resources analysis determined that the intensification of land uses anticipated to occur in certain areas of the City under the Land Use and Circulation Element update, including the San Luis Ranch Specific Plan area, could have an adverse effect on historic structures, as well as identified and previously unidentified archaeological and paleontological resources, including human remains. However, the LUCE Update EIR concluded that implementation of LUCE Update EIR Mitigation Measures CR-1 through CR-3, which changed the language of General Plan Conservation and Open Space Policies 3.3.2, 3.3.5, 3.5.10 to be more stringent in order to better facilitate the protection of the City’s historical resources, as well as various other General Plan policies regarding cultural and paleontological resources, would reduce impacts to historic structures and archaeological and paleontological resources to a less than significant level. 4.5.3 Impact Analysis a. Methodology and Significance Thresholds for Cultural Resources. If a project may cause a substantial adverse change in the characteristics of a resource that convey its significance or justify its eligibility for inclusion in the CRHR or a local register, either through demolition, destruction, relocation, alteration, or other means, then the project is judged to have a significant effect on the environment (CEQA Guidelines, Section 15064.5[b]). The following thresholds are based on Appendix G of the State CEQA Guidelines. Impacts would be significant if the project would: 1. Cause a substantial adverse change in the significance of a historic resource as defined in §15064.5; 2. Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5; 3. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature; or 4. Disturb any human remains, including those interred outside of formal cemeteries. The Initial Study determined that the project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. Therefore, Threshold 3 is not discussed further in this section. Refer to Section 4.14, Issues Addressed in the Initial Study, for a discussion of this issue. Direct impacts can be assessed by identifying the types and locations of proposed development, determining the exact locations of cultural resources within the project area, assessing the significance of the resources that may be affected, and determining the appropriate mitigation. Removal, demolition, or alteration of historical resources can permanently impact the historic fabric of an archaeological site, structure, or historic district. San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-20 Methodology. The analysis within this section builds upon the conclusions identified in the LUCE Update EIR, as described in Section 4.5.2. Where applicable, this analysis includes mitigation that implements applicable City policies for the protection of archaeological and historical resources. A Cultural Resources Study of the project site and vicinity was completed in August 2016 (Appendix G). As described in Section 4.5.1(d), as part of the Cultural Resources Study, a records search was obtained from the CCIC. The search was conducted to identify previous cultural resources evaluations and previously recorded cultural resources on the project site as well as within a 0.5-mile radius of the project site. In addition to the records search, the Cultural Resources Study included archival research for the project site. The methodology for the archival research focused on the review of primary and secondary source materials related to the history and development of the project site and vicinity. Sources for this research included historic maps, aerial photographs, and written histories of the area. In addition, Rincon staff conducted a pedestrian survey of the project site for archaeological resources between March 14, 2016 and March 16, 2016. On March 15, 2016 Rincon staff also conducted survey of the project site for historic resources, which included examination, documentation, photographing, and evaluating the built environment features on the project site. Between August 1, 2016 and August 16, 2016, Rincon staff conducted test excavations to evaluate the CRHR eligibility of the prehistoric lithic scatter located on the western edge of the project site (SLR-S-01). During archaeological testing all identified surface artifacts were also collected for temporary storage, cataloging, and analysis. All data was recorded on standard archaeological forms. All excavations were backfilled upon completion of testing. Rincon conducted Native American consultation consistent with Senate Bill 18 and Assembly Bill 52 for the project to identify potential concerns or issues associated with Native American cultural resources within the project vicinity. Rincon contacted the NAHC to determine whether any sites recorded in the NAHC’s Sacred Lands File occur in or near the project site. The NAHC responded on January 27, 2016 stating that the search of the sacred land files “failed to indicate the presence of Native American cultural resources in the immediate project area.” In addition, the NAHC provided a list of Native American groups and individuals who may have knowledge of cultural resources within the project site. The Native American scoping did not identify any identify any specific resources important to the consulted groups within the project site. However, several contacts noted that the area is sensitive. All Native American parties contacted about the project site are described in the Cultural Resource Study (Appendix G). b. Impacts and Mitigation Measures. Threshold 1 Would the project cause a substantial adverse change in the significance of a historic resource as defined in §15064.5? Impact CR-1 The project would result in the relocation, demolition, and removal of structures on the San Luis Ranch property which are individually identified as historic resources. In addition, the project would eliminate the San Luis Ranch Complex, which is eligible for listing as a historic resource. Relocation, demolition, and/or removal of these historic resources would permanently alter the historic context of the project site and on-site San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-21 structures. This impact would be Class I, significant and unavoidable. As described in Section 4.5.1(d), the San Luis Ranch property, which includes the San Luis Ranch Complex, is eligible for listing as a City landmark, and is eligible for listing in the CRHR under Criterion 1 (association with early agricultural development in San Luis Obispo) and Criterion 3 (distinctive characteristics of early 20th century vernacular agricultural architecture). The characteristics and history of the San Luis Ranch property make it eligible for designation as a City of San Luis Obispo landmark property under Criterion B.2 (event) or B.3 (context). In addition, the main residence and the main barn that are within the San Luis Ranch Complex are individually eligible for listing as City landmarks, and are eligible for listing under CRHR Criterion 3 (distinctive characteristics of early 20th century vernacular agricultural and Craftsman architecture). In addition, the characteristics and history of the main residence and main barn make these structures eligible for designation as City landmark properties under Criterion A.1 (style). As such, the San Luis Ranch Complex, as well as the individual main residence and main barn structures are considered historic resources under CEQA. The project includes the adaptive reuse and relocation of the existing main residence and the former spectators’ barn/viewing stand to new locations on the site within the Agricultural Heritage and Learning Center. The project would also result in the demolition or off-site relocation of the remaining building and structures included in the San Luis Ranch Complex, including the historic main barn. Salvageable materials from the main barn are proposed to be reused to the greatest extent possible in the construction of a new barn in the project’s proposed Agricultural Heritage and Learning Center. The main residence and former spectators’ barn/viewing stand are proposed to be restored and adaptively reused following the Secretary of the Interior’s Standards. These proposed actions of the project would be subject to the requirements of the City Municipal Code Sections 14.01.100 and 14.01.110, which include requirements for the demolition and relocation of structures listed in the inventory of historic resources. Although the project site is not currently listed by the City as a historic resource because the project site is currently outside of the City limit, the project applicant seeks annexation by the City. Therefore, with annexation of the project site into the City, Municipal Code Sections 14.01.100 and 14.01.110 would apply to removal of the San Luis Ranch Complex and relocation of the main residence and spectators’ barn/viewing stand structure. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan proposes programs and policies intended to reduce impacts to historical resources to the maximum extent practicable. Specific Plan Policy 2.5 states that the Specific plan would “Protect associated structures such as the Dalidio Home, Laguna Race Track viewing stand, barn, and water tower.” Specific Plan Program 2.5.1 would require evaluation of the historic structures on the site for the purposes of preservation and protective reuse. The Specific Plan proposes relocation of the main residence and spectators’ barn/viewing stand to the Agricultural Heritage and Learning Center area for permanent preservation, and specifies that both structures would be subject to historic documentation by a qualified historian prior to relocation, including being photographed and recorded consistent with professional historical standards, and a qualified historic preservation architect would be consulted during relocation planning to ensure that significant historic materials and fabric are retained and reconstructed San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-22 appropriately. The Specific Plan also specifies that the associated structures in the San Luis Ranch Complex would be photographed and recorded before they are removed from the site. Removal of the San Luis Ranch Complex and relocation, demolition, and/or removal of the historic main residence and main barn as part of the project would result in adverse changes to individually identified historic structures as well as the historic context of the San Luis Ranch property, which is collectively identified as historically significant. Additionally, demolition of the historic main barn, which is part of the San Luis Ranch Complex, would conflict with Conservation and Open Space Element Policy 3.3.1, Historic Preservation, which states that significant historic and architectural resources should be identified, preserved, and rehabilitated, as well as Conservation and Open Space Element Policy 3.3.2, Demolitions, which prohibits demolition or substantial changes in outward appearance of historically or architecturally significant buildings, unless doing so is necessary to remove a threat to health and safety and other means to eliminate or reduce the threat to acceptable levels are infeasible. For these reasons, the project would result in a potentially significant impact to historic resources and mitigation would be required. Mitigation Measures. The following mitigation measures would reduce project impacts on historical resources to the maximum extent practicable. CR-1(a) Historical Structure Relocation and Reconstruction Plan. In order to implement Specific Plan Policy 2.5, a relocation and reconstruction plan for the former spectator’s barn/viewing stand, and main residence, and main barn shall be developed by a qualified historic architect. The plan shall include a structural/architectural report documenting existing integrity and conditions and include detailed treatment methods and measures to ensure that historic integrity is retained and that all identified character defining features will be preserved. CR-1(b) Archival Documentation of Historic Buildings. The applicant shall provide archival documentation of the San Luis Ranch Complex in as- built and as-found condition in the form of a Historic American Building Survey (HABS) Level II documentation. The documentation shall comply with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation (NPS 1990), and shall include large-format photographic recordation, detailed historic narrative report, and compilation of historic research. The documentation shall be completed by a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualification Standards for History and/or Architectural History (NPS 1983). The original archival-quality documentation shall be offered as donated material to the History Center of San Luis Obispo County. Archival copies of the documentation shall also be submitted to the San Luis Obispo County Library. CR-1(c) Informational Display of Historic Resources. A retrospective interpretive display detailing the history of the San Luis Ranch San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-23 Complex and the project site, its significance, and its important details and features shall be developed by the applicant. The information should be incorporated into a publicly-accessed building on the project site, such as the proposed Agricultural Heritage Facilities and Learning Center, or a publicly-accessed outdoor location. The display shall include images and details from the HABS documentation described in Mitigation Measure CR-1(b) and any collected research pertaining to the historic property. The content shall be prepared by a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualification Standards for History and/or Architectural History (NPS 1983). Plan Requirements and Timing. The project applicant shall prepare the relocation and reconstruction plan for the main residence and the spectators’ barn/viewing stand to the satisfaction of the Community Development Director prior to the issuance of project grading permits. Project grading plans shall detail phasing and include sufficient detail to demonstrate the sequencing and completion of the relocation and reconstruction plan. The applicant shall complete archival documentation of the San Luis Ranch Complex prior to the removal, relocation, reconstruction, and/or demolition of the structures on the project site to the satisfaction of the Community Development Director. The applicant shall develop and install an informational display of the site’s identified historical resources prior to opening of the Agricultural Heritage Facilities and Learning Center to the public. Monitoring. The City shall confirm completion of and approve the relocation and reconstruction plan and archival documentation. The City shall confirm submittal of the documentation to the History Center of San Luis Obispo County and the San Luis Obispo County Library. The City shall also review applicable plans for compliance with recommendations of the relocation and reconstruction plan and periodically inspect the site to ensure compliance. The information display shall be prepared in accordance with recommendations of a qualified historic consultant and shall be approved by the Community Development Director. Residual Impacts. Mitigation Measure CR-1(a) would ensure that the main residence and barn/viewing stand would retain their individual integrity and character defining features. Mitigation Measure CR-1(a) would mitigate impacts to this individually significant resource to the maximum extent feasible. In addition, Mitigation Measures CR-1(b) and CR-1(c) would reduce significant direct impacts to the remainder of the historically significant San Luis Ranch Complex, including the individually significant historic main barn, to the maximum extent feasible. However, the removal and/or demolition of the historically significant main barn and the relocation, demolition, and removal of other structures in the San Luis Ranch Complex would change the San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-24 historic context of the San Luis Ranch property. Furthermore, mitigation would not avoid the removal of the main barn, despite the proposed reuse of salvageable materials from the structure to the greatest extent possible in the construction of a new barn in the project’s proposed Agricultural Heritage and Learning Center. Therefore, the potential impact to the San Luis Ranch Complex and the main barn individually would remain significant and unavoidable despite implementation of the required mitigation. Threshold 2 Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5? Threshold 4 Would the project disturb any human remains, including those interred outside of formal cemeteries? Impact CR-2 Identified archaeological resources on the project site are ineligible for listing in the CRHR and NRHP, and disturbance of these resources would not constitute a significant impact. However, the potential remains for the project to result in impacts to previously unidentified archaeological resources. Therefore, this impact would be Class II, significant but mitigable. As described in Section 4.5.1(d), one prehistoric archaeological site (SLR-S-01) has been identified and recorded on the project site. SLR-S-01 is highly disturbed by repeated plowing, planting, harvesting, and other activities associated with crop cultivation. Although subsurface artifacts are present, they are limited to disturbed sediments above 40 centimeters below the surface, and do not represent an intact deposit. Based on the finding of the Cultural Resources Study (Appendix G), it is likely that the subsurface component consists of artifacts that were previously located on the surface scatter and have been redeposited due to remixing of sediments caused by agricultural activities. SLR-S-01 is not directly associated with important events or any persons significant in our past and, due to the absence of an intact subsurface component and lack of specific, interpretable context, the site is unlikely to yield important information about prehistory or history. As such, SLR-S-01 is not significant under CRHR Criteria 1, 2, 3 or 4. Therefore, the site is ineligible for listing in the CRHR and NRHP and requires no further management consideration under CEQA or the NHPA. Two prehistoric isolated artifacts (SLR-I-01 and SLR-I-02) have also been identified and recorded on the project site. Under CEQA, the isolates are not eligible for listing in the CRHR. The information potential of isolates SLR-I-01 and SLR-I-02 and site SLR-S-01 has been exhausted by their recordation and analysis as part of the Cultural Resources Study. The surface of the project site has been previously disturbed by over 100 years of agricultural activities including planting, harvesting, and other activities associated with crop cultivation and thus the possibility of encountering undisturbed archaeological resources during construction is unlikely. However, prehistoric archaeological deposits could be preserved at depth beneath the project site. Construction of the project involves grading and excavation in areas that could contain subsurface archaeological remains. Unanticipated discovery of human remains during project excavation would require compliance with Health and Safety Code Section 7050.5 and PRC Sections 5097.94 and 5097.98. Compliance with Health and Safety Code Section 7050.5 and PRC Sections 5097.94 and 5097.98 would ensure that unanticipated discovery San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-25 of human remains during project excavation would be addressed appropriately by the County Coroner and NAHC (if required), and would not constitute a significant impact. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes requirements intended to protect archaeological resources. Specific Plan Policy 3.5.4 requires a preliminary site survey for development within archaeologically sensitive areas. As described in Section 4.5.1(d), the Cultural Resources Study (Appendix G) includes an evaluation of known archaeological resources on the project site, and determined that these resources are not intact or otherwise archaeologically significant. However, excavation associated with the project grading plan would have the potential to encounter buried archaeological deposits. Therefore, mitigation is required to ensure that any discovered resources would be protected and curated if encountered during project construction. Mitigation Measures. The following measures would reduce potential impacts to archaeological resources to a less than significant level. CR-2(a) Retain a Qualified Principal Investigator. In accordance with Conservation and Open Space Policies 3.5.6 and 3.5.7, a qualified principal investigator, defined as an archaeologist who meets the Secretary of the Interior’s Standards for professional archaeology (hereafter qualified archaeologist), shall be retained to carry out all mitigation measures related to archaeological resources. Monitoring shall involve inspection of subsurface construction disturbance at or in the immediate vicinity of known sites, or at locations that may harbor buried resources that were not identified on the site surface. A Native American monitor shall also be present because the area is a culturally sensitive location. The monitor(s) shall be on-site on a full-time basis during earthmoving activities, including grading, trenching, vegetation removal, or other excavation activities. CR-2(b) Unanticipated Discovery of Archaeological Resources. In the event that archaeological resources are exposed during construction, all work shall be halted in the vicinity of the archaeological discovery until a qualified archaeologist can visit the site of discovery and assess the significance of the cultural resource. In the event that any artifact or an unusual amount of bone or shell is encountered during construction, work shall be immediately stopped and relocated to another area. The lead agency shall stop construction within 100 feet of the exposed resource until a qualified archaeologist/paleontologist can evaluate the find (see 36 CFR 800.11.1 and CCR, Title 14, Section 15064.5[f]). Examples of such cultural materials might include: ground stone tools such as mortars, bowls, pestles, and manos; chipped stone tools such as projectile points or choppers; flakes of stone not consistent with the immediate geology such as obsidian or fused shale; historic trash pits containing bottles and/or ceramics; or structural remains. If the resources are found to be significant, they San Luis Ranch Project EIR Section 4.5 Cultural Resources City of San Luis Obispo 4.5-26 must be avoided or will be mitigated consistent with State Historic Preservation Office (SHPO) Guidelines. Plan Requirements and Timing. The project applicant shall retain a qualified principal investigator and Native American monitor prior to the issuance of grading permits. The requirement that construction work be stopped in the event of discovery of archaeological resources shall be included on construction plans prior to the issuance of grading permits. Monitoring. The City shall confirm the qualifications of and approve the applicant’s choice of a qualified principal investigator and Native American monitor. The City shall also inspect the site periodically during grading and demolition to ensure compliance with this measure. The City shall review construction plans and periodically inspect project construction to ensure compliance with this measure. Residual Impacts. Implementation of Mitigation Measures CR-2(a) and CR-2(b) would reduce impacts to archaeological resources to a less than significant level. c. Cumulative Impacts. Planned buildout of the City of San Luis Obispo under the General Plan, including buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans, would cumulatively increase the potential for adverse effects on historic and archaeological resources in the City. The project would incrementally contribute to this cumulative effect. Impacts to historic and archaeological resources are generally site-specific. Accordingly, as required under applicable laws and regulations, potential impacts associated with cumulative developments would be addressed on a case-by-case basis. As discussed in Section 4.5.2, the San Luis Ranch Specific Plan, as well as other approved and proposed plans in the City, is required to comply with existing General Plan Conservation and Open Space Element Policies 3.3.1, 3.3.2, 3.3.3, 3.5.1, 3.5.2, 3.5.3, 3.5.4, 3.5.5, 3.5.6, 3.5.7, and 3.6.3, which address the protection of historical and archaeological resources within the City. As described in Impact CR-2, the project would not result in the loss of any significant archaeological resources and, therefore, would not contribute substantially to the cumulative loss of archaeological resources in the City. However, the project would result in a significant and unavoidable impact associated with the removal, relocation, or reconstruction of individually historic structures that are part of the historically significant San Luis Ranch Complex. As such, the project would contribute to the cumulative loss of historic resources in the City. Therefore, the project would also result in a Class I, significant and unavoidable, cumulative impact to historical resources. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-1 GREENHOUSE GAS EMISSIONS 4.6 4.6.1 Setting a. Climate Change and Greenhouse Gases. Climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period of time. The potential effects of climate change are described in more detail below. The term “climate change” is often used interchangeably with the term “global warming,” but “climate change” is preferred to “global warming” because it helps convey that there are other changes in addition to rising temperatures. The baseline against which these changes are measured originates in historical records identifying temperature changes that have occurred in the past, such as during previous ice ages. The global climate is continuously changing, as evidenced by repeated episodes of substantial warming and cooling documented in the geologic record. The rate of change has typically been incremental, with warming or cooling trends occurring over the course of thousands of years. The past 10,000 years have been marked by a period of incremental warming, as glaciers have steadily retreated across the globe. However, scientists have observed acceleration in the rate of warming during the past 150 years. Per the United Nations Intergovernmental Panel on Climate Change (IPCC, 2014), the understanding of anthropogenic warming and cooling influences on climate has led to a high confidence (95 percent or greater chance) that the global average net effect of human activities has been the dominant cause of warming since the mid- 20th century (IPCC, 2014). Gases that absorb and re-emit infrared radiation in the atmosphere are called greenhouse gases (GHGs). The gases that are widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O), fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. GHGs are emitted by both natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are largely by- products of fossil fuel combustion, whereas CH4 results from off-gassing associated with agricultural practices and landfills. Observations of CO2 concentrations, globally-averaged temperature, and sea level rise are generally well within the range of the extent of the earlier IPCC projections. The recently observed increases in CH4 and N2O concentrations are smaller than those assumed in the scenarios in the previous assessments. Each IPCC assessment has used new projections of future climate change that have become more detailed as the models have become more advanced. Man-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and sulfur hexafluoride (SF6) (California Environmental Protection Agency [CalEPA], 2006). Different types of GHGs have varying global warming potentials (GWPs). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-2 reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emissions, referred to as “carbon dioxide equivalent” (CO2e), and is the amount of a GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, methane CH4 has a GWP of 25, meaning its global warming effect is 25 times greater than carbon dioxide on a molecule per molecule basis (IPCC, 2007). The accumulation of GHGs in the atmosphere regulates the earth’s temperature. Without the natural heat trapping effect of GHGs, Earth’s surface would be about 34° C cooler (CalEPA, 2015). However, it is believed that emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, have elevated the concentration of these gases in the atmosphere beyond the level of naturally occurring concentrations. The following discusses the primary GHGs of concern. Carbon Dioxide. The global carbon cycle is made up of large carbon flows and reservoirs. Billions of tons of carbon in the form of CO2 are absorbed by oceans and living biomass (i.e., sinks) and are emitted to the atmosphere annually through natural processes (i.e., sources). When in equilibrium, carbon fluxes among these various reservoirs are roughly balanced (United States Environmental Protection Agency [U.S. EPA], 2014). CO2 was the first GHG demonstrated to be increasing in atmospheric concentration, with the first conclusive measurements being made in the second half of the 20th century. Concentrations of CO2 in the atmosphere have risen approximately 40 percent since the industrial revolution. The global atmospheric concentration of CO2 has increased from a pre-industrial value of about 280 parts per million (ppm) to 391 ppm in 2011 (IPCC, 2007; Oceanic and Atmospheric Administration [NOAA], 2010). The average annual CO2 concentration growth rate was larger between 1995 and 2005 (average: 1.9 ppm per year) than it has been since the beginning of continuous direct atmospheric measurements (1960–2005 average: 1.4 ppm per year), although there is year-to-year variability in growth rates (NOAA, 2010). Currently, CO2 represents an estimated 74 percent of total GHG emissions (IPCC, 2007). The largest source of CO2 emissions, and of overall GHG emissions, is fossil fuel combustion. Methane. Methane (CH4) is an effective absorber of radiation, though its atmospheric concentration is less than that of CO2 and its lifetime in the atmosphere is limited to 10 to 12 years. It has a GWP approximately 25 times that of CO2. Over the last 250 years, the concentration of CH4 in the atmosphere has increased by 148 percent (IPCC, 2007), although emissions have declined from 1990 levels. Anthropogenic sources of CH4 include enteric fermentation associated with domestic livestock, landfills, natural gas and petroleum systems, agricultural activities, coal mining, wastewater treatment, stationary and mobile combustion, and certain industrial processes (U.S. EPA, 2014). Nitrous Oxide. Concentrations of nitrous oxide (N2O) began to rise at the beginning of the industrial revolution and continue to increase at a relatively uniform growth rate (NOAA, 2010). N2O is produced by microbial processes in soil and water, including those reactions that occur in fertilizers that contain nitrogen, fossil fuel combustion, and other chemical processes. Use of these fertilizers has increased over the last century. Agricultural soil management and mobile source fossil fuel combustion are the major sources of N2O emissions. The GWP of nitrous oxide is approximately 298 times that of CO2 (IPCC, 2007). San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-3 Fluorinated Gases (HFCS, PFCS and SF6). Fluorinated gases, such as hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfurhexafluoride (SF6), are powerful GHGs that are emitted from a variety of industrial processes. Fluorinated gases are used as substitutes for ozone- depleting substances such as chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), and halons, which have been regulated since the mid-1980s because of their ozone-destroying potential and are phased out under the Montreal Protocol (1987) and Clean Air Act Amendments of 1990. Electrical transmission and distribution systems account for most SF6 emissions, while PFC emissions result from semiconductor manufacturing and as a by-product of primary aluminum production. Fluorinated gases are typically emitted in smaller quantities than CO2, CH4, and N2O, but these compounds have much higher GWPs. SF6 is the most potent GHG the IPCC has evaluated. Greenhouse Gas Emissions Inventory. Worldwide anthropogenic emissions of GHGs were approximately 46,000 million metric tons (MMT, or gigatonne) CO2e in 2010 (IPCC, 2014). CO2 emissions from fossil fuel combustion and industrial processes contributed about 65 percent of total emissions in 2010. Of anthropogenic GHGs, carbon dioxide was the most abundant accounting for 76 percent of total 2010 emissions. Methane emissions accounted for 16 percent of the 2010 total, while nitrous oxide and fluorinated gases account for 6 and 2 percent respectively (IPCC, 2014). Total U.S. GHG emissions were 6,870.5 MMT CO2e in 2014 (U.S. EPA, 2016). Total U.S. emissions have increased by 7.4 percent since 1990; emissions increased by 1.0 percent from 2013 to 2014 (U.S. EPA, 2016). The increase from 2013 to 2014 was due to relatively cool winter conditions, which led to an increase in fuels consumed for heating and cooling for the residential and commercial sectors. Additionally, transportation emissions increased as a result of a small increase in vehicle miles traveled (VMT) and fuel use across on-road transportation modes. There also was an increase in industrial production across multiple sectors resulting in slight increases in industrial sector emissions (U.S. EPA, 2016). Since 1990, U.S. emissions have increased at an average annual rate of 0.3 percent. In 2014, the industrial and transportation end-use sectors accounted for 29.2 percent and 26.4 percent of CO2 emissions (with electricity-related emissions distributed), respectively. Meanwhile, the residential and commercial end-use sectors accounted for 16.6 percent and 17.1 percent of CO2 emissions, respectively (U.S. EPA, 2016). Based upon the California Air Resources Board (ARB) California Greenhouse Gas Inventory for 2000-2014, California produced 441.5 MMT CO2E in 2014 (ARB, 2016). The major source of GHG in California is transportation, contributing 37 percent of the State’s total GHG emissions. Industrial sources are the second largest source of the State’s GHG emissions, contributing 24 percent of the State’s GHG emissions (ARB, 2016). California emissions are due in part to its large size and large population compared to other states. However, a factor that reduces California’s per capita fuel use and GHG emissions, as compared to other states, is its relatively mild climate. ARB has projected statewide unregulated GHG emissions for the year 2020 will be 509.4 MMT CO2e (ARB, 2016). These projections represent the emissions that would be expected to occur in the absence of any GHG reduction actions. In 2009, the City of San Luis Obispo published the Community and Municipal Operations Baseline Greenhouse Gas Emissions Inventory. Using 2005 emissions from community-wide activities San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-4 within the City’s jurisdictional boundary, including municipal government operations, the inventory identifies the major sources of GHG emissions within the City and provides a baseline for the climate action planning process. The City’s community-wide emissions in 2005 came to a total of 264,240 MTCO2e (City of San Luis Obispo, 2009). The major source of GHG emissions in the community were from transportation (50 percent). Other sources identified include commercial and industrial operations (21.9 percent), residential operations (21 percent), and solid waste (7.1 percent) (City of San Luis Obispo, 2009). Potential Effects of Climate Change. Globally, climate change has the potential to affect numerous environmental resources through potential impacts related to future air temperatures and precipitation patterns. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 21st century than were observed during the 20th century. According to the CalEPA’s 2010 Climate Action Team Biennial Report, potential impacts of climate change in California may include loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years (CalEPA, 2010). A summary of some of the potential effects that could be experienced in California as a result of climate change is provided below. Long-term trends have found that each of the past three decades has been warmer than all the previous decades in the instrumental record, and the decade from 2000 through 2010 has been the warmest. The global combined land and ocean temperature data show an increase of about 0.89°C (0.69°C–1.08°C) over the period 1901–2012 and about 0.72°C (0.49°C–0.89°C) over the period 1951–2012 when described by a linear trend. Several independently analyzed data records of global and regional Land-Surface Air Temperature (LSAT) obtained from station observations are in agreement that LSAT as well as sea surface temperatures have increased. In addition to these findings, there are identifiable signs that global warming is currently taking place, including substantial ice loss in the Arctic over the past two decades (IPCC, 2014). Air Quality. Higher temperatures, which are conducive to air pollution formation, could worsen air quality in California. Climate change may increase the concentration of ground-level ozone, but the magnitude of the effect, and therefore its indirect effects, are uncertain. If higher temperatures are accompanied by drier conditions, the potential for large wildfires could increase, which, in turn, would further worsen air quality. However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains would tend to temporarily clear the air of particulate pollution and reduce the incidence of large wildfires, thereby ameliorating the pollution associated with wildfires. Additionally, severe heat accompanied by drier conditions and poor air quality could increase the number of heat-related deaths, illnesses, and asthma attacks throughout the state (California Energy Commission [CEC], 2009). Water Supply. Analysis of paleoclimatic data (such as tree-ring reconstructions of stream flow and precipitation) indicates a history of naturally and widely varying hydrologic conditions in California and the west, including a pattern of recurring and extended droughts. Uncertainty remains with respect to the overall impact of climate change on future water supplies in California. However, the average early spring snowpack in the Sierra Nevada decreased by about 10 percent during the last century, a loss of 1.5 million acre-feet of snowpack storage. During the same period, sea level rose eight inches along California’s coast. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-5 California’s temperature has risen 1°F, mostly at night and during the winter, with higher elevations experiencing the highest increase. Many Southern California cities have experienced their lowest recorded annual precipitation twice within the past decade. In a span of only two years, Los Angeles experienced both its driest and wettest years on record (California Department of Water Resources [DWR], 2008; CCCC, 2009). This uncertainty complicates the analysis of future water demand, especially where the relationship between climate change and its potential effect on water demand is not well understood. The Sierra snowpack provides the majority of California's water supply by accumulating snow during the state’s wet winters and releasing it slowly during the state’s dry springs and summers. Based upon historical data and modeling DWR projects that the Sierra snowpack will experience a 25 to 40 percent reduction from its historic average by 2050. Climate change is also anticipated to bring warmer storms that result in less snowfall at lower elevations, reducing the total snowpack (DWR, 2008). Hydrology and Sea Level Rise. As discussed above, climate change could potentially affect: the amount of snowfall, rainfall, and snow pack; the intensity and frequency of storms; flood hydrographs (flash floods, rain or snow events, coincidental high tide and high runoff events); sea level rise and coastal flooding; coastal erosion; and the potential for salt water intrusion. According to The Impacts of Sea-Level Rise on the California Coast, prepared by the California Climate Change Center (CCCC) (CCCC, 2009), climate change has the potential to induce substantial sea level rise in the coming century. The rising sea level increases the likelihood and risk of flooding. The rate of increase of global mean sea levels over the 2001-2010 decade, as observed by satellites, ocean buoys and land gauges, was approximately 3.2 mm per year, which is double the observed 20th century trend of 1.6 mm per year (World Meteorological Organization [WMO], 2013). As a result, sea levels averaged over the last decade were about 8 inches higher than those of 1880 (WMO, 2013). Sea levels are rising faster now than in the previous two millennia, and the rise is expected to accelerate, even with robust GHG emission control measures. The most recent IPCC report (2013) predicts a mean sea–level rise of 11-38 inches by 2100. This prediction is more than 50 percent higher than earlier projections of 7-23 inches, when comparing the same emissions scenarios and time periods. A rise in sea levels could result in coastal flooding and erosion and could jeopardize California’s water supply due to salt water intrusion. In addition, increased CO2 emissions can cause oceans to acidify due to the carbonic acid it forms. Increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events. Agriculture. California has a $30 billion annual agricultural industry that produces half of the country’s fruits and vegetables. Higher CO2 levels can stimulate plant production and increase plant water-use efficiency. However, if temperatures rise and drier conditions prevail, water demand could increase; crop-yield could be threatened by a less reliable water supply; and greater air pollution could render plants more susceptible to pest and disease outbreaks. In addition, temperature increases could change the time of year certain crops, such as wine grapes, bloom or ripen, and thereby affect their quality (CCCC, 2006). Ecosystems and Wildlife. Climate change and the potential resulting changes in weather patterns could have ecological effects on a global and local scale. Increasing concentrations of San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-6 GHGs are likely to accelerate the rate of climate change. Scientists project that the average global surface temperature could rise by 1.0-4.5°F (0.6-2.5°C) in the next 50 years, and 2.2-10°F (1.4-5.8°C) in the next century, with substantial regional variation. Soil moisture is likely to decline in many regions, and intense rainstorms are likely to become more frequent. Rising temperatures could have four major impacts on plants and animals: (1) timing of ecological events; (2) geographic range; (3) species’ composition within communities; and (4) ecosystem processes, such as carbon cycling and storage (Parmesan, 2006). In summary, climate change could result in destabilization of the existing distribution of habitat, plants, and animals, potentially resulting in adverse effects to such resources. b. Regulatory Setting. The following regulations address both climate change and GHG emissions. International Regulations. The United States is, and has been, a participant in the United Nations Framework Convention on Climate Change (UNFCCC) since it was produced in 1992. The UNFCCC is an international environmental treaty with the objective of, “stabilization of GHG concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system.” This is generally understood to be achieved by stabilizing global GHG concentrations between 350 and 400 ppm, in order to limit the global average temperature increases between 2 and 2.4°C above pre-industrial levels (IPCC, 2007). The UNFCCC itself does not set limits on GHG emissions for individual countries or enforcement mechanisms. Instead, the treaty provides for updates, called “protocols,” that would identify mandatory emissions limits. Five years later, the UNFCCC brought nations together again to draft the Kyoto Protocol (1997). The Kyoto Protocol established commitments for industrialized nations to reduce their collective emissions of six GHGs (CO2, CH4, N2O, SF6, HFCs, and PFCs) to 5.2 percent below 1990 levels by 2012. The United States is a signatory of the Kyoto Protocol, but Congress has not ratified it and the United States has not bound itself to the Protocol’s commitments (UNFCCC, 2007). The first commitment period of the Kyoto Protocol ended in 2012. Governments, including 38 industrialized countries, agreed to a second commitment period of the Kyoto Protocol beginning January 1, 2013 and ending either on December 31, 2017 or December 31, 2020, to be decided by the Ad Hoc Working Group on Further Commitments for Annex I Parties under the Kyoto Protocol at its seventeenth session (UNFCCC, 2011). In Durban (17th session of the Conference of the Parties in Durban, South Africa, 2011), governments decided to adopt a universal legal agreement on climate change. Work began on that task immediately under a new group called the Ad Hoc Working Group on the Durban Platform for Enhanced Action. Progress was also made regarding the creation of a Green Climate Fund (GCF) for which a management framework was adopted (UNFCCC, 2011; United Nations, 2011). In December 2015, the 21st session of the Conference of the Parties (COP21) adopted the Paris Agreement. The deal requires all countries that ratify it to commit to cutting greenhouse gas emissions, with the goal of peaking greenhouse gas emissions “as soon as possible” (Worland, 2015). The agreement includes commitments to (1) achieve a balance between sources and sinks San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-7 of greenhouse gases in the second half of this century; (2) to keep global temperature increase “well below” 2 degrees Celsius (C) or 3.6 degrees Fahrenheit (F) and to pursue efforts to limit it to 1.5 C; (3) to review progress every five years; and (4) to spend $100 billion a year in climate finance for developing countries by 2020 (UNFCCC, 2015). The agreement includes both legally binding measures, like reporting requirements, as well as voluntary or non-binding measures while, such as the setting of emissions targets for any individual country (Worland, 2015). Federal Regulations. The United States Supreme Court in Massachusetts et al. v. Environmental Protection Agency et al. ([2007] 549 U.S. 05-1120) held that the U.S. EPA has the authority to regulate motor-vehicle GHG emissions under the federal Clean Air Act. The U.S. EPA issued a Final Rule for mandatory reporting of GHG emissions in October 2009. This Final Rule applies to fossil fuel suppliers, industrial gas suppliers, direct GHG emitters, and manufacturers of heavy-duty and off-road vehicles and vehicle engines, and requires annual reporting of emissions. The first annual reports for these sources were due in March 2011. On May 13, 2010, the U.S. EPA issued a Final Rule that took effect on January 2, 2011, setting a threshold of 75,000 tons CO2e per year for GHG emissions. New and existing industrial facilities that meet or exceed that threshold will require a permit after that date. On November 10, 2010, the U.S. EPA published the “PSD and Title V Permitting Guidance for Greenhouse Gases.” The U.S. EPA’s guidance document is directed at state agencies responsible for air pollution permits under the Federal Clean Air Act to help them understand how to implement GHG reduction requirements while mitigating costs for industry. It is expected that most states will use the U.S. EPA’s new guidelines when processing new air pollution permits for power plants, oil refineries, cement manufacturing, and other large pollution point sources. On January 2, 2011, the U.S. EPA implemented the first phase of the Tailoring Rule for GHG emissions Title V Permitting. Under the first phase of the Tailoring Rule, all new sources of emissions are subject to GHG Title V permitting if they are otherwise subject to Title V for another air pollutant and they emit at least 75,000 tons CO2e per year. Under Phase 1, no sources were required to obtain a Title V permit solely due to GHG emissions. Phase 2 of the Tailoring Rule went into effect July 1, 2011. At that time new sources were subject to GHG Title V permitting if the source emits 100,000 tons CO2e per year, or they are otherwise subject to Title V permitting for another pollutant and emit at least 75,000 tons CO2e per year. On July 3, 2012 the U.S. EPA issued the final rule that retains the GHG permitting thresholds that were established in Phases 1 and 2 of the GHG Tailoring Rule. These emission thresholds determine when Clean Air Act permits under the New Source Review Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs are required for new and existing industrial facilities. California Regulations. California Air Resources Board (ARB) is responsible for the coordination and oversight of State and local air pollution control programs in California. California has a numerous regulations aimed at reducing the state’s GHG emissions. These initiatives are summarized below. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-8 Assembly Bill (AB) 1493 (2002), California’s Advanced Clean Cars program (referred to as “Pavley”), requires ARB to develop and adopt regulations to achieve “the maximum feasible and cost-effective reduction of GHG emissions from motor vehicles.” On June 30, 2009, U.S. EPA granted the waiver of Clean Air Act preemption to California for its greenhouse gas emission standards for motor vehicles beginning with the 2009 model year. Pavley I took effect for model years starting in 2009 to 2016 and Pavley II, which is now referred to as “LEV (Low Emission Vehicle) III GHG” will cover 2017 to 2025. Fleet average emission standards would reach 22 percent reduction from 2009 levels by 2012 and 30 percent by 2016. The Advanced Clean Cars program coordinates the goals of the Low Emissions Vehicles (LEV), Zero Emissions Vehicles (ZEV), and Clean Fuels Outlet programs and would provide major reductions in GHG emissions. By 2025, when the rules will be fully implemented, new automobiles will emit 34 percent fewer GHGs and 75 percent fewer smog-forming emissions from their model year 2016 levels (ARB, 2011). In 2005, the governor issued Executive Order (EO) S-3-05, establishing statewide GHG emissions reduction targets. EO S-3-05 provides that by 2010, emissions shall be reduced to 2000 levels; by 2020, emissions shall be reduced to 1990 levels; and by 2050, emissions shall be reduced to 80 percent below 1990 levels (CalEPA, 2006). In response to EO S-3-05, CalEPA created the Climate Action Team (CAT), which in March 2006 published the Climate Action Team Report (the “2006 CAT Report”) (CalEPA, 2006). The 2006 CAT Report identified a recommended list of strategies that the state could pursue to reduce GHG emissions. These are strategies that could be implemented by various state agencies to ensure that the emission reduction targets in EO S-3- 05 are met and can be met with existing authority of the state agencies. The strategies include the reduction of passenger and light duty truck emissions, the reduction of idling times for diesel trucks, an overhaul of shipping technology/infrastructure, increased use of alternative fuels, increased recycling, and landfill methane capture, etc. In April 2015 the governor issued EO B-30-15, calling for a new target of 40 percent below 1990 levels by 2030. California’s major initiative for reducing GHG emissions is outlined in Assembly Bill 32 (AB 32), the “California Global Warming Solutions Act of 2006,” signed into law in 2006. AB 32 codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020 (essentially a 15 percent reduction below 2005 emission levels; the same requirement as under S-3-05), and requires ARB to prepare a Scoping Plan that outlines the main State strategies for reducing GHGs to meet the 2020 deadline. In addition, AB 32 requires ARB to adopt regulations to require reporting and verification of statewide GHG emissions. California is on track to meet or exceed the current target of reducing GHG emissions to 1990 levels by 2020, as established in AB 32. California's new emissions reduction target of 40 percent below 1990 levels by 2030 will make it possible to reach the ultimate goal of reducing emissions 80 percent under 1990 levels by 2050. This is in line with the scientifically established levels needed in the U.S. to limit global warming below 2 degrees Celsius - the warming threshold at which scientists say there will likely be major climate disruptions such as super droughts and rising sea levels. After completing a comprehensive review and update process, ARB approved a 1990 statewide GHG level and 2020 limit of 427 MMT CO2e. The Scoping Plan was approved by ARB on December 11, 2008, and included measures to address GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among other measures. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-9 Many of the GHG reduction measures included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-and-Trade) have been adopted over the last five years. Implementation activities are ongoing and ARB is currently the process of updating the Scoping Plan. In May 2014, ARB approved the first update to the AB 32 Scoping Plan. The 2013 Scoping Plan update defines ARB’s climate change priorities for the next five years and sets the groundwork to reach post-2020 goals set forth in EO S-3-05. The update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan. It also evaluates how to align the State’s longer-term GHG reduction strategies with other State policy priorities, such as for water, waste, natural resources, clean energy and transportation, and land use (ARB, 2014). Senate Bill (SB) 97, signed in August 2007, acknowledges that climate change is an environmental issue that requires analysis in California Environmental Quality Act (CEQA) documents. In March 2010, the California Resources Agency (Resources Agency) adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted guidelines give lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs and climate change impacts. ARB Resolution 07-54 establishes 25,000 MT of GHG emissions as the threshold for identifying the largest stationary emission sources in California for purposes of requiring the annual reporting of emissions. This threshold is just over 0.005 percent of California’s total inventory of GHG emissions for 2004. Senate Bill (SB) 375, signed in August 2008, enhances the state’s ability to reach AB 32 goals by directing ARB to develop regional GHG emission reduction targets to be achieved from passenger vehicles for 2020 and 2035. In addition, SB 375 directs each of the state’s 18 major Metropolitan Planning Organizations (MPO) to prepare a “sustainable communities strategy” (SCS) that contains a growth strategy to meet these emission targets for inclusion in the Regional Transportation Plan (RTP). On September 23, 2010, ARB adopted final regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035. The San Luis Obispo Council of Governments (SLOCOG) was assigned targets of an 8 percent reduction in GHGs from transportation sources by 2020 and an 8 percent reduction in GHGs from transportation sources by 2035. When implemented, the plans in SLOCOG’s 2014-2035 RTP/SCS are expected to meet and exceed those targets, achieving a 9.4 percent per capita reduction by 2020, and a 10.9 percent per capita reduction by 2035. Executive Order S-13-08 indicates that “climate change in California during the next century is expected to shift precipitation patterns, accelerate sea level rise and increase temperatures, thereby posing a serious threat to California’s economy, to the health and welfare of its population and to its natural resources.” Pursuant to the requirements in the order, the 2009 California Climate Adaptation Strategy (California Natural Resources Agency 2009) was adopted, which is the “...first statewide, multi-sector, region-specific, and information-based climate change adaptation strategy in the United States.” Objectives include analyzing risks of San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-10 climate change in California, identifying and exploring strategies to adapt to climate change, and specifying a direction for future research. In April 2011, the governor signed SB 2X requiring California to generate 33 percent of its electricity from renewable energy by 2020. On September 8, 2016, the governor signed Senate Bill 32 (SB 32) into law, which requires the State to further reduce GHGs to 40 percent below 1990 levels by 2030. SB 32 is an extension of AB 32. The other provisions of AB 32 remain unchanged. ARB is currently working to update the Scoping Plan to provide a framework for achieving the 2030 target. The updated Scoping Plan is expected to be completed and adopted by ARB in 2016 (ARB 2015). For more information on the Senate and Assembly Bills, Executive Orders, and reports discussed above, and to view reports and research referenced above, please refer to the following websites: www.climatechange.ca.gov and www.arb.ca.gov/cc/cc.htm. California Environmental Quality Act. Pursuant to the requirements of SB 97, the Resources Agency has adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted CEQA Guidelines provide general regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents, while giving lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs and climate change impacts. To date, a variety of air districts have adopted quantitative significance thresholds for GHGs. Local Regulations. City of San Luis Obispo Climate Action Plan. In 2012, the City of San Luis Obispo adopted its Climate Action Plan for reducing greenhouse gas emissions. The plan identifies strategies to guide the development and implementation of GHG reduction measures in the City of San Luis Obispo and quantifies the emissions reductions that result from these strategies. In addition to addressing strategies to reduce GHG emissions, the Climate Action Plan includes adaptation measures to improve the City’s ability to address the potential impacts that climate change may have on the City and its residents. The Climate Action Plan enables the City to maintain local control of implementing state direction (AB 32 – the California Global Warming Solutions Act) to reduce GHG emissions to 1990 levels by 2020. GHG reduction strategies align with existing General Plan policies, and adoption of a Climate Action Plan is an Other Important Objective in the City’s 2011-13 Financial Plan. Having an adopted Climate Action Plan also allows the City to streamline the CEQA review process of certain development projects. City of San Luis Obispo General Plan. The City also addresses GHG emissions through adopted General Plan policies and programs. The policies are found in the Land Use Element, the Circulation Element, and the Conservation and Open Space Element. The following Land Use Element policies define the local regulatory setting related to GHG emissions and climate change: San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-11 Policy 1.1.1. Growth Management Objectives. The City shall manage its growth so that: A. The natural environment and air quality will be protected. Policy 1.5. Jobs/Housing Relationship. The gap between housing demand (due to more jobs and college enrollment) and supply should not increase. Policy 1.7.1 Open Space Protection. Within the City's planning area and outside the urban reserve line, undeveloped land should be kept open. Prime agricultural land, productive agricultural land, and potentially productive agricultural land should be protected for farming. Scenic lands, sensitive wildlife habitat, and undeveloped prime agricultural land should be permanently protected as open space. Policy 2.2.4. Neighborhood Connections. The City shall provide all areas with a pattern of streets, pedestrian network, and bicycle facilities that promote neighborhood and community cohesiveness. There should be continuous sidewalks or paths of adequate width, connecting neighborhoods with each other and with public and commercial services and public open space to provide continuous pedestrian paths throughout the city. Connectivity to nearby community facilities (such as parks and schools), open space, and supporting commercial areas shall also be enhanced, but shall not be done in a method that would increase cut-through traffic. (See also the Circulation Element.) Policy 2.2.6. Neighborhood Characteristics. The City shall promote livability, quiet enjoyment, and safety for all residents. Characteristics of quality neighborhoods vary from neighborhood to neighborhood, but often include one or more of the following characteristics: • A mix of housing type styles, density, and affordability. • Design and circulation features that create and maintain a pedestrian scale. • Nearby services and facilities including schools, parks, retail (e.g., grocery store, drug store), restaurants and cafes, and community centers or other public facilities. • A tree canopy and well-maintained landscaping. • A sense of personal safety (e.g., low crime rate, short police and emergency response times). • Convenient access to public transportation. • Well-maintained housing and public facilities. Policy 2.3.9. Compatible Development. The City shall require that new housing built within an existing neighborhood be sited and designed to be compatible with the character of the neighborhood. Compatibility for all development shall be evaluated using the following criteria: F. Privacy and Solar Access New buildings will respect the privacy and solar access of neighboring buildings and outdoor areas, particularly where multistory buildings or additions may overlook backyards of adjacent dwellings. (See also the City’s Conservation and Open Space Element.) Policy 2.9. Reduced Automobile Dependence in Downtown. The City shall encourage the development of Downtown housing that minimizes the need for automobile use and minimizes the storage of vehicles in surrounding neighborhoods. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-12 The following Circulation Element policies define the local regulatory setting related to GHG emissions and climate change: Policy 4.1.1. Bicycle Use. The City shall expand the bicycle network and provide end- of-trip facilities to encourage bicycle use and to make bicycling safe, convenient and enjoyable. Policy 4.1.3. Continuous Network. The City shall collaborate with SLO County to coordinate planning and development of county bikeways to support a regional bike network and identify and acquire additional rights of way in the City as they become available. Policy 4.1.4. New Development. The City shall require that new development provide bikeways, secure bicycle storage, parking facilities and showers consistent with City plans and development standards. When evaluating transportation impacts, the City shall use a Multimodal Level of Service analysis. Policy 6.1.1. Complete Streets. The City shall design and operate city streets to enable safe, comfortable, and convenient access and travel for users of all abilities including pedestrians, bicyclists, transit users, and motorists. The following Conservation and Open Space Element policies define the local regulatory setting related to GHG emissions and climate change: Policy 4.3.1. Use of best available practices. The City will employ the best available practices in energy conservation, procurement, use and production, and will encourage individuals, organizations and other agencies to do likewise. “Best available practices” means behavior and technologies that reflect recommendations of specialists and that use the least energy for a desired outcome, considering available equipment, life-cycle costs, social and environmental side effects, and the regulations of other agencies. Best available practices include use of sustainable sources. Sustainable sources are naturally renewed in a relatively short time and avoid substantial undesirable side effects. Policy 4.3.4. Use of energy efficient, renewable energy sources. The City will promote the use of cost effective, renewable, non-depleting energy sources wherever possible, both in new construction projects and in existing buildings and facilities. Policy 4.3.6. Energy efficiency and Green Building in new development. The City shall encourage energy-efficient “green buildings” as certified by the U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) Program or equivalent certification, as further described in Chapter 5.5.7. Policy 4.4.3. Compact, high-density housing. The City will promote higher-density, compact housing to achieve more efficient use of public facilities and services, land resources, and to improve the jobs/housing balance. Goal 4.4.4. Solar access. Encourage the provision for and protection of solar access. 4.6.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) analyzed GHG impacts for the City of San Luis Obispo related to the adoption of the updated General Plan San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-13 Land Use and Circulation Elements. The LUCE Update EIR determined that project-level and cumulative impacts would be less than significant because the Land Use and Circulation Element updates included policies that would be consistent with the City’s Climate Action Plan and would minimize cumulative GHG emissions resulting from buildout of the City. 4.6.3 Impact Analysis a. Methodology and Significance Thresholds. Based on Appendix G of the State CEQA Guidelines, impacts related to GHG emissions from the project would be significant if the project would: 1. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and/or 2. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. The vast majority of individual projects do not generate sufficient GHG emissions to directly influence climate change. However, physical changes caused by a project can contribute incrementally to cumulative effects that are significant, even if individual changes resulting from a project are limited. The issue of climate change typically involves an analysis of whether a project’s contribution towards an impact would be cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (State CEQA Guidelines, Section 15355). City of San Luis Obispo Climate Action Plan. For future projects, the significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds, or consistency with a regional GHG reduction plan, such as the City’s Climate Action Plan. The Climate Action Plan, adopted in 2012, serves as the City’s qualified GHG reduction plan, because it contains the following required plan elements: • Community-wide GHG emissions inventory and “business-as-usual” forecast of 2020 community-wide GHG emissions; • GHG reduction targets consistent with AB 32 (i.e. a level, based on substantial evidence, below which the contribution to greenhouse gas emissions from activities covered by the plan would not be cumulatively considerable); • Analysis of local and state policies and actions that may impact GHG emissions within the jurisdiction; • Quantification of GHG reduction measures demonstrating that, if implemented, the GHG reduction targets will be met; • Implementation and monitoring strategy and timeline; and • Adequate environmental review of the Climate Action Plan. Incorporation of these plan elements allows the Climate Action Plan to be used in the cumulative impacts analysis of later projects. As described in the Climate Action Plan, to analyze a project’s consistency with the Climate Action Plan, “the environmental document for each project must identify those requirements specified in the Climate Action Plan that apply to San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-14 the project, and if those requirements are not otherwise binding or enforceable, should be incorporated as mitigation measures applicable to the project” (State CEQA Guidelines, Section 15183.5b). The City is in the process of developing a mitigation matrix for projects that exceed specified GHG thresholds. The matrix will include quantifiable Climate Action Plan reduction measures consistent with SB 97 direction. For this analysis, the project’s consistency with the Climate Action Plan is analyzed qualitatively against the applicable implementation strategies contained in the Climate Action Plan. SLOAPCD CEQA Thresholds. The City of San Luis Obispo has not adopted GHG emissions thresholds for use in CEQA documents. In March 2012, the SLOAPCD adopted CEQA thresholds for GHG emissions. Based on the adopted SLOAPCD guidance, the following three quantitative thresholds may be used to evaluate the level of significance of GHG emissions impacts for residential and commercial projects: 1. Qualified GHG Reductions Strategies. A project would have a significant impact if it is not consistent with a qualified GHG reduction strategy that meets the requirements of the State CEQA Guidelines. If a project is consistent with a qualified GHG reduction strategy, it would not have a significant impact; OR, 2. Bright-Line Threshold. A project would have a significant impact if it exceeds the “bright-line threshold” of 1,150 metric tons CO2E/year; OR, 3. Efficiency Threshold. A project would have a significant impact if the efficiency threshold exceeds 4.9 metric tons of CO2E/service population/year. The service population is defined as the number of residents plus employees for a given project. The efficiency threshold is specifically intended to avoid penalizing large-scale plans or projects that incorporate emissions-reducing features and/or that are located in a manner that results in relatively low vehicle miles traveled. The City of San Luis Obispo Climate Action Plan, adopted in 2012, serves as the City’s qualified GHG reduction plan. Therefore, the project’s contribution to cumulative GHG impacts would be cumulatively considerable if it is inconsistent with the Climate Action Plan. For informational purposes, the project’s GHG emissions per service population are also quantified. Methodology. Calculations of CO2, CH4, and N2O emissions are provided to identify the magnitude of potential project effects. The analysis focuses on CO2, CH4, and N2O because these make up 98.9 percent of all GHG emissions by volume (IPCC, 2007) and are the GHG emissions that the project would emit in the largest quantities. Fluorinated gases, such as HFCs, PFCs, CFCs, and SF6, which are primarily associated with industrial processes, were also considered for the analysis. However, because the project is a residential/commercial development, the quantity of fluorinated gases would not be significant. Emissions of all GHGs are converted into their equivalent GWP in terms of CO2 (CO2e). Calculations are based on the methodologies discussed in the California Air Pollution Control Officers Association (CAPCOA) CEQA and Climate Change white paper (January 2008) and included the use of the California Climate Action Registry (CCAR) General Reporting Protocol (January 2009). GHG emissions associated with the project were calculated using the California Emissions Estimator Model (CalEEMod) version 2016.3.1 (see Appendix D for calculations). San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-15 Operational Emissions. CalEEMod provides operational emissions of CO2, N2O, and CH4. Emissions from energy use include electricity and natural gas use. The emissions factors for natural gas combustion are based on EPA’s AP-42 (Compilation of Air Pollutant Emissions Factors) and CCAR. Electricity emissions are calculated by multiplying the energy use times the carbon intensity of the utility district per kilowatt hour (CalEEMod User Guide, 2016). The default electricity consumption values in CalEEMod include the CEC-sponsored California Commercial End Use Survey (CEUS) and Residential Appliance Saturation Survey (RASS) studies. Emissions associated with area sources, including consumer products, landscape maintenance, and architectural coating were calculated in CalEEMod and utilize standard emission rates from ARB, U.S. EPA, and emission factor values provided by the local air district (CalEEMod User Guide, 2016). Emissions from waste generation were also calculated in CalEEMod and are based on the IPCC’s methods for quantifying GHG emissions from solid waste using the degradable organic content of waste (CalEEMod User Guide, 2016). Waste disposal rates by land use and overall composition of municipal solid waste in California was primarily based on data provided by the California Department of Resources Recycling and Recovery (CalRecycle). Emissions from water and wastewater usage calculated in CalEEMod were based on the default electricity intensity from the CEC’s 2006 Refining Estimates of Water-Related Energy Use in California using the average values for Northern and Southern California. For mobile sources, CO2 and CH4 emissions were quantified in CalEEMod. Because CalEEMod does not calculate N2O emissions from mobile sources, N2O emissions were quantified using the California Climate Action Registry General Reporting Protocol (January 2009) direct emissions factors for mobile combustion (see Appendix D for calculations). Estimates of vehicle trips associated with the proposed development are based on peak hour trip generation rates from the project Traffic Impact Study (refer to Section 4.12, Transportation/Traffic and Appendix L). The trip generation rates in the TIS are based on the Institute of Transportation Engineers 9th Edition Trip Generation Manual, and also account for reductions expected from the mixed use and pedestrian-oriented characteristics of the project (see Appendix L), including internal capture and pass-by trips. The estimate of total daily trips associated with the proposed project was based on the standard Institute of Transportation Engineers (ITE) vehicle trip rates and was calculated and extrapolated to derive total annual mileage in CalEEMod. Emission rates for N2O emissions were based on the vehicle mix output generated by CalEEMod and the emission factors found in the California Climate Action Registry General Reporting Protocol. Construction Emissions. Although construction activity is addressed in this analysis, CAPCOA does not discuss whether any of the suggested threshold approaches adequately address impacts from temporary construction activity. As stated in the CEQA and Climate Change white paper, “more study is needed to make this assessment or to develop separate thresholds for construction activity” (CAPCOA, 2008). Nevertheless, air districts such as the SLOAPCD (2012) have recommended amortizing construction-related emissions over the life of the project; SLOAPCD suggests the life of a project is typically 50 years for residential projects and 25 years for commercial projects. The project includes both commercial and residential uses; therefore, to San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-16 provide a conservative estimate of construction emissions, emissions were amortized over the shorter lifetime duration of 25 years. Construction of the project would generate temporary GHG emissions primarily as a result of operation of construction equipment on-site, as well as from vehicles transporting construction workers to and from the project site and heavy trucks to export earth materials offsite. Site preparation and grading typically generate the greatest amount of emissions due to the use of grading equipment and soil hauling. Re-grading of the project site would require approximately 248,000 cubic yards (cy) of import. Off-site hauling of import materials was included in the emissions modeling. This analysis assumes that soil would be imported to the site during each phase and, as exact import volumes per phase are unknown, total import was divided between phases proportionally by phase acreage. CalEEMod provides an estimate of emissions associated with the construction period, based on parameters such as the duration of construction activity, area of disturbance, and anticipated equipment use during construction. Service Population. The service population is defined as the number of residents plus employees for a given project. Development of the project would add an estimated 1,293 residents to the City (546 new single family and multi-family dwelling units x 2.29 people/unit and 34 new affordable units x 1.25 people/unit).1 In addition, based on employment generation rates for retail, hotel, and office uses from the SLOAPCD’s CEQA Air Quality Handbook (SLOAPCD 2012), the project would result in a net increase of approximately 842 new employees.2 Therefore, the total service population would be 2,135 persons. b. Project Impacts and Mitigation Measures. Threshold 1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Threshold 2: Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Impact GHG-1 The San Luis Ranch Specific Plan is consistent with the City’s Climate Action Plan. This impact would be Class III, less than significant. As described in Section 4.6.3(a), the project’s GHG emissions per service population are quantified to provide an estimate of the scale of future GHG emissions. In addition to this quantitative analysis, the project’s consistency with the Climate Action Plan is evaluated below. 1 Persons per household from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). 2 Based on the following rates: 0.64 employees per 1,000 square feet for proposed 200 room hotel (290,400 square feet from CalEEMod results, see Appendix D); 2.52 employees per 1,000 square feet for proposed 150,000 square feet of office space; and 1.39 employees per 1,000 square feet for proposed 200,000 square feet regional retail (SLOAPCD 2012). San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-17 GHG Emissions Estimate. Construction Emissions. Construction of the project would generate temporary GHG emissions, primarily resulting from the operation of construction equipment and on- and off- site truck trips, including soil hauling trips. Site preparation and grading typically generate the greatest amount of GHG emissions due to the use of grading equipment and other large diesel- powered construction equipment. Total and annualized construction emissions are shown in Table 4.6-1. Table 4.6-1 Estimated Construction Emissions of GHGs Source Annual Emissions Total Estimated Construction Emissions 6,073 metric tons CO2e Amortized over 25 years 243 metric tons CO2e per year See Appendix D for CalEEMod results. As shown in Table 4.6-1, construction activity associated with the project would generate an estimated 6,073 MT of CO2e. SLOAPCD has recommended amortizing construction-related emissions over the life of a project. Over this lifetime for the project (conservatively assumed to be 25 years), the construction emissions would amount to 243 MT of CO2e per year. Combined Annual Construction, Operational, and Mobile GHG Emissions. The project’s operational emissions from energy use (electricity and natural gas use) were estimated using CalEEMod. Table 4.6-2 combines the construction and operational GHG emissions associated with development for the project. As shown in Table 4.6-2, the combined annual emissions from the project would total approximately 10,801 10,839 MT per year of CO2e or 5.1 MT CO2e/SP/year. Table 4.6-2 Combined Annual Emissions of GHGs Emission Source Annual Emissions Construction 243 metric tons CO2e Operational Area Energy Solid Waste Water 13 metric tons CO2e 4,426 metric tons CO2e 423 metric tons CO2e 262 metric tons CO2e Mobile CO2 and CH4 N2O only 5,143 metric tons CO2e 292 329 metric tons CO2e Total 10,801 10,839 metric tons CO2e Project Total MT CO2e/SP/year 5.1 MT CO2e/SP/year1 Sources: See Appendix D for calculations and for GHG emission factor assumptions. 1 10,801 10,839 MT CO2e/2,135 Service Population = 5.1 MT CO2e/SP/year San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-18 Climate Action Plan Consistency. As discussed in Section 4.6.3(a), in 2012 the City of San Luis Obispo adopted the Climate Action Plan, which serves as a Qualified GHG Reduction Strategy consistent with State CEQA Guidelines. The GHG-reducing policy provisions contained in the Climate Action Plan were prepared with the purpose of complying with the requirements of AB 32 and achieving the goals of the AB 32 Scoping Plan. As a result, the Climate Action Plan is consistent with statewide efforts established in ARB’s Climate Change Scoping Plan to reduce statewide GHG emissions to 1990 levels by 2020. The Climate Action Plan outlines a course of action to improve environmental, social, and economic sustainability and includes six emission reductions strategies: 1) buildings, 2) renewable energy, 3) transportation and land use, 4) water, 5) solid waste, and 6) parks and open space. The project would be consistent with the City’s Climate Action Plan if it includes provisions to further the emissions reduction goals in the Plan. Table 4.6-3 shows the project’s consistency with applicable Climate Action Plan measures. The CAP’s renewable energy measure requires the City to “incentivize renewable energy generation in new and existing development.” As the measure is a requirement for the City and not for private development, it is not directly applicable to the project and not included in the consistency analysis. As shown, the project would be consistent with the Climate Action Plan. Table 4.6-3 Project Consistency with Applicable Climate Action Plan Measures Climate Action Plan Control Measure Project Consistency Buildings BLD 2: New Construction Energy Conservation Encourage and incentivize new development to exceed minimum Cal Green requirements. Consistent As indicated in the Specific Plan, one of the goals of the Specific Plan is to meet leading technology standards in building design and construction. New structures, renovated buildings, and new infrastructure facilities would be designed to minimize energy consumption and maximize renewable energy generation. Energy conservation construction techniques include: • Meeting or Exceeding Title 24 Standards • Natural Lighting and Ventilation • High R-Value Insulation • Energy Efficient HVAC Systems and Appliances • Noise Reduction • Water Usage Reduction Transportation and Land Use TLU 1: Transit Services Maintain and expand transit services consistent with the City’s Short Range Transit Plan. Consistent The project would maintain and expand transit services consistent with the City’s Short Range Transit Plan because the Specific Plan includes a transit center that would provide direct transit access between the project site and downtown San Luis Obispo. The location of the proposed transit center would be coordinated with SLO Transit and the Regional Transit Authority upon submittal of individual project plans. If transit ridership meets specified demand thresholds, direct Regional Transit Authority access will be considered at this future transit center. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-19 Table 4.6-3 Project Consistency with Applicable Climate Action Plan Measures Climate Action Plan Control Measure Project Consistency TLU 2: Alternative Vehicles Promote clean air vehicles (CAV), and expand the network of electric car charging stations and car- sharing parking spaces. Consistent A percentage of the project’s parking would be outfitted with electric vehicle charging stations. These parking spaces would be reserved for electric vehicles, along with the area’s multimodal transportation network, to encourage energy conscience transportation. TLU 3: Bike Travel Increase the percentage of non-recreational trips that are made by bicycle. Consistent The project would increase the percentage of non- recreational trips that are made by bike by establishing links within the City’s Bicycle Transportation Plan. Specifically, the project would include construction of a segment of the Bob Jones Bike Trail and provide a connection from Laguna Lake area neighborhoods and businesses along Madonna Road to the southern portion of the City Limit at Froom Ranch Way. The project would also include interior bicycle trails and lanes, including a Class I bike trail and Class II bike lanes. TLU 5: Land Use Diversity and Density Encourage compact urban form and mixed-use developments. Consistent The project is a mixed-use project that includes residential, commercial, office, hotel, agriculture, and open space uses. Therefore, the project development would encourage compact urban form and mixed-use development. TLU 6: Parking Management Motivate Downtown visitors to park once and walk or ride to multiple destinations, or use transit to get to and from downtown. Consistent The project would include a transit center that would provide direct transit access between the project site and downtown San Luis Obispo, motivating downtown visitors to park once and walk or ride to multiple destinations or use transit to get to and from downtown. The location of the proposed transit center would be coordinated with SLO Transit and the Regional Transit Authority upon submittal of individual project plans. If transit ridership meets specified demand thresholds, direct Regional Transit Authority access will be considered at this future transit center. TLU 8: Reduce the Need for Commuting Increase local housing options for workers in the community that include variety in location, type, size, tenure and style of dwellings. Consistent The project includes workforce housing, including 34 affordable units. There would be a range of housing options such as attached compact housing, detached compact housing, 40’ single-family, 30’ single family and multifamily units. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-20 Table 4.6-3 Project Consistency with Applicable Climate Action Plan Measures Climate Action Plan Control Measure Project Consistency Water WTR 2: Water Conservation: New Development Implement CALGreen standards, Water Reuse Master Plan, and Water Efficient Landscape Standards to reduce potable water use in new development. Consistent As described in Chapter 7 of the Specific Plan, the project would incorporate water reduction methods and infrastructure to minimize water use at the site, such as drought tolerant landscaping, use of recycled water for exterior landscaped areas, low-flow water features, onsite rainwater harvesting, and indoor gray water re-use. The project would include a combination of bio-swales, detention and retention facilities, and cisterns that will manage on-site drainage and recharge the aquifer onsite. Open Space areas along the creek, parks, and portions of the commercial and office areas would be irrigated using recycled water sourced from an extension of the City’s Recycled Water System. Proposed water infrastructure improvements include a 6-inch Recycled Water Main from Madonna Road through the project site. The existing onsite wells would continue to be used for irrigation of ongoing agricultural uses on the project site. Onsite landscaping would be drought tolerant and require minimum water use. Parks and Open Space PKS 2: Parks & Open Space Development Continue to develop and acquire parks and open space resources. Consistent The project would provide public parks and open space. A key goal of the project is to connect the City’s park and open space system and improve Prefumo Creek. Senate Bill 32. In late 2015, the California Supreme Court’s Newhall Ranch decision confirmed that there are multiple potential pathways for evaluating GHG emissions consistent with CEQA, depending on the circumstances of a given project (Center for Biological Diversity v. Department of Fish and Wildlife (2015) 62 Cal. 4th 204). The decision also identified the need to analyze both near term and post-2020 emissions, as applicable, stating that an “EIR taking a goal-consistency approach to CEQA significance may in the near future need to consider the project’s effects on meeting longer term emissions reduction targets.” While not legally binding on local land use agencies, SB 32 extends the statewide AB 32 reduction goal, requiring the State to further reduce GHGs to 40 percent below 1990 levels by 2030, and Executive Order S-03-05 has set forth a long-term reduction target to reduce GHG emissions in California by 80 percent below 1990 level by the year 2050. While the State has adopted the AB 32 Scoping Plan and multiple regulations to achieve the AB 32 year 2020 target, there is no currently adopted State plan to meet post-2020 GHG reduction goals. ARB is currently working to update the Scoping Plan to provide a framework for achieving the 2030 target set forth by SB 32 (ARB 2015). As a result, State reduction strategies cannot be applied to the project to achieve long-term reductions. Achieving these long-term GHG reduction policies will require State and federal plans and policies for achieving post-2020 reduction goals. Placing the entire burden of meeting long-term reduction targets on local government or individual new development projects would be disproportionate and likely ineffective. San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-21 Given the recent legislative attention and judicial action regarding post-2020 goals and the scientific evidence that additional GHG reductions are needed through the year 2050, the Association of Environmental Professionals’ (AEP) Climate Change Committee published a white paper in 2015 recommending that CEQA analyses for most land use development projects may continue to rely on current adopted thresholds for the immediate future (AEP, Beyond 2020: The Challenges of Greenhouse Gas Reduction Planning by Local Governments in California, 2015). As such, for the GHG impacts resulting from development under the San Luis Ranch Specific Plan, this analysis evaluates future conditions in the year 2020 based on the City’s adopted Climate Action Plan. Mitigative Components of the Specific Plan and Impact Conclusion. As described in Table 4.6- 3, the project is a compact community including mixed uses and workforce housing to balance jobs and housing. The project also emphasizes bikeways, pedestrian, and transit connections, all of which contribute to reduced VMT and correspondingly reduced GHG emissions. Therefore, the project would be consistent with the City of San Luis Obispo Climate Action Plan. Mitigation Measures. No mitigation is required. However, implementation of SLOAPCD requirements in Mitigation Measure AQ-3(a) would also reduce the project’s GHG emissions. Significance After Mitigation. Impacts would be less than significant without mitigation. Although mitigation is not required, implementation of SLOAPCD requirements in Mitigation Measure AQ-3(a) would further reduce the project’s GHG emissions. For informational purposes, Table 4.6-4 shows emissions with implementation of Mitigation Measure AQ-3(a), which includes exceedance of Title 24 energy efficiency requirements by 20 percent. As shown in Table 4.6-4, exceeding Title 24 energy efficiency requirements by 20 percent would reduce per service population emissions from 5.1 MT CO2e per year (see Table 4.6-2) to 4.89 MT CO2e per year, which would not exceed SLOAPCD’s efficiency threshold of 4.9 MT CO2e per year. Table 4.6-4 Combined Mitigated Annual Emissions of GHGs Emission Source Annual Emissions Construction 243 metric tons CO2e Operational Area Energy Solid Waste Water 13 metric tons CO2e 4,080 metric tons CO2e 423 metric tons CO2e 262 metric tons CO2e Mobile CO2 and CH4 N2O only 5,143 metric tons CO2e 292 metric tons CO2e Total1 10,455 metric tons CO2e Project Total MT CO2e/SP/year 4.89 MT CO2e/SP/year1 Sources: Totals are from CalEEMod Mitigated results, plus See Appendix D for calculations and for GHG emission factor assumptions. 1 10,455 MT CO2e/2,135 Service Population = 4.89 MT CO2e/SP/year San Luis Ranch Project EIR Section 4.6 Greenhouse Gas Emissions City of San Luis Obispo 4.6-22 c. Cumulative Impacts. Table 3 in Section 3.0, Environmental Setting, lists future development capacity within the Planning Subarea under the General Plan Land Use Element. Such development would increase overall GHG emissions generated within the City. Analyses of GHG emissions and climate change are cumulative in nature, as they affect the accumulation of GHGs in the atmosphere. Projects that exceed the thresholds discussed above would have a significant impact on GHG emissions and climate change, both individually and cumulatively. As indicated in Impact GHG-1, GHG emissions associated with the project would be less than significant, and further reduced with implementation of Mitigation Measure AQ-3. As a result, the project’s contribution to cumulative levels of GHGs would not be cumulatively considerable and cumulative impacts to climate change would be less than significant. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-1 HAZARDS AND HAZARDOUS MATERIALS 4.7 4.7.1 Setting a. Overview. The San Luis Ranch Specific Plan Area is located within a transition area with commercial development to the north and the residential development to the west. Adjacent land uses include single-family residences to the west; Laguna Lake Park to the northwest, commercial uses to the north, including a post office and the San Luis Promenade shopping center; U.S. Highway 101 (U.S. 101) and public facilities such as the City’s Water Resource Recovery Facility to the east; and the SLO City Farm to the south. Agricultural operations such as grain crop farming and small dairy operations on the San Luis Ranch project site date back to approximately 1900. In approximately 1921, the site was converted to row crop farming of onion, artichoke, garbanzo beans, and flowers for seed. The site has remained in use for row crop production. Approximately 109 acres of the 131-acre project site are currently used for the production of irrigated row crops including celery, broccoli, lettuce, specialty vegetables, and peas. A vegetable packing facility, storage areas, Prefumo Creek watershed drainages, and eucalyptus trees occupy the remaining 22 acres. The packing facility is used to process locally grown crops and the storage areas primarily store agricultural equipment. Crops on the site are grown with conventional practices and materials, and packed in the field. On any given year various combinations of row crops may be grown on the site. b. Known Hazardous Materials Sites. The following databases were searched in May 2016 for records relating to any known hazardous materials contamination within the San Luis Ranch Specific Plan Area: • The State Water Resources Control Board (SWRCB) Geotracker database; • Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) database; • Department of Toxic Substances Control’s Envirostor database; • State Water Resources Control Board (SWRCB) solid waste disposal sites, active Cease and Desist Orders (CDOs), and Cleanup and Abatement Orders (CAOs); and • The Cortese list. The search of the SWRCB Geotracker database identified two listings of the subject property in the Irrigated Lands Regulatory Program (ILRP), a program which regulates discharges from irrigated agricultural land to prevent impairment of the receiving waters. The older of the two listings of the property in the ILRP was terminated, while the site is listed with “enrolled” ILRP status under the most recent listing. Under the ILRP, SWRCB regulates agricultural discharge by issuing waste discharge requirements (WDRs) or conditional waivers of WDRs (Orders) to growers that contain conditions requiring water quality monitoring of receiving waters and corrective actions when impairments are identified. The SWRBC Geotracker database also identified a former Leaking Underground Storage Tank (LUST) facility adjacent and hydrologically upgradient to the project site. The facility is identified to have three former gasoline and waste oil underground storage tanks. The LUST facility has a “Completed-Case San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-2 Closed” cleanup status. The CERCLIS, EnviroStor, SWRCB solid waste disposal site, CDO, CAO, and Cortese databases did not list any potential contamination sites within the San Luis Ranch Specific Plan Area. No other sites with known hazardous materials contamination were identified on the project site. Adjacent Hazardous Materials Sites. In November 2014, Cleath-Harris Geologists, Inc. (Cleath-Harris) prepared a Hydrogeologic Description and PCE Characterization for Dalidio Laguna Ranch, San Luis Obispo County, California report (Hydrogeology Report; refer to Appendix H), which identified tetrachloroethylene (also called perchloroethylene, or PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. The project site is located adjacent to commercial uses to the northeast and residential uses to the southwest. Dry cleaning facilities have been recorded present to the north of the site as early as the 1930s. According to the Hydrogeology Report, the identified PCE groundwater contamination is attributed to spills at these hydrologically upgradient dry cleaning facilities. Shallow groundwater at the site generally flows towards the south-southwest, and wells on the project site have exhibited PCE groundwater contamination above the United States Environmental Protection Agency (U.S. EPA)/Central Coast Regional Water Quality Control Board (RWQCB) Maximum Contaminant Level (MCL) for drinking water of 5 micro grams per liter (µg/L). Cleath-Harris Analyzed PCE concentrations in four on-site wells and two off-site City wells to the south and the east of the site. The highest concentrations of PCE were detected at wells near U.S. 101 along the eastern side of the project site. PCE contamination is within the shallow aquifer groundwater (refer to Appendix H for detailed PCE characterization results). Groundwater within the deep aquifer could not be isolated in existing wells on the project site. Therefore, the PCE concentration in the deep aquifer is unknown. The domestic water well has a PCE concentration of 1.0 µg/L, which is within the U.S. EPA/RWQCB MCL for drinking water of 5.0 µg/L. The irrigation groundwater well has a PCE concentration of 9.5 µg/L, which exceeds the U.S. EPA MCL. c. Airport Safety Hazards. The project site is located approximately 1.5 miles northwest of the San Luis Obispo County Regional Airport (Airport), and falls within the jurisdiction of both the San Luis Obispo County Airport Land Use Commission’s (ALUC) ALUP and within the General Plan Land Use Element safety zones. This section briefly describes the operations at the Airport and associated physical safety hazards associated with the project site in terms of both the ALUP and General Plan Land Use Element safety zones and associated compatibility standards. A more detailed description of the standards for allowable development intensity within the ALUP Safety Areas and General Plan Land Use Element airport compatibility policies, along with associated land use impacts are described Section 4.9 Land Use/Policy Consistency. San Luis Obispo County Regional Airport. The Airport provides commuter, charter, and private aviation service to the City of San Luis Obispo and vicinity. The primary hazard associated with land uses near the airport is the risk of aircraft incidents on approach and take- off. Aircraft flight operations are determined largely by the physical layout of the airport and rules of the Federal Aviation Administration (FAA) (City of San Luis Obispo 2014). There are two runways at the Airport, both of which have parallel taxiways. Runway 11-29 is utilized for the majority of aircraft operations, with 97 percent of all aircraft operating at the Airport using this runway for departures and arrivals, as well as touch-and-go flights. Runway San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-3 7-25 is mostly used during crosswind conditions and is utilized for the remaining three percent of aircraft flights, only for General Aviation1 propeller aircraft. According to the Airport Imaginary Surfaces and Existing Obstructions map of the Airport Land Use Plan for the San Luis Obispo County Regional Airport (ALUP Figure 9), the project site is located in the path of the approach surface and extended runway centerline for Runway 11-29. There are no traffic patterns off Runway 7-25 and all arriving and departing aircraft using this runway enter the traffic pattern for Runway 11-29 which improves safety for all aircraft operating at the Airport (Johnson Aviation 2013; Appendix I). As shown in the Aviation Safety Areas Map of the ALUP (ALUP Figure 3), the project site is located within Airport Safety Areas S-1b and S-2. Safety Area S-1b encompasses the areas within gliding distance of prescribed flight paths for aircraft operations at less than 500 feet above ground level, plus sideline safety areas, and inner turning zones and outer safety zones for each runway. Safety Area S-2 encompasses the areas with aircraft operations at 501 to 1,000 feet above ground level. Airport safety is primarily related to the potential for accidents related to aircraft operations such as emergency landings (or in rare cases crashes) as well as ensuring that land use development is carried out in manner that minimizes or avoids risks associated with such aircraft incidents or accidents. Minimizing or avoiding risks to sensitive land uses (such as residential neighborhoods) involves designating areas around the ends of runways that must be free of objects or sensitive land uses, limiting the height of new structures in the surrounding airspace, and understanding historical accident patterns. This section briefly describes the operations at the Airport and associated physical safety hazards associated with the project site in terms of both the ALUP and City’s 2014 Land Use and Circulation Elements safety zones. A more detailed description of the standards for allowable development intensity within the ALUP Safety Areas and California Department of Transportation (Caltrans) California Airport Land Use Planning Handbook (CALUPH; 2011) Airport Safety Zones, along with associated land use impacts are described Section 4.9, Land Use/Policy Consistency. Figure 4.7-1 shows the ALUP Safety Areas on the project site and Figure 4.7-2 shows the CALUPH Airport Safety Zones on the site. Airport Land Use Plan Update. The project site falls within the jurisdiction of both the San Luis Obispo County Airport Land Use Commission’s (ALUC) ALUP, as well as City General Plan Land Use Element safety zones. Section 7 of the Land Use Element describes applicable Airport Safety Zones, which are required to “be consistent with the ALUP unless the City overrides a determination of inconsistency in accordance with Section 21676 and 21676.5 et. seq. of the Public Utilities Code.” As described above, the ALUP is currently undergoing an update which is expected to be completed in 2017. Section 21674.7(a) of the California Public Utilities Code requires that the ALUC use the CALUPH in formulating an ALUP. The ALUP and CALUPH provide guidance for development intensity within identified Airport Safety Zones under the ALUC’s and Caltrans’ respective jurisdiction. The CALUPH identifies potential airport safety hazards using criteria for governing allowable types and intensity of future development and the location of safety zones. The southeastern portion of the project site 1 General aviation is all civil aviation operations other than scheduled air services and non-scheduled air transport operations for remuneration or hire. £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r Safety Area S-1b Safety Area S-2 ALUP Airport Safety Zonesin the Specific Plan Area Figure 4.7-1 City of San Luis Obispo Section 4.7 Hazards and Hazardous MaterialsSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2015. ±0 500250 Feet Site Boundary 4.7-4 Source: ALUP, USDA NAIP 2012 Image, City of San Luis ObispoCaltrans Handbook Airport Safety Zones Applied to San Luis Obispo County Regional AirportFigure 4.7-2City of San Luis ObispoSan Luis Ranch Project EIRSection 4.7 Hazards and Hazardous Materials!!!!!!!!!!!!!!!! ! ! ! ! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! ! ! ! !!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!! ! ! !!!!!!!!!!!!!!!!! ! !6632114323322344533551615LegendAirport Area Specific Plan (AASP)Caltrans Handbook Safety Compatibility Zones(zone numbers labeled)!!!City Limits00.250.5Miles/Site Boundary4.7-5 San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-6 along U.S. 101 is located within CALUPH Airport Safety Zones 4 and 6. Airport Safety Zone 4 allows for non-residential development intensity of up to 200 persons per acre and allows for residential infill at up to the average of surrounding residential areas. Airport Safety Zone 6 has no limit for non-residential development intensity, but suggests avoidance of large stadiums and similar uses. Airport Safety Zone 6 also has no limit for residential development intensity, but suggests consideration of noise and overflight during such development. The 2014 Airport Land Use Compatibility Report prepared by Johnson Aviation (refer to Appendix I) in support of the City’s recent Land Use and Circulation update process and the Land Use and Circulation Update EIR (LUCE Update EIR) analyzed potential airport hazards and includes recommendations to update safety and hazards planning around the Airport based on guidance from the CALUPH and other sources. The CALUPH describes the characteristics of “ideal” safety zones such as “easily definable geometric shapes,” a limited number of five or six zones, a distinct progression in the degree of safety risk farther from the runway, providing that “each zone should be as compact as possible.” The Land Use Element and associated Airport Safety Zones implement these suggested standards by identifying six revised safety zones that represent distinct progression in the degree of safety risk farther from the runway. These Airport Safety Zones are supported by Land Use Element and Circulation Element policies, programs, and development standards consistent with those guidelines. Aviation Accidents at the Airport. According to the CALUPH , over two-thirds of both general aviation (68 percent) and commercial (67 percent) aircraft accidents take place on an airport. Another three percent of general aviation and seven percent of commercial aviation are en-route accidents occurring more than five miles from an airport. The remaining 29 percent of general aviation and 26 percent of commercial aviation accidents are classified as airport- vicinity accidents, potentially including some en-route accidents which took place within five miles of an airport. Accident sites are generally close to the extended runway centerline (Caltrans 2011). Between 1982 and 2013, 33 aviation accidents have been investigated at the Airport. As shown in Table 4.7-1, six of the investigated accidents were fatal. Of the six fatal accidents, five occurred during the takeoff, climb, approach, or land phase of flight within five miles of the Airport and four occurred within Airport Safety Zones as defined in the CALUPH . None of the fatal accidents associated with the Airport involved fatalities of persons on the ground. As shown in Table 4.7-1, the 1990 accident occurred within the project site and 1994 accident occurred approximately adjacent to the northeastern corner of the project site along U.S. 101. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-7 Table 4.7-1 Fatal Aircraft Accidents within the Vicinity of the Airport Approximate Location of Accident Site within CALUPH Airport Safety Zones and/or ALUP Safety Areas Flight Date CALUPH Airport Safety Zones ALUP Safety Area August 24, 1984 N/A N/A September 24, 1990 N/A S-2 August 7, 1994 4 S-1b January 16, 2001 6 S-1c August 1, 2005 6 S-2 June 24, 2016 2 S-1b Source: Figure 4-3, Johnson Aviation 2014. d. Other Potential Hazards. Other potential hazards that may occur on the project site include residual agricultural chemicals in soils, asbestos containing materials and lead based paint, naturally occurring asbestos, electromagnetic fields, radiation, wildland fires, and hazardous material transport. The project site setting associated with each of these potential hazards is discussed more fully below. Residual Agricultural Chemicals. The project site has been used for agricultural purposes for over 100 years. As a result, residual agricultural chemicals including pesticides, arsenic, and herbicides may be present in the soil. Asbestos Containing Materials and Lead Based Paint. Asbestos was used as insulation in walls or ceilings or as a component in adhesives in older buildings (pre-1979). Asbestos can pose a health risk when very small particles become airborne. Lead is a highly toxic metal that was used for many years in products found in and around homes, including paint. Lead-based paint (LBP) was commonly used in residential construction prior to the enactment of federal regulations limiting its use in the late 1970s. Exposure to lead can cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. The primary source of lead exposure in residential settings is deteriorating LBP. Lead dust can form when LBP is dry scraped, dry sanded, or heated. Dust also forms when painted surfaces bump or rub together. LBP that is in good condition is usually not a hazard. The subject property includes the Dalidio Farm Complex, a collection of structures including the Dalidio home, the former Laguna Racetrack viewing stand that has been converted to other farm uses, barn, water tower, and other buildings supporting the farming of the ranch which date back to the turn of the 20th century. Due to the age of the on-site structures that may be removed under the project, asbestos and lead may be present in those structures. Naturally Occurring Asbestos. Serpentine rock is located in many regions of San Luis Obispo County, including coastal and coastal mountain areas, western north County, and the extreme eastern County area along the San Andreas Fault. According to the San Luis Obispo Air Pollution Control District’s (SLOAPCD) naturally occurring asbestos (NOA) map, the San Luis Ranch Specific Plan Area is located in an area where geologic analysis for NOA is required prior to grading. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-8 Electromagnetic Fields. The flow of electricity through a conductor creates electromagnetic fields (EMFs). These fields form around power transmission and distribution lines, wiring in buildings, and equipment and appliances used at home and in businesses. The strength of an EMF depends mainly on the voltage in the conductor, and declines with distance from the conductor. Other EMF characteristics depend on the type of current (alternating or direct) and the frequency of alternation. While an EMF from one conductor may interact with and in effect “neutralize” an EMF from another conductor, there is generally no way to shield against EMF exposure. Studies of EMF exposure have shown that exposure to EMFs can cause illness, especially from long-term exposure to strong fields. The mechanisms for the harmful effects have not been clearly defined. All life processes involve electromagnetic interactions at the cellular and molecular level, and fields from external sources may interfere with these processes. However, there is not a clear dose-response relationship (General Plan Safety Element, City of San Luis Obispo 2014c). Pacific Gas and Electric Company (PG&E) provides the City of San Luis Obispo with electricity through 115 kilovolt (kV) transmission lines around which EMFs may form. Transmission lines run along the western edge and cross over the northwestern corner of the project site near U.S. 101 (City of San Luis Obispo 2014c). Radiation. Ionizing radiation damages tissues at the molecular and genetic levels, potentially causing illness, reproductive problems, and/or death. The particular type of damage depends on the intensity and duration of exposure and the part of the body that is exposed. Humans have evolved in an environment that includes very low‐level exposure to natural sources of radiation. Unnatural (man-made) sources can cause much higher levels of radiation exposure. Man-made radiation is radiation produced in devices, such as x-ray machines, and artificially produced radioisotopes made in a reactor or accelerator. This type of radiation is used in both medicine and industry. The primary users of man-made radiation include medical facilities, such as hospitals and pharmaceutical facilities; research and teaching institutions; nuclear reactors and their supporting facilities, such as uranium mills and fuel preparation plants; and federal facilities involved in nuclear weapons production. Chronic exposure (i.e. continuous or intermittent exposure to low doses of radiation over a long period of time) to radiation from these sources can result in cancer and other health outcomes such as benign tumors, cataracts, and potentially harmful genetic effects (U.S. EPA 2007). The Diablo Canyon Nuclear Power Plant in Avila Beach is the primary hazard for ionizing radiation in the San Luis Obispo area. Risks of radiation release and exposure result from the potential for equipment and/or operator errors during day‐to‐day operations, accidents associated with refueling, and damage from earthquakes or other causes. There is added risk from on‐site storage of spent fuel that remains radioactive for several generations. Long‐term, off‐site storage facilities for spent fuel are not currently available. A release of radioactive material could seriously damage human health and make property unusable. The plant operator and local agencies have jointly prepared Emergency Response Plans for warning, sheltering, evacuation, and other responses to radiation emergencies which are distributed to the public each year. The plant is regulated by the Federal Government. Land close to the plant, and downwind from it under prevailing conditions, is under County jurisdiction. The project site is located approximately 10 miles east-northeast of the power plant. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-9 Wildland Fires. Fires have the potential to cause significant losses to life, property, and the environment. Fire hazard severity in rural areas, including areas on the edge between urban and rural land (commonly called the wildland interface), are highly influenced by the slope of the landscape and site vegetation and climate. This risk is somewhat amplified by the native, Mediterranean vegetation common to the rural setting of the City of San Luis Obispo. Wildland fires affect grass, forest, and brushlands, as well as any structures on these lands, and can result from either human‐made or natural causes. The region’s topography, type, and amount of fuel, climate, and the availability of water for firefighting are the primary factors influencing the degree of fire risk. According to California Department of Forestry and Fire Protection (CAL FIRE), vegetation fires comprise the majority of fires in San Luis Obispo County. The northwestern portion of the project site includes a mature stand of tall eucalyptus trees which, although not connected to outlying wildland areas, has the potential to present fire fuel risks and vertical fire ladder structure that can increase potential fire intensity. The project site is designated as a Moderate Wildland Fire Hazard Area (LUCE Update EIR, City of San Luis Obispo, 2014). Hazardous Material Transport. Portions of the project site border U.S. 101 and Madonna Road. These high-volume roadways could be used for the transport of hazardous wastes and materials. Truck accidents could result in spills of such materials. All transport of hazardous materials are subject to federal, State, and local laws and regulations pertaining to the transportation of hazardous materials, discussed further in Section 4.7.1(e), below. e. Regulatory Setting. The management of hazardous materials and hazardous wastes is regulated at federal, State, and local levels, including through programs administered by the U.S. EPA; agencies within the California Environmental Protection Agency (CalEPA), such as the Department of Toxic Substances Control (DTSC); federal and State occupational safety agencies; and the San Luis Obispo County Environmental Health Services. Regulations pertaining to flood hazards are further discussed in Section 4.8, Hydrology and Water Quality. Definition of Hazardous Materials. A material is considered hazardous if it appears on a list of hazardous materials prepared by a federal, state, or local agency, or if it has characteristics defined as hazardous by such an agency. A hazardous material is defined in Title 22 of the California Code of Regulations as follows: “A substance or combination of substances which, because of its quantity, concentration, or physical, chemical or infectious characteristics, may either (1) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or (2) pose a substantial present or potential hazard to human health or environment when improperly treated, stored, transported or disposed of or otherwise managed.” (California Code of Regulations, Title 22, Section 66261.10) Chemical and physical properties cause a substance to be considered hazardous. Such properties include toxicity, ignitability, corrosiveness, and reactivity. California Code of Regulations, Title 22, Sections 66261.20 through 66261.24 defines the aforementioned properties. The release of hazardous materials into the environment can contaminate soils, surface water, and groundwater supplies. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-10 Federal. The Federal Toxic Substances Control Act (1976) and the Resource Conservation and Recovery Act of 1976 (RCRA) established a program administered by the U.S. EPA for the regulation of the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid Waste Act (HSWA), which affirmed and extended the “cradle to grave” system of regulating hazardous wastes. Among other things, the use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by HSWA. The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was enacted in 1980 and amended by the Superfund Amendments and Reauthorization Act (SARA) in 1986. This law provides broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. Among other things, CERCLA established requirements concerning closed and abandoned hazardous waste sites, provided for liability of persons responsible for releases of hazardous waste at these sites, and established a trust fund to provide for cleanup when no responsible party could be identified. CERCLA also enabled revision of the National Contingency Plan (NCP), which provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The NCP also established the National Priorities List (NPL). Asbestos Hazard Emergency Response Act (AHERA) (1986). This Act is the federal legislation that governs the control and abatement of asbestos hazards present in school buildings. The purpose of this Act is to also require U.S. EPA to evaluate the extent of danger to human health posed by asbestos in public and commercial buildings and the means to respond to any identified danger. National Emission Standards for Hazardous Air Pollutants 40 CFR 61 Subpart M – (NESHAP). Projects requiring the removal or relocation of utility pipelines or removal or renovation of buildings may be subject to the requirements stipulated in NESHAP. These requirements include but are not limited to: 1) Notification requirements to the San Luis Obispo County Air Pollution Control District (SLOAPCD); 2) Asbestos survey conducted by a Certified Asbestos Inspector; and 3) Applicable removal and disposal requirements of ACMs. Federal Occupational Safety and Health Administration (OSHA) - Process Safety Management Standard (29 CFR 1910.119). This standard includes requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Requirements of this standard include providing employees with information pertaining to hazardous chemicals, training employees on the operation of equipment with hazardous materials, and employer requirements to perform a process hazard analysis. U.S. Department of Transportation. The U.S. Department of Transportation regulates hazardous materials transportation between states. Within California, the California Department of Transportation (Caltrans) and California Highway Patrol enforce federal law. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-11 Together, these agencies determine driver training requirements, load labeling procedures, and specifications for container types to be used. State. The DTSC, a department of the California EPA, is the primary agency in California that regulates hazardous waste, cleans up existing contamination, and looks for ways to reduce the hazardous waste produced in California. DTSC regulates hazardous waste in California primarily under the authority of RCRA and the California Health and Safety Code. DTSC also administers the California Hazardous Waste Control Law (HWCL) to regulate hazardous wastes. While the HWCL is generally more stringent than RCRA, until the U.S. EPA approves the California program, both state and federal laws apply in California. The HWCL lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills. Government Code Section 65962.5 requires the DTSC, the State Department of Health Services, the SWRCB, and CalRecycle to compile and annually update lists of hazardous waste sites and land designated as hazardous waste sites throughout the state. The Secretary for Environmental Protection consolidates the information submitted by these agencies and distributes it to each city and county where sites on the lists are located. Before the lead agency accepts an application for any development project as complete, the applicant must consult these lists to determine if the site at issue is included. If any soil is excavated from a site containing hazardous materials, it would be considered a hazardous waste if it exceeded specific criteria in Title 22 of the California Code of Regulations. Remediation of hazardous wastes found at a site may be required if excavation of these materials is performed, or if certain other soil disturbing activities would occur. Even if soil or groundwater at a contaminated site does not have the characteristics required to be defined as hazardous waste, remediation of the site may be required by regulatory agencies subject to jurisdictional authority. Cleanup requirements are determined on a case-by-case basis by the agency taking jurisdiction. The State of California Food and Agricultural Code regulates the use of pesticides. Section 12972 requires that the use of pesticides not result in substantial drift to non-target areas. Section 12977 empowers the Agricultural Commissioner to enforce this provision. In addition, Section 12982 states that the local health officer shall investigate any health hazard from pesticide use and take necessary action, in cooperation with the Agricultural Commissioner, to abate the hazard. California Code of Regulations, Title 3, Section 6614 restricts pesticide application when there is a reasonable possibility of: substantial drift to non-target areas; contamination of the bodies or clothing of persons not involved in the application process; damage to non-target crops, animals or other public or private property; or contamination of public or private property, including the creation of a health hazard that prevents normal usage of that property. In conformance with the Clean Air Act, the U.S. EPA established the National Emissions Standards for Hazardous Air Pollutants (NESHAP) to protect the public. The asbestos regulations under NESHAP control work practices during the demolition and renovation of San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-12 institutional, commercial or industrial structures. Following identification of friable asbestos the Federal Occupational Safety and Health Administration and San Luis Obispo Air Pollution Control District require that asbestos trained and certified abatement personnel perform asbestos abatement and all asbestos containing material (ACM) removed from on-site structures be hauled to a licensed receiving facility and disposed of under proper manifest by a transportation company certified to handle asbestos. NOA is regulated by the California Code of Regulations (CCR) Title 17 Section 93105. This regulation outlines dust mitigation practices and monitoring to reduce exposure to NOA as a result of earth-disturbing activities. If serpentine or ultramafic rocks are identified within the site, an asbestos dust mitigation plan is required in accordance with CCR Title 17, Section 93105 Asbestos Airborne Toxic Control Measure for Construction, Grading, Quarrying, and Surface Mining Operations. Regulations for LBP are contained in the Lead-Based Paint Elimination Final Rule 24 Code of Federal Regulations (CFR) 33, governed by the U.S. Housing and Urban Development (HUD), which requires sellers and lessors to disclose known LBP and LBP hazards to perspective purchasers and lessees. Additionally, all LBP abatement activities must be in compliance with California and Federal OSHA and with the State of California Department of Health Services requirements. Only LBP trained and certified abatement personnel are allowed to perform abatement activities. All lead LBP removed from structures must be hauled and disposed of by a transportation company licensed to transport this type of material at a landfill or receiving facility licensed to accept the waste. Site-Specific Health and Safety (California Division of Occupational Safety and Health Administration [Cal/OSHA] Title 8 and OSHA 29 Code of Federal Regulations [CFR] 1910). Under these requirements, employers must develop site-specific Health and Safety Plans. Workers potentially exposed to hazardous materials in their workplace must be trained so that they are aware of the hazards and provided necessary protection from the hazardous materials. California Air Resources Board (ARB) Airborne Toxics Control Measure (ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations (Section 93105). This regulation applies to any area to be disturbed that is located in a geographic ultramafic rock unit, or to any area where Naturally Occurring Asbestos (NOA) or serpentine would be disturbed. Specific requirements may include conducting a geologic evaluation, development of an Asbestos Dust Mitigation Plan and an Asbestos Health and Safety Program for approval by SLOAPCD. Hazardous Material Release Response Plans and Inventory Law (California Health and Safety Code [HSC], Chapter 6.95). This law requires businesses to develop a Release Response Plan for hazardous materials emergencies if they handle more than 500 pounds, 55 gallons, or 200 cubic feet of hazardous materials. In addition, the business must prepare a Hazardous Materials Inventory of all hazardous materials stored or handled at the facility over the above thresholds. Also, all hazardous materials must be stored in a safe manner. Both the Release Response Plan and the Hazardous Materials Inventory must be supplied to the Certified Unified Program Agency (CUPA) for the program. For the project site, the CUPA is the San Luis Obispo County Health Agency. California HSC, Division 20, Chapter 6.8, Section 25319.5 - Preliminary Endangerment Assessment (PEA). The California HSC requires that a PEA provide sufficient information to San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-13 determine whether or not current or past waste management practices have resulted in the release or a threatened release of hazardous substances that pose a threat to public health or the environment. The PEA should also provide sufficient information to conclude whether or not significant response actions are necessary at the site as well as include an analysis of the scope and identity of the affected community. Safe Drinking Water and Toxic Enforcement Act (Proposition 65) (1986). In California, pursuant to the Safe Drinking Water and Toxic Enforcement Act of 1986: (1) no person in the course of doing business shall knowingly discharge or release a chemical known to the State to cause cancer or reproductive toxicity into water or onto land where such chemical passes or probably will pass into any source of drinking water, and (2) no person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning to such individual. The “no significant risk” level for carcinogens that is enforced by this Act is one in one hundred thousand (1 x 10-5). Porter-Cologne Water Quality Control Act (Division 7 of the California Water Code). The Porter-Cologne Act establishes a regulatory program to protect water quality and to protect beneficial uses of state waters. The Porter-Cologne Act also establishes the State board and regional boards as the principal State agencies responsible for control of water quality. Each of the nine Regional Water Quality Control Boards (RWQCBs) in California is required to develop guidance to assist in ensuring that the intent of the Porter-Cologne Act is met. Cleanup criteria are based on the type of contaminant (e.g., gasoline, diesel, or oil) released and the depth to groundwater. HSC, Division 20, Chapter 6.5, and California Code of Regulations (CCR) Title 22 – Hazardous Waste Management. Waste that is toxic, corrosive, flammable, or reactive when tested in accordance with the CCR, Title 22, Article 11, Section 66693, must be handled, stored, transported, and disposed of in accordance with these regulations, which are more stringent than federal regulations. HSC, Division 20, Chapter 6.7, and CCR, Title 23 – UST Management. USTs used for storing petroleum products must be managed in accordance with California law, which provides requirements for installation, materials used, secondary containment, overspill protection, and monitoring. California Fire Code. To minimize risks to public health and the environment, a Fire Prevention Inspector shall review a list of hazardous materials stored aboveground on a property to assess potential individual and/or cumulative impacts to the property and surrounding areas. The inspector would ensure that hazardous materials stored onsite are in compliance with Chapter 6.95 of the California HSC. The fire code provides uniform fire prevention, hazardous material, and building construction regulations. Local. City of San Luis Obispo Fire Department. Permits are required to maintain, store, use, or hand materials which produce conditions hazardous to life or property. The City of San Luis Obispo Fire Department issues and manages Hazardous Waste Generator Permits. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-14 City of San Luis Obispo Municipal Code. The City of San Luis Obispo 2013 Construction and Fire Code Amendment establishes the minimum standards and procedures for the demolition and relocation of buildings and structures to safeguard life, property, health, and public welfare. Specifically, Section A201 outlines the City requirements for demolition and moving of buildings in accordance with Chapter 1, Division II of the California Building Code. These requirements include general requirements for building demolition activities, permitting for such activities, hauling operations, and routes of moving materials, as well as specific requirements for dust and debris, fire safety, and removal and disposal of demolition materials. City of San Luis Obispo General Plan Safety Element. The City’s General Plan guides the use and protection of various resources to meet community purposes. The Safety Element is focused on achieving acceptable levels of risk through decisions on land use and the form of development, with consideration for the closely related factor of transportation. The Safety Element includes policies that describe an approach to achieving the goals of the General Plan. In terms of hazards and hazardous materials, the following policies and programs are pertinent to the San Luis Ranch Specific Plan: Policy S 5.2. Minimizing Hazardous Materials Exposure. People’s exposure to hazardous substances should be minimized. Policy S 9.18. Safety of Structures and Facilities. Existing and new structures and facilities should reflect adopted safety standards. Within this policy, the City has developed a program, Program S 8.6.5 Required Inspections, whereby the City will conduct safety inspections for hazardous materials in commercial, industrial, and multifamily residential buildings. Policy 6.2: Minimizing Hazardous Materials Exposure. People’s exposure to hazardous substances should be minimized. Policy 7.0: Uses in the Airport Land Use Plan Area. Development should be permitted only if it is consistent with the requirements of the California State Aeronautics Act (Public Utilities Code §21670, et. seq.), guidance from the California Airport Land Use Planning Handbook, other related federal and state requirements relating to airport land use compatibility planning, and the San Luis Obispo County Regional Airport Land Use Plan unless the City overrules a determination of inconsistency in accordance with Section 21676.5 et. seq. of the Public Utilities Code. Prospective buyers of property that is subject to airport influence should be so informed. Program 10.23 Required Inspections. The City will conduct safety inspections for hazardous materials in commercial, industrial, and multifamily residential buildings. City of San Luis Obispo General Plan Land Use Element. The City’s 2014 LUCE Update EIR and the 2014 Johnson Aviation Report address the issues of airport hazards in detail. Based on the analysis in these documents, the General Plan includes policies and programs to address airport safety which are summarized below and discussed in more detail in Section 4.9, Land Use/Policy Consistency. It should be noted that Program 7.16 and 7.17 have been completed and adopted and are presented here for informational purposes only. Policy 7.4 Airport Safety Zones. Density and allowed uses within the Airport Safety Zones shall be consistent with the San Luis Obispo County Regional Airport ALUP unless the San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-15 City overrides a determination of inconsistency in accordance with Section 21676 and 21676.5 et seq. of the Public Utilities Code. If the City overrides a determination, all land uses shall be consistent with the State Aeronautics Act and guidance provided in the California Airport Land Use Planning Handbook guidelines, City policies, and noise standards as substantiated by the San Luis Obispo County Regional Airport Master Plan activity forecasts as used for noise planning purposes. Program 7.16. Airport Overlay Zone. The City shall create an AOZ to reflect the boundaries of the ALUP within the City limits. The purpose of the AOZ is to codify airport compatibility criteria in areas for which the City may override the ALUC determination to ensure compliance with the requirements of the California State Aeronautics Act (Cal. Pub. Utilities Code, Section 21670, et seq.), which establishes statewide requirements for airport land use compatibility planning, guidance from the California Airport Land Use Planning Handbook, which is published by the Caltrans Division of Aeronautics to support and amplify the State Aeronautics Act requirements, and other related federal and state requirements relating to airport land use compatibility planning. Implementation of the compatibility policies will be accomplished through the Zoning Code. Program 7.17. Airport Land Use and Zoning Code. The City shall update its Zoning Regulations to address allowable uses and development standards for areas in which the City may override a determination of inconsistency. Zoning regulations shall be consistent with the requirements of the State Aeronautics Act, use guidance from the Caltrans Airport Land Use Planning Handbook, and comply with related state and federal requirements relating to airport land use compatibility. These development standards will include, but not be limited to, intensity and density limitations, identification of prohibited uses, infill development, height limitations, obstructions, and other hazards to flight, noise insulation requirements, buyer awareness measures, nonconforming uses and reconstruction and the process for airport compatibility criteria reviews by the City consistent with these development standards. Airport Compatible Open Space Plan. The Airport Compatible Open Space Plan (ACOS) establishes open spaces in the areas around the Airport that can serve as reserve spaces (for aircraft emergency situations). By maintaining reserve spaces that keep certain land adjacent to the Airport free and clear from obstruction or from buildings and uses where people congregate, the ACOS improves airport safety while allowing for more intense development of urban areas. The areas identified as reserve space in the ACOS include land that is close to the Airport, in line with the main airport runway, or along an over-flight area where aircraft typically operate at lower altitudes. Identification of these areas in the ACOS adds airport safety to the list of reasons why these lands should not be developed (City of San Luis Obispo and County of San Luis Obispo 2013). On July 21, 2004, the ALUC voted to amend the ALUP with inclusion of the City’s ACOS. Airport Land Use Plan for the San Luis Obispo County Regional Airport. State law requires an independent, County-wide ALUC to adopt an ALUP for each airport. The ALUP establishes zones based on flight patterns, with the aim of having future development be compatible with airport operations, considering safety and noise exposure. The ALUP was last amended in 2005 and is in process of being updated to reflect the adopted Airport Master Plan. A draft ALUP amendment was released in 2014 and is anticipated to be finalized and available in 2017. The ALUP contains several safety-related policies to address future development: San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-16 Policy S-1. Would permit or lack sufficient provisions to prohibit structures and other obstacles within the Runway Protection Zones for any runway at the Airport, as depicted in ALUP Figure 4. Policy S-2. Would permit or fail to adequately prohibit any future residential or nonresidential development or redevelopment which would create, within the site to be developed or redeveloped, a density greater than specified in ALUP Table 7 or any mixed-use development or redevelopment which would create, within the site to be developed or redeveloped, densities greater than illustrated in ALUP Figures 5 through 8. Policy S-3. Would permit or fail to adequately prohibit any future development project which specifies, entails, or would result in a greater building coverage than permitted by ALUP Table 7. Policy S-4. Would permit or fail to adequately prohibit high intensity land uses or special land use functions (impaired egress uses or unusually hazardous uses), except that, when conditions specified by ALUP Table 7 for density adjustments have been determined to be met by the ALUC, high intensity land and/or special function uses may be allowed in Aviation Safety Area S-2. City of San Luis Obispo Conservation and Open Space Element. As noted in Section 4.2, Agricultural Resources, the City of San Luis Obispo addresses agricultural uses and compatibility with urban development through implementation of adopted policies and programs in the City’s Conservation and Open Space Element (COSE). The following policy promotes compatibility between agricultural land use and other adjacent land uses through the implementation of buffers: Policy 8.3.2. Open Space Buffers. [Relevant Portion]. When activities close to open space resources within or outside the urban area could harm them, the City will require buffers between the activities and the resources. The City will actively encourage individuals, organizations and other agencies to follow this policy. Buffers associated with new development shall be on the site of the development, rather than on neighboring land containing the open space resource. Buffers provide distance in the form of setbacks, within which certain features or activities are not allowed or conditionally allowed. Buffers shall also use techniques such as planting and wildlife-compatible fencing. Buffers shall be adequate for the most sensitive species in the protected area, as determined by a qualified professional and shall complement the protected area’s habitat values. Buffers shall be required in the following situations: • Between urban development and agricultural operations, to address dust, noise, odors, chemical use, and access by people and pets. • Between agricultural operations and natural habitat, to address noise, chemical use, sediment transport, and livestock access. 4.7.2 Previous Program-Level Environmental Review The 2014 LUCE Update EIR previously analyzed potential hazards and hazardous materials impacts of development planned under the Land Use and Circulation Element Update, San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-17 including planned development on the project site. The LUCE Update EIR noted that there are no records of previous or existing sources of contamination in this area. However, it acknowledges that historic agricultural use onsite may have resulted in undocumented residual quantities of presently banned agricultural chemicals, which could pose a health hazard to construction workers or future residents or visitors. The LUCE Update EIR also notes that the site is located in proximity to a major transportation corridor which creates the potential for risks associated with the transportation of hazardous materials. Future mixed use development in this area, as envisioned under the updated Land Use Element, could expose individuals to health risks due to the site location in proximity to U.S. 101. Although the LUCE Update EIR described potential hazards impacts related to historic agricultural use in the San Luis Ranch Specific Plan Area, risk of injury or damage from wildland fires, and health risks due to the site location in proximity to U.S. 101, the EIR concluded that implementation of the LUCE Update EIR policies, amendments to existing City policies, and compliance with existing local, State and federal regulations, would reduce impacts to a less than significant level. For example, compliance with Land Use Element policy 12.9, Environmental Review, would reduce impacts related to development in direct proximity to hazardous materials transportation corridors, including U.S. 101. In addition, the LUCE Update EIR noted that ALUP Safety Area S-1b and Safety Area S-2 and CALUPH Airport Safety Zones 4 and 6 cover portions of the site (described in Section 4.7.1[c]). However, the EIR concluded that implementation of the Land Use and Circulation Element policies, amendments to existing City policies, and compliance with existing local, State and federal regulations, would reduce potential impacts associated with airport-related safety hazards to a less than significant level. Specifically, use limitations, overflight notification and avigation easements would ensure that future development under the General Plan would not result in significant airport‐related safety hazards. 4.7.3 Impact Analysis a. Methodology and Significance Thresholds. Assessment of impacts is based on review of the Specific Plan and environmental conditions on the project site; listed hazardous materials sites within and near the project site; the Cleath-Harris Hydrogeology Report (Appendix H); the ALUP for the San Luis Obispo County Regional Airport; the 2014 Johnson Aviation Airport Land Use Compatibility Report (Appendix I); and the 2014 LUCE Update EIR, as well as other applicable laws and regulations related to hazards and hazardous materials issues. The following thresholds are based on Appendix G of the State CEQA Guidelines. A significant impact related to hazards and hazardous materials would occur if the project would: 1. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; 2. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; 3. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-18 4. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment; 5. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, result in a safety hazard for people residing or working in the project area; 6. For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area; 7. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; and/or 8. Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. The Initial Study determined that that the site is not near a private airstrip (Threshold 6), that the site does not expose people to significant risk of wildland fire (Threshold 7), and that the project would not interfere with an adopted emergency response or evacuation plan (Threshold 8). Therefore, Thresholds 6, 7, and 8 are not discussed further in this section. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of these issues as well as discussions of potential hazards related to exposure to radiation and electromagnetic fields and identified tetrachloroethylene (also called perchloroethylene, or PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. Additionally, impacts associated with exposure to hazardous materials (Threshold 1) due to proposed agriculture uses adjacent to residential and commercial land uses are addressed in Section 4.2, Agricultural Resources. b. Project Impacts and Mitigation Measures. Threshold 1: Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Impact HAZ-1 Small quantities of hazardous materials may be used in conjunction with the proposed residential and commercial retail uses on site. However, these materials would be limited in type and quantity such that they would not create a hazard to the public or environment. Therefore, this impact would be Class III, less than significant. Residential and commercial retail uses may involve use and storage of some materials that are considered hazardous. Such materials would be limited to typical solvents, paints, chemicals used for cleaning and building maintenance, and landscaping supplies. These materials would not be substantially different from household chemicals and solvents already in general and wide use throughout the City and in the vicinity of the project site. The use of such materials is also regulated by federal, State, and local laws, with which the project would be required to comply. Mitigative Components of the Specific Plan and Impact Conclusion. The proposed residential and commercial land uses included in the San Luis Ranch Specific Plan would not involve the San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-19 transport, use, or disposal of substantial amounts of hazardous substances. Therefore, this impact would be less than significant. Mitigation Measures. No mitigation would be required. Residual Impacts. Impacts would be less than significant without mitigation. Threshold 2: Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Impact HAZ-2 The project site is adjacent to U.S. Highway 101, on which accidents that involve hazardous materials could occur. Such accidents could potentially create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. However, compliance with applicable regulations related to the handling and storage of hazardous materials would minimize the risk of the public’s potential exposure to these substances, resulting in a Class III, less than significant, impact. The proposed development is located on the west side of U.S. 101. Other roadways near the site include Madonna Road and Oceanaire Drive. Vehicles that service the site during construction may transport soil contaminated with pesticides, asbestos, and or heavy materials away from the site for disposal (refer to Impact HAZ-4 for a detailed discussion of proper handling and disposal of soil containing residual quantities of agricultural chemicals). Additionally, during site operation, vehicles may transport pesticides, fertilizer, or other agricultural chemicals used by the ongoing agricultural uses on site. These vehicles, along with other commercial vehicles transporting hazardous materials near the site would use U.S. 101. The project would retain most of the land adjacent to U.S. 101 in agricultural use. In the northeastern portion of the project site’s frontage with U.S. 101, the project includes new commercial uses adjacent to the highway. In the unlikely event of an accident involving the transport of hazardous wastes and materials on roadways abutting the site, the health of construction workers or residents in the community could be adversely affected. However, local agencies must respond to the incident in accordance with the assignment of duties and procedures in the San Luis Obispo County Office of Emergency Services Hazardous Materials Emergency Response Plan (November 2013). In addition, U.S. EPA and U.S. Department of Transportation (DOT) laws and regulations have been promulgated to track and manage the safe interstate transportation of hazardous materials and waste. U.S. EPA administers permitting, tracking, reporting, and operations requirements established by RCRA. DOT regulates the transportation of hazardous materials through implementation of the Hazardous Materials Transportation Act. This act administers container design, and labeling and driver training requirements. State and local agencies enforce the application of these acts and provide coordination of safety and mitigation responses in the case that accidents involving hazardous materials occur. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-20 Mitigative Components of the Specific Plan and Impact Conclusion. Development associated with the San Luis Ranch Specific Plan would retain most of the land adjacent to U.S. 101 in agricultural use, with residential and recreational uses, and most commercial development distanced from U.S. 101. However, some commercial development proposed for the Specific Plan Area would be located adjacent to the highway. Enforcement of the Hazardous Materials Transportation Act, laws and regulations to track and manage the safe interstate transportation of hazardous materials and waste, and rapid response by local agencies would ensure that hazards to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment would remain less than significant. Mitigation Measures. Transport of hazardous materials on U.S. 101 and other roadways, including U.S. 101, would be required to comply with all federal, State, and local laws pertaining to the handling of hazardous materials. No mitigation would be required. Residual Impacts. Impacts would be less than significant without mitigation. Threshold 3: Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Impact HAZ-3 Two schools are located within one-quarter mile of the project site. Compliance with existing federal, State, and local regulations would ensure that hazardous materials impacts to schools would remain Class III, less than significant. Pacific Beach High School, located at 11950 Los Osos Valley Road, and CL Smith Elementary School, located at 1375 Balboa Street, are within one-quarter mile of the San Luis Ranch Specific Plan Area. Potential impacts associated with the transport, use, or disposal of hazardous materials are discussed in Impact HAZ-1, above. As described therein, proposed residential and commercial land uses would not involve the transport, use, or disposal of substantial amounts of hazardous substances. In addition, the project would involve ongoing agricultural uses on the project site, which may use agricultural chemicals, including sprayed pesticides. The project is consistent with COSE Policy 8.3.2, which requires agricultural buffers to reduce and/ or avoid dust and pesticide drift, and the nearest school would be a minimum of 800 feet from the project site. Mitigative Components of the Specific Plan and Impact Conclusion. Potential impacts associated with reasonably foreseeable upset and accident conditions are discussed in Impact HAZ-2, above. As described therein, DOT regulates the transportation of hazardous materials through implementation of the Hazardous Materials Transportation Act. Therefore, enforcement of federal, State, and local regulations would ensure that impacts associated with hazardous emissions or materials near schools would remain less than significant. Mitigation Measures. No mitigation would be required. Residual Impacts. Impacts would be less than significant without mitigation. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-21 Threshold 4: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment? Impact HAZ-4 Hazardous materials sites identified on and upgradient to the project site as well as residual pesticides and agricultural chemicals in soil due to historical use of pesticides and other agricultural chemicals onsite could create a hazard to construction workers during the construction phase of the project. Impacts would be Class II, significant but mitigable. As described in Section 4.7.1(b), the search of the SWRCB Geotracker database identified two sites within the subject property that are listed in the Irrigated Lands Regulatory Program and one former LUST facility adjacent and hydrologically upgradient to the project site with a ‘Completed-Case Closed’ cleanup status. The CERCLIS, EnviroStor, SWRCB solid waste disposal site, CDO, CAO, and Cortese databases did not list any potential contamination sites within the San Luis Ranch Specific Plan Area, and no other sites with known hazardous materials contamination were identified on the project site. Construction activities, including excavation and trenching related to utility infrastructure and future residential and commercial development on site, may encounter shallow groundwater. In the event that shallow groundwater is encountered, dewatering of the excavation or trenching site may be required, which could result in discharge of contaminated groundwater. In accordance with the Waste Discharge Requirements for Dewatering and other Low Threat Discharges to Surface Waters (Order R5-2013-0074, and National Pollutant Discharge Elimination System [NPDES] No. CAG995001), contaminated groundwater would be treated prior to discharge or disposed of at an appropriate disposal facility or wastewater treatment plant. Also, discharges of dewatered groundwater to a water of the state would require authorization under a NPDES permit from the RWQCB (refer to Section 4.8, Hydrology and Water Quality, for a detailed discussion of NPDES permit requirements). Compliance with State and regional regulations for treatment and discharge of any potentially contaminated groundwater would ensure that impacts related to water quality degradation through the discharge of dewatered groundwater would be less than significant. Mitigative Components of the Specific Plan and Impact Conclusion. Due to the presence of identified hazardous materials sites and current and historical agricultural practices on site, the potential exists for the presence of residual quantities of agricultural chemicals and other hazardous materials, including undocumented residual quantities of presently-banned chemicals. Ground disturbing activities during construction could expose construction workers to residual agricultural chemicals in on-site soil via direct contact or inhalation of dust particles. Improper handling and disposal of contaminated soils could result in a health risk to people which would be potentially significant unless mitigation is incorporated. Mitigation Measures. The following mitigation would reduce risk of exposure to residual agricultural chemicals in on-site soil: San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-22 HAZ-4 Soil Sampling and Remediation. Prior to issuance of any grading permits, a contaminated soil assessment shall be completed in the portions of land to be graded for development. Soil samples shall be collected under the supervision of a professional geologist or environmental professional to determine the presence or absence of contaminated soil in these areas. The sampling density shall be in accordance with guidance from San Luis Obispo County Environmental Health Services, so as to define the volume of soil that may require remediation. Laboratory analysis of soil samples shall be analyzed for the presence of organochlorine pesticides, in accordance with EPA Test Method SW8081A, and heavy metals in accordance with EPA Test Methods 6010B and 7471A. If soil sampling indicates the presence of pesticides or heavy metals exceeding applicable environmental screening levels, the soil assessment shall identify the volume of contaminated soil to be excavated. If concentrations of contaminants exceed EPA action levels and therefore warrant remediation, contaminated materials shall be remediated either prior to concurrent with construction and an Environmental Site Assessment (ESA) shall be prepared. Cleanup may include excavation, disposal, bio-remediation, or any other treatment of conditions subject to regulatory action. All necessary reports, regulations and permits shall be followed to achieve cleanup of the site. The contaminated materials shall be remediated under the supervision of an environmental consultant licensed to oversee such remediation and under the direction of the lead oversight agency. The remediation program shall also be approved by a regulatory oversight agency, such as the San Luis Obispo County Environmental Health Services, the Regional Water Quality Control Board (RWQCB), or DTSC. All proper waste handling and disposal procedures shall be followed. Upon completion of the remediation, the environmental consultant shall prepare a report summarizing the project, the remediation approach implemented, and the analytical results after completion of the remediation, including all waste disposal or treatment manifests. Plan Requirements and Timing. The contaminated soils assessment and remediation program, if necessary, shall be submitted and approved by the City’s Community Development Department and applicable regulatory oversight agency prior to the issuance of project grading permits. Monitoring. As applicable, the Community Development Department shall ensure implementation of a remediation San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-23 program according to the measures included therein and as approved by a regulatory oversight agency. Residual Impacts. With implementation of Mitigation Measure HAZ-4, impacts related to exposure to residual agricultural chemicals would be reduced to a less than significant level. Threshold 4: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment? Impact HAZ-5 Tetrachloroethene (also called perchloroethylene, or PCE) has been detected in the shallow aquifer in concentrations that exceed the Maximum Contaminant Level (MCL) in active irrigation wells on the eastern portion of the site. As future on-site residents or workers could potentially be exposed to PCE from irrigation water, this would be a Class II, significant but mitigable, impact. As described in Section 4.7.1(b), the Cleath-Harris Hydrogeology Report (Appendix H) identified tetrachloroethene (PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. Figure 4.7-3 shows the wells on the project site and the PCE concentration at four of the on-site wells, including the domestic well in the northwestern portion of the site, in addition to Wells #1, #2, and #5. The highest concentrations of PCE were detected along U.S. 101 (from 8.1 µg/L at Well #2 at the northeastern corner of the Specific Plan Area to 10.4 µg/L at the CJAR irrigation well at the southeastern corner of the Specific Plan Area), with a lower concentration at the domestic well along the northwestern side of Specific Plan Area adjacent to Madonna Road (1.0 µg/L to 1.8 µg/L). The domestic water well has a PCE concentration of 1.0, which is within the U.S. EPA/RWQCB MCL for drinking water of 5 µg/L. The proposed residential and commercial development on the project site would be served by the City’s existing municipal water supply. The existing onsite wells would continue to be used for irrigation of ongoing agricultural uses on the project site, but would not be a source of drinking water. Groundwater produced by the on-site wells would continue to be used for agricultural irrigation. As the water is sprayed through the air onto the irrigated fields, the PCE concentration in the applied water may reduce as the compound volatilizes. However, the reduction in PCE concentration has not been determined. Mitigative Components of the Specific Plan and Impact Conclusion. Consistent with COSE Policy 8.3.2, Open Space Buffers, the San Luis Ranch Specific Plan includes a 72-foot buffer between existing agricultural operations and urban development to reduce and/ or avoid dust and pesticide drift to new residential and commercial land uses on the project site. The proposed 72-foot buffer would similarly limit exposure of future on-site residents to PCE associated with sprayed irrigation water. Nevertheless, because the ongoing agricultural uses within the Specific Plan Area would continue to use on-site wells for agricultural irrigation, future on-site residents or workers could potentially be exposed to PCE at concentrations in San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-24 Figure 4.7-3 excess of the MCL contained in sprayed irrigation water, which would be a potentially significant impact. Mitigation Measures. Mitigation Measures AG-3(a) through AG-3(c), in Section 4.2, Agricultural Resources, would strengthen the agricultural conflict avoidance measures included in the San Luis Ranch Specific Plan, reducing availability of public access to agricultural cultivation areas adjacent to the project site. By reducing public access to agricultural cultivation areas, this measure would reduce potential exposure of on-site residents to PCE contained in sprayed irrigation water. In addition, the following mitigation measures would reduce potential impacts to future on-site workers and residents from PCE contained in sprayed irrigation water. HAZ-5(a) Groundwater Assessment for Contamination at Untested Wells. Any groundwater wells on the project site that would be used for agricultural irrigation shall be sampled by a registered soils engineer or remediation specialist to determine the presence or absence of regulated contaminants prior to issuance of grading permits. This assessment shall target on-site PCE associated with off-site dry cleaning operations. HAZ-5(b) Groundwater Remediation. If groundwater sampling indicates the presence of any contaminant in hazardous quantities, the project applicant (or authorized agent thereof) shall contact the Regional Water Quality Control Board (RWQCB) and Department of Toxic Substances (DTSC) to determine the level of any necessary remediation efforts. These may include: • Installation of charcoal filtration into well-head systems at wells where PCE is identified in hazardous quantities. After installation of charcoal filtration, groundwater wells shall be re-sampled consistent with Mitigation Measure HAZ-5(a). • Groundwater remediation to contaminant concentrations below applicable standards in compliance with applicable laws prior to issuance of grading permits. A copy of the applicable remediation certification from Regional Water Quality Control Board (RWQCB) and/or Department of Toxic Substances (DTSC), or written confirmation that a certification is not required, shall be submitted to the Community Development Department. Residual Impacts. Mitigation Measures AG-3(a) through AG-3(c), HAZ-5(a), and HAZ- 5(b) would ensure that groundwater would not pose the risk of potential PCE exposure to future residents or workers on the project site. Therefore, with incorporation of these mitigation measures, this impact would be less than significant. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-25 Threshold 4: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment? Impact HAZ-6 The project site is located in an area where geologic analysis for NOA is required prior to grading and could potentially result in exposure of people to NOA during grading and construction activities. Therefore, this impact would be Class II, significant but mitigable. NOA can be released from serpentine and ultramafic rocks when the rock is broken or crushed. At the point of release, the asbestos fibers may become airborne, causing air quality and human health hazards. These rocks are commonly used for unpaved gravel roads, landscaping, fill projects, and other improvement projects in some localities. Asbestos can also be released into the atmosphere due to vehicular traffic on unpaved roads during grading. According to the SLOAPCD’s NOA map, the San Luis Ranch Specific Plan Area is located in an area where geologic analysis for NOA is required prior to grading. If the results of the geologic analysis for a project are favorable, the project can apply for a NOA Air Toxics Control Measure (ATCM) exemption. If serpentine or ultramafic rocks are found within the site, an asbestos dust mitigation plan is required in accordance with CCR Title 17, Section 93105 Asbestos Airborne Toxic Control Measure for Construction, Grading, Quarrying, and Surface Mining Operations. Mitigative Components of the Specific Plan and Impact Conclusion. Compliance with existing requirements – including preparation of a geologic analysis and implementation of an asbestos dust mitigation plan, if required – would reduce the potential for NOA to pose a significant hazard during construction proposed under the San Luis Ranch Specific Plan. However, mitigation would be required to ensure compliance and reduce this impact to a less than significant level. Mitigation Measures. If NOA is identified at the site, an asbestos dust mitigation plan in accordance with CCR Title 17, Section 93105 Asbestos Airborne Toxic Control Measure for Construction, Grading, Quarrying, and Surface Mining Operations would be required to be implemented during project construction, as a standard condition of approval. Additionally, the following mitigation would be required to further reduce potential impacts associated with NOA hazards: HAZ-6 Naturally Occurring Asbestos Exposure Avoidance and Minimization: a. Prior to earthwork activities, a site-specific health and safety plan shall be developed per California Occupational Safety and Health Administration (CalOSHA) requirements. The plan shall include appropriate health and safety measures if NOA is detected in soil or bedrock beneath the project site. All construction workers that have the potential to come into contact with contaminated soil/bedrock and groundwater San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-26 shall be knowledgeable of the requirements in the health and safety plan, which includes proper training and personal protective equipment. The health and safety plan shall prescribe appropriate respiratory protection for construction workers. b. Prior to beginning construction, a soil and bedrock analysis for asbestos using polarized light microscopy and transmission electron microscopy by a qualified laboratory shall be conducted. Samples of soil shall be collected from multiple locations across the site, and bedrock samples shall be collected from locations where excavation into bedrock is anticipated. If NOA is detected, appropriate regulations pertaining to excavation, removal, transportation, and disposal of NOA shall be followed. The sampling strategy shall take into account the locations of potential source areas, and the anticipated lateral and vertical distribution of contaminants in soil and/or groundwater. The results of the investigation shall be documented in a report that is signed by a California Professional Geologist. The report shall include recommendations based upon the findings for additional investigation/remediation if contaminants are detected above applicable screening levels (e.g., excavate and dispose, groundwater and/or soil vapor extraction, or in situ bioremediation). c. During earthwork activities, appropriate procedures shall be incorporated in the event that NOA is detected in soil or bedrock beneath the project site. These procedures shall be followed to eliminate or minimize construction worker or general public exposure to potential contaminants in soil. Procedures shall include efforts to control fugitive dust, contain and cover excavation debris piles, appropriate laboratory analysis of soil for waste characterization, and segregation of contaminated soil from uncontaminated soil. The applicable regulations associated with excavation, removal, transportation, and disposal of contaminated soil shall be followed (e.g., tarping of trucks and waste manifesting). These procedures may be subject to San Luis Obispo APCD requirements under the California ARB ATCM for Construction, Grading, Quarrying, and Surface Mining Operations. Plan Requirements and Timing. The measures to avoid and minimize exposure to NOA shall be included on project grading and building plans, and submitted to and approved by the City’s Community Development Department and, as applicable, California Professional Geologist prior to the issuance of project grading and building permits. Monitoring. As applicable, the Community Development Department shall ensure implementation of avoidance and San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-27 minimization measures included therein and as approved by a California Professional Geologist. Residual Impacts. With implementation of Mitigation Measure HAZ-6, impacts related to exposure to NOA would be reduced to a less than significant level. Threshold 4: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment? Impact HAZ-7 Asbestos Containing Material (ACM) and Lead Based Paint (LBP) may be present in existing on-site structures. Demolition of these structures would be required to comply with applicable State and local policies and regulations for the control and remediation of hazardous materials to prevent human exposure. Therefore, this impact would be Class III, less than significant. The project would involve demolition of some or all of the structures in the existing Dalidio Farm Complex. The Dalidio Farm Complex includes buildings that, due to their age, may contain asbestos and/or LBP. As a result, demolition of these structures could result in health hazards to workers if not remediated prior to construction activities. Mitigative Components of the Specific Plan and Impact Conclusion. Demolition activities associated with the San Luis Ranch Specific Plan would be required to comply with SLOAPCD Rule 412 (Airborne Toxic Control Measures), which includes Section 93106 of the California Code of Regulations (Asbestos Airborne Toxic Control Measure for Surfacing Applications). Compliance with Rule 412 would ensure that if a building includes asbestos-containing materials, those materials would be identified and remediated prior to demolition. The applicant would also be required to comply with California Occupational Safety and Health Administration (CalOSHA) regulations regarding lead-based materials and the California Code of Regulations §1532.1, which requires testing, monitoring, containment, and disposal of lead- based materials such that exposure levels do not exceed CalOSHA standards. Compliance with these regulations would ensure that impacts associated with exposure of construction workers to ACMs or lead during demolition or disposal of such materials would be less than significant. Mitigation Measures. No mitigation would be required. Residual Impacts. Impacts would be less than significant without mitigation. Threshold 5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? Impact HAZ-8 The project site is located within a San Luis Obispo County Regional Airport area of influence. The project would be San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-28 consistent with the CALUPH Airport Safety Zones, which represent the extent of Airport-related safety hazard zones for people residing or working in these areas. Therefore, this impact would be Class III, less than significant. Airport safety is primarily related to the potential for accidents related to aircraft operations such as emergency landings, or in rare cases crashes, as well as ensuring that land use development is carried out in manner that minimizes or avoids risks associated with such aircraft incidents or accidents. Minimizing or avoiding risks to such land uses (e.g., residential neighborhoods) involves designating areas around the ends of runways that must be free of objects or sensitive land uses, limiting the height of new structures in the surrounding airspace, and understanding historical accident patterns. The San Luis Ranch Specific Plan Area is located in proximity to the end of Runaway 11-29. The risk of an aircraft accident increases with proximity to the runway and its approach path, and airport land use planning documents generally discourage development in the zones closest to the ends of runways to prevent placing people at risk of aircraft-related hazards. The project site is located approximately 1.5 miles away from Runway 11-29 and is within the extended centerline path of the runway. The project site is also within the general approach area of Runway 11-29. The project site is overlapped by ALUP Safety Areas S-1b and S-2 and CALUPH Airport Safety Zones 4 and 6, which indicate the airport’s outer approach/departure zone and traffic pattern zone. Figure 4.7- 1 shows the ALUP Safety Areas on the project site and Figure 4.7-2 shows the CALUPH Airport Safety Zones on the site. As described in Section 4.7.1(c), one aircraft accident occurred within the project site in ALUP Safety Area S-2 in 1990. Another accident occurred approximately adjacent to the northeastern corner of the project site along U.S. 101 in CALUPH Airport Safety Zone 4 and ALUP Safety Area S-1b in 1994. However, accidents associated with airport operations have been very infrequent, even in areas closer to the airport. In addition, the historical occurrence of aircraft accidents within the San Luis Obispo County Regional Airport area of influence indicates that accidents are no more likely on the project site than anywhere else within these ALUP Safety Areas and CALUPH Airport Safety Zones. Project development would result in construction of up to 580 residential units, 150,000 square feet of commercial development, 100,000 square feet of office development, and a 200-room hotel. Accordingly, the project would add an estimated 1,293 new residents (546 new single family and multi-family dwelling units x 2.29 people/unit and 34 new affordable units x 1.25 people/unit)2 in the vicinity of the approaches to Runway 11-29, and within CALUPH Airport Safety Zones and ALUP Safety Areas. As shown in the ALUP, and in Figure 4.7-1, a majority of the project site (approximately 119 acres) is within ALUP Safety Area S-1b. Safety Area S-1b identifies an outer approach/departure zone for the airport and allows a maximum non- residential development intensity of 40 persons per acre and a maximum residential development density of 0.2 units per acre. Approximately 16 acres in the northeastern portion of the project site is located in Safety Area S-2 which allows six to twelve dwelling units per acre with an approved Airport Compatible Open Space (ACOS) plan. Project residential and commercial development would be located within ALUP Safety Areas S-1b and S-2, creating an 2 Population growth rate from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-29 inconsistency with the adopted ALUP due to safety areas within the due an exceedance of allowable densities under the ALUP. Potential inconsistencies between the ALUP Safety Area standards and CALUPH Airport Safety Zone standards are discussed in Section 4.9, Land Use/Policy Consistency (refer to Table 4.9-1 and Impact LU-4). In comparison, as shown in Figure 4.7-1, the southeastern portion of the project site along U.S. 101 is located within CALUPH Airport Safety Zones 4 and 6. Airport Safety Zone 4 allows for non-residential development intensity of up to 200 persons per acre and allows for residential infill at up to the average of surrounding residential areas. Airport Safety Zone 6 has no limit for non-residential development intensity, but suggests avoidance of large stadiums and similar uses. Airport Safety Zone 6 also has no limit for residential development intensity, but suggests consideration of noise and overflight during such development. No residential development is proposed within the portion of the project site located in Airport Safety Zone 4 and no residential or commercial development is proposed for the portion of the site in Airport Safety Zone 6. The remainder of the project site is not located within an Airport Safety Zone, as defined by the CALUPH (refer to Figure 4.7-1). As such, the level of proposed development on the project site would be consistent with the restrictions specified in the CALUPH for the Airport Safety Zones and consistent with additional statewide safety standards for new development as described in Section 4.7.1(e). As described in Section 4.7.1(c), the 2014 Airport Land Use Compatibility Report (Appendix I) analyzed potential airport hazards and set forth recommendations to update safety and hazards planning around the Airport based on guidance from the CALUPH and other sources. The CALUPH describes the characteristics of “ideal” safety zones such as “easily definable geometric shapes,” a limited number of five or six zones, a distinct progression in the degree of safety risk farther from the runway, providing that “each zone should be as compact as possible.” The Land Use Element and associated Airport Safety Zones implement these suggested standards by identifying six revised safety zones that consist of clearly justified and compact geometric shapes that represent distinct progression in the degree of safety risk farther from the runway. These Airport Safety Zones are supported by Land Use Element and Circulation Element policies, programs, and development standards consistent with those guidelines. While the project would conflict with the allowable densities in the ALUP Safety Areas, the City Council found during its review of airport compatibility for the Land Use and Circulation Element update that the 2014 Airport Land Use Compatibility Report and revised LUCE Update EIR provided substantial evidence in the record that the City’s Land Use Element accurately reflects Airport-related safety hazard zones as set forth in the CALUPH and supporting federal guidance, and that the maps provided in the ALUP did not accurately reflect the actual extent of Airport-related safety zones (Council Agenda Report, City of San Luis Obispo 2014d). For the Land Use and Circulation Element Update, the City Council elected to issue an overrule of the ALUP, including planned development in the San Luis Ranch Specific Plan Area, as long as such development was found to be consistent with the Land Use Element Airport policies (refer to Section 4.9, Land Use/Policy Consistency). Mitigative Components of the Specific Plan and Impact Conclusion. Section 2.6 of the San Luis Ranch Specific Plan (Appendix B) includes various Airport Compatibility Performance San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-30 Standards intended to maintain safety of the airspace of the airport and avoid potential airport- related hazards. The following standards, described in Section 2.6 of the San Luis Ranch Specific Plan, would be implemented throughout the Specific Plan Area to avoid airport hazards: Risk of Injury, Airspace Protection; Operations Interference; Bird Attractants; Indoor Noise; Avigation Easements, Real Estate Disclosure; and Non-reflective Building Materials. In addition, because the project would be consistent with the CALUPH Airport Safety Zones, which the City has found represents the actual extent of Airport-related safety hazard zones, physical Airport-related safety hazards would be minimized consistent with the State Aeronautics Act upon project implementation. While the project would still be subject to review by the ALUC for consistency with the ALUP, potential policy consistency issues are discussed in Section 4.9, Land Use/Policy Consistency. Based on the analysis provided above and substantial evidence in the record provided by the LUCE Update EIR and 2014 Airport Land Use Compatibility Report, airport safety impacts to San Luis Ranch Specific Plan Area residents and commercial employees or patrons would be less than significant. Mitigation Measures. No mitigation would be required. Residual Impacts. Impacts would be less than significant without mitigation. c. Cumulative Impacts. Planned buildout of the City of San Luis Obispo under the General Plan, including buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans, would cumulatively increase the potential for exposure of people to hazards and hazardous materials, including soil contamination, pesticides, LBP, asbestos, groundwater contamination of PCE, and upset risks along major transportation routes. The project would incrementally contribute to this cumulative effect. However, as discussed throughout this section, such risks of exposure are reduced through adherence to existing federal, State, and local regulations. U.S. EPA and U.S. DOT laws regulate the safe interstate transportation of hazardous materials and waste. Impacts associated with hazards and hazardous materials are generally site-specific. Accordingly, as required under applicable laws and regulations, potential impacts associated with cumulative developments would be addressed on a case-by-case basis and appropriate mitigation would be designed to mitigate impacts resulting from individual projects, depending upon the type and severity of hazards present. Enforcement of federal, State, and local laws and regulations would ensure that hazards to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment would remain less than significant. In addition, as described in the LUCE Update EIR, adherence to applicable General Plan policies and applicable State and federal regulatory requirements would reduce any cumulative hazards and hazardous materials impacts resulting from buildout of the City under the General Plan, including buildout of the San Luis Ranch Specific Plan, to a less than significant level. Therefore, cumulative impacts related to hazards and hazardous materials would be less than significant. Increased development within the vicinity of the San Luis Obispo County Regional Airport could expose residents, employees, and visitors to potential aircraft-related hazards. Approved, planned, and pending projects in the City, which involve residential and commercial development, may also be within ALUP Safety Areas and Caltrans Airport Safety Zones, San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-31 thereby potentially exposing persons to risk of airport safety hazards. The severity of potential hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites and would require evaluation on a project-by-project basis. As such, cumulative impacts would be based on each project’s contribution to cumulative aircraft related hazards in the City. The uses proposed for the San Luis Ranch Project would be consistent with the CALUPH Airport Safety Zones, which represent the extent of Airport-related safety hazard zones for people residing or working in these areas. As such, the project would not result in a substantial contribution to cumulative aircraft related hazards in the City. Any other development in the City, if approved pursuant to the City’s General Plan Land Use Element policies, would be consistent with the CALUPH Airport Safety Zones and, therefore, would not result in a substantial contribution to cumulative aircraft related hazards in the City. San Luis Ranch Project EIR Section 4.7 Hazards and Hazardous Materials City of San Luis Obispo 4.7-32 This page intentionally left blank. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-1 4.8 HYDROLOGY AND WATER QUALITY 4.8.1 Setting a. Regional Hydrology and Drainage. The project site is located within the Froom Creek sub watershed, within the San Luis Obispo Creek watershed of the Estero Bay Hydrologic Unit. The Estero Bay Hydrologic Unit stretches roughly 80 miles between the Monterey County line to the north and the Santa Maria River to the south. Within the Estero Bay Hydrologic Unit, the San Luis Obispo Creek watershed drains approximately 84 square miles (refer to Figure 4.8-1). The San Luis Obispo Creek watershed generally drains to the south‐southwest via San Luis Obispo Creek where it meets the Pacific Ocean at Avila Beach. San Luis Obispo Creek originates in the Cuesta Grade area north of San Luis Obispo at an elevation of 2,200 feet above mean sea level, in the western slopes of the Santa Lucia Range. San Luis Obispo Creek flows south through the City of San Luis Obispo easterly adjacent to U.S. Highway 101 (U.S. 101) until it reaches the southern extent of the Irish Hills where it veers west to the ocean. According to the Safety Element of the City of San Luis Obispo General Plan, average seasonal precipitation in the City is 22 inches and average seasonal precipitation throughout San Luis Obispo County varies from 8.5 inches (in California Valley) to 25.6 inches (in San Simeon). Flooding within the San Luis Obispo Creek system is generally caused by intense Pacific storm systems that occur during the months of December, January, February, and March. The great topographic variability of the watershed causes these systems to release large amounts of precipitation, especially along the higher ridgelines. The watershed is dominated by agricultural land uses including ranches and open space and includes the urban core of the City of San Luis Obispo. Other land uses include the California Polytechnic State University, rural residential uses, San Luis Obispo airport, and two wastewater treatment plants. b. Project Site Hydrology and Drainage. The project site is currently in agricultural use. The site contains permeable agricultural land, which allows for the recharge of water to the subsurface. The site is characterized by two water bodies: Prefumo Creek, which runs along the southwest border of the site, and the Cerro San Luis Drainage Channel, which bisects the site and runs north along the project boundary just south of the U.S. Post Office located at the intersection of Madonna Road and Dalidio Road. The general flow of surface water at the site is from the northeast to the southwest along the Cerro San Luis Drainage Channel and along the west side of U.S. 101, across the agricultural fields in a general widening surface flow path, finally draining into Prefumo Creek. Existing on-site drainage is shown in Figure 4.8-2. c. Project Site Flooding. Approximately 75 percent of the Specific Plan Area is designated as Special Flood Hazard Area because it is situated in a designated 100-year floodplain as identified by the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM). A base flood, also referred to as a 100-year flood, is defined as a flood event with a one percent probability of being equaled or exceeded during any given year. Warden Lake Laguna Lake See Canyon Prefumo Canyon Stenner Lake Pecho Creek Reservoir Canyon San Luis Obispo CreekPrefumo Cre e k San Luis Obispo Creek Watershed Figure 4.8-1 City of San Luis Obispo Section 4.8 Hydrology and Water QualitySan Luis Ranch Project EIR Imagery provided by ESRI and its licensors © 2016.Additional data provided by SLO Watershed Project, 2016. Project Boundary San Luis Obispo CreekWatershed Sub Watersheds ±0 21 Miles 4.8-2 £¤101 Madonna Rd L os O s o s V alle y R d S Higuera St Prad o R d Seaward St Cayucos Dr c c c cc cc c cccExisting MajorSurface FlowPath Existing MajorSurface FlowPathExisting MajorSurface FlowPathExisting Cerro San Luis BoxCulvert Existing CerroSan Luis DrainageChannel Existing PromenadeShopping Mall c c c Existing Drainage and Floodplain Conditions Figure 4.8-2 City of San Luis Obispo Section 4.8 Hydrology and Water QualitySan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. Additional dataprovided by City of San Luis Obsipo, 2016; FEMA, 2016, USGS 2016. Project Boundary FEMA 100- Year Flood Plain Project Land Use Agriculture Commercial Parks, Creek, Basins,Internal Open SpaceResidential 3-StoryAttached and Detached Residential 30' Wide Lots Residential 40' Wide Lots ±0 800400 Feet SanLuisObispoCreekPrefumoCreek cFlow Direction 4.8-3 San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-4 Regulatory fFloodways are defined as stream channels plus adjacent floodplainsland areas that must be kept free of encroachment as much as possible so that in order to discharge the base 100-year floods can occur without substantial increases to flood elevations. The north- northeastern portion of the site is not within the 100-year floodplain, and therefore, is not within a FEMA-designated floodway. The remaindermajority of the project site, with the exception of the north-northwestern portion of the site and a small portion of the site along the eastern boundary, is located within the FEMA-designated 100-year floodplain., and therefore, No portion of the site is within thea FEMA-designated regulatory floodway. The extent of the 100- year floodplain is shown on Figure 4.8-2. d. Water Quality. For undeveloped areas like San Luis Ranch, surface waters entering the watercourse from undeveloped areas usually travel over vegetative cover, resulting in little erosion or sedimentation. Urbanized areas typically contain pollutants on the ground surface that are harmful to water quality and natural ecosystems. These include heavy metals, hydrocarbons, detergents, fertilizers, and pesticides that originate from vehicle use and commercial and residential land use activities. For the most part, these pollutants are associated with sediments that collect on roadways and are flushed into the creek systems either in dry weather flows, during construction, or by rainfall. Construction activities can also create erosion and cause sediment to be transported off-site, as surface water runs through the construction site. Therefore, water quality depends primarily on the hydrologic characteristics of the drainage basin, the makeup of the soils in the watershed, and source of pollution in the watershed. The quality of stormwater varies in the region depending on climactic and land use conditions. Urban and industrial runoff generally contains more pollutants than rural runoff. The protection of water quality within San Luis Obispo County is under the jurisdiction of the Central Coast Regional Water Quality Control Board (CCRWQCB). The CCRWQCB establishes requirements that prescribe the discharge limits and establish water quality objectives through the Water Quality Control Plan for the Central Coast Basin (Basin Plan (CCRWQCB March 2016). Water quality characteristics typically measured include pH, total dissolved solids, levels of herbicides and pesticides, sediment levels, vehicle-related oils, and chemicals such as chloride, sulfate, and nitrate. Water quality objectives are established based on the designated beneficial uses for a particular surface water or groundwater basin. Surface water and groundwater quality and their beneficial uses are discussed herein. Surface Water. The project site is currently in agricultural use including irrigated row crops. Irrigation and rainwater percolate through the soil or runoff discharge into Prefumo Creek. The runoff from the site is not currently treated and may carry contaminants such as pesticides or fertilizers, contributing to non-point source runoff including sediment, nutrients, and trace amounts of pesticides and herbicides. Runoff from the project site enters Prefumo Creek, which drains into San Luis Obispo Creek and then to the Pacific Ocean. The current water quality statuses of Prefumo Creek and San Luis Obispo Creek are discussed below. Impaired Water Bodies. Section 303(d) of the federal Clean Water Act requires states to identify waters that do not meet water quality standards after applying effluent limits for point sources (other than publicly owned treatment works) that are based on the best practicable control technology currently available. States are then required to prioritize waters/watersheds San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-5 for total maximum daily loads (TMDL) development. A TMDL is a written plan that describes how an impaired water body will meet water quality standards. It contains the following: • A measurable feature to describe attainment of the water quality standards; • A description of required actions to remove the impairment; and • An allocation of responsibility among dischargers to act in the form of actions or water quality conditions for which each discharger is responsible. The Clean Water Act requires that states develop rankings for TMDLs. California ranks TMDLs as high, medium, or low priority, based on a number of factors. These factors include the severity of impairments and the importance of the specific beneficial uses identified for that water body. Regional Boards develop schedules that set the order for TMDL completion. States are to compile this information in a list and submit the list to the US Environmental Protection Agency for review and approval. This list is known as the 303(d) list of impaired waters. The State Water Resources Control Board (SWRCB) and the Regional Water Quality Control Boards (RWQCBs) monitor and assess water quality to prepare the Section 303(d) list and to develop TMDLs. The site’s receiving waters are Prefumo Creek, which drains into San Luis Obispo Creek and then to the Pacific Ocean at Avila Beach. Both Prefumo Creek and San Luis Obispo Creek (below Osos Street) are listed as Category 5 on the 2010 California 303(d) List of water quality limited segments. The Category 5 listing describes a water segment where standards are not met and a TMDL is required, but not yet completed, for at least one of the pollutants being listed for this segment. Table 4.8-1 identifies the constituent pollutants for which Prefumo Creek and San Luis Obispo Creek (below Los Osos Street) are included on the Section 303(d) list. Table 4.8-1 Prefumo and San Luis Obispo Creek (below Osos Street) TMDLs Waterbody Pollutant Sources Expected TMDL Completion Prefumo Creek Fecal Coliform Agriculture, Urban Runoff, Unknown nonpoint source 2021 Low Dissolved Oxygen Agriculture, Urban Runoff, Unknown nonpoint source 2021 Nitrate Agriculture, Urban Runoff, Unknown nonpoint source 2021 Turbidity Agriculture, Urban Runoff, Unknown nonpoint source 2021 San Luis Obispo Creek (below Osos Street) Chloride Agriculture, Grazing-Related Sources, Municipal Point Sources, Other Urban Runoff 2021 Chlorpyrifos Agriculture, Grazing-Related Sources, Other Urban Runoff 2021 Nitrate as Nitrate (NO3) Agriculture, Grazing Related Sources, Major Municipal Point Source-dray and/or wet weather discharge, Natural Sources, Upstream Impoundment, Urban Runoff/Storm Sewers 2007 (TMDL completed) Nutrients Agriculture, Municipal Point Sources 2007 (TMDL completed) Pathogens Agriculture, Grazing Related Sources, Major Municipal Point Source-dray and/or wet weather discharge, 2004 San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-6 Table 4.8-1 Prefumo and San Luis Obispo Creek (below Osos Street) TMDLs Waterbody Pollutant Sources Expected TMDL Completion Natural Sources, Transient encampments, Urban Runoff/Storm Sewers Sodium Agriculture, Grazing Related Sources, Major Municipal Point Sources, Other Urban Runoff 2021 Source: SWRCB, 2010 Beneficial Uses. There are 20 categories of “beneficial uses” that are outlined in the Basin Plan (CCRWQCB March 2016). Each body of water in the State has a set of beneficial uses that may or may not include all 20 categories. For example, a reservoir may provide beneficial use as a municipal water supply, agricultural supply, wildlife habitat, and groundwater recharge at the same time. Different beneficial uses require different water quality control. Therefore, each beneficial use has a set of water quality objectives designed to protect that use. Table 4.8-2 contains a list of beneficial uses of Prefumo Creek. Table 4.8-2 Beneficial Uses for Prefumo Creek Abbreviatio n Beneficial Use Definition MUN Municipal & Domestic Water Supply Community, military, or individual water supply systems including, but not limited to, drinking water supply. AGR Agricultural Supply Farming or ranching including, but not limited to, irrigation, stock watering, or support of vegetation for grazing. GWR Ground Water Recharge Natural or artificial recharge of ground water for purpose of future extraction or maintenance of water quality. REC1 Contact Water Recreation Recreational activities involving body contact with water, where ingestion of water is reasonably possible. Example: swimming, fishing, and wading. REC2 Non-Contact Water Recreation Recreational activities close to water, but not normally involving body contact with water. Example: picnicking, hiking, and boating. WILD Wildlife Habitat Terrestrial ecosystems including, but not limited to, preservation and enhancement of terrestrial habitats, vegetation, and wildlife. COLD Cold Freshwater Habitat Cold water ecosystems including, but not limited to, preservation or enhancement of aquatic habitats, vegetation, fish or wildlife. SPWN Spawning, Reproduction, and/or Early Development Support for high quality aquatic habitats suitable for reproduction and early development of fish. MIGR Migration of Aquatic Organisms Support for habitats necessary for migration or other temporary activities by aquatic organisms, such as anadromous fish. RARE Rare, Threatened, or Endangered Species Habitats necessary for the survival of plant and animal species identified under state or federal law as rare, threatened, or endangered. FRSH Freshwater Replenishment Natural or artificial maintenance of surface water quantity or quality (e.g. salinity). San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-7 Table 4.8-2 Beneficial Uses for Prefumo Creek Abbreviatio n Beneficial Use Definition COMM Commercial & Sport Fishing Commercial or recreational collection of fish or other organisms including, but not limited to, uses of the organism for human consumption or bait. Source: CCRWQCB 2016. Water Quality Objectives. Water quality objectives are the limits or levels of water quality constituents or the characteristics of a water body that are established for the reasonable protection of beneficial uses of water. Water quality objectives are numeric limits and narrative objectives designed to ensure that bodies of water in the state can support their designated beneficial uses. At concentrations equal to or greater than the numeric objectives, constituents (or pollutants) are considered to have impaired the beneficial uses of the state’s water. In some cases, objectives are narrative (qualitative), rather than numerical. The CCRWQCB Basin Plan provides specific water quality objectives for potential releases of pollutants into County surface waters. Groundwater. The San Luis Obispo Valley Groundwater Basin is situated in the San Luis and Edna Valleys in central to southwest San Luis Obispo County. A rise in bedrock south of the San Luis Obispo Airport has created the two separate subsurface drainage systems. The basin is bounded on the northeast by the Santa Lucia Range, on the southwest by the San Luis Range, and on all other sides by contact with impermeable Miocene and Franciscan Group rocks and the Los Osos and Edna faults. The northwestern part of the valley is drained by San Luis Obispo, Prefumo, and Stenner Creeks. The southeastern part of the valley is drained by tributaries of Pismo and Davenport Creeks. Laguna Lake lies in the northwestern part of the valley within the City of San Luis Obispo. The basin overlies an area of approximately 12,700 acres (19.9 square miles) and is part of the Central Coast Watershed. The Edna Valley Sub-basin (approximately 4,700 acres) is entirely within unincorporated San Luis Obispo County, while the San Luis Valley Sub-basin (approximately 8,000 acres) includes both unincorporated County and the City of San Luis Obispo. The San Luis Obispo Basin and its contributing watershed receive annual precipitation ranging between 19 and 23 inches. Groundwater is relatively shallow in this 50- to 100-feet thick unconfined aquifer. Groundwater in the basin is recharged primarily by infiltration of precipitation, applied irrigation water, and streamflow. A sizeable portion of the San Luis Obispo Valley includes urban developments with impervious surfaces that inhibit deeper percolation. Municipal water supply for the City San Luis Obispo comes from both water imported from neighboring watersheds and its water reclamation facility. Treated wastewater generated by the City is discharged into San Luis Obispo Creek, and is used to irrigate various sites, including parks, schools, sports fields, and commercial centers. The City continues to explore other approved uses and potential users of recycled water. The City of San Luis Obispo has historically drawn water from this basin, most recently during the drought of 1986 through 1990. In 2011, the City relied on groundwater to supply approximately two percent of the City’s annual water demand. As discussed in more detail in Section 4.13, Water Resources, the City discontinued use of the groundwater as part of its drinking water system in April 2015 due to San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-8 new regulations requiring additional treatment of the wells prior to use. Previously used wells remain in operable standby condition should the use of groundwater be required in the future to meet City needs. The San Luis Obispo Groundwater Basin remains a viable alternative for future groundwater pumping to supplement the City’s existing water resources. In November 2014, Cleath-Harris Geologists, Inc. (Cleath-Harris) prepared a Hydrogeologic Description and PCE Characterization for Dalidio Laguna Ranch, San Luis Obispo County, California report (Hydrogeology Report; refer to Appendix H), which characterized tetrachloroethene (also called perchloroethylene, or PCE) in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. The project site is located adjacent to commercial uses to the northeast and residential uses to the southwest. Dry cleaning facilities have been recorded present to the north of the site as early as the 1930s. According to the Hydrogeology Report, the identified PCE groundwater contamination is attributed to spills at these hydrologically upgradient dry cleaning facilities. Shallow groundwater at the site generally flows towards the south- southwest, and wells on the project site have exhibited PCE groundwater contamination above the United States Environmental Protection Agency (U.S. EPA) Maximum Contaminant Level (MCL) for drinking water of 5 micrograms per liter (µg/L). Cleath-Harris Analyzed analyzed PCE concentrations in four on-site wells and two off-site City wells to the south and the east of the site. The highest concentrations of PCE were detected at wells along the eastern side of the project site. PCE contamination was also identified within the shallow aquifer groundwater (refer to Appendix H for detailed PCE characterization results). There are two aquifers underlying portions of the project site. The shallow aquifer underlies most of the site, except the westernmost area, and the deep aquifer underlies the southern portion of the site. Groundwater within the deep aquifer could not be isolated in existing wells on the project site. Therefore, the PCE concentration in the deep aquifer is unknown. The domestic water well has a PCE concentration of 1.0 µg/L, which is within the U.S. EPA MCL for drinking water of 5 µg/L. The irrigation groundwater well has a PCE concentration of 9.5 µg/L, which exceeds the U.S. EPA MCL. e. Regulatory Setting. Federal, State, and local agencies that regulate surface water and groundwater resources and their associated water quality are regulated in California include, but are not limited to the following: • U.S. Army Corps of Engineers • San Luis Obispo County Flood Control and Water Conservation District • California Department of Water Resources • State Water Resources Control Board • Central Coast Regional Water Quality Control Board • California Department of Fish and Wildlife • City of San Luis Obispo The above agencies are responsible for the protection of watersheds, floodplains, and water quality. These agencies ensure that the hydrologic characteristics of surface water and groundwater are considered, so that the existing identified beneficial uses are not impaired. Similarly, water quality regulations are designed to limit the discharged of pollutants into the environment, maintain surface water and groundwater quality, protect fish and wildlife and their habitats, and protect beneficial uses. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-9 Federal. Federal Clean Water Act (CWA), 33 U.S.C. 1251 et seq. (1977). This law is the primary federal law regulating water pollution. Relevant sections include: • Section 208, requiring that states develop programs to identify and control non-point sources of pollution, including runoff. • Section 303, requiring states to establish and enforce water quality standards to protect and enhance beneficial uses of water for such purposes as recreation and fisheries. • Section 304(a)(1), requiring the administrator of the U.S. Environmental Protection Agency (USEPA) to develop and publish water quality criteria that reflect the latest scientific knowledge regarding the effects of pollutants in any body of water. • Section 313(a), requiring that federal agencies observe state and local water quality regulations. • Section 405 of the Water Quality Act of 1987 added to Section 402(p) to the CWA. Pursuant to Section 402(p)(4) of the CWA, the EPA is required to promulgate regulations for NPDES permit applications for stormwater discharges. • Safe Drinking Water Act, 40 U.S.C. 100 et seq. This act sets limits on concentrations of pollutants in drinking water sources. Federal Emergency Management Agency (FEMA). FEMA is the federal agency that oversees floodplains and manages the National Flood Insurance Program (NFIP). FEMA also prepares the FIRMs for communities participating in the NFIP. The FIRMs indicate the regulatory floodplain to assist communities with land use and floodplain management decisions, so that the requirements of the NFIP are met in the event of damaging floods. However, FEMA studies and maps are not necessarily an accurate, up-to-date reflection of all physical flood risk or hazards. The City participates in the Community Rating System (CRS) of the NFIP. As such, the City is required to document and report annually on creditable activities related to the program. The City CRS Class of 7 provides for reduced insurance premiums for commercial and residential developments. The San Luis Obispo County Flood Control and Irrigation District provides for control, disposition, and distribution of flood and stormwaters of the District and of streams flowing into the district and for protection of the watersheds and watercourses in the district from such waters. Section 22.05.040 of the San Luis Obispo County Land Use Ordinance establishes the County’s standards for the control of drainage to minimize the harmful effects of stormwater runoff. However, incorporated cities within the County have their own responsibilities with regard to drainage and flood control. County restrictions on development in floodplains require that incorporated cities, at a minimum, enforce the current federal floodplain management regulations as defined in the FEMA NFIP. U.S. Army Corps of Engineers. The Army Corps of Engineers (USACE) is the federal agency that studies, constructs, and operates regional-scale flood protection systems in partnership with state and local agencies. Specific agreements between the USACE and its state and local partners on particular projects are used to define shared financial responsibilities and regulations that affect the local partners. Any work that is within USACE jurisdiction, which includes San Luis Obispo Creek and its tributaries, requires permitting through USACE. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-10 State. California Department of Fish and Wildlife (CDFW). Any work that is within CDFW jurisdiction requires permitting through CDFW. Section 1602 of the Fish and Game Code requires an entity notify the CDFW prior to commencing any activity that may substantially divert or obstruct the flow of any channel or bank. California Department of Water Resources (DWR). DWR is the state agency that studies, constructs, and operates regional-scale flood protection systems, in partnership with federal and local agencies. DWR also provides technical, financial, and emergency response assistances to local agencies related to flooding. FloodSAFE California is a strategic multifaceted program initiated by DWR in 2006. FloodSAFE is guiding the development of regional flood management plans, which encourage regional cooperation in identifying and addressing flood hazards. Regional flood plans include flood hazard identification, risk analyses, review of existing measures, and identification of potential projects and funding strategies. The plans emphasize multiple objectives, system resiliency, and compatibility with state goals and Integrated Regional Water Management Plans (IRWMP). DWR has the lead role to implement FloodSAFE, and works closely with State, federal, tribal, and local partners to help improve integrated flood management systems State-wide. DWR’s role is to advise and provide assistance as a resource to local jurisdictions as they pursue compliance. Table 4.8-3 provides the State-mandated requirements for local agency (including cities and counties) flood planning. Table 4.8-3 Flood Risk Management Legislation and Local Responsibilities Planning Document Tool State-Wide Requirements General Plan Land Use Element Identify and annually review areas subject to flooding (identified by FEMA or DWR); consider the location of natural resources used for groundwater recharge and stormwater management. General Plan Conservation Element Identify areas that may accommodate floodwater for groundwater recharge and stormwater management; in coordination with agencies, develop a water resources section. General Plan Safety Element Identify and revise, per new flood hazard information; establish goals, policies (objectives), and mitigation measures to protect from the risk of flooding; allows information in floodplain management ordinances to be used. General Plan Housing Element and Regional Housing Needs Assessment Consider and may exclude land that is not adequately protected, to avoid the risk of flooding. Local Hazard Mitigation Plan May adopt safety element in conjunction with local hazard mitigation plan (financial benefits). Source: DWR, 2010. Porter-Cologne Water Quality Control Act (1969). The Porter-Cologne Water Quality Control Act act mandates that waters of the State shall be protected such that activities that may affect waters of the State shall be regulated to attain the highest quality. The SWRCB is given authority to enforce Porter-Cologne Water Control Act as well as Section 401 of the Clean Water Act and has adopted a statewide general permit that applies to almost all stormwater San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-11 discharges. This general permit, which is implemented and enforced in the San Luis Obispo area, is implemented by the local Central Coast RWQCB and requires all owners of land where construction activity occurs to: • Eliminate or reduce non-stormwater discharges to stormwater systems and other waters of the U.S.; • Develop and implement a Stormwater Pollution Control Plan emphasizing stormwater BMPs; and • Perform inspections of stormwater pollution prevention measures to assess their effectiveness. In addition, SWRCB regulations mandate a “non-degradation policy” for state waters, especially those of high quality. Under the authority of the SWRCB, the protection of water quality in San Luis Obispo Creek and its tributaries is under the jurisdiction of the Central Coast RWQCB. The RWQCB establishes requirements prescribing the quality of point sources of discharge and establishes water quality objectives. These objectives are established based on the designated beneficial uses for a particular surface water or groundwater. Beneficial uses of San Luis Obispo Creek include municipal, domestic, and agricultural water supply, groundwater recharge, water contact and non-water contact recreation, wildlife habitat, warm and cold water habitats, migration of aquatic organisms, spawning, freshwater replenishment, sport fishing, and rare, threatened, and endangered species habitat. Within city limits of San Luis Obispo, the jurisdiction for the water quality of the San Luis Obispo Creek watershed overlaps with the city public works and utilities agencies. In accordance with the California Water Code, the CCRWQCB has developed a Basin Plan (March 2016) designed to preserve and enhance water quality and protect the beneficial uses of all regional waters. Water quality objectives for the Central Coastal Basin satisfy State and federal requirements established to protect waters for beneficial uses, and are consistent with existing statewide plans and policies. Regional Central Coast Regional Water Quality Control Board. Since 1990, regulations have increasingly emphasized the control of water pollution from non-point sources, which include stormwater systems and runoff from point-source construction sites and industrial areas. In California, the SWRCB issues a statewide General Permit to regulate runoff from construction sites involving grading and earth moving in areas over one acre. The Construction General Permit also applies to projects of less than one acre that are part of a larger plan of common development. The SWRCB has been designated by the U.S. EPA to enforce requirements of the federal Clean Water Act, as part of the National Pollutant Discharge Elimination System (NPDES). The State Order 1 requires covered construction projects to use the “best available technology economically achievable,” and the “best conventional pollution control technology.” Each construction project subject to the Construction General Permit is required to have Stormwater Pollution Prevention Plan (SWPPP) prepared. A SWPPP identifies likely sources of sediment and pollution and incorporates measures to minimize sediment and pollution in 1 Construction General Permit: Water Quality Order #2009-0009-DWQ, as amended by Water Quality Orders #2010- 0014-DWQ and #2012-006-DWQ. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-12 runoff water. These objectives are established based on the designated beneficial uses for the receiving water. Under Phase II of the NPDES, the County was required to seek coverage under SWRCB’s General Permit for Municipal Separate Storm Sewer Systems (MS4s). The City of San Luis Obispo NPDES Phase II Program submitted their stormwater management plan to the CCRWQCB in July 2013 under the NPDES Phase II program. The City requires strict accordance with the program including new treatment and retention requirements for developments. The CCRWQB’s Resolution R3-2013-0032, which outlines runoff reduction and treatment requirements, are also applicable to the project site. The Resolution R3-2013-0032 requires Central Coast municipalities to implement Post Construction Requirements to comply with the statewide Phase II Municipal General Permit. The following applicable Post-Construction Requirements are summarized below: 1. Runoff Reduction: Requirements include limiting disturbance to creeks and drainage features, minimize compaction of permeable soils, limit clearing and grading of vegetation, and minimizing impermeable surfaces. 2. Water Quality Treatment: Requirements include treating urban runoff with onsite source control systems such as Low Impact Development (LID) treatment systems, Bio filtration Treatment Systems, or other BMPs to reduce pollution before runoff enters the MS4. 3. Runoff Retention: Prevent offsite discharge from events up to the 95th percentile 24-hour rainfall event (as determined from local rainfall data). 4. Peak Management: Post development peak flows, discharged from the site, shall not exceed peak flows for the 10-year storm event (note: the City’s Drainage Design Manual [DDM] requires that post-development peak flows from a project site do not exceed peak flows for the 2-year through 100-year storm events). Local Policies and Regulations. The protection of water quality in San Luis Obispo Creek and its tributaries is under the jurisdiction of the RWQCB. The City also has the responsibility for regulating water quality under its NPDES MS4 permits program. The RWQCB establishes requirements prescribing the quality of point sources of discharge and establishes water quality objectives. These objectives are established based on the designated beneficial uses for a particular surface water or groundwater. Within the City limits, the jurisdiction for the water quality of the San Luis Obispo Creek watershed overlaps with the City Public Works and Utilities agencies. City of San Luis Obispo General Plan. The City addresses hydrology and water quality issues through implementation of adopted General Plan policies and programs. These policies are found in the Land Use, Conservation and Open Space, and Safety Elements. The goals and policies from the existing General Plan relate to protecting water quality and minimizing flood hazard risk within the city. The City seeks to protect and enhance creek corridors to promote wildlife and water conservation. The City seeks to accomplish these goals by promoting responsible stormwater management techniques including using porous paving, preventing creek bank encroachment, and ensuring new developments do not decrease flood capacity of waterways. Under the General Plan, any property within the FIRM defined 100-year flood zone is considered as having a hazard potential requiring specified controls or protective measures. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-13 Land Use Element. The Land Use Element contains the following policies which define the local regulatory setting related to hydrology and water quality: Policy 6.6.1. Creek and Wetlands Management Objectives. The City shall manage its lake, creeks, wetlands, floodplains, and associated wetlands to achieve the multiple objectives of: B. Preventing loss of life and minimizing property damage from flooding; C. Providing recreational opportunities which are compatible with fish and wildlife habitat, flood protection, and use of adjacent private properties. Policy 6.6.5. Runoff Reduction and Groundwater Recharge. The City shall require the use of methods to facilitate rainwater percolation for roof areas and outdoor hardscaped areas where practical to reduce surface water runoff and aid in groundwater recharge. Policy 6.6.6. Development Requirements. The City shall require project designs that minimize drainage concentrations and impervious coverage. Floodplain areas should be avoided and, where feasible, any channelization shall be designed to provide the appearance of a natural water course. Policy 6.6.7. Discharge of Urban Pollutants. The City shall require appropriate runoff control measure as part of future development proposals to minimize discharge of urban pollutants (such as oil and grease) into area drainages. Policy 6.6.8. Erosion Control Measures. The City shall require adequate provision of erosion control measures as part of new development to minimize sedimentation of streams and drainage channels. Policy 6.7.2. National Flood Program. The City shall administer the national Flood Insurance Program standards. Policy 6.7.3. Creekside Care and Notification. In maintaining creek channels to accommodate flood waters, the City shall notify owners of creeks and adjacent properties in advance of work, and use care in any needed removal of vegetation. Conservation and Open Space Element. The COSE contains the following goals and policies which define the local regulatory setting related to hydrology and water quality: Policy 7.7.9. Creek Setbacks. As further described in the Zoning Regulations, the City will maintain creek setbacks to include: an appropriate separation from the physical top of the bank, the appropriate floodway as identified in the Flood Management Policy, native riparian plants or wildlife habitat and space for paths called for by any City-adopted plan. In addition, creek setbacks should be consistent with the following: A. The following items should be no closer to the wetland or creek than the setback line: buildings, streets, driveways, parking lots, above-ground utilities, and outdoor commercial storage or work areas. B. Development approvals should respect the separation from creek banks and protection of floodways and natural features identified in part A above, whether or not the setback line has been established. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-14 Policy 8.3.3. Open Space for Safety. Secure open space where development would be unsafe. Generally, the following locations are considered to be unsafe: D. Areas subject to flooding, where the frequency, depth, or velocity of floodwaters poses an unacceptable risk to life, health, or property. Goal 10.1.3. Water Quality. Protect and maintain water quality in aquifers, Laguna Lake, streams, and wetlands that supports all beneficial uses, agriculture, and wildlife habitat. Policy 10.2.1. Water Quality. The City will employ the best available practices for pollution avoidance and control, and will encourage others to do likewise. “Best available practices” means behavior and technologies that result in the highest water quality, considering available equipment, life-cycle costs, social and environmental side effects, and the regulations of other agencies. Policy 10.2.2. Ahwahnee Water Principles. In planning for its water operations, programs, and services, the City will be guided by the Ahwahnee Water Principles and will encourage individuals, agencies, and organizations to follow these policies: A. Community design should be compact, mixed use, walkable and transit-oriented so that automobile-generated urban runoff pollutants are minimized and the open lands that absorb water are preserved to the maximum extent possible. B. Natural resources such as wetlands, floodplains, recharge zones, riparian areas, open space, and native habitats should be identified, preserved and restored as valued assets for flood protection, water quality improvement, groundwater recharge, habitat, and overall long-term water resource sustainability. C. Water holding areas such as creekbeds, recessed athletic fields, ponds, cisterns, and other features that serve to recharge groundwater, reduce runoff, improve water quality and decrease flooding should be incorporated into the urban landscape. D. All aspects of landscaping from the selection of plants to soil preparation and the installation of irrigation systems should be designed to reduce water demand, retain runoff, decrease flooding, and recharge groundwater. E. Permeable surfaces should be used for hardscape. Impervious surfaces such as driveways, streets, and parking lots should be minimized so that land is available to absorb stormwater, which reduces polluted urban runoff, recharges groundwater, and reduces flooding. F. Dual plumbing that allows grey water from showers, sinks, and washers to be reused for landscape irrigation should be included in the infrastructure of new development, consistent with state guidelines. G. Community design should maximize the use of recycled water for appropriate applications including outdoor irrigation, toilet flushing, and commercial and industrial processes. Purple pipe should be installed in all new construction and remodeled buildings in anticipation of future availability of recycled water. H. Urban water conservation technologies such as low-flow toilets, efficient clothes washers, and more efficient water-using industrial equipment should be incorporated in all new construction and retrofitted in remodeled buildings. I. Groundwater treatment and brackish water desalination should be pursued when necessary to maximize locally available, drought-proof water supplies. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-15 Policy 10.3.2. Maintain Water Quality. The City will do the following to maintain a high level of water quality, and will encourage individuals, organizations, and other agencies to do likewise: A. Design and operate its water supply, treatment, and distribution system to prevent adverse effects on water quality (potential point source of pollutants such as chlorine). B. Design and operate its wastewater collection and treatment system to prevent adverse effects on water quality (potential point source of pollutants such as untreated sewage and chlorine). C. Design, construct, and maintain its facilities such as parks, buildings and grounds, stormwater facilities and parking to prevent adverse effects on water quality (potential point sources for pollutants such as petroleum and non-point sources of runoff contaminated with fertilizers, pesticides, litter, and vehicle residues). D. Regulate the design, construction, and operation of private facilities over which the City has permit authority to ensure they will not have adverse effects on water quality (potential point sources for, as examples, sediment from construction and chemicals used in operations, and non-point sources for contaminated runoff). E. Participate with other agencies, in particular the California Regional Water Quality Control Board, in watershed planning and management. F. In locations subject to flooding, not allow activities, such as outdoor storage, that would be substantial sources of chemical or biological contamination during a flood, even though buildings associated with the activities would meet flood-protection standards. G. Establish standards for non-point source water pollution in cooperation with the Regional Water Quality Control Board. H. Establish a program of baseline water quality testing for City creeks. I. Identify and protect groundwater recharge areas to maintain suitable groundwater levels and to protect groundwater quality for existing and potential municipal water sources. Safety Element. The General Plan Safety Element contains the following relevant policies which define the local regulatory setting related to flooding: Policy 2.1. Flood Hazard Avoidance and Reduction. A. The City will develop and carry out environmentally sensitive programs to reduce or eliminate the potential for flooding in previously developed, flood-prone areas of the City. B. The City should allow flood waters to move through natural channels. Flow should be accommodated by removing debris and man-made obstructions. The City recognizes that many natural channels cannot contain runoff from a storm greater than a 25-year event. Areas flooded by storms as large as a 100-year event will be mapped. C. No new building or fill should encroach beyond, or extend over, the top-of-bank of any creek. D. Within predominantly developed areas (such as downtown) infill, remodel, and replacement projects should not displace more flood water than previous structures San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-16 on the site or in the vicinity. Commercial buildings may be flood-proofed where providing floor levels above the 100-year storm flow is not appropriate due to adjacent improvements. New infill buildings may be required to have greater setbacks than their older neighbors. E. Within new development areas, substantial displacement of flood waters should be avoided by: 1. Keeping a substantial amount of flood-prone land in the vicinity as open space; 2. Enlarging man-made bottlenecks, such as culverts, which contribute to flood waters backing up from them; 3. Accommodating in such places uses which have relatively low ratios of building coverage to site area, for which shallow flooding of parking and landscape areas would cause minimum damage; and 4. Requiring new buildings to be construction above the 100-year flood level. F. Creek alterations shall be considered only if there is no practical alternative, consistent with the Conservation and Open Space Element. G. Development close to creeks shall be designed to avoid damage due to future creek bank erosion. Property owners shall be responsible for protecting their developments from damage caused by future bank loss due to flood flows. City of San Luis Obispo Municipal Code. Municipal Code 12.08 – Stormwater Quality Ordinance. The purpose and intent of this ordinance is to ensure the health, safety, and general welfare of citizens. The ordinance also protects and enhances the quality of watercourses and water bodies in a manner pursuant to and consistent with the Clean Water Act by reducing pollutants in stormwater discharges to the maximum extent practicable, by prohibiting non-stormwater discharges to the storm drain system, and improving stormwater management. The City will adopt design standards requiring appropriate Best Management Practices (BMPs) to control the volume, rate, and potential pollutant load of stormwater runoff from newly developed property. These requirements will be incorporated, in any land use entitlement and construction or building- related permit to be issued relative to such development or redevelopment. Municipal Code 13.08 – Sewers. The purpose and intent of this ordinance is to authorize the issuance of wastewater discharge permits to industrial users, provide for monitoring, compliance, and enforcement activities, and require significant industrial user reporting. Municipal Code 17.16.025 – Creek Setbacks. The City’s Creek Setback requirement applies to all creeks that are shown on Figure 9 of the Conservation and Open Space Element in the General Plan, including Prefumo Creek. A 35-foot setback is required for Prefumo Creek “from the existing top of bank (or the future top of bank resulting from a creek alteration reflected in a plan approved by the City), or from the edge of the predominant pattern of riparian vegetation, whichever is farther from the creek flow line.” Municipal Code 17.84 – Floodplain Management Regulations. Based on FEMA NFIP requirements, the City’s Floodplain Management Regulations apply to areas of special flood hazard as identified by FEMA, which are areas that FEMA has identified as subject to inundation by the 100-year flood. Approximately 75 percent of the Specific Plan Area is designated as Special Flood Hazard Area because it is situated in a designated 100-year San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-17 floodplain as identified by the FEMA FIRM. As a result, the following Municipal Code provisions would apply to the project: • The proposed development is within a special floodplain management zone as defined by the City, so the requirements of the City’s Floodplain Management Regulations for those zones must be met. • Base flood elevations for the Project site must be determined. • An approved Letter of Map Revision (LOMR) is required prior to issuance of building permits. • All proposed nonresidential structures require certification from a registered civil engineer or architect that they are floodproofed in accordance with Section 17.84.050(A)(3) of the Municipal Code. • All proposed residential structures require post-construction certification from a registered civil engineer or licensed land surveyor that their lowest floors are one foot above the base flood elevation. • Public utilities and facilities such as sewer, gas, electrical, and water systems are to be located and constructed to minimize flood damage. Special Floodplain Management Zone Regulations (Managed Fill Criteria). The City’s Floodplain Management Regulations require that all building pads within a 100-year flood zone be raised at least 1 foot above the specified 100-year flood elevation. The regulations also state that, cumulatively, developments will not displace floodwater sufficient to raise the flood elevation more than 1 foot at any point, without causing damage to any offsite properties. Development of vacant lands in Special Floodplain Management Zone areas have been determined to have a potentially significant effect on downstream flooding and bank stability. These potential impacts can be mitigated by incorporation of the specific floodplain management policies in project design. For any development or subdivision proposal within the 100-year FEMA floodplain, on individual parcels or developments larger than 2.5 acres, the development proposal shall include a Concept Grading Plan and Master Drainage Plan. These Plans shall be submitted to the City or County Public Works Director for approval and shall meet specific criteria, including: • The project shall not cause the 100-year flood elevation to increase more than 2.5 inches. • The project shall not cause stream velocities to increase more than 0.3 feet per second. • The project shall not cause a significant net decrease in floodplain storage volume unless several exceptions are met. Municipal Code 17.84.050 Provisions for flood hazard reduction - C. Standards for Subdivisions and Other Proposed Development makes the following specifications relative to the timing and applicability of conditional letters of map revision (CLOMR) and LOMRs: 1. All new subdivisions proposals and other proposed development, including proposals for manufactured home parks and subdivisions, greater than fifty lots or five acres, whichever is the lesser, shall: a. Identify the special flood hazard areas (SFHA) and base flood elevations (BFE). b. Identify the elevations of lowest floors of all proposed structures and pads on the final plans. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-18 c. If the site is filled above the base flood elevation, the following as-built information for each structure shall be certified by a registered civil engineer or licensed land surveyor and provided as part of an application for a letter of map revision based on fill (LOMR-F) to the floodplain administrator: i. Lowest floor elevation. ii. Pad elevation. iii. Lowest adjacent grade. City of San Luis Obispo NPDES Phase II Program. The City has developed a stormwater management plan (SWMP) that was submitted to the RWQCB in July 2009 under the NPDES Phase II program. Development is required to be undertaken in strict accordance with conditions and requirements of that program. City of San Luis Obispo Waterway Management Plan (2003). The City of San Luis Obispo Waterway Management Plan incorporates three volumes: the WMP, the DDM, and the Stream Management and Maintenance Program (SMMP). The WMP is a watershed-based management plan for San Luis Obispo Creek and its tributaries. The City’s WMP serves as a basis for future project planning, decision-making, and permitting. The DDM contains policies for floodplain and stream corridor management, and Best Management Practices for construction related stormwater management. The floodplain management policies in the DDM generally require that fill placed on floodplains be managed so that there is no adverse impact in terms of flooding or bank stability, and that post-development peak flows from a project site do not exceed peak flows for the 2-year through 100-year storm events. These are referred to as the “Managed Fill” and “No Adverse Impact” policies. The DDM also requires applicants that create adverse hydrologic impacts to fully mitigate them. The SMMP outlines the Best Management Practices for stream maintenance such as sediment removal, bank repair, and vegetation management. City of San Luis Obispo Engineering Standards. The current Engineering Standards for the City include the following requirement relevant to water quality: • All new development or redevelopment shall comply with the criteria and standards set forth in the Waterways Management Plan DDM, applicable area specific plans, and the Post-Construction Stormwater Management Requirements for Development Projects in the Central Coast Region, adopted by the Central Coast Regional Water Quality Control Board, and included in the appendices. Where requirements conflict, the stricter shall apply. • Stormwater Control Plan, and Operation and Maintenance Plan are required prior to final approvals. • Projects with pollution generating activities and sources must be designed to implement operation or source control measures consistent with recommendations from the California Stormwater Quality Association Handbook for New Development and Redevelopment or equivalent, including: a. Accidental spills or leaks b. Interior floor drains c. Parking / storage areas and maintenance d. Indoor and structural pest control San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-19 e. Landscape / outdoor pesticide use f. Pools, spas, ponds, decorative fountains and other water features g. Restaurants, grocery stores, and other food service operations h. Refuse areas i. Industrial processes j. Outdoor storage of equipment or materials k. Vehicle and equipment cleaning, repair, and maintenance l. Fuel dispensing areas m. Loading docks n. Fire sprinkler test water o. Drain or wash water from boiler drain lines, condensate drain lines, rooftop equipment, drainage sumps, and other sources p. Unauthorized non-stormwater discharges q. Building and grounds maintenance • Design should prevent water from contacting work areas, prevent pollutants from coming in contact with surfaces used by stormwater runoff, or where contact is unavoidable, and treat stormwater to remove pollutants. • Operations and maintenance activities required to achieve Source Control are to be included in the Operation and Maintenance Plan submitted for approvals and recorded with the property as required by the 2013 State General Stormwater Permit Section E.12.d. 4.8.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Element Update EIR (LUCE Update EIR) previously analyzed potential impacts to hydrology and water quality from development planned under the Land Use and Circulation Element update, including the planned development on the project site. In particular the LUCE Update EIR addressed the impact of development on floodplains, water quality and runoff, water resources, and drainage patterns. The LUCE Update EIR noted that development in the San Luis Ranch Specific Plan Area within the 100- year floodplain could be subject to flooding and have the potential to impede flow, increase the amount of impervious surfaces on the site, add new point and non-point source contamination of local waterways, and contribute to runoff water that could exceed existing drainage capacity. However, the LUCE Update EIR concluded that implementation of applicable General Plan policies, City Ordinance requirements, adherence to the City’s Floodplain Management Regulations, the City’s SWMP, the CCRWQCB Post Construction Requirements, and state regulatory requirements would reduce impacts associated with General Plan buildout to a less than significant level. The LUCE Update EIR also stated that individual development, such as the project, would be required to undergo separate environmental review, which may result in specific impacts that require project-specific mitigation consistent with these policies. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-20 4.8.3 Impact Analysis a. Methodology and Significance Thresholds. The analysis of site drainage in this section is based on the Preliminary Storm Water Control & Treatment Strategy (July 2016) for the project prepared by Cannon (refer to Appendix J). An impact would occur if development of the project significantly alters drainage and hydrology. Potential impacts to drainage are assessed based on site topography, the proposed layout and elevations of potential project components, the erodibility of soils, the amount of impervious surfacing proposed, and the regulatory framework necessary for the project. In addition, pursuant to City standards, hydrological and water quality impacts would be potentially significant if: • Flooding impacts would be considered potentially significant if shallow groundwater came in contact with building foundations and retaining walls, exposing people or structures to potentially adverse effects. • Flooding impacts would be considered potentially significant if the development is proposed within an identified flood-prone area, as determined by the City of San Luis Obispo FIRM, thereby increasing the number of buildings exposed to the existing flood hazard; or if the new development conflicted with Flood Hazard avoidance policies in the City’s Safety Element. • Water quality impacts would be considered potentially significant if development of the project would result in the increased degradation of surface or subsurface water quality, including indirect impacts to threatened and endangered species downstream of the Downtown area. With respect to water quality, determining significance is more indirect, because there are no specific discharge requirements or standards for stormwater runoff than can be compared at this time. For the purposes of this EIR, the determination of significance is based on a review of typical construction site pollutants usually found on job sites which may contribute to disproportionate amounts of polluting materials in runoff. The SWRCB has not attempted to identify numerical limits to be achieved in runoff from construction sites. Instead, the General Order contains narrative restrictions referencing best available technology economically achievable and the best conventional pollution control technology. Thus, the significance of water quality impacts will be evaluated based on conformance with these requirements. The analysis within this section also builds upon conclusions identified in the LUCE Update EIR, which identified impacts to hydrology and water quality as less than significant with the implementation of existing federal, State, and local regulatory policies. Mitigation measures provided in this section implement these existing policies. The assessment of hydrology and water quality impacts for the project includes a review of regulations that control the City’s water resources. Construction impacts are assessed based on information provided within the preliminary tract map, development plan, and grading and drainage plans, which include the size, location, and grade of building pads, and location and size of drainage infrastructure. As some of this information is at the conceptual or preliminary stage, a conservative, reasonable worst-case approach has been taken to ensure that potential impacts are addressed. Operational San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-21 impacts are assessed based on the increase of development, impervious surfaces, and changes in drainage features throughout the project site. In accordance with Appendix G of the State CEQA Guidelines, impacts would be considered significant if the project would result in any of the following: 1. Violate any water quality standards or waste discharge requirements; 2. Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level; 3. Substantially alter the existing drainage pattern of a site or areas, including through the alteration of the course of a stream or river, in a manner which result in substantial erosion or siltation on- or off-site; 4. Substantially alter the existing drainage pattern of a site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; 5. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; 6. Otherwise substantially degrade water quality; 7. Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map; 8. Place within a 100-year flood hazard area structures which would impede or redirect flood flows; 9. Expose people or structure to a significant risk of loss, injury, or death involving flooding, including flooding as the result of failure of a dam or levee; and/or 10. Be subject to inundation by seiche, tsunami, or mudflow. The Initial Study determined that the project would not interfere substantially with groundwater recharge with compliance with applicable General Plan policies, and would not be subject to inundation by seiche, tsunami, or mudflow. Therefore, Thresholds 2 and 10 are not discussed further in this section. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of these impacts. See Section 4.13, Water Resources, for a discussion of the project’s potential impact to groundwater resources. In addition, the project would result in no impact related to flooding as the result of failure of a levee or dam. Regionally, the Salinas Dam and the Nacimiento Dam provide some measure of flood protection to northern San Luis Obispo County. However, these dams are not located within the same watershed as the project site, and a large-scale dam failure would be unlikely to cause significant loss, injury, or death onsite. Therefore, Threshold 9 is not discussed further in this section. As described in Section 4.8.1(d), the Hydrogeology Report (Appendix H) identified PCE contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. However, the domestic water well has a PCE concentration of 1.0, which is within the U.S. EPA MCL for drinking water of 5 µg/L. The project does not include any uses that would contribute to increased PCE concentration in groundwater in the vicinity of the site such that it would result in any new violations of water quality standards. Therefore, impacts related to PCE contamination are not discussed further in this section. Refer to Section 4.7, Hazards and Hazardous Materials, for a discussion of hazards associated with risk of exposure to PCE in groundwater. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-22 b. Impacts and Mitigation Measures. Threshold 1 Would the project violate any water quality standards or waste discharge requirements? Threshold 6 Would the project otherwise substantially degrade water quality? Impact HWQ-1 During project construction, the surface soil would be subject to erosion and the downstream watershed would be subject to pollution. The project’s impact on water quality during construction would be Class II, significant but mitigable. Grading associated with construction of each phase of the project would temporarily expose bare soil, which could be removed from the site and transported through the drainages on and downstream of the project site. Construction wastes, paving materials, heavy equipment fuels, lubricants and solvents, or products of incomplete combustion, could also contribute to water pollution. Uncontrolled discharges of sediment and other pollutants could create temporary adverse effects to water quality in downstream surface waters, including Prefumo Creek and the Cerro San Luis Drainage Channel. As shown in Table 4.8-1, Prefumo Creek, the project’s receiving water, is impaired by fecal coliform, low dissolved oxygen, nitrate, and turbidity as a result of current agricultural, urban runoff, and other unknown point sources. TMDLs have not yet been established for these contaminants for Prefumo Creek. Project construction would be phased over an approximately 7-year period. In total, earthwork for buildout of the project site is estimated to require 817,200 cubic yards (CY) of cut, and 569,200 CY of fill, resulting in a need for approximately 248,000 CY of soil import. Approximately 428,600 cubic yards of soils would be redistributed across the site, particularly to fill lower lying floodplain areas, potentially resulting in large exposed areas within the project site over an extended period of time. Based on the site’s existing topography and proposed elevation pads, runoff from exposed construction areas during storm events would flow into Prefumo Creek. Construction activities could impact hydrology by exposing disturbed ground to potential erosion or by introducing pollutants such as oils, chemicals, sediments, and construction debris into the runoff. Construction activities could also result in the pollution of natural watercourses downstream or underground aquifers. In particular, Phases 1 and 3 of project development would include grading and construction activities in close proximity or adjacent to Prefumo Creek. Grading, excavation, and placement of fill soils near Prefumo Creek would also occur during the installation of the bicycle pathways within the open space corridor. Grading for housing pads adjacent to Prefumo Creek included in Phases 1 and 3 (refer to Figures 2-13 and 2-14 in Section 2.0, Project Description) would be within 100 feet of the top of the Creek bank. The presence and use of large construction machinery within close proximity of the Creek has the potential to result in a spill of fluids, such as oil, gasoline, and hydraulic fluids, which could be mobilized by stormwater runoff. Refer to Section 4.4, Biological Resources, for additional detail on impacts of runoff within the creek to biological resources. Construction activities that disturb one or more acres of soil (such as the project) are required to comply with the NPDES program through preparation of a SWPPP, which outlines BMPs that San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-23 would address construction-related runoff. The project would be subject to construction-phase stormwater regulations, as described in Section 4.8.1(e), Regulatory Setting. Construction would be completed in compliance with the State’s Construction General Permit (Order No. 2009-0009- DWQ). The Construction General Permit requires the development of a SWPPP be developed by a Qualified SWPPP Developer (QSD). Mitigative Components of the Specific Plan and Impact Conclusion. Section 7.3 of the San Luis Ranch Specific Plan requires development in the Plan Area to be designed to conform to stormwater management requirements of the City of San Luis Obispo, including standards for LID set forth by SWRCB, and construction of retention and detention systems that would be adequate to meet the needs of future development and consistent with State and local requirements. Preparation of the required SWPPP and compliance with applicable State and local regulations would reduce potential impacts to water quality due to polluted runoff from construction activities. In order to ensure implementation of SWPPP requirements, this impact is identified as potentially significant, and incorporation of the following mitigation measures is required. Mitigation Measures. The following mitigation measures are required to reduce impacts to water quality due to due to polluted runoff from construction activities: HWQ-1(a) Stormwater Pollution Prevention Plan. All required actions shall be implemented pursuant to a SWPPP and SWMP to be prepared by the project applicant and submitted by the City to the Regional Water Quality Control Board under the NPDES Phase II program. At a minimum, the SWPPP/SWMP shall including the following BMPs: • The use of sandbags, straw bales, and temporary de-silting basins during project grading and construction during the rainy season to prevent discharge of sediment-laden runoff into stormwater facilities; • Revegetation as soon as practicable after completion of grading to reduce sediment transport during storms; • Installation of straw bales, wattles, or silt fencing at the base of bare slopes before the onset of the rainy season (October 15th through April 15th); • Installation of straw bales, wattles, or silt fencing at the project perimeter and in front of storm drains before the onset of the rainy season (October 15th through April 15th); and/or • Alternative BMPs as approved by the RWQCB as part of the SWPPP submittal. HWQ-1(b) Berms and Basins. As specified in the SWPPP, the applicant shall be required to manage and control runoff by constructing temporary berms, sediment basins, runoff diversions, or alternative BMP’s as approved by the RWQCB as part of the SWPPP submittal, in order to avoid unnecessary siltation into San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-24 local streams during construction activities where grading and construction shall occur in the vicinity of such streams. • Berms and basins shall be constructed when grading commences and be periodically inspected and maintained. The project applicant shall sufficiently document, to the CCRWQCB satisfaction, the proper installation of such berms and basins during grading. HWQ-1(c) Concept Grading Plan and Master Drainage Plan. As specified in the SWPPP and the City’s Floodplain Management Regulations, the applicant shall be required to submit a Grading Plan and Master Drainage Plan to the Planning Division and City Public Works Director for approval prior to approval of the VTTM. The grading and drainage plans shall be designed to minimize erosion and water quality impacts, to the extent feasible, and shall be consistent with the project’s SWPPP. The plans shall include the following: a. Graded areas shall be revegetated with deep-rooted, native, non- invasive drought-tolerant species to minimize slope failure and erosion potential. Geotextile fabrics shall be used if necessary to hold slope soils until vegetation is established; b. Temporary storage of construction equipment shall be limited to a minimum of 100 feet away from drainages on the project site; and c. Erosion control structures shall be installed. d. Demonstrate peak flows and runoff for each phase of construction. e. Be coordinated with habitat restoration efforts, including measures to minimize removal of riparian and wetland habitats and trees (Mitigation Measures BIO-2[a] and BIO-2[b]). Grading and drainage plans shall be submitted for review and approval by the Planning Division. The applicant shall ensure installation of erosion control structures prior to beginning of construction of any structures, subject to review and approval by the City. Plan Requirements and Timing. The project applicant shall prepare a SWPPP and SWMP that identifies construction-related staging and maintenance areas, and at a minimum, the BMPs identified in Mitigation Measure HWQ-1(a). The SWPPP and notices shall be submitted for review and approval by the City prior to the initiation of construction. The SWPPP/SWMP shall be designed to address erosion and sediment control during all phases of development of the site until all disturbed areas are permanently stabilized. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-25 Monitoring. The City shall ensure compliance with the SWPPP. A Geotechnical Engineer or an Engineering Geologist shall be made available to monitor technical aspects of the grading activities, including installation of the drainage outlets and associated headwalls and aprons. The City shall also inspect the site during grading to monitor runoff and after conclusion of grading activities. Residual Impacts. Implementation of the above mitigation measures and compliance with existing regulations would ensure that the potentially significant construction runoff and associated impacts to water quality would be reduced to a less than significant level. Threshold 3 Would the project substantially alter the existing drainage pattern of a site or areas, including through the alteration of the course of a stream or river, in a manner which result in substantial erosion or siltation on- or off-site? Threshold 4 Would the project substantially alter the existing drainage pattern of a site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Threshold 5 Would the project create or contribute runoff water that would exceed the capacity of the existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Impact HWQ-2 The project would alter the existing drainage pattern of the project site, which could result in flooding, erosion, or siltation onsite and offsite. However, the proposed retention and detention systems, along with compliance with applicable regulations, would ensure that this impact would remain Class III, less than significant. The project would alter the existing drainage pattern on the project site through re-grading of the project site and soil import to the site to raise building ground elevations above the existing 100-year floodplain. In addition, the project design includes the construction of a diversion structure on the upstream side of the property at the Cerro San Luis Channel, which would divert flows to underground storage chambers within the commercial portion of the project site. The proposed detention facilities on the project site are shown in Figure 2-12 in Section 2.0, Project Description, and described in detail in the Preliminary Storm Water Control & Treatment Strategy for the project (July 2016, refer to Appendix J). Flows from these chambers would be released through a metered outlet structure to a storm drain, which would outfall to Prefumo Creek south of the Froom Ranch Way Bridge. The proposed design of the chambers and the outflow structure are based on the requirements in the City’s DDM, matching post- development flows to pre-development for the 2-year through 100-year storm events. The detention structures would be designed to address increased runoff from the proposed residential properties, as well as runoff due to development of the project roadway San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-26 infrastructure. Table 4.8-4 depicts the peak flow rates off of the site for the 2-year through 100- year storms. Table 4.8-4 Combined Peak Discharge from Proposed Drainage Basins Scenario Peak Flow (cubic feet per second [cfs]) 2-Year 10-Year 25-Year 50-Year 100-Year Existing Conditions 262.20 505.92 673.51 804.08 906.47 Proposed Conditions 265.39 495.44 646.58 756.58 861.59 Difference 3.20 -10.48 -26.93 -47.27 -44.88 Percent Change 1.2% -2.1% -4.0% -5.9% -5.0% 1. Peak flows shown are preliminary and are subject to change as the design develops. 2. The San Luis Obispo City DDM (Section 3.3) allows up to a 5 percent increase in peak flows from existing conditions. Source: Cannon, July 2016. Refer to Appendix J. For those areas not included in this regional detention (commercial, hotel, office and Agricultural Heritage Facilities and Learning Center) drainage would be treated and detained on-site, including retention within underlying rock below biofiltration areas (refer to Figure 2- 12 in Section 2.0, Project Description). Flows from these areas would be released through a metered outlet structure to the project storm drain network which would outfall to Prefumo Creek south of the proposed Froom Ranch Way bridge, or to Cerro San Luis Channel. Design of the chambers and the outflow structure is based on City requirements in the DDM. Potential effects on agricultural resources associated with changes to the floodplain on the project site are discussed in Section 4.2, Agricultural Resources. Mitigative Components of the Specific Plan and Impact Conclusion. As described above, the Specific Plan includes a preliminary drainage plan that would satisfy City flow requirements with the proposed development. The proposed detention facilities and stormwater conveyance infrastructure would change the way water is conveyed through the site to Prefumo Creek and would result in changes to stormwater management control and peak surface flows. However, the proposed detention and existing drainage facilities would meet applicable City requirements, and would not result in an increase in post-development peak runoff from the project site. Therefore, this impact would be less than significant. Mitigation Measures. No mitigation measures are required. Residual Impacts. This impact would be less than significant without mitigation. Threshold 1 Would the project violate any water quality standards or waste discharge requirements? Threshold 6 Would the project otherwise substantially degrade water quality? Impact HWQ-3 During operation, the proposed residential, and commercial, and agricultural uses would increase the quantities of pollutants associated with runoff and San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-27 sedimentation. The project’s impact on water quality would be Class II, significant but mitigable impact. Project development would replace approximately 78 acres of agricultural land with an equivalent area of urban development and associated changes in pollutant runoff. Current agricultural operations use chemicals such as pesticides and fertilizers which may currently enter Prefumo Creek and affect water quality. Development of the project with residential and commercial uses would be expected to increase the quantities of pollutants associated with runoff from streets, lawns, landscaping, and gardens. Other activities that may increase pollutants due to site development include motor vehicle operations in the area, pesticide/herbicide/fertilizer uses, human littering, careless material storage and handling, pavement disintegration, and domestic animal waste. During storm events, these pollutants would be transported into drainage systems by surface runoff. Disturbed soils, sedimentation, and contaminants that are mobilized by water flow through Prefumo Creek may ultimately be conveyed to San Luis Obispo Creek. The project would be required to manage stormwater treatment in accordance with the CCRWQCB’s Resolution R3-2013-0032, which requires Central Coast municipalities to implement Post Construction Requirements to comply with the Statewide Phase II Municipal General Permit. The General Permit requires MS4s to develop and implement Best Management Practices (described in Section 4.8.1[e], above) to reduce the discharge of pollutants and protect water quality. In addition, the project would be required to prepare a SWMP consistent with the City’s NPDES Phase II Program. As described in Impact HWQ-2, the project design includes the construction of a diversion structure on the upstream side of the property at the Cerro San Luis Chanel which would divert flows into an underground storage chambersdetention system within the commercial portion of the project site (refer to Figure 2-12 in Section 2.0, Project Description). The underground detention structures would be designed to limit the release of “first flush” water, which generally contains the highest concentration of pollutants from buildup during the dry season. Runoff from the high-density residential development in the northern portion of the project site would be retained within underlying rock below biofiltration areas located throughout the residential development. Biofiltration uses grass or other dense plants to filter out sediments, oily materials, and other pollutants through the combined effects of filtration, infiltration, and settling. Therefore, in accordance with the CCRWQCB Post-Construction requirements, residential and commercial runoff would be treated prior to entering the receiving waters. No stormwater treatment is required for agricultural uses; however, the project represents a net reduction in agricultural acreage in the Specific Plan Area. As a result, implementation of the project would be expected to reduce the long-term agricultural pollutant load into Prefumo Creek. Mitigative Components of the Specific Plan and Impact Conclusion. As described above, the Specific Plan includes retention and detention structures and LID measures intended to minimize pollutants associated with runoff and sedimentation, consistent with State and local requirements, including new standards for LID set forth by SWRCB. Compliance with the CCRWQCB’s Post Construction Requirements, NPDES discharge permits, the City’s SWMP, Engineering Standards, General Plan, and City Ordinance requirements would reduce potential impacts to water quality due to polluted runoff during operation of the project. However, mitigation is required to ensure the inclusion of locally-appropriate stormwater best San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-28 management practices in the final design of the stormwater quality system, and to ensure that the stormwater quality system is maintained in order to ensure continued to ensure long-term operation. Therefore, potential impacts to water quality resulting from runoff during operation of the project would be significant but mitigable. Mitigation Measures. The following mitigation measures are required to reduce impacts to water quality due to due to polluted runoff during operation of the project: HWQ-3(a) Stormwater Quality Treatment Controls. BMP devices shall be incorporated into the stormwater quality system depicted in the Master Drainage Plan (refer to Mitigation Measure HWQ-1[c]). The final design of the stormwater quality system shall be reviewed and approved by the City. The Master Drainage Plan shall contain the following relevant BMPs: • Vegetated bioswales to reduce sediment and particulate forms of metals and other pollutants along corridors of planted grasses. • Vegetated buffer strips to reduce sediment and particulate forms of metals and nutrients. • Hydrodynamic separation products to reduce suspended solids greater than 240 microns, trash, and hydrocarbons. These hydrodynamic separators shall be sized to handle peak flows from the project site consistent with applicable regulatory standards. HWQ-3(b) Stormwater BMP Maintenance Manual. The project applicant shall prepare a development maintenance manual for the stormwater quality system BMPs (refer to Mitigation Measure HWQ-3[a]). The maintenance manual shall include detailed procedures for maintenance and operations of all stormwater facilities to ensure long-term operation and maintenance of post- construction stormwater controls. The maintenance manual shall require that stormwater BMP devices be inspected, cleaned, and maintained in accordance with the manufacturer’s maintenance specifications. The manual shall require that devices be cleaned prior to the onset of the rainy season (i.e., October 15th) and immediately after the end of the rainy season (i.e., May 15th). The manual shall also require that all devices be checked after major storm events. HWQ-3(c) Stormwater BMP Semi-Annual Maintenance Report. The property manager(s) or acceptable maintenance organization shall submit to the City of San Luis Obispo Public Works Department a detailed report prepared by a licensed Civil Engineer addressing the condition of all private stormwater facilities, BMPs, and any necessary maintenance activities on a semi-annual basis (October San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-29 15th and May 15th of each year). The requirement for maintenance and report submittal shall be recorded against the property. Plan Requirements and Timing. The applicant shall demonstrate inclusion of BMPs within the VTTM, Utilities Plan, and Master Drainage Plan, which shall be submitted for review and approval by the City prior to Development Plan approval and VTTM recordation. Monitoring. The City shall review and approve the required plans and maintenance manual prior to Development Plan approval and VTTM recordation. Residual Impacts. Implementation of the above mitigation measures and compliance with existing regulations would ensure that the potentially significant impacts to water quality resulting from runoff during operation of the project would be reduced to a less than significant level. Threshold 7 Would the project place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map Threshold 8 Would the project place structures within the 100-year flood zone hazard area which would impede or redirect flood flows. Impact HWQ-4 Approximately 98 acres of the project site is within the existing 100-year flood zone. However, proposed grading and elevation modifications would ensure that the project would not place housing within a 100-year flood hazard area or expose people or structures downstream of the Specific Plan Area to flood hazards due to increased runoff or loss of floodplain storage. This impact would be Class II, significant but mitigable. On-Site Flooding Hazards. As shown in Figure 4.8-2, approximately 98 acres (75 percent) of the 131-acre project site is located within the 100-year floodplain identified by FEMA. High- density residential development is proposed in the northernmost portion of the site which is not within the identified 100-year floodplain, and low/medium- and medium-density residential and commercial development is proposed in the central portion of the site which is within the identified 100-year floodplain. The project grading plan (refer to Figure 2-13 in Section 2.0, Project Description) would raise the elevation of the central portion of the project site above the floodplain elevation using approximately 248,000 CY of soil import to the site as well as fill soil relocated from elsewhere on the project site. Figure 4.8-3 depicts the post-development 100-year floodplain, based on the City of San Luis Obispo Waterway Management Plan hydrologic and hydraulic models, revised to include the project grading plan. It should be noted that the City Waterway Management Plan hydrologic and hydraulic models provide regional floodplain elevations at a higher level of detail than the 100-year floodplain identified by FEMA, because Source: Wallace Group, August 2016Proposed Post-Development 100-Year FloodplainFigure 4.8-3City of San Luis ObispoSan Luis Ranch Project EIRSection 4.8 Hydrology and Water Quality1050 Southwood DriveSan Luis Obispo, CA 93401P 805.544.7407 F 805.544.3863/0600 FeetLEGENDProposed Post-Development 100-Year Floodplain.Project BoundaryProposed ContoursExisting ContoursBioretention AreaApproximate floodplain mapping is based on the City of San Luis Obispo Waterway Management Plan Hydrologic and Hydraulic Models, revised to include the proposed tentative map grading for the San Luis Ranch project. The proposed tentative map grading plan was provided by Cannon on August 3, 2016.1204.8-30 San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-31 the City hydrologic and hydraulic models include smaller waterways which are not included in the FEMA floodplain, such as Cerro San Luis Channel. Through grading of the property to increase elevations on the central portion of the project site, and installation of detention/ retention and drainage facilities described in Section 2.0, Project Description, and Impact HWQ- 2, proposed residential and commercial building pads on the central portion of the project site would be elevated above the post-development 100-year floodplain consistent with standards in the Special Floodplain Management Zone Regulations (refer to Appendix J). This would ensure that no housing would occur within the 100-year floodplain based on the City of San Luis Obispo hydrologic and hydraulic models, and thereby achieve compliance with the City Flood Damage Prevention Regulations Code 17.84.050. Potential effects on agricultural resources associated with changes to the floodplain on the project site are discussed in Section 4.2, Agricultural Resources. Downstream Flooding Hazards. Floodplains provide surface area and storage capacity for flood flows that overtop the banks of waterways, including Prefumo Creek and Cerro San Luis Channel. This storage area attenuates downstream flood peaks. When such areas are reduced, peak flows downstream may be impacted. The re-grading of the site and movement of extensive amounts of fill into the existing 100-year floodplain to construct the project as well as the proposed channel capacity enhancements for Prefumo Creek and Cerro San Luis Channel could affect flood water surface elevations and reduce the amount of existing floodplain storage available in Prefumo Creek and downstream in the San Luis Obispo Creek watershed. Flood waters that currently are spread out and retained temporarily in the existing floodplain onsite would be displaced by fill placement, and the displaced water volume would enter the Prefumo Creek and San Luis Obispo Creek drainages, potentially increasing downstream peak flows, water velocities, and downstream flood water surface elevations and resulting in flooding at on- site agricultural areas and the adjacent SLO City Farm. As described in Section 4.8.1(e), Regulatory Setting, the City’s Floodplain Management Regulations require that projects within the 100-year FEMA floodplain prepare a Master Drainage Plan which demonstrates that new development would not cause the 100-year flood elevation to increase more than 2.5 inches, cause stream velocities to increase more than 0.3 feet per second, or cause a significant net decrease in floodplain storage volume unless the conditions listed in the Managed Fill Criteria of the DDM are met. In addition, the proposed Froom Ranch Way Bridge, as well as all culverts, outfalls, and modifications to the existing creek channels would be required to comply with the applicable requirements of the City’s WMP, DDM, and SMMP, and be approved by the City Engineer, USACE, CDFW, and Central Coast RWQCB. The WMP serves as a basis for future project planning, decision-making, and permitting. The floodplain management policies in the DDM require that fill placed on floodplains be managed so that there is no adverse impact in terms of flooding or bank stability and requires applicants to fully mitigate adverse hydrologic impacts. The SMMP requires BMPs for stream maintenance such as sediment removal, bank repair, and vegetation management. Mitigative Components of the Specific Plan and Impact Conclusion. As described above, the Specific Plan includes a preliminary grading plan that would raise the elevation of the central San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-32 portion of the project site above the post-development 100-year floodplain as shown in Figure 4.8-3. The project includes a conditional letter of map revision (CLOMR) application2 requesting that the FEMA 100-year floodplain boundary be redefined, and that the FIRM revised by FEMA to be consistent with the post-development 100-year floodplain as mapped based on the City of San Luis Obispo Waterway Management Plan hydrologic and hydraulic models consistent with the proposed site development, creek improvements and bridge, Prado Road Overpass, site and floodplain grading, and proposed detention facilities. Compliance with required City Flood Damage Prevention Regulations Code 17.84.050 and flood management measures including Special Floodplain Management Zone Regulation and the City Waterways Management Plan would reduce the risk of significant loss or injury as a result of flooding. In addition, the Specific Plan includes a preliminary drainage plan and retention and detention structures intended to ensure that that proposed development would not substantially increase runoff from the project site. Compliance with these State and local regulations would ensure that downstream flooding impacts would remain less than significant. As described in Impact HWQ-2, the Specific Plan includes excavation and fill in the floodplain, peak flow management, and channel capacity enhancements for Prefumo Creek and Cerro San Luis Channel, and would satisfy City flow requirements with the proposed development. With the implementation of these measures, the project is in compliance with FEMA and City floodplain regulations and potential floodplain elevation increases affecting other properties would be avoided. However, mitigation is required to ensure the final grading plan and resulting post-development floodplain would exclude areas proposed for housing, and confirm that the CLOMR application to redefine the FEMA 100-year floodplain boundary is approved and an official letter of map revision (LOMR)3 is issued by FEMA. Therefore, potential impacts related to on-site flood hazards would be significant but mitigable. Mitigation Measures. The following mitigation measure is required to reduce impacts related to locating housing with a 100-year floodplain to a less than significant level: HWQ-4 Conditional Letter of Map Revision/Letter of Map Revision. The applicant, in conjunction with the City of San Luis Obispo, shall prepare the CLOMR application and obtain a LOMR from FEMA. Plan Requirements and Timing. The applicant shall prepare the CLOMR application and submit it to FEMA. Monitoring. The City will confirm that FEMA has approved the CLOMR prior to issuance of a grading permit, and LOMR prior to occupancy. Residual Impacts. Implementation of Mitigation Measure HWQ-4 and compliance with existing regulations would ensure that this impact would be reduced to a less than significant level. 2 A CLOMR is based on proposed conditions and does not change the FIRMs. A CLOMR is the method used by FEMA to let people know that if projects are constructed per the design submitted to and approved by FEMA, revision of the FIRM panel with an official letter of map revision (LOMR) is likely. 3 A LOMR is an official revision to the FIRMs issued by FEMA. LOMRs reflect changes to the 100-year floodplains or Special Flood Hazard Areas (SFHA) shown on the FIRMs. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-33 c. Cumulative Impacts. The project, in combination with approved, pending, and proposed development within the City, would further contribute to the increase in development and associated water quality impacts, as well as alter the existing hydrologic environment, thereby altering the abundance, natural flow of water resources of the area. As analyzed in the LUCE Update EIR, cumulative impacts of the Land Use and Circulation Element update, which includes the project site, to hydrology and water quality would be reduced to a less than significant level with the implementation of and adherence to the policies and requirements discussed above. Water Quality. Cumulative development would result in a change from agricultural to urban pollutant discharge to surface and groundwater. Construction activities could also result in the pollution of natural watercourses or underground aquifers. The types of pollutant discharges that could occur as a result of construction include accidental spillage of fuel and lubricants, discharge of excess concrete, and an increase in sediment runoff. Storm runoff concentrations of oil, grease, heavy metals, and debris increases as the amount of urban development increases in the watershed. However, when properly implemented, water quality requirements of the CCRWQCB and the City and County of San Luis Obispo would be expected to mitigate any adverse impacts resulting from new development. Therefore, the project, in conjunction with pending cumulative development would not significantly increase the concentration of urban pollutants such as oil, grease, and vehicular heavy metals in surface runoff. Polluted runoff which may be generated during construction activities of cumulative development and projects considered in this analysis would be regulated by the SWRCB under General Construction, NPDES permits, and would be minimized through the implementation of standard construction BMPs. Cumulative impacts would therefore be less than significant for water quality. Flooding. Cumulative development in the City and the San Luis Obispo Creek watershed are anticipated to contribute to an incremental increase in runoff and peak flood flows. Development of planned or pending projects upstream of the project site would contribute to the risk of flooding within the San Luis Ranch Specific Plan Area. Each cumulative project would be expected to provide its own facilities or other mitigation measures, where feasible, to mitigate increased peak flows and exacerbated downstream flooding. Project- specific mitigation measures would reduce cumulative impacts to the extent feasible. The project would increase stormwater runoff due to the increase in impervious surfaces in the Specific Plan Area. However, the proposed on-site drainage system would adequately capture associated runoff, and the project would not substantially contribute to flooding on- or off-site. The project grading plan has been designed such that the resulting post-development floodplain would exclude areas proposed for housing. Overall, cumulative impacts to hydrology and water quality would be less than significant. San Luis Ranch Project EIR Section 4.8 Hydrology and Water Quality City of San Luis Obispo 4.8-34 This page intentionally left blank. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-1 4.9 LAND USE/POLICY CONSISTENCY 4.9.1 Setting a. Regional Land Use. The project site is located in San Luis Obispo County, which has a rural and small-scale community character due to its relatively remote location midway between San Francisco and Los Angeles (County of San Luis Obispo, General Plan, 2011). The site is currently located in unincorporated San Luis Obispo County, approximately 5.7 miles northeast of the Pacific Ocean and outside of the local coastal zone (County of San Luis Obispo, PermitView, 2016). The site is completely surrounded by the City of San Luis Obispo, and is within the City’s Sphere of Influence. As described in the County’s Land Use and Circulation Elements, the project site is located within the San Luis Obispo Planning Area, Sub Area North (2014). Figure 2-1 in Section 2.0, Project Description, shows the regional location of the project. b. Project Site Setting. Over time, land uses surrounding the property have transitioned from agricultural to a variety of urban uses, including residential areas, shopping centers, and auto dealerships. With these changes, the project site is bordered by urban uses on north, east, and west, and by the SLO City Farm to the south. The project site is generally bounded by Madonna Road to the west, Dalidio Drive to the north, U.S. Highway 101 (U.S. 101) to the east and the San Luis Obispo City Farm to the south. Prefumo Creek is located south of the site. Figure 2-2 in Section 2.0, Project Description, shows the site in its local context. The site is identified by assessor’s parcel number (APN) 067-121-022. Under the City’s General Plan, the site has a land use designation of San Luis Ranch Specific Plan and is intended for the future adoption of a specific plan. Policy 8.1.4: SP-2 in the Land Use Element provides general requirements and guidance for the future development of a mixed-use project that maintains the agricultural heritage of the San Luis Ranch site. The project site is currently used for agricultural purposes, primarily as cultivated row crops. The site is important for its historic agricultural use, and is highly visible from U.S. 101. Because if the site’s visually sensitive location at a southern gateway to the City, Policy 8.1.4 in the Land Use Element states that the City shall to preserve approximately half of the agriculture and open space on site, both to preserve views and to maintain the City’s agricultural heritage. The San Luis Ranch Farm Complex (also known as the Dalidio Farm Complex), which includes a farm house and several outbuildings, is located on the western portion of the property adjacent to Madonna Road. Refer to Section 4.2, Agricultural Resources, for a discussion of the project’s agricultural setting. Refer to Section 4.5, Cultural Resources, for a discussion of the existing structures on the project site. c. Regulatory Setting. This section summarizes federal, state, and regional, and local land use plans and regulations. Federal. Federal Aviation Administration (FAA), Federal Aviation Regulation, Part 77 Objects Affecting Navigable Airspace. The FAA Airport Design Guide, Advisory Circular (AC) 150/5300-13, contains guidance pertaining to land uses within the runway protection zone (RPZ). As part of FAA grant assurances, if an airport sponsor receives federal funds for an airport, it is required San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-2 that use of land adjacent to or in the immediate vicinity of the airport be restricted to activities and purposes compatible with normal airport operations. State. Government Code Section 63450. State law (Government Code Section 63450) authorizes cities to adopt specific plans for implementation of their general plans in a defined area. All specific plans must comply with Sections 6540-65457 of the Government Code. These provisions require that a specific plan be consistent with the adopted general plan and, in turn that all subsequent subdivisions and development, public works projects and zoning regulations must be consistent with the specific plan. Specific plans are required to include distribution, location and types of uses, development, and improvements to public facilities and infrastructure. Tailored regulations, conditions, programs, standards and guidelines help implement the vision for long-range development of the specific plan area. Caltrans Airport Land Use Planning Handbook. The purpose of the California Airport Land Use Planning Handbook (CALUPH; Caltrans, 2011) is to provide guidance for conducting airport land use compatibility planning as required by Article 3.5, Airport Land Use Commissions, Public Utilities Code Sections 21670-21679.5. The CALUPH also outlines the legal authority (and limitations thereof) possessed by an Airport Land Use Commission (ALUC) when establishing noise and safety corridors around airports that potentially restrict land use development. The CALUPH makes recommendations for an ALUC to establish land use development policies based upon FAA regulations, rather than specifying precise statutes or means of interpreting FAA regulations. Each ALUC has the final authority to establish safety and noise zones, policies and regulations based on the input from the CALUPH, local conditions, and special exceptions. For the purposes of safety and noise hazards assessment, Public Resources Code Section 21096 and CEQA Guidelines Section 15154 prescribe that the CALUPH is to be used to assist in determining the potential for airport and safety issues, including aspects of the Project’s conformity with local land use plans and regulations. San Luis Obispo Local Agency Formation Commission. A Local Agency Formation Commission (LAFCO) is a state agency that performs growth management functions, and has approval authority regarding the establishment, expansion, reorganization, and elimination of any city and most types of special districts. LAFCO establishes sphere of influence for cities and special districts that define the territory that LAFCO independently finds will represent the appropriate and probable future jurisdictional boundary and service area of the subject agency. The State legislature has prescribed a “uniform process” for boundary changes for both cities and special districts that is now embodied in the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (California Government Code Section 56000 et seq.). This Act delegates the legislature’s boundary powers to local agency formation commissions (LAFCOs). The San Luis Obispo LAFCO is responsible for reviewing and approving proposed jurisdictional boundary changes in San Luis Obispo County, including the annexation and detachment of territory to and/or from cities and most special districts, incorporations of new cities, formations of new special districts, and consolidations, mergers, and dissolutions of existing districts. In addition, LAFCOs must review and approve contractual service San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-3 agreements, conduct service reviews, and determine spheres of influence for each city and district. In addition to the Cortese-Knox-Hertzberg Act, San Luis Obispo LAFCO has adopted local policies that it considers in its review of projects Regional. 2014 Regional Transportation Plan/Sustainable Community Strategy. The 2014 Regional Transportation Plan/Sustainable Community Strategy (RTP/SCS), adopted by the San Luis Obispo Council of Governments (SLOCOG) in April 2015, is the current regional transportation plan for SLOCOG’s planning area. The primary purpose of the 2014 RTP/SCS is to develop a fully intermodal transportation system that enhances the livability of the region. To this purpose, the plan delineates a set of regional transportation goals, policies, and actions. In addition, it integrates new requirements of SB 375 to address the interrelationship of transportation and land use policies and practices. The SCS Element of the plan describes the “preferred growth scenario” for the next two decades, as identified by the SLOCOG Board. This scenario is intended to decrease strain on natural resources, reduce the amount of travel and greenhouse gas (GHG) emissions, improve air quality, and promote public health by supplying more efficient options for transportation and housing. Consistent with the preferred growth scenario, a key strategy in the SCS is to focus new growth within Target Development Areas (TDAs) in existing urbanized areas. The project site is located within the Central County TDA in the greater San Luis Obispo area. San Luis Obispo County Regional Airport Master Plan. This plan was adopted in 2005 and provides aircraft operations forecasts and identifies capital improvements needed at the Airport to address future aeronautic activity at this commercial service airport. The planned facilities identified in the Master Plan are depicted on the FAA – approved Airport Layout Plan. The FAA‐approved forecasts project aircraft operations to exceed 140,000 operations by 2023. San Luis Obispo County Regional Airport – Airport Land Use Plan. The San Luis Obispo County Regional Airport – Airport Land Use Plan (ALUP) was adopted in December 1973, most recently amended in May 2005, and is currently being updated by the County ALUC. The ALUP provides a set of policies and criteria by which the ALUC evaluates compatibility of land uses around the airport to promote well‐being of the public and to protect long term viability of the Airport. The ALUP identifies noise restrictions and safety zones and identifies land uses and density and intensity limitations with each zone. It is expected that the ALUC will update the ALUP’s policies in 2017. The existing ALUP Safety Area “analog” maps have recently been reinterpreted to a more precise GIS format that will be compatible with local mapping accuracy standards for viewing and consistency with ALUP Safety Areas. The maps and the location of safety zones and noise contours used for the Project have been reviewed by the ALUC. As shown in Figure 4.7-1 in Section 4.7, Hazards and Hazardous Materials, the entire project site is located within ALUP Safety Areas S-1b and S-2, which are described below in detail. ALUP Safety Area S-1b is comprised of those portions of Safety Area S-1 that are not included in Safety Area S-1a, but are within probable gliding distance for aircraft on expected approach or departure courses. This Safety Area also includes State-defined sideline Safety Areas, inner San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-4 turning zones and outer safety zones for both Runway 11-29 and Runway 7-25. Aviation safety hazards to be particularly considered in this area include mechanical failures, fuel exhaustion, deviation from glideslope or minimum descent altitude (MDA) during instrument flight rules (IFR) operations (due to pilot error or equipment malfunction), loss of control during short approach procedures, stall/spin incidents during engine-out maneuvers in multi-engine aircraft, loss of control during “go around” or missed approach procedures, and midair collisions. Approximately 119 acres in the northwest portion of the project site is within this area. ALUP Safety Area S-2 represents the area within the vicinity of which aircrafts operate frequently or in conditions of reduced visibility at altitudes between 501 and 1,000 feet above ground level (AGL). Aviation safety hazards identified in the ALUP include mechanical failures, fuel exhaustion, loss of control during turns from downwind to base legs or from base to final legs of the traffic pattern, stall/spin incidents during engine‐out maneuvers in twin engine aircraft, and midair collisions. Because aircraft in Area S‐2 are at greater altitude and are less densely concentrated than in other portions of the Airport Land Use Planning Area (ALUPA), the overall level of aviation safety risk is considered to be lower than that in Area S‐1 or the RPZs (San Luis Obispo 2014). Approximately 16 acres in the northwest portion of the project site is within Safety Area S-2. ALUP Safety Policies. The ALUC reviews projects within the ALUPA to determine consistency with the ALUP. A proposed general plan, general plan amendment, specific plan, specific plan amendment, zoning ordinance, zoning ordinance amendment, building regulation modification, or individual development proposal may be determined to be inconsistent with the ALUP by the ALUC. Key policies used to review a project or local action for consistency with the ALUP include: • Policy S-1: Would permit or lack sufficient provisions to prohibit structures and other obstacles within the RPZs for any runway at the Airport, as depicted in ALUP Figure 4. • Policy S-2: Would permit or fail to adequately prohibit any future residential or nonresidential development or redevelopment which would create, within the site to be developed or redeveloped, a density greater than specified in ALUP Table 7 or any mixed-use development or redevelopment which would create, within the site to be developed or redeveloped, densities greater than illustrated in ALUP Table 7. • Policy S-3: Would permit or fail to adequately prohibit any future development project which specifies, entails, or would result in a greater building coverage than permitted by ALUP Table 7. • Policy S-4: Would permit or fail to adequately prohibit high intensity land uses or special land use functions (impaired egress uses or unusually hazardous uses), except that, when conditions specified by ALUP Table 7 for density adjustments have been determined to be met by the ALUC, high intensity land and/or special function uses may be allowed in ALUP Safety Area S-2. Pursuant to ALUP Policy S-4, increases in allowable residential and non-residential densities may be allowed with inclusion of an approved Airport Compatible Open Space Plan (ACOS), Clustered Development Zone (CDZ) and/or Detailed Area Plan, as described below. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-5 Airport Compatible Open Space Plan On July 21, 2004, the ALUC voted to amend the ALUP with inclusion of the City’s ACOS. The ACOS establishes open spaces in the areas around the Airport that can serve as reserve spaces (for aircraft emergency situations). By maintaining reserve spaces that keep certain land adjacent to the Airport free and clear from obstruction or from buildings and uses where people congregate, the ACOS improves airport safety while allowing for more intense development of urban areas. The areas identified as reserve space in the ACOS include land that is close to the Airport, in line with the main Airport runway, or along an over-flight area where aircraft typically operate at lower altitudes. Identification of these areas in the ACOS plan adds Airport safety to the list of reasons why these lands should not be developed (City of San Luis Obispo & County of San Luis Obispo 2013). Clustered Development Zone A CDZ may include any part or all of the area encompassed by an ACOS, and the geographic extent of each CDZ will be determined and specified by the responsible local agency. In order to be approved by the ALUC, an ACOS that proposes to establish one or more CDZs must be provided for the establishment, protection, and maintenance in perpetuity of the following percentages of each proposed CDZ as Reserve Space: • in ALUP Airport Safety Area S-1c: 35% of the gross area of the CDZ • in ALUP Airport Safety Area S-2: 25% of the gross area of the CDZ Detailed Area Plan The development of a Detailed Area Plan is a process which affords local agencies an opportunity to work with the ALUC in planning for development that meets local needs with respect to density while, by virtue of an increased level of specificity, protects the public against undue aviation safety hazards. Applicability of ALUP to Project Site As the project site lies within the ALUPA, the project is subject to the ALUP’s restrictions in building height, allowable uses, and population densities in the interest of safety and airport hazards. The project site is located within Airport Safety Areas S-1b and S-2. Regulations in the ALUP limit the density of residential and non-residential development. Local. City of San Luis Obispo General Plan. The City’s General Plan is intended to guide development and municipal service improvements in San Luis Obispo. It has eight elements: Land Use (adopted in 2014), Circulation (2014), Housing, (2015), Noise (1996), Safety (2012), Conservation and Open Space (2006), Parks and Recreation (2001), and Water and Wastewater (2010). As the core of the General Plan, the Land Use Element represents a generalized blueprint for the City’s future and sets forth a pattern for the orderly development of land within the City’s planning area. Land Use Element Policy 8.1.4 provides the regulatory basis for the San Luis Ranch Specific Plan in the City’s updated Land Use and Circulation Elements: Policy 8.1.4. SP-2, San Luis Ranch (Dalidio) Specific Plan Area. Purpose: This project site should be developed as a mixed use project that maintains the agricultural heritage of the site, provides a San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-6 commercial/office transition to the existing commercial center to the north, and provides a diverse housing experience. Protection of the adjacent creek and a well-planned integration into the existing circulation system will be required. The specific plan for this area should consider and address the following land use and design issues. A Provide land and appropriate financial support for development of a Prado Road connection. Appropriate land to support road infrastructure identified in the Final Project EIR (overpass or interchange) at this location shall be dedicated as part of any proposal and any area in excess of the project’s fair share of this facility shall not be included as part of the project site area used to calculate the required 50% open space. B Circulation connections to integrate property with surrounding circulation network for all modes of travel. C Connection to Froom Ranch and Calle Joaquin, if proposed, shall not bifurcate on- site or neighboring agricultural lands. Any connection to Calle Joaquin shall be principally a secondary / emergency access by design. D Development shall include a transit hub. Developer shall work with transit officials to provide express connections to Downtown area. E Maintain agricultural views along Highway 101 by maintaining active agricultural uses on the site, and maintain viewshed of Bishop Peak and Cerro San Luis. F Maintain significant agricultural and open space resources on site (see Policy 1.13.8.B). Land dedicated to Agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. G Where buffering or transitions to agricultural uses are needed to support viability of the agricultural use, these shall be provided on lands not counted towards the minimum size for the agriculture / open space component. Provide appropriate transition to agricultural uses on-site. H Integrate agricultural open space with adjacent SLO City Farm and development on property. I Site should include walkable retail and pedestrian and bicycle connections to surrounding commercial and residential areas. J Commercial and office uses shall have parking placed behind and to side of buildings so as to not be a prominent feature. K Neighborhood Commercial uses for proposed residential development shall be provided. L Potential flooding issues along Prefumo Creek need to be studied and addressed without impacting off-site uses. M All land uses proposed shall be in keeping with safety parameters described in this General Plan or other applicable regulations relative to the San Luis Obispo Regional Airport. N Historic evaluation of the existing farm house and associated structures shall be included. City of San Luis Obispo Zoning Regulations The City’s Zoning Regulations are intended to guide the development of the city in an orderly manner, based on the adopted general plan, to protect and enhance the quality of the natural and built environment, and to promote the public health, safety and general welfare by regulating the use of land and buildings and the location and basic form of structures. These regulations define 15 zoning districts in three categories: residential, non‐residential, and overlay. The residential zones include: low‐density residential, medium‐density residential, medium‐high‐density residential and high‐density residential. The non‐residential zones include: conservation/open space, office, public facility, neighborhood commercial, retail commercial, community commercial, Downtown commercial, tourist San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-7 commercial, service commercial, manufacturing, and business park. The overlay zones include: planned development, specific plan, historic, mixed‐use, and special considerations. City of San Luis Obispo’s Right to Overrule. In a circumstance where the ALUC makes a determination of inconsistency with the ALUP for a project, the City may overrule the ALUC determination of inconsistency as allowed under Section 21676.5 et. seq. of the Public Utilities Code. As directed by the General Plan, should an overrule action be taken, development shall be consistent with General Plan policies and standards that reflect direction in the State Aeronautics Act, FAA regulations concerning obstructions and notification, and guidance provided in the CALUPH (City of San Luis Obispo 2014). 4.9.2 Previous Program-Level Environmental Review The LUCE Update EIR previously analyzed land use impacts related to the adoption of the updated Land Use and Circulation Elements, including impacts at the San Luis Ranch Specific Plan Area. The LUCE Update EIR evaluated impacts in the Specific Plan area and assumed future development parameters of approximately 500 dwelling units and 470,000 square feet of non-residential uses (San Luis Obispo 2014). Based on this buildout of the Specific Plan area, the LUCE Update EIR identified potential land use conflicts with nearby agricultural operations associated with odors, dust, noise, pesticide or herbicide spraying, and trespass onto agricultural lands. The LUCE Update EIR determined that additional land use conflicts could result from noise and traffic, the impairment of views of important visual resources, shadows and loss of privacy, and short-term construction impacts. The LUCE Update EIR concluded that potential land use conflicts at the site could feasibly be reduced to a less than significant level with implementation of existing and updated Land Use and Circulation Element policies intended to ensure compatibility of new development with existing land uses. Because of the proximity of the Airport to planned residential growth areas in the southern part of the City, a key issue addressed in the LUCE Update EIR was consistency of future development under the updated Land Use and Circulation Elements with the ALUP and the potential risks or hazards associated with development near the Airport. The City determined that the technical studies and Council Agenda Reports prepared for and as a result of the LUCE Update EIR provided substantial evidence that the development of the San Luis Ranch Specific Plan Area under the updated General Plan land use designations would be consistent with the State Aeronautics Act (SAA) and guidance in the CALUPH associated with safety and noise. The LUCE Update EIR found that residential development envisioned in the Specific Plan area would exceed the ALUP’s density limits for Safety Zones S-1b and S-2, even if allowable increases in density under the Airport Compatible Open Space (ACOS) plan are assumed. In addition, it was found that non-residential development envisioned in the Specific Plan area could exceed the respective density limits for these safety zones. Nevertheless, the City’s findings associated with adoption of the LUCE Update EIR concluded the potential land use conflict impacts between development in the Specific Plan area and the ALUP would be less than significant for the following reasons (San Luis Obispo 2014): • The existing ALUP is outdated and non-compliant with statutory requirements that it be based on the Airport Master Plan; • The adopted plan zones and contours are not supported by the operations data in the adopted Airport Master Plan, FAA forecasts, technical compatibility analyses, or the San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-8 CALUPH, nor do the adopted zones further the objectives of the SAA based on any objective, verifiable data or standard; and • The City has developed data-supported zones, contours and standards that do further the objectives of the SAA, while not unreasonably restricting compatible development Based on this determination, the LUCE Update EIR concluded that potential inconsistency with the ALUP would present a policy impact without resulting in significant impacts on the physical environment. The City Council found during its review of airport compatibility for the LUCE Update that the 2014 Airport Land Use Compatibility Report (Appendix I) and Final LUCE Update EIR provided substantial evidence in the record that the City’s Airport Safety Zones accurately reflect Airport-related hazard zones as set forth in the CALUPH and supporting federal guidance, and that maps provided in the ALUP did not accurately reflect the actual extent of Airport-related safety zones (Council Agenda Report, City of San Luis Obispo 2014d). The ALUC made a determination that the LUCE Update EIR did not adequately address airport land use issues or comply with the ALUP policies. For the LUCE Update, the City Council elected to issue an overrule of the ALUC’s determination of inconsistency, including planned development in the LUCE Update at the programmatic level for planned Specific Plan areas, including the San Luis Ranch Specific Plan Area. The adopted LUCE Update included Airport Compatibility policies (Land Use Element Chapter 7) applicable to development within the Airport Influence Area. 4.9.3 Impact Analysis a. Methodology and Significance Thresholds. The following criteria are based on Appendix G of the State CEQA Guidelines. An impact is considered significant if the project would result in one or more of the following conditions: 1. Physically divide an established community; 2. Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including but not limited to the general plan, specific plan, local coastal program, clean air plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect; 3. Conflict with any applicable habitat conservation plan or natural community conservation plan. The Initial Study determined that development under the project would be designed to fit among existing surrounding urban development and would not physically divide an established community or conflict with any applicable habitat conservation plan or natural community conservation plans. Therefore, Thresholds 1 and 3 are not discussed further in this section. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of these impacts. Growth inducing impacts and impacts related to the use of substantial fuel and energy are discussed in Section 5.0, Other CEQA-Required Discussions. In addition, applicable policies from the SLOAPCD’s 2001 Clean Air Plan and the 2012 City of San Luis Obispo Climate Action Plan are discussed in Section 4.3, Air Quality, and 4.6, Greenhouse Gas Emissions. b. Impacts and Mitigation Measures. The following impact analysis examines the implementation of the Specific Plan at a programmatic level of detail. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-9 Impact LU-1 The project would be potentially inconsistent with adopted City policies in the General Plan designed to protect historical resources, and ensure provision of parkland. This would be a Class I, significant and unavoidable, impact. The San Luis Obispo General Plan is the principal tool the City uses when evaluating municipal service improvements and land use proposals. Land use decisions in the City are governed by the General Plan and must be consistent with the General Plan’s direction. This discussion focuses on those goals and policies in the City’s General Plan that relate to avoiding or mitigating environmental impacts, and an assessment of whether any potential inconsistency with these standards would create a significant physical impact on the environment. Only policies relevant and applicable to the project are included. Policies that are redundant between elements are omitted. In addition, some policies have been truncated in instances where the overall meaning of the policy would not be made unclear. The City’s Zoning Regulations, which implement the General Plan, do not apply to the project site because it is currently outside of the incorporated City. The proposed pre-zoning for the site is shown in Figure 2-4 in Section 2.0, Project Description, and is consistent with the proposed land use plan, shown in Figure 2-5. Therefore, the Specific Plan would not conflict with any existing zoning standards. It should be noted that this discussion is intended to guide policy interpretation, but is not intended to replace the City decision-making process. The final determination of consistency will be made by City Board of Supervisors when they act on the Specific Plan. The General Plan consistency determination is based on the Specific Plan’s overall consistency with the General Plan rather than strict adherence to every single principle and policy of each General Plan element. Table 4.9-1 describes the project’s preliminary consistency with applicable policies of the General Plan related to avoiding or mitigating environmental effects. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-10 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Land Use Element Policy 1.2: Urban Separation. Broad, undeveloped open spaces should separate the City from nearby urban areas. This element establishes a final edge for urban development. Potentially Consistent. The project site is located inside of the City’s Urban Reserve Line, which is intended to protect open space between the City and nearby jurisdictions. Furthermore, existing agricultural land on the project site is surrounded by existing urban development. Development in the Specific Plan area would not affect the City’s separation from nearby urban areas. Policy 1.4: Urban Edges Character. The City shall maintain a boundary between urban development and surrounding open land. Development just inside the boundary shall provide measures to avoid a stark-appearing edge between buildings in the city and adjacent open land. Such measures may include: using new or existing groves or windrows of trees, or hills or other landforms, to set the edge of development; increasing the required side-yard and rear-yard setbacks; and providing open space or agricultural transition buffers. Potentially Consistent. The project would preserve approximately 53 acres of prime farmland on-site in perpetuity, as well as approximately 7.67.4 acres in parks and open space on-site within the southern limit of the City’s Urban Reserve Line. These areas would serve as a transition buffer between urban development and adjacent open land. Policy 1.5: Jobs/Housing Relationship. The gap between housing demand (due to more jobs and college enrollment) and supply should not increase. Potentially Consistent. The project includes mixed uses and workforce housing to balance the provision of jobs and housing within the San Luis Ranch Specific Plan Area and the City. Policy 1.7.1: Urban Reserve. The City shall maintain an urban reserve line containing the area around the City where urban development might occur (Land Use Element Figure 3, Land Use Diagram). Urban uses within this line should only be developed if consistent with City-approved plans. Non-urban agricultural, open space, and wildlife corridor uses are also encouraged within the urban reserve, as interim or permanent uses shown on City-approved plans. Potentially Consistent. The 131-acre San Luis Ranch property is currently outside the City, but within its Sphere of Influence and Urban Reserve Line. The site is currently designated for future urban use under the City’s Land Use Element. The project would involve annexation of the 131- acre property to the City. The project includes development of a mix of residential, commercial, and office uses while preserving substantial areas of open space and agriculture on the property. The Specific Plan and related actions would allow for the development of the San Luis Ranch area as identified in the City’s General Plan as Special Focus Area SP-2. The intent is for the project to be consistent with the development parameters described in the General Plan. Policy 1.8.1: Open Space Protection. Within the City's planning area and outside the urban reserve line, undeveloped land should be kept open. Prime agricultural land, productive agricultural land, and potentially productive agricultural land shall be protected for farming. Scenic lands, sensitive wildlife habitat, and undeveloped prime agricultural land shall be permanently protected as open space. Potentially Consistent. The project site is located within the City’s planning area and the urban reserve line, and it would be annexed into the City under the project. The project would contribute to the protection of agricultural land within this City planning area by preserving approximately 53 acres of prime farmland on-site in perpetuity, as well as San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-11 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis approximately 7.67.4 acres in parks and open space. In addition, the project includes a commitment to procure an off-site agricultural conservation easement/deed restriction such that one half of total land on-site is preserved for agricultural and open space use. In addition, the project would provide restored and enhanced wildlife habitat areas. Policy 1.8.5: Building Design and Siting. All new buildings and structures should be subordinate to and in harmony with the surrounding landscape. The City should encourage County adoption of regulations prohibiting new structures on ridge lines or in other visually prominent or environmentally sensitive locations, and allowing transfer of development rights from one parcel to another in order to facilitate this policy. Potentially Consistent. As discussed in Impact AES-2 in Section 4.1, Aesthetics, the design features of development in the project site would be consistent with the visual character of surrounding residential and commercial land uses. In addition, the City’s Architectural Review Commission (ARC) would review and approve the design for proposed buildings, examining the layout, building design, its relationship to the neighborhood in which it would be located, landscaping, parking, signage, lighting, and other features affecting the project’s appearance. Policy 1.9.1: Agricultural Protection. The City shall support preservation of economically viable agricultural operations and land within the urban reserve and city limits. The City should provide for the continuation of farming through steps such as provision of appropriate general plan designations and zoning. Policy 1.9.2: Prime Agricultural Land. The City may allow development on prime agricultural land if the development contributes to the protection of agricultural land in the urban reserve or greenbelt by one or more of the following methods, or an equally effective method: acting as a receiver site for transfer of development credit from prime agricultural land of equal quantity; securing for the City or for a suitable land conservation organization open space or agricultural easements or fee ownership with deed restrictions; helping to directly fund the acquisition of fee ownership or open space easements by the City or a suitable land conservation organization. Development of small parcels which are essentially surrounded by urbanization need not contribute to agricultural land protection. Policy 1.10.2: Means of Protection. The City shall require that open space be preserved either by dedication of permanent easements or transfer of fee ownership to the City, the County, or a responsible, nonprofit conservation organization. Potentially Consistent. As discussed in Section 4.2, Agricultural Resources, the project would result in the direct conversion of approximately 56 59 acres of prime farmland to non-agricultural use; however, the project would contribute to the protection of agricultural land within the urban reserve by preserving approximately 53 acres of prime farmland on-site in perpetuity, as well as approximately 7.67.4 acres in parks and open space. In addition, the project includes a commitment to procure an off-site agricultural conservation easement/deed restriction such that one half of total land on-site is preserved for agricultural and open space use. Mitigation Measure AG-1, Agricultural Conservation, would ensure that for every one acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that would be permanently converted to non-agricultural use as a result of project development, one acre of land of comparable agricultural productivity shall be preserved in perpetuity. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-12 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 1.10.3: Public Access. Areas preserved for open space should include public trail access, controlled to protect the natural resources, to assure reasonable security and privacy of dwellings, and to allow continuing agricultural operations. Public access through production agricultural land will not be considered, unless the owner agrees. Potentially Consistent. The proposed open space in the northwestern portion of the project site along Prefumo Creek would include a link to the Bob Jones Regional Bicycle Trail. Public trail access would not be provided through the portion of the site where agricultural cultivation would continue. Policy 1.10.4: Design Standards. The City shall require cluster development to: A. Be screened from public views by land forms or vegetation, but not at the expense of habitat. If the visually screened locations contain sensitive habitats or unique resources as defined in the Conservation and Open Space Element, development should be avoided in those areas and instead designed to cluster in the form of vernacular farm building complexes, to blend into the traditional agricultural working landscape. B. Be located on other than prime agricultural land and be situated to allow continued agricultural use. C. Prohibit building sites and roads within stream corridors and other wetlands, on ridge lines, rock outcrops, or visually prominent or steep hillsides, or other sensitive habitats or unique resources as defined in the Conservation and Open Space Element. D. Preserve historic or archaeological resources. Potentially Inconsistent (with 1.10.4.D). A. Development would be clustered on the western portion of the project site, so that vegetation in open space along Froom Ranch Way would screen it from public views from U.S. 101. Although the project would result in conversion of approximately 56 59 acres of prime farmland to non- agricultural, development would be clustered to preserve approximately 53 acres of the site in agricultural use. B. Refer to discussion of Land Use Element Policy 1.9.2. C. As described in Section 4.4, Biological Resources, the project would have a potentially significant but mitigable impact on sensitive habitats, including riparian areas. Mitigation Measures BIO-2(a) through BIO-2(c) would ensure that potential habitat impacts would remain less than significant. D. As described in Section 4.5 Cultural Resources, existing structures on the site are individually eligible for historic designation. The project includes the adaptive reuse and relocation of the existing main residence and the historic former spectators’ barn/viewing stand to new locations on the site. Mitigation Measure CR-1(a) would reduce impacts to these historic resources to the maximum extent feasible. Demolition of the historic main barn, which is part of the San Luis Ranch Complex, would conflict with Conservation and Open Space Element Policies 3.3.1 and 3.3.2. Salvageable materials from the main barn are proposed to be reused to the greatest extent possible. Mitigation Measures CR-1(b) and CR-1(c) would reduce significant direct impacts to the remainder of the historically significant San Luis Ranch Complex to the maximum extent feasible. However, the San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-13 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis potential impact to these historic resources would remain significant and unavoidable. Policy 1.13.5: Annexation in Airport Area. Properties in the Airport Area Specific Plan may only be annexed if they meet the following criteria: A. The property is contiguous to the existing city limits; and B. The property is within the existing urban reserve line; and C. The property is located near to existing infrastructure; and D. Existing infrastructure capacity is available to serve the proposed development; and E. A development plan for the property belonging to the applicant(s) accompanies the application for annexation; and F. The applicant(s) agree to contribute to the cost of preparing the specific plan and constructing area- wide infrastructure improvements according to a cost-sharing plan maintained by the City. Potentially Consistent. The project would involve annexation of the 131-acre San Luis Ranch property to the City. The project site is entirely surrounded by the existing City limit, within the existing urban reserve line, and adjacent to urban development served by existing infrastructure. As discussed in Section 4.14, Issues Addressed in the Initial Study, the Specific Plan Area could be adequately served by the City’s sewer, water, and wastewater infrastructure, provided that impact fees are collected for wastewater facilities. The Specific Plan also comprises a development plan for the property and includes a cost-sharing plan for infrastructure improvements. Policy 1.13.8: Open Space. The City shall require that each annexation help secure permanent protection for areas designated Open Space, and for the habitat types and wildlife corridors within the annexation area that are identified in the Conservation and Open Space Element. Properties, which are both along the urban reserve line and on hillsides, shall dedicate land or easements for about four times the area to be developed (developed area includes building lots, roads, parking and other paved areas, and setbacks required by zoning). (See also Policy 6.4 and Policies 6.4.1 – 6.4.7). The following standards shall apply to the indicated areas: A. Airport Area Specific Plan properties shall secure protection for any on-site resources as identified in the Conservation and Open Space Element. These properties, to help maintain the greenbelt, shall also secure open space protection for any contiguous, commonly owned land outside the urban reserve. If it is not feasible to directly obtain protection for such land, fees in lieu of dedication shall be paid when the property is developed, to help secure the greenbelt in the area south of the City’s southerly urban reserve line. B. San Luis Ranch property (outside the city limit and generally bounded by Highway 101 and Madonna Road) shall dedicate land or easements for approximately one-half of the ownership that is to be preserved as open space. C. Foothill Annexation: The northern portion of the Foothill property, and the creek area shall be annexed as open space. Development on this site should be clustered or located near Foothill Boulevard, with the northern portion of the site and creek area preserved as open space. Potentially Consistent. The project would involve annexation of the San Luis Ranch property and dedication of land or easements for approximately one-half of the ownership that is to be preserved as open space. (Refer to discussion of Land Use Element Policy 1.9.2). The project site is not located adjacent to the urban reserve line, on hillsides, or within the Airport Area Specific Plan, or the Foothill property. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-14 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 1.13.10: Solid Waste Capacity. In addition to other requirements for adequate resources and services prior to development, the City shall require that adequate solid waste disposal capacity exists before granting any discretionary land use approval which would increase solid waste generation. Potentially Consistent. As discussed in Section 4.14, Issues Addressed in the Initial Study, the project would be served by the San Luis Garbage Company. The incremental additional waste stream generated by this project would not create significant impacts related to the solid waste disposal capacity of landfills. Policy 1.8.6: Wildlife Habitat. The City shall ensure that continuous wildlife habitat – including corridors free of human disruption - are preserved, and, where necessary, created. Potentially Consistent. The San Luis Ranch Specific Plan would provide permanently dedicated open space and restored and enhanced wildlife habitat areas. Policy 1.8.7: Trees Outside City Limits. The City shall preserve significant trees, particularly native species, outside its limits and in the greenbelt on lands owned or leased by the City or for which the City has an easement. For other areas in the greenbelt, the City will work with the County, Cal Poly, and other public agencies to protect these trees. Potentially Consistent. As discussed in Section 4.4, Biological Resources, the project would result in potential impacts to Great Blue Heron and Monarch Butterflies due removal of the on-site eucalyptus trees which serve as overwintering habitat for these species. Mitigation Measures BIO-1(f), BIO-1(h), and BIO-2(b) would ensure that impacts to trees and the habitat they provide would remain less than significant. Policy 2.3.7: Natural Features. The City shall require residential developments to preserve and incorporate as amenities natural site features, such as land forms, views, creeks, wetlands, wildlife habitats, wildlife corridors, and plants. Potentially Consistent. The Specific Plan includes landscaping with drought tolerant, native species, as well as restoration and enhancement of creeks, drainages, and habitat areas. Policy 2.3.8: Parking. The City shall discourage the development of large parking lots and require parking lots be screened from street views. In general, parking should not be located between buildings and public streets. Potentially Consistent. The Specific Plan does not include any standards for the placement of parking associated with proposed on-site uses. However, development on the project site would be required to adhere to this policy. In addition, the ARC would review and approve the design for proposed buildings, examining the layout, building design, its relationship to the neighborhood in which it would be located, landscaping, parking, signage, lighting, and other features affecting the project’s appearance. Policy 2.3.10: Site Constraints. The City shall 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. Potentially Consistent. The project would dedicate approximately 7.67.4 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to riparian habitat along these corridors. Access routes and construction staging areas would be located outside of wetlands and riparian areas to the maximum extent practicable and would not permanently interfere with the San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-15 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis movement of resident or migratory fish or wildlife species or migratory wildlife corridors. Policy 3.2.1: Locations for Regional Attractions. The City should focus its retailing with regional draw in the locations of downtown, the area around the intersection of Madonna Road and Highway 101, and the area around Highway 101 and Los Osos Valley Road. Policy 3.2.2: Specialty Store Locations. The City shall direct most specialty retail stores to locate in the Downtown Core, in the Madonna Road area, or the Los Osos Valley Road area, and in other community shopping areas identified by the Community Commercial district (see the Community Commercial section) where they will not detract from the role of the Downtown Core as the City’s primary concentration of specialty stores; some may also be in neighborhood shopping centers so long as they are a minor part of the centers and serve neighborhood rather than citywide or regional markets. Policy 3.8.3: Neighborhood Centers. The City shall identify suitable sites for new or expanded neighborhood centers as it prepares specific plans and development plans. Potentially Consistent. The project would include development of neighborhood retail uses that may include specialty retail stores in the Madonna Road area. The project would not include regional attractions that would detract from other identified commercial areas in the City. Policy 3.3.1: New or Expanded Areas of Neighborhood Commercial Use. The City shall provide for new or expanded areas of neighborhood commercial uses that: A. Are created within, or extended into, nonresidential areas adjacent to residential neighborhoods; B. Provide uses to serve nearby residents, not the whole City; C. Have access from arterial streets, and not increase traffic on residential streets; D. Have safe and pleasant pedestrian access from the surrounding service area, as well as good internal circulation; E. Are designed to be pedestrian-oriented, and architecturally compatible with the adjacent neighborhoods being served. Pedestrian-oriented features of the project design should include: i. Off-street parking areas located to the side or rear of buildings rather than between buildings and the street; ii. Landscaped areas with public seating; and iii. Indoor and outdoor space for public use, designed to provide a focus for some neighborhood activities. Potentially Consistent. The project would include development of neighborhood commercial uses adjacent to the proposed residential neighborhoods on the project site. These uses may include specialty retail stores that would to serve nearby residents. The project would also provide pedestrian and bicycle facilities from nearby residential uses to the proposed neighborhood commercial uses. Furthermore, development on the project site would be required to adhere to the City’s policies related to the provision of parking areas. In addition, the ARC would review and approve the design for proposed buildings, examining the layout, building design, its relationship to the neighborhood in which it would be located, landscaping, parking, signage, lighting, and other features affecting the project’s appearance. Policy 6.3.1: Open Space and Greenbelt Designations. The City shall designate the following types of land as open space: A Upland and valley sensitive habitats or unique resources, as defined in the Conservation and Open Space Element, including corridors which connect habitats. B Undeveloped prime agricultural soils which are to remain in agricultural use as provided in Policy 1.9.2. C Those areas which are best suited to non-urban uses due to: infeasibility of providing proper access or utilities; excessive slope or slope instability; wildland fire hazard; noise exposure; Potentially Consistent. The Specific Plan would not involve hillside development or the creation of new parcels within the greenbelt. As described in Section 4.4, Biological Resources, the project would have a potentially significant but mitigable impact on sensitive habitats, including riparian areas. Mitigation Measures BIO-2(a) through BIO-2(c) would San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-16 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis flood hazard; scenic value; wildlife habitat value, including sensitive habitats or unique resources as defined in the Conservation and Open Space Element; agricultural value; and value for passive recreation. D A greenbelt, outside the urban reserve, that surrounds the ultimate boundaries of the urban area, and which should connect with wildlife corridors that cross the urbanized area. E Sufficient area of each habitat type to ensure the ecological integrity of that habitat type within the urban reserve and the greenbelt, including connections between habitats for wildlife movement and dispersal; these habitat types will be as identified in the natural resource inventory, as discussed in the “Background to this Land Use Element Update” and in Community Goal #8. Policy 6.3.2: Open Space Uses include: watershed protection; wildlife and native plant habitat; grazing; cultivated crops; and passive recreation. The City shall require that buildings, lighting, paving, use of vehicles, and alterations on open space lands are minimized, so rural character and resources are maintained. Buildings and paved surfaces shall not exceed the following: where a parcel smaller than ten acres already exists, five percent of the site area; on a parcel of ten acres or more, three percent. (As explained in the Conservation and Open Space Element, the characteristics of an open space area may result in it being suitable for some open space uses, but not the full range.) Parcels within Open Space areas should not be further subdivided. ensure that potential habitat impacts would remain less than significant. The Specific Plan would preserve approximately 53 acres of prime farmland on-site in perpetuity, as well as approximately 7.67.4 acres in parks and open space. Agricultural operations would be protected and highlighted through on-site and off-site agricultural preservation and the proposed Agricultural Heritage Facilities & Learning Center. Policy 6.6.1: Creek and Wetlands Management Objectives. The City should manage its lake, creeks, wetlands, floodplains, and associated wetlands to achieve the multiple objectives of: A Maintaining and restoring natural conditions, and fish and wildlife habitat; B Preventing loss of life and minimizing property damage from flooding; C Providing recreational opportunities which are compatible with fish and wildlife habitat, flood protection and use of adjacent private properties; and D Recognizing and distinguishing between those sections of creeks and Laguna Lake which are in previously urbanized areas, such as the downtown core and sections which are in largely natural areas. Those sections already heavily impacted by urban development and activity may be appropriate for multiple use whereas creeks and lakeshore in a more natural state shall be managed for maximized ecological value. Potentially Consistent. As described in Section 4.4, Biological Resources, the project would have a potentially significant but mitigable impact on sensitive habitats, including riparian areas. Mitigation Measures BIO-2(a) through BIO-2(c) would ensure that potential habitat impacts would remain less than significant. The Specific Plan would dedicate approximately 7.67.4 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to riparian habitat along these corridors. The Specific Plan includes no built structures within the Plan Area’s flood plain. Policy 6.6.2: Citywide Network. The City shall include the lake, creeks, and wetlands as part of a citywide and regional network of open space, parks, and – where appropriate – trails, all fostering understanding, enjoyment, and protection of the natural landscape and wildlife. Potentially Consistent. The Specific Plan would connect with the City’s park and open space system with convenient access through the various bike paths and pedestrian trails and complete a segment of the Bob Jones Regional Bicycle Trail. Visitors to the Agricultural Heritage Facilities & Learning Center would be able to access the facility via the Bob Jones Regional Bicycle Trail. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-17 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 6.6.3: Amenities and Access. The City shall require new public or private development adjacent to the lake, creeks, and wetlands to respect the natural environment and incorporate the natural features as project amenities, provided doing so does not diminish natural values. Developments along creeks should include public access across the development site to the creek and along the creek, provided that wildlife habitat, public safety, and reasonable privacy and security of the development can be maintained, consistent with the Conservation and Open Space Element. Potentially Consistent. The Specific Plan would not conflict with any Zoning Code requirements regarding development adjacent to creeks, wetlands, and lakes. The project would dedicate approximately 7.67.4 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to riparian habitat along these corridors. Policy 6.6.5: Runoff Reduction and Groundwater Recharge. The City shall require the use of methods to facilitate rainwater percolation for roof areas and outdoor hardscaped areas where practical to reduce surface water runoff and aid in groundwater recharge. Policy 6.6.6: Development Requirements. The City shall require project designs that minimize drainage concentrations and impervious coverage. Floodplain areas should be avoided and, where feasible, any channelization shall be designed to provide the appearance of a natural water course. Policy 6.6.7: Discharge of Urban Pollutants. The City shall require appropriate runoff control measures as part of future development proposals to minimize discharge of urban pollutants (such as oil and grease) into area drainages. Policy 6.6.8: Erosion Control Measures. The City shall require adequate provision of erosion control measures as part of new development to minimize sedimentation of streams and drainage channels. Potentially Consistent. As discussed in Section 4.8, Hydrology and Water Quality, the Specific Plan details requirements for best management practices (BMPs) regarding site drainage and impervious coverage consistent with San Luis Obispo Zoning Code Chapter 12.08 (Urban Storm Water Quality Management and Discharge Control). Policy 6.7: Creeks and Flooding Programs. Policy 6.7.1: Previously Developed Areas. To limit the potential for increased flood damage in urbanized areas, the City shall ensure new development complies with the City’s flood plain ordinance, setbacks, specific plans, and design standards to minimize flood damage and flood plain encroachment. Policy 6.7.2: National Flood Program. The City shall administer the National Flood Insurance Program standards. Policy 6.7.3: Creekside Care and Notification. In maintaining creek channels to accommodate flood waters, the City shall notify owners of creeks and adjacent properties in advance of work, and use care in any needed removal of vegetation. Policy 6.7.4: Evaluate Use of Financing Districts. The City shall evaluate the feasibility of establishing a financing district or districts to address flood concerns in affected areas. Cost and benefits will be weighed in relation to the cost of flood insurance for affected property owners. Potentially Consistent. As described in Section 4.4, Biological Resources, the project would have a potentially significant but mitigable impact on sensitive habitats, including riparian areas. Mitigation Measures BIO-2(a) through BIO-2(c) would ensure that potential habitat impacts would remain less than significant. The Specific Plan would dedicate approximately 7.67.4 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to riparian habitat along these corridors. As discussed in Impact HWQ-2 in Section 4.8, Hydrology and Water Quality, the Specific Plan Area is located partly within a 100-year floodplain. However, residential development would be located in the portion of the site that is not within the 100- year flood plain. Compliance with local flood management measures including Special Floodplain Management Zone Regulation and the City Waterways Management Plan would minimize the impact of placing structures within the 100-year flood plain. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-18 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 7.3: Airport Land Use Plan. Land use density and intensity shall carefully balance noise impacts and the progression in the degree of reduced safety risk further away from the runways, using guidance from the San Luis Obispo County Regional Airport Land Use Plan, State Aeronautics Act, and California Airport Land Use Planning Handbook guidelines. The City shall use the Airport Master Plan forecasts of aviation activity as a reasonably foreseeable projection of ultimate aviation activity sufficient for long-term land use planning purposes. Prospective buyers of property subject to airport influence should be so informed. Policy 7.4: Airport Safety Zones. Density and allowed uses within the Airport Safety Zones shall be consistent with the San Luis Obispo County Regional Airport Land Use Plan unless the City overrides a determination of inconsistency in accordance with Section 21676 and 21676.5 et. seq. of the Public Utilities Code. If the City overrides a determination, all land uses shall be consistent with the State Aeronautics Act and guidance provided in the California Airport Land Use Planning Handbook guidelines, City policies, and noise standards as substantiated by the San Luis Obispo County Airport Master Plan activity forecasts as used for noise planning purposes. Policy 7.5: Airport Noise Compatibility. The City shall use the aircraft noise analysis prepared for the Airport Master Plan Environmental Impact Report as an accurate mapping of the long term noise impact of the airport’s aviation activity that is tied to the ultimate facilities development depicted in the FAA-approved Airport Layout Plan. The City shall use the 60 dB CNEL aircraft noise contour (FAA and State aircraft noise planning standard) as the threshold for new urban residential areas. Interiors of new residential structures shall be constructed to meet a maximum 45 dB CNEL. Potentially Consistent. The Specific Plan would preserve the southeastern portion of the site in agricultural use. Residential and commercial uses are clustered in the northern and western portions of the site adjacent to Madonna Road and existing residential (to the west) and commercial (to the east) areas. As discussed in Impact LU- 4, although the project would conflict with the ALUP’s density standards, based on this analysis the 2014 Airport Land Use Compatibility Report, airport land use planning impacts to future residents and commercial employees or patrons the project would be consistent with the City’s Airport Safety Zones. The Specific Plan’s uses are consistent with the applicable Airport Master Plan, California State Aeronautics Act and CALUPH standards and guidelines, as well as the City’s safety and noise standards. Policy 8.1.4: SP-2, San Luis Ranch (Dalidio) Specific Plan Area. The project site should be developed as a mixed use project that maintains the agricultural heritage of the site, provides a commercial/ office transition to the existing commercial center to the north, and provides a diverse housing experience. Protection of the adjacent creek and a well-planned integration into the existing circulation system will be required. The specific plan for this area should consider and address the following land use and design issues: a. Provide land and appropriate financial support for development of a Prado Road connection. Appropriate land to support road infrastructure identified in the Final Project EIR (overpass or interchange) at this location shall be dedicated as part of any proposal and any area in excess of the project’s fair share of this facility shall not be included as part of the project site area used to calculate the required 50% open space. b. Circulation connections to integrate property with surrounding circulation network for all modes of travel. c. Connection to Froom Ranch and Calle Joaquin, if proposed, shall not bifurcate on- site or neighboring agricultural lands. Any connection to Calle Joaquin shall be principally a secondary / emergency access by design. d. Development shall include a transit hub. Developer shall work with transit officials to provide express connections to Downtown area. e. Maintain agricultural views along Highway 101 by maintaining active agricultural uses on the site, Potentially Consistent. The project would allow for mixed- use development on the San Luis Ranch property, providing a commercial transition to the existing commercial center to the north, which may include neighborhood retail, restaurants, offices, and a hotel. The project includes a range of housing types, from detached single-family units to attached multi-family dwellings. The agricultural heritage of the site would be protected by preserving approximately 53 acres of the site in agricultural cultivation and building an Agricultural Heritage Facilities & Learning Center intended to promote the education of local residents and agritourism. The project would dedicate approximately 7.67.4 acres of internal open space, primarily along the Prefumo Creek and Cerro San Luis Channel, which would reduce permanent adverse impacts to riparian habitat along these corridors. In addition, the project would be consistent with items a through n in Policy 8.1.4: a. The project would be required to provide or pay fair share San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-19 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis and maintain viewshed of Bishop Peak and Cerro San Luis. f. Maintain significant agricultural and open space resources on site (see Policy 1.13.8.B). Land dedicated to Agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. g. Where buffering or transitions to agricultural uses are needed to support viability of the agricultural use, these shall be provided on lands not counted towards the minimum size for the agriculture / open space component. Provide appropriate transition to agricultural uses on-site. h. Integrate agricultural open space with adjacent SLO City Farm and development on property. i. Site should include walkable retail and pedestrian and bicycle connections to surrounding commercial and residential areas. j. Commercial and office uses shall have parking placed behind and to side of buildings so as to not be a prominent feature. k. Neighborhood Commercial uses for proposed residential development shall be provided. l. Potential flooding issues along Prefumo Creek need to be studied and addressed without impacting off-site uses. m. All land uses proposed shall be in keeping with safety parameters described in this General Plan or other applicable regulations relative to the San Luis Obispo Regional Airport. n. Historic evaluation of the existing farm house and associated structures shall be included. This specific plan shall meet the following performance standards. Type Designations Allowed % of Site Minimum Maximum Residential LDR, MDR, MHDR, HDR 350 units 500 units Commercial NC, CC 50,000 sf 200,000 sf Office/High tech O 50,000 sf 150,000 sf Hotel/Visitor- serving 200 rooms Parks PARK 5.8 acres Open Space/ Agriculture OS, AG Minimum 50% 1 No maximum Public n/a Infrastructure n/a 1. The City Council may consider allowing a portion of required open space to be met through off-site dedication provided: a. A substantial multiplier for the amount of open space is provided for the off-site property exchanged to meet the on-site requirement; and b. Off-site land is of similar agricultural and visual value to the community; and c. Off-site land is protected through an easement, dedication or fee title in perpetuity for agriculture/ open space. fees for an extension of Prado Road and an overpass or interchange connection for Prado Road. Refer Section 4.11, Transportation and Circulation. b, c. The proposed circulation system would connect the project site with surrounding multi-modal facilities, including the Bob Jones Regional Bicycle Trail, and would not bifurcate the site or neighboring agricultural lands. d. The Specific Plan includes a transit center that would provide direct transit access between the site and downtown San Luis Obispo. e-h. Development would be clustered to the west to preserve agricultural views along U.S. 101. Approximately 53 acres of land would be preserved for working agricultural operations on-site. Agricultural land would be preserved next to existing farmland at the San Luis Obispo City Farm. i. The project would establish links in the City’s Bicycle Transportation Plan, constructing a segment of the Bob Jones Regional Bicycle Trail and providing a connection from Laguna Lake area neighborhoods and businesses along Madonna Road to the southern portion of the City Limits at Froom Ranch Way. j. The Specific Plan does not include any standards for the placement of parking associated with commercial and office uses; however, site-specific commercial development on the project site would be required to adhere to this policy. k. As shown in Figure 2-5 in Section 2.0, Project Description, the proposed zoning for the Specific Plan Area would allow Neighborhood Commercial uses on the northeast portion of the site. l. As described in Section 4.4, Biological Resources, the project would have a potentially significant but mitigable impact on sensitive habitats, including riparian areas such as Prefumo Creek and its tributaries. Mitigation Measures BIO- 2(a) through BIO-2(c) would ensure that potential habitat impacts would remain less than significant. m. Refer to discussion of Land Use Element Policy 7.4. n. As described in Section 4.5, Cultural Resources, a Cultural Resources Study was prepared for the project site in October 2016, and includes a historic evaluation of the San Luis Ranch Complex and associated structures San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-20 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis (Appendix G). As shown in Table 2-3 in Section 2.0, Project Description, the proposed land uses would be generally consistent with the performance standards described in Land Use Element Policy 8.1.4. Approximately 53 acres of prime farmland would be preserved on-site. The project also includes a commitment to procure an off-site agricultural conservation easement/deed restriction, such that the equivalent of 50 percent of the site acreage would be preserved. However, only 3.4 acres of parks would be provided, which is lower than the minimum of 5.8 acres required by the performance standards described in Land Use Element Policy 8.1.4. However, as described in Section 4.11, Recreation, with payment of the City’s required parkland in- lieu fees to ensure compliance with the policies and performance standards in the City’s General Plan as part of the project, impacts associated with parks and recreational facilities would be less than significant. Policy 10.4: Encouraging Walkability. The City shall encourage projects which provide for and enhance active and environmentally sustainable modes of transportation, such as pedestrian movement, bicycle access, and transit services. Potentially Consistent. The project would provide for a walkable community by constructing a segment of the Bob Jones Regional Bicycle Trail and providing a connection from Laguna Lake area neighborhoods and businesses along Madonna Road to the southern portion of the City Limits at Froom Ranch Way. The project also would create interior bicycle trails and lanes, including a Class I Bike Trail and Class II Bike lanes, and complete a segment of the Bob Jones Regional Bicycle Trail. Circulation Element Policy 3.1.6: Service Standards. The City shall implement the following service standards for its transit system and for development that is proximate to the transit network: A. Routes, schedules and transfer procedures of the City and regional transit systems should be coordinated to encourage use of buses. B. In existing developed areas, transit routes should be located within 1/4 mile of existing businesses or dwellings. Potentially Consistent. The project would include a transit center that would provide transit access between the San Luis Ranch Specific Plan Area and downtown San Luis Obispo. The location of the proposed transit center would be coordinated with SLO Transit and the Regional Transit Authority upon submittal of individual project plans. In San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-21 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis C. In City expansion areas, employment-intensive uses or medium, medium-high or high density residential uses should be located within 1/8 mile of a transit route. D. The spacing of stops should balance patron convenience and speed of operation. Policy 3.1.7: Transit Service Access. New development should be designed to facilitate access to transit service. addition, revised San Luis Obispo Transit bus routes through the project site would be coordinated with the City based on an analysis of expected demand. Policy 4.1.4: New Development. The City shall require that new development provide bikeways, secure bicycle storage, parking facilities and showers consistent with City plans and development standards. When evaluating transportation impacts, the City shall use a Multimodal Level of Service analysis. Potentially Consistent. Refer to discussion of Land Use Element Policy 10.4 for a discussion of proposed bikeways on the project site. As discussed in Chapter 6 of the Specific Plan, new development on the project site would provide both short-term and secure long-term bicycle parking facilities. Policy 5.1.2: Sidewalks and Paths. The City should complete a continuous pedestrian network connecting residential areas with major activity centers as well as trails leading into City and county open spaces. Policy 5.1.4: Pedestrian Access. New or renovated commercial and government public buildings shall provide convenient pedestrian access from nearby sidewalks and pedestrian paths, separate from driveways and vehicle entrances. Potentially Consistent. The Specific Plan would connect with the City’s park and open space system through bike paths and pedestrian trails. The project would provide for a continuous pedestrian network by constructing a segment of the Bob Jones Regional Bicycle Trail and providing a connection from Laguna Lake area neighborhoods and businesses along Madonna Road to the southern portion of the City Limits at Froom Ranch Way. Streets in the project site would also devote space to multi-modal access, including pedestrian access, and collector streets would have landscaped parkways at least six feet total on each side of the road. Policy 6.1.2: Multimodal Level of Service (LOS) Objectives, Service Standards, and Significance Criteria. The City shall strive to achieve level of service objectives and shall maintain level of service minimums for all four modes of travel; Pedestrians, Bicyclists, Transit, & Vehicles per Table 2 and the Highway Capacity manual. Travel Mode LOS Objective Minimum LOS Standard Bicycle B D Pedestrian B C Transit C Baseline LOS or LOD D, whichever is lower Vehicle C E (Downtown), D (All Other Routes) Potentially Inconsistent. The Multimodal Transportation Impact Study (Appendix L) evaluated projected transportation impact conditions associated with development of the project. As discussed in Section 4.12 Transportation and Circulation, traffic conditions for automobile and bike, pedestrian and transit LOS were evaluated under project conditions near term (2023) and cumulative (2035) conditions. Mitigation Measures in Section 4.12, Transportation, have been included to reduce potential impacts to regional vehicle and multimodal traffic to the maximum extent feasible. However, as described in Section 4.12, Transportation, impacts associated with multimodal level of service standards at several study area intersections under Existing Plus Project, Near-Term Plus Project, and Cumulative Plus Project conditions were found to remain San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-22 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis significant and unavoidable with mitigation. Policy 15.1.2. Development Along Scenic Routes. The City will preserve and improve views of important scenic resources form streets and roads. Development along scenic roadways should not block views or detract from the quality of views. A. Projects, including signs, in the viewshed of a scenic roadway should be considered as "sensitive" and require architectural review. B. Development projects should not wall off scenic roadways and block views. C. As part of the city's environmental review process, blocking of views along scenic roadways should be considered a significant environmental impact. D. Signs along scenic roadways should not clutter vistas or views. E. Street lights should be low scale and focus light at intersections where it is most needed. Tall light standards should be avoided. Street lighting should be integrated with other street furniture at locations where views are least disturbed. However, safety priorities should remain superior to scenic concerns. F. Lighting along scenic roadways should not degrade the nighttime visual environment and night sky per the City’s Night Sky Preservation Ordinance. Potentially Consistent. The project would involve development adjacent to U.S. 101, which is eligible for designation as a State scenic highway and is identified in the City’s General Plan as a scenic corridor. The project would cluster development on the northern portion of the project site while preserving approximately 53 acres of prime farmland on-site in perpetuity, as well as approximately 7.67.4 acres in parks and open space adjacent to the highway. As discussed in Impact AES-1 in Section 4.1, Aesthetics, commercial development in the northeast corner of the site would be adjacent to and highly visible from U.S. 101; however, the outside of the commercial area facing the highway would be partially blocked from view by landscape screening. Background views from the east would continue to be visible at the same extent as they are currently, as the heights of the proposed structures would not project above the existing tree line to the west or the existing development to the north. As a result, scenic views of Cerro San Luis and the Irish Hills would remain visible from U.S. 101. Housing Element Policy 2.4. Encourage housing production for all financial strata of the City's population, in the proportions shown in the Regional Housing Needs Allocation, for the 2014 - 2019 planning period. These proportions are: extremely low income, 12 percent, very low income, 12 percent; low income, 16 percent; moderate income, 18 percent; and above moderate income, 42 percent. 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. Policy 4.2. Include both market-rate and affordable units in apartment and residential condominium projects and intermix the types of units. Affordable units should be comparable in size, appearance and basic quality to market-rate units. Policy 5.3. Encourage the development of housing above ground-level retail stores and offices to provide housing opportunities close to activity centers and to use land efficiently. Policy 5.4. In general, housing developments of twenty (20) or more units should provide a variety of dwelling types, sizes or forms of tenure. Potentially Consistent. The proposed mixed-use development would include 580 residential units including affordable housing, in accordance with the City requirements. Proposed housing types would range from single-family homes to high- density multi-family housing. Different forms of housing tenure would be allowed on-site, including homes and condominiums for purchase and apartments for rent. Commercial building height restrictions would limit the opportunity for vertically mixed-use development. However, the project would provide residential development in close proximity to office and retail uses, and the range of residential densities would allow for work-live opportunities. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-23 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 3.2: Discourage the removal or replacement of housing affordable to extremely low, very-low, low- and moderate income households, and avoid permit approvals, private development, municipal actions or public projects that remove or adversely impact such housing unless such actions are necessary to achieve General Plan objectives and: (1) it can be demonstrated that rehabilitation of lower-cost units at risk of replacement is financially or physically infeasible, or (2) an equivalent number of new units comparable or better in affordability and amenities to those being replaced is provided, or (3) the project will correct substandard, blighted or unsafe housing; and (4) removal or replacement will not adversely affect housing which is already designated, or is determined to qualify for designation as a historic resource. Potentially Consistent. The proposed mixed-use development would include 580 residential units including affordable housing, in accordance with the City requirements. By providing units that are affordable by design, the Specific Plan would increase the supply of affordable housing in the City without displacing or adversely impacting existing affordable units. Policy 7.4. Within expansion areas, new residential development should be an integral part of an existing neighborhood or should establish a new neighborhood, with pedestrian and bicycle linkages that provide direct, convenient and safe access to adjacent neighborhoods, schools and shopping areas. Policy 7.7. The physical design of neighborhoods and dwellings should promote walking and bicycling and preserve open spaces and views. Potentially Consistent. Refer to discussion of Land Use Element Policy 10.4 for a discussion of proposed pedestrian and bicycle linkages to adjacent destinations. In addition, open spaces and views would be preserved adjacent to U.S. 101. Policy 7.5. The creation of walled-off residential enclaves, or of separate, unconnected tracts, is discouraged because physical separations prevent the formation of safe, walkable, and enjoyable neighborhoods. Potentially Consistent. As shown in Figure 2-8 in Section 2.0, Project Description, the Specific Plan’s vehicular circulation network does not include avoid cul-de-sacs or dead end streets. No neighborhood separation walls are proposed. 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. Potentially Consistent. The project includes housing types at a variety of densities, which range in number of rooms, size, and configuration of units to accommodate different household needs. All proposed development would be constructed in compliance with applicable accessibility standards. Policy 9.2. Residential site, subdivision, and neighborhood designs should be coordinated to make residential sustainability work. Some ways to do this include: A) Design subdivisions to maximize solar access for each dwelling and site. B) Design sites so residents have usable outdoor space with access to both sun and shade. C) Streets and access ways should minimize pavement devoted to vehicular use. D) Use neighborhood retention basins to purify street runoff prior to its entering creeks. Retention basins should be designed to be visually attractive as well as functional. Fenced-off retention basins should be avoided. E) Encourage cluster development with dwellings grouped around significantly-sized, shared open space in return for City approval of smaller individual lots. F) Treat public streets as landscaped parkways, using continuous plantings at least six feet wide and where feasible, median planters to enhance, define, and to buffer residential neighborhoods of all Potentially Consistent. The project includes open space, parks, and other recreational opportunities intended to provide area residents with access to usable outdoor space. Streets in the project site would devote space to multi-modal access, minimizing pavement devoted to vehicular use. Development would be clustered in the northern portion of the site to preserve agricultural land and open space on approximately half of the project site. In addition, collector streets would have landscaped parkways at least six feet total on each side of the road, and landscaped medians would be constructed on Froom Ranch Way and some local streets. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-24 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis densities from the effects of vehicle traffic. As discussed in Section 4.8 Hydrology and Water Quality, best Management Practices and Low Impact Development strategies are utilized to retain and filter storm water. Policy 11.2. Prevent new housing development on sites that should be preserved as dedicated open space or parks, on sites subject to natural hazards such as unmitigatable geological or flood risks, or wild fire dangers, and on sites subject to unacceptable levels of man-made hazards or nuisances, including severe soil contamination, airport noise or hazards, traffic noise or hazards, odors or incompatible neighboring uses. Potentially Consistent. The Specific Plan would not involve development on existing dedicated open space or parks. The project would preserve approximately 53 acres of project site in agriculture and open space. As discussed in Section 4.14, Issues Addressed in the Initial Study; Section 4.7, Hazards and Hazardous Materials; Section 4.10, Noise; Section 4.12, Transportation and Circulation, and Section 4.3, Air Quality, the project would not result in significant hazards related to geology and soils, flooding, wildfire, man- made hazards, traffic, or odors after implementation of Mitigation Measures HAZ-4, HAZ-5(a), HAZ-5(b), and HAZ- 6. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-25 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Noise Element Policy 1.3. New Development Design and Transportation Noise Sources. New noise-sensitive development shall be located and designed to meet the maximum outdoor and indoor noise exposure levels of Table 1. Land Use Outdoor Activity Areas Indoor Spaces Ldn or CNEL, in dB Ldn or CNEL, in dB Leq in dB Lmax in dB Residences, hotels, motels, hospitals, nursing homes 60 45 - 60 Theaters, auditoriums, music halls - - 35 60 Churches, meeting halls, office building, mortuaries 60 - 45 - Schools, libraries, museums - - 45 60 Neighborhood parks 65 - - - Playgrounds 70 - - - Policy 1.4. New Transportation Noise Sources. Noise created by new transportation noise sources, including road, railroad, and airport expansion projects, shall be mitigated to not exceed the levels specified in Table 1 for outdoor activity areas and indoor spaces of noise-sensitive land uses which were established before the new transportation noise source. Policy 1.6. New Development and Stationary Noise Sources. New development of noise-sensitive land uses may be permitted only where location or design allow the development to meet the standards of Table 2, for existing stationary noise sources. Policy 1.7. New or Modified Stationary Noise Sources. Noise created by new stationary; noise sources, or by existing stationary noise sources which undergo modifications that may increase noise levels, shall be mitigated to not exceed the noise level standards of Table 2, for lands designated for noise-sensitive uses. This policy does not apply to noise levels associated with agricultural operations. Potentially Consistent. As discussed in Section 4.10 Noise, the project would not result in any long-term noise impacts associated with transportation noise sources or stationary noise sources, with incorporation of Mitigation Measures N- 4(a), N-4(b) and N-5(a) through N-5(d). Policy 1.8. Preferred Noise Mitigation Approaches. When approving new development of noise- sensitive uses or noise sources, the City will require noise mitigation in the descending order of Potentially Consistent. As discussed in Section 4.10, Noise, a mitigation measures are identified for short-term and long- San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-26 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis desirability shown below. For example, when mitigating outdoor noise exposure, providing distance between source and recipient is preferred to providing berms and walls. Before using a less desirable approach, the applicant must show that more desirable approaches are not effective or that it is not practical to use the preferred approaches consistent with other design criteria based on the General Plan. 1.8.1. Mitigating Noise Sources. A. Arrange activity areas on the site of the noise-producing project so project features, such as buildings containing uses that are not noise-sensitive, shield neighboring noise-sensitive uses; B. Limit the operating times of noise-producing activities; C. Provide features, such as walls, with a primary purpose of blocking noise. 1.8.2. Mitigating Outdoor Noise Exposure. A. Provide distance between noise source and recipient; B. Provide distance plus planted earthern berms; C. Provide distance and planted earthern berms, combined with sound walls; D. Provide earthern berms combined with sound walls; E. Provide sound walls only; F. Integrate buildings and sound walls to create a continuous noise barrier. 1.8.3. Mitigating Indoor Noise Exposure. A. Achieve indoor noise level standards assuming windows are open B. Achieve indoor noise level standards assuming windows must be closed (this option requires air conditioning or mechanical ventilation in buildings.) term noise impacts. These include Mitigation Measures N- 1(a) through N-1(g), which address temporary construction noise, as well as Mitigation Measures N-4(a), N-4(b) and N- 5(a) through N-5(d), which address long-term operational noise, including roadways and stationary sources of noise. These measures prioritize noise reduction through setbacks where feasible. Other mitigation measures identify interior noise reduction construction materials in addition to sound barriers. Policy 1.10: Existing and Cumulative Impacts. The City will consider the following mitigation measures where existing noise levels significantly impact existing noise-sensitive land uses, or where cumulative increases in noise levels resulting from new development significantly impact existing noise-sensitive land uses (See also Chapter 2 of the Land Use Element, concerning residential neighborhoods). A. Rerouting traffic onto streets that can maintain desired levels of service, consistent with the Circulation Element, and which do not adjoin noise-sensitive land uses. B. Rerouting trucks onto streets that do not adjoin noise-sensitive land uses. C. Constructing noise barriers. D. Lowering traffic speeds through street or intersection design methods (see also the Circulation Element). E. Retrofitting buildings with noise-reducing features. F. Establishing financial programs, such as low cost loans to owners of noise-impacted property, or establishment of developer fees to pay for noise mitigation or trip reduction programs. Potentially Consistent. As discussed in Section 4.10 Noise, project construction would represent a temporary source of noise to sensitive receptors adjacent to the project site and along the route used by haul trucks. Mitigation Measures N- 1(a) through N-1(g) require implementation of noise reduction devices and techniques during construction, and would reduce noise associated with on- and off-site construction activity to the maximum extent feasible. In addition, implementation of Mitigation Measures N-4(a) and N-4(b) would ensure that HVAC and delivery/garbage truck noise would not exceed the City’s maximum noise standards at adjacent residences on the project site. Furthermore, construction techniques described in Mitigation Measure N- 5(a) would ensure that interior noise levels would not exceed the City’s interior standard in proposed residential, hotel, and office uses and Mitigation Measures N-5(b) through N-5(d) would ensure that the City’s exterior noise standard of 60 dBA CNEL would be achieved at affected land uses in the San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-27 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Specific Plan Area. Implementation of these measures would also ensure that the project’s contribution to cumulative noise impacts in the vicinity would be less than significant Conservation and Open Space Element Air Policies Policy 2.2.4. Promote walking, biking and use of public transit to reduce dependency on motor vehicles. City actions shall seek to reduce dependency on gasoline- or diesel powered motor vehicles and to encourage walking, biking and public transit use. Potentially Consistent. The Specific Plan would connect with the City’s park and open space system with convenient access through the various bike paths and pedestrian trails and complete a segment of the Bob Jones Regional Bicycle Trail. The Specific Plan includes a transit center that would provide direct transit access between the site and downtown San Luis Obispo, Additional neighborhood-serving commercial would further reduce dependence on motor vehicles. Cultural Heritage Policies Policy 3.3.2: Demolitions. Historically or architecturally significant buildings shall not be demolished or substantially changed in outward appearance, unless doing so is necessary to remove a threat to health and safety and other means to eliminate or reduce the threat to acceptable levels are infeasible. Policy 3.3.3: Historical Documentation. Buildings and other cultural features that are not historically significant but which have historical or architectural value should be preserved or relocated where feasible. Where preservation or relocation is not feasible, the resource shall be documented and the information retained in a secure but publicly accessible location. An acknowledgment of the resource should be incorporated within the site through historic signage and the reuse or display of historic materials and artifacts. Potentially Inconsistent. As described in Section 4.5 Cultural Resources, existing structures on the site are individually eligible for historic designation. The project includes the adaptive reuse and relocation of the existing main residence and the historic former spectators’ barn/viewing stand to new locations on the site. Mitigation Measure CR-1(a) would reduce impacts to these historic resources to the maximum extent feasible. Demolition of the historic main barn, which is part of the San Luis Ranch Complex, would conflict with Conservation and Open Space Element Policies 3.3.1 and 3.3.2. Salvageable materials from the main barn are proposed to be reused to the greatest extent possible. Mitigation Measures CR-1(b) and CR-1(c) would reduce significant direct impacts to the remainder of the historically significant San Luis Ranch Complex to the maximum extent feasible. However, the potential impact to these historic resources would remain significant and unavoidable. Policy 3.5.1: Archaeological resource protection. The City shall provide for the protection of both known and potential archaeological resources. To avoid significant damage to important archaeological sites, all available measures, including purchase of the property in fee or easement, shall be explored at the time of a development proposal. Where such measures are not feasible and Potentially Consistent. As described in Section 4.5 Cultural Resources, archaeological resources that have been identified on the project site are ineligible for listing in the CRHR and NRHP, and disturbance of these resources San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-28 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis development would adversely affect identified archaeological or paleontological resources, mitigation shall be required pursuant to the Archaeological Resource Preservation Program Guidelines. Policy 3.5.2: Native American sites. All Native American cultural and archaeological sites shall be protected as open space wherever possible. Policy 3.5.5: Archaeological resources present. Where a preliminary site survey finds substantial archaeological resources, before permitting construction, the City shall require a mitigation plan to protect the resources. Possible mitigation measures include: presence of a qualified professional during initial grading or trenching; project redesign; covering with a layer of fill; excavation, removal and curation in an appropriate facility under the direction of a qualified professional. would not constitute a significant impact. The potential remains for the project to result in impacts to previously unidentified archaeological resources. The Native American scoping did not identify any identify any specific resources important to the consulted groups within the project site. However, several contacts noted that the area is sensitive. Unanticipated discovery of human remains during project excavation would comply with Health and Safety Code Section 7050.5 and PRC Sections 5097.94 and 5097.98 to ensure that these would be addressed appropriately by the County Coroner and NAHC (if required). Energy Policies Policy 4.3.4: Use of energy efficient, renewable energy sources. The City will promote the use of cost effective, renewable, non-depleting energy sources wherever possible, both in new construction projects and in existing buildings and facilities. Policy 4.3.6: Energy efficiency and Green Building in new development. The City shall encourage energy-efficient “green buildings” as certified by the U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) Program or equivalent certification, as further described in Chapter 5.5.7. Policy 4.6.8: Energy-efficient project design. Encourage energy-efficient project design by emphasizing use of daylight and solar exposure, shading and natural ventilation, as opposed to designing a particular image and relying on mechanical systems to maintain functionality and comfort. Educate City staff, citizen advisers, developers and designers on ways to exceed minimum State energy standards. Potentially Consistent. The Specific Plan would include the following construction techniques for energy conservation: • Meeting or exceeding Title 24 standards • Natural lighting and ventilation • High R-value insulation • Energy-efficient HVAC systems and appliances • Noise reduction • Water usage reduction In addition, guidelines for commercial, office, and hotel design state that the lighting plan should incorporate current energy-efficient fixtures and technology, and design standards call for energy-efficient windows. Policy 4.4.1: Pedestrian- and bicycle-friendly design. Residences, work places and facilities for all other activities will be located and designed to promote travel by pedestrians and bicyclists. (Also see the Land Use and Circulation Elements) Potentially Consistent. Refer to discussion of Land Use Element Policy 10.4 for a discussion of proposed pedestrian and bicycle linkages to adjacent destinations. Materials Policies Policy 5.5.8: Recycling Facilities in New Development. During development review, the City shall require facilities in new developments to accommodate and encourage recycling. Potentially Consistent. Consistent with the City’s Source Reduction and Recycling Element, the Specific Plan design would accommodated recycling facilities on the project site and would include a solid waste reduction plan for recycling discarded construction materials with the building permit application. The project would also include facilities for recycling to reduce the waste stream generated by operation of the project. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-29 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Natural Communities Policies Policy 7.3.1 (A through D): Protect Listed Species. The City will comply with state and federal requirements; the City will protect listed species through its actions on: land-use designations; development standards; development applications; location, design, construction and maintenance of creeks, City roads and facilities; and on land that the City owns or manages. Additionally, the City may approve a project where mitigation requires relocation of a species if there is no practicable alternative. Potentially Consistent. As described in Section 4.4, Biological Resources, Mitigation Measures BIO-1(a) through BIO-1(h) would ensure that the project would not result in unavoidable impacts on candidate, sensitive, or special status species that may occur on the project site. Policy 7.3.2: Species of local concern. The City will: A. Maintain healthy populations of native species in the long term, even though they are not listed for protection under State or Federal laws. These “species of local concern” are at the limit of their range in San Luis Obispo, or threats to their habitat are increasing. B. Identify the location, habitat and buffer needs of species of local concern. This information will be developed by qualified people early in the planning and development review process. (These species are listed in Appendix A [to the Conservation and Open Space Element], which may be revised by the City’s Natural Resources Manager or other biological resource professional upon public notice. Anyone may nominate species for the list.) C. Protect species of local concern through: its actions on land use designations, development standards, development applications; the location, design, construction and maintenance of City facilities; land that the City owns or manages. D. Encourage individuals, organizations and other agencies to protect species of local concern within their areas of responsibility and jurisdiction. E. Protect sensitive habitat, including creeks, from encroachment by livestock and human activities. Potentially Consistent. As described in Section 4.4, Biological Resources, the project would have a potentially significant but mitigable impact on sensitive habitats, including riparian areas. Mitigation Measures BIO-2(a) through BIO-2(c) would ensure that potential habitat impacts would remain less than significant. Refer to discussion of Conservation and Open Space Element Policy 7.3.1 for a discussion of the project’s potential impacts and mitigation for candidate, sensitive, or special status species that may occur on the project site. Policy 7.3.3: Wildlife habitat and corridors. Continuous wildlife habitat, including corridors free of human disruption, shall be preserved and where necessary, created by interconnecting open spaces, wildlife habitat and corridors. To accomplish this, the City will: A. Require public and private developments, including public works projects, to evaluate animal species and their movements within and through development sites and create habitats and corridors appropriate for wildlife. B. Plan for connectivity of open spaces and wildlife habitat and corridors using specific area plans, neighborhood plans, subdivision maps or other applicable planning processes, consistent with Open Space Guidelines. C. Coordinate with San Luis Obispo County and adjoining jurisdictions, federal and state agencies such as Caltrans to assure regional connectivity of open space and wildlife corridors. D. Preserve and expand links between open spaces and creek corridors, as shown in Figure 3. Potentially Consistent. Refer to discussion of Conservation and Open Space Element Policy 7.3.2 for a discussion of habitat protection, and sensitive species protection measures. In addition, as discussed in Section 4.4 Biological Resources, the open agricultural lands on the project site do not provide a corridor between other non-disturbed habitat. Impacts to Prefumo Creek would be temporary, and this existing wildlife corridor would not be removed or narrowed. Therefore, no permanent impacts to wildlife movement are expected. Policy 7.5.1: Protection of Significant Trees. Significant trees, as determined by the City Council upon the recommendation of the Tree Committee, Planning or Architectural Review Committee, are those making substantial contributions to natural habitat or to the urban landscape due to their species, size, or rarity. Significant trees, particularly native species, shall be protected. Removal of significant trees Potentially Consistent. As discussed in Section 4.4, Biological Resources, the project would result in potential impacts to Great Blue Heron and Monarch Butterflies due removal of the on-site eucalyptus trees which serve as San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-30 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis shall be subject to the criteria and mitigation requirements in Chapter 8.6.3. Oak Woodland communities in the Greenbelt and in open space areas shall be protected. overwintering habitat for these species. Mitigation Measures BIO-1(f), BIO-1(h), and BIO-2(b) would ensure that impacts to significant trees and the habitat they provide would remain less than significant. Policy 7.5.2: Use of Native California plants in urban landscaping. Landscaping should incorporate native plant species, with selection appropriate for location. Potentially Consistent. Design guidelines for residential and commercial areas in the Specific Plan call for landscaping that incorporates native plant species, in addition to edible and other drought-tolerant plants. Policy 7.5.3: Heritage Tree Program. The City will continue a program to designate and help protect “heritage trees.” Potentially Consistent. As discussed in Section 4.14, Issues Addressed in the Initial Study; No heritage trees have been identified in the project area. Policy 7.5.5: Soil Conservation and Landform modification. Public and private development projects shall be designed to prevent soil erosion, minimize landform modifications to avoid habitat disturbance and conserve and reuse onsite soils. Potentially Consistent. The Specific Plan includes Low Impact Development and best management practices to minimize landform modifications, avoid habitat disturbance, and conserve and reuse on-site soils. Policy 7.7.6 Replace Invasive, Non-Native Vegetation with Native Vegetation. The City and private development will protect and enhance habitat by removing invasive, non-native vegetation that detracts from habitat values and by replanting it with native California plant species. The Natural Resources Manager will prioritize projects and enlist the help of properly trained volunteers to assist in non-native vegetation removal and replanting when appropriate. Potentially Consistent. Several eucalyptus trees that border the developed area on the west and along Prefumo Creek would be subject to cutting or thinning for development. Direct impacts to species that rely on this habitat if the species are present at the time of removal. As required in Mitigation Measure BIO-1(f), as eucalyptus trees senesce, they shall be replaced with native species. Native trees and shrubs shall also be used to supplement gaps in canopy or act as windbreaks. Policy 7.7.7: Preserve Ecotones. Condition or modify development approvals to ensure that “ecotones,” or natural transitions along the edges of different habitat types, are preserved and enhanced because of their importance to wildlife. Natural ecotones of particular concern include those along the margins of riparian corridors, marshlands, vernal pools and oak woodlands where they transition to grasslands and other habitat types. Potentially Consistent. The project site currently supports limited ecotones as it primarily consists of open agricultural fields, which border native habitats along Prefumo Creek. Regular cultivation and other agricultural practices generally eliminate habitat for burrowing animals, amphibian and reptile species. Conservation and Open Space Element Policy 8.3.2 requires buffers between resources and urban uses using techniques such as planting and wildlife- compatible fencing. Mitigation for sensitive species and habitats included in Section 4.4, Biological Resources, would address this policy. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-31 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 7.7.8: Protect Wildlife Corridors. Condition development permits in accordance with applicable mitigation measures to ensure that important corridors for wildlife movement and dispersal are protected. Features of particular importance to wildlife include riparian corridors, wetlands, lake shorelines, and protected natural areas with cover and water. Linkages and corridors shall be provided to maintain connections between habitat areas. Potentially Consistent. Refer to discussion of Land Use Element Policies 1.13.8, 2.3.7, and 2.3.10. Policy 7.7.9: Creek Setbacks. As further described in the zoning regulations (Section 17.16.025), the City will maintain creek setbacks to include: an appropriate separation from the physical top of bank, the appropriate floodway as identified in the Flood Management Policy, native riparian plants or wildlife habitat and space for paths called for by any city-adopted plan. In addition, creek setbacks should be consistent with the following: • The following items should be no closer to the wetland or creek than the setback line: buildings, streets, driveways, parking lots, aboveground utilities, and outdoor commercial storage or work areas. • Development approvals should respect the separation from creek banks and protection of floodways and natural features identified in Part A above, whether or not the setback line has been established. • Features which normally would be outside the creek setback may be permitted to encroach where there is no practical alternative, to allow reasonable development of a parcel, consistent with the Conservation and Open Space Element. • Existing bridges may be replaced or widened, consistent with policies in this Element. Removal of any existing bridge or restoration of a channel to more natural conditions will provide for wildlife corridors, traffic circulation, access, utilities and reasonable use of adjacent properties. Potentially Consistent. Refer to the discussion under Conservation and Open Space Element Policy 7.3.3 Wildlife habitat and corridors above. Open Space Policies Policy 8.3.1: Open space within the urban area. The City will preserve the areas listed in Goal 8.2.2, and will encourage individuals, organizations, and other agencies to do likewise. The City will designate these areas as Open Space or Agriculture in the General Plan. Potentially Consistent. Refer to the discussion of Land Use Element Policy 1.4 above. Policy 8.3.2: Open Space Buffers. When activities close to open space resources within or outside the urban area could harm them, the City will require buffers between the activities and the resources. Potentially Consistent. Refer to discussion of Open Space and Conservation Element Policy 7.7.7. Policy 8.6.3.: Required Mitigation. Loss or harm shall be mitigated to the maximum extent feasible. Mitigation must at least comply with Federal and State requirements. Mitigation shall be implemented and monitored in compliance with State and Federal requirements, by qualified professionals, and shall be funded by the project applicant. Any development that is allowed on a site designated as Open Space or Agriculture, or containing open space resources, shall be designed to minimize its impact on open space values on the site and on neighboring land. 1. Hillside development shall comply with the standards of the Land Use Element, including minimization of grading for structures and access, and use of building forms, colors, and landscaping Potentially Consistent. Although development under the Specific Plan would convert existing prime agricultural land on-site, development would be clustered to minimize impacts to agriculture and open space. The project would preserve approximately 53 acres of prime farmland on-site in perpetuity, as well as approximately 7.67.4 acres in parks and open space along Prefumo Creek and Cerro San Luis Channel, while urban development would occur in the northwest portion of the site. The agricultural preserve and San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-32 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis that are not visually intrusive. (See also Chapter 9.2.1) 2. Creek corridors, wetlands, grassland communities, other valuable habitat areas, archaeological resources, agricultural land, and necessary buffers should be within their own parcel, rather than divided among newly created parcels (Figure 8). Where creation of a separate parcel is not practical, the resources shall be within an easement. The easement must clearly establish allowed uses and maintenance responsibilities in furtherance of resource protection. 3. The City will encourage the County not to create new parcels within the greenbelt, with the exception of those permitted under the County’s agriculture cluster incentive. Outside of cluster districts, allowed parcel sizes within the greenbelt should be no smaller, and the number of dwellings allowed on a parcel should be no greater than as designated in the September 2002 San Luis Obispo Area Plan and related County codes. open space would be located adjacent to the SLO City Farm, minimizing impacts on the open space values of that neighboring property. In addition, the Specific Plan would not involve hillside development or the creation of new parcels within the greenbelt. As discussed in Section 4.2 Ag Resources, 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 and Conservation and Open Space Element Policy 8.6.3. Policy 8.7.2.C Enhance and Restore Open Space. Remove invasive, non-native species in natural habitat areas, and prevent the introduction or spread of invasive, non-native species and pathogens. Potentially Consistent. Refer to discussion of Open Space and Conservation Policies 7.7.6 and 8.3.2. In addition, project specific BMPs including maintenance activities during the monitoring period, including weed removal and irrigation as appropriate. Views Policies Policy 9.1.1: Preserve Natural and Agricultural Landscapes. The City will implement the following policies and will encourage other agencies with jurisdiction to do likewise: A. Natural and agricultural landscapes that the City has not designated for urban use shall be maintained in their current patterns of use. B. Any development that is permitted in natural or agricultural landscapes shall be visually subordinate to and compatible with the landscape features. Development includes, but is not limited to buildings, signs (including billboard signs), roads, utility and telecommunication lines and structures. Such development shall: 1. Avoid visually prominent locations such as ridgelines, and slopes exceeding 20 percent. 2. Avoid unnecessary grading, vegetation removal, and site lighting. 3. Incorporate building forms, architectural materials, and landscaping, that respect the setting, including the historical pattern of development in similar settings, and avoid stark contrasts with its setting. 4. Preserve scenic or unique landforms, significant trees in terms of size, age, species or rarity, and rock outcroppings. C. The City’s non-emergency repair, maintenance, and small construction projects in highly visible locations, such as hillsides and downtown creeks, where scenic resources could be affected, shall be subject to at least “minor or incidental” architectural review. Potentially Consistent. The project site is currently designated for future urban use under the City’s Land Use Element. Agricultural land and open space would be clustered adjacent to U.S. 101 to preserve views of these landscapes. No development would occur on visually prominent locations, such as ridgelines. As discussed in Impact AES-2 in Section 4.1, Aesthetics, the design features of development in the project site would be consistent with the visual character of surrounding residential and commercial land uses. Development on-site would remove scenic resources by thinning groves of mature eucalyptus trees that shield views from Madonna Road and nearby residences. With the removal of these trees, residents would foreground views of high-density residential development. However, implementation of Mitigation Measure AES-1(a) BIO-2(b) would require replacement of trees on-site where feasible, which would in order to screen development from neighbors’ views. With maturity, these trees would mitigate for the loss of scenic resources. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-33 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 9.1.4: Streetscapes and Major Roadways. In the acquisition, design, construction or significant modification of major roadways (highways/regional routes and arterial streets), the City will promote the creation of “streetscapes” and linear scenic parkways or corridors that promote the City’s visual quality and character, enhance adjacent uses, and integrate roadways with surrounding districts. To accomplish this, the City will: A. Establish streetscape design standards for major roadways. B. Encourage the creation and maintenance median planters and widened parkway plantings. C. Retain mature trees in the public right-of-way. D. Emphasize the planting and maintenance of California Native tree species of sufficient height, spread, form and horticultural characteristics to create the desired streetscape canopy, shade, buffering from adjacent uses, and other desired streetscape characteristics, consistent with the Tree Ordinance or as recommended by the Tree Committee or as approved by the Architectural Review Commission. E. Encourage the use of water-conserving landscaping, street furniture, decorative lighting and paving, arcaded walkways, public art, and other pedestrian-oriented features to enhance the streetscape appearance, comfort and safety. F. Encourage and where possible, require undergrounding of overhead utility lines and structures. Potentially Consistent. The project does not include modification of any major roadways (highways/regional routes and arterial streets). Mitigation described in Section 4.12, Transportation, would require the project to pay its fair- share contribution toward the development of an interchange or overcrossing at Prado Road and U.S. 101. This improvement would be required to comply with all applicable City standards for streetscape design, plantings, tree protection, landscaping, and utility lines in structures at the time the improvement is completed. Policy 9.2.1: Views to and from public places, including scenic roadways. The City will preserve and improve views of important scenic resources from public places, and encourage other agencies with jurisdiction to do so. Public places include parks, plazas, the grounds of civic buildings, streets and roads, and publicly accessible open space. In particular, the route segments shown in Figure 11 are designated as scenic roadways. A. Development projects shall not wall off scenic roadways and block views. B. Utilities, traffic signals, and public and private signs and lights shall not intrude on or clutter views, consistent with safety needs. C. Where important vistas of distant landscape features occur along streets, street trees shall be clustered to facilitate viewing of the distant features. D. Development projects, including signs, in the viewshed of a scenic roadway shall be considered “sensitive” and require architectural review. Policy 9.3.6: View blockage along scenic highways. Determine that view blockage along scenic roadways is a significant impact. Potentially Consistent. The proposed Specific Plan proposes to maintain agriculture and open space along U.S. 101, reducing the visual change from this high scenic value corridor. The proposed commercial and residential development would be visually consistent with adjacent land uses to the north and west. Views from Madonna Road would change substantially with the replacement of the existing eucalyptus trees with multi-family residential development. However, based on surrounding development on the south side of Madonna Road, viewer expectations along this roadway are generally of suburban and commercial uses. The proposed multi-family residential development along this approximately 800-foot segment of Madonna Road would be consistent with the surrounding development along the south side of the roadway, and would provide a visual transition from suburban residential uses west of the project site frontage to commercial uses east of the project site frontage. Also refer to the discussion of Policy 9.1.1 with regard to views of scenic resources and views from U.S. 101. Where proposed commercial development would obstruct foreground views from the highway, implementation of Mitigation Measure AES-1(b) San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-34 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis would require landscaping to screen commercial structures from public view. In addition, the ARC would review and approve the design for proposed buildings, examining the layout, building design, its relationship to the neighborhood in which it would be located, landscaping, parking, signage, lighting, and other features affecting the project’s appearance. Water Policies Policy 10.2.2: Ahwahnee Water Principles. In planning for its water operations, programs and services, the City will be guided by the Ahwahnee Water Principles and will encourage individuals, organizations, and other agencies to follow these policies: A. Community design should be compact, mixed use, walkable and transit-oriented so that automobile-generated urban runoff pollutants are minimized and the open lands that absorb water are preserved to the maximum extent possible. B. Natural resources such as wetlands, flood plains, recharge zones, riparian areas, open space, and native habitats should be identified, preserved and restored as valued assets for flood protection, water quality improvement, groundwater recharge, habitat, and overall long-term water resource sustainability. C. Water holding areas such as creekbeds, recessed athletic fields, ponds, cisterns, and other features that serve to recharge groundwater, reduce runoff, improve water quality and decrease flooding should be incorporated into the urban landscape. D. All aspects of landscaping from the selection of plants to soil preparation and the installation of irrigation systems should be designed to reduce water demand, retain runoff, decrease flooding, and recharge groundwater. E. Permeable surfaces should be used for hardscape. Impervious surfaces such as driveways, streets, and parking lots should be minimized so that land is available to absorb storm water, reduce polluted urban runoff, recharge groundwater and reduce flooding. F. Dual plumbing that allows grey water from showers, sinks and washers to be reused for landscape irrigation should be included in the infrastructure of new development, consistent with State guidelines. G. Community design should maximize the use of recycled water for appropriate applications including outdoor irrigation, toilet flushing, and commercial and industrial processes. Purple pipe should be installed in all new construction and remodeled buildings in anticipation of the future availability of recycled water. H. Urban water conservation technologies such as low-flow toilets, efficient clothes washers, and more efficient water-using industrial equipment should be incorporated in all new construction and retrofitted in remodeled buildings. I. Ground water treatment and brackish water desalination should be pursued when necessary to maximize locally available, drought-proof water supplies. Potentially Consistent. The Specific Plan would allow for compact, mixed use, walkable, and transit-oriented development, and would preserve open space in riparian areas. As discussed in Section 4.8, Hydrology and Water Quality, landscaping would include native and drought- tolerant plants to reduce water demand. As discussed in Section 4.13, Water Resources, the water supply would be sufficient to serve anticipated water demand in the Specific Plan Area. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-35 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Safety Element Policy 2.1. Policy S: Flood Hazard Avoidance and Reduction. E. Within new development areas, such as the potential expansion areas shown in Figure 2 of the Land Use Element, substantial displacement of flood waters should be avoided by: 1. Keeping a substantial amount of flood-prone land in the vicinity as open space; 2. Enlarging man-made bottlenecks, such as culverts, which contribute to flood waters backing up from them; 3. Accommodating in such places uses which have relatively low ratios of building coverage to site area, for which shallow flooding of parking and landscape areas would cause minimum damage. 4. Requiring new buildings to be constructed above the 100-year flood level. Potentially Consistent. As discussed in Impact HWQ-2 in Section 4.8, Hydrology and Water Quality, the Specific Plan Area is located partly within a 100-year floodplain. However, residential development would be located in the portion of the site that is not within the 100-year flood plain. Compliance with local flood management measures including Special Floodplain Management Zone Regulation and the City Waterways Management Plan would minimize the impact of placing structures within the 100-year flood plain. Policy S 3.0: Adequate Fire Services. Development shall be approved only when adequate fire suppression services and facilities are available or will be made available concurrent with development, considering the setting, type, intensity, and form of the proposed development. Potentially Consistent. As discussed in Section 4.14, Issues Addressed in the Initial Study, the project site would be adequately served by the City’s existing fire protection services. The project site is an infill site and not directly adjacent to any wildlands. Project plans would be required to be evaluated by the Fire Marshal and comply with applicable Uniform Fire Code, CBC, and General Plan policies. Additionally, a Fire Flow Analysis was prepared for the project on March 18, 2016 by Cannon and determined that the San Luis Ranch water system would be able to meet the required fire flow and pressures throughout the site. Policy 4.7. Avoiding Liquefaction Hazards. Development may be located in areas of high liquefaction potential only if a site-specific investigation by a qualified professional determines that the proposed development will not be at risk of damage from liquefaction. The Chief Building Official may waive this requirement upon determining that previous studies in the immediate area provide sufficient information. Potentially Consistent. According to the Safety Element of the City’s General Plan, the project site has been identified as being located in an area of very high liquefaction potential. However, as discussed in Section 4.14, Issues Addressed in the Initial Study, Mitigation Measures GEO-1 and GEO-3 require that new buildings and roadway infrastructure are designed to minimize hazards from ground motion and liquefaction. Policy 5.2: Minimizing Hazardous Materials Exposure. People’s exposure to hazardous substances should be minimized. Potentially Consistent. The proposed residential and commercial land uses included in the San Luis Ranch Specific Plan would not involve the transport, use, or disposal of substantial amounts of hazardous substances. Enforcement of the Hazardous Materials Transportation Act, laws and regulations to track and manage the safe interstate transportation of hazardous materials and waste, and rapid response by local agencies would ensure that hazards to the San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-36 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment and/or associated with hazardous emissions or materials near schools would remain less than significant. Additionally, with implementation of Mitigation Measures HAZ-4, AG-3, HAZ- 5(a), HAZ-5(b) and HAZ-6, impacts related to exposure to residual agricultural chemicals, PCE, and NOA would be reduced to a less than significant level. Policy S 6.0: Exposure to Electromagnetic Fields. Land-use decisions should avoid prolonged exposure of people to strong electromagnetic fields. Appropriate uses for areas under or next to high- voltage power transmission lines are agriculture, floodwater detention, roads, parking, materials storage, and parks and greenways with low-intensity use. Residential yards may be located along but outside of high‐voltage power transmission line easements. School buildings and playgrounds, residential buildings, and work places should be set back from high-voltage power transmission lines. The amount of setback will be a matter of judgment, considering the space available in which to locate uses within the site being planned. Policy S 6.1: Notification to Buyers Near Electromagnetic Fields. When land containing major sources of electromagnetic fields, such as power transmission lines, is subdivided, the City will determine if a condition will be imposed requiring notification of prospective buyers that a source of electromagnetic fields exists and that studies have raised concerns about long‐term exposure. Potentially Consistent. As discussed in Section 4.14, Issues Addressed in the Initial Study, there are overhead transmission lines in the vicinity of the project site. However, these lines are elevated such that they are not close enough to pose a risk to residents and other users of the project site associated with electromagnetic fields. Policy S 7.0: Uses in the Airport Land Use Plan Area. Development should be permitted only if it is consistent with the requirements of the California State Aeronautics Act (Public Utilities Code §21670, et. seq.), guidance from the California Airport Land Use Planning Handbook, other related federal and state requirements relating to airport land use compatibility planning, and the San Luis Obispo County Regional Airport Land Use Plan unless the City overrules a determination of inconsistency in accordance with Section 21676.5 et. seq. of the Public Utilities Code. Prospective buyers of property that is subject to airport influence should be so informed. Potentially Consistent. Refer to the discussion of Land Use Element Policies 7.3 through 7.5 with regard to airport land use compatibility and compliance with applicable regulations. As discussed in Impact LU-4, although the project would conflict with the ALUP’s density standards, based on this analysis the 2014 Airport Land Use Compatibility Report, airport land use planning impacts to future residents and commercial employees or patrons the project would be consistent with the City’s Airport Safety Zones. The Specific Plan’s uses are consistent with the applicable Airport Master Plan, California State Aeronautics Act and CALUPH standards and guidelines, as well as the City’s safety and noise standards related to the airport. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-37 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Policy 9.13. Emergency Access and Evacuation. Substantial development will be allowed only where multiple routes of road access can be provided, consistent with other General Plan policies on development location and open space protection. “Substantial development” means industrial, commercial, and institutional uses, multifamily housing, and more than ten single-family dwellings. ”Multiple routes” include vehicle connections that provide emergency access only, as well as public and private streets. Potentially Consistent. As discussed in Impact HAZ-5 in Section 4.7, Hazards and Hazardous Materials, the San Luis Ranch development includes a circulation plan that would ensure adequate public and emergency vehicular access. Parks and Recreation Element Policy 3.13.1. The City shall develop and maintain a park system at the rate of 10 acres of parkland per 1,000 residents. Five acres shall be dedicated as a neighborhood park. The remaining five acres required under the 10 acres per 1000 residents in the residential annexation policy may be located anywhere within the City’s park system as deemed appropriate. Policy 3.14.4. New significant residential developments and annexations, shall provide sufficient athletic fields to meet the demands of the youth who will reside in the development. Potentially Consistent. The Specific Plan would include playground and recreational spaces to serve residents. Refer to Section 4.12, Recreation. Policy 3.15.1. San Luis Obispo residents shall have access to a neighborhood park within .5 to 1.0 mile walking distance of their residence. Potentially Consistent. The project includes a central park area that would provide residents with access to a park within 0.5 to 1.0 mile walking distance. Policy 3.15.3. All residential annexation areas shall provide developed neighborhood parks at the rate of 5 acres per 1000 residents. Policy 5.0.2. For annexation areas, at least 10 acres of developed parkland for each 1000 new residents shall be provided by the developer. Potentially Consistent. The Specific Plan would comply with the City's neighborhood park requirement. Refer to Section 4.12, Recreation. Policy 3.20.6. Open space and parks shall be connected where possible by trails or bike paths. Potentially Consistent. As shown in Figure 2-8 in Section 2.0, Project Description, proposed parks in the project site would be connected by an internal multi-modal network that includes trails and bike paths. Water and Wastewater Element Policy A 5.2.5. Paying for Water for New Development. New development shall pay its proportionate or “fair share” for water supplies, expanded treatment and distribution system capacity and upgrades. Policy B 2.2.3. Wastewater Service for New Development. New development shall pay its proportionate or “fair share” of expanded treatment and collection system capacity and upgrades. New development will only be permitted if adequate capacity is available within the wastewater collection system and/or Water Reclamation Facility. Potentially Consistent. New development in the Specific Plan area would be required to pay its fair share for the provision of water supplies and water and wastewater infrastructure. Policy B 2.2.2: Service Capacity. The City's wastewater collection system and Water Reclamation Facility shall support population and related service demands consistent with the General Plan. Potentially Consistent. The project includes development of water, wastewater, and storm water infrastructure to connect the project to existing City infrastructure. With the proposed infrastructure, the project would be adequately served by the City’s sewer and water systems. The City’s Water Resource San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-38 Table 4.9-1 Consistency with City of San Luis Obispo General Plan Plan, Policy, or Regulation Consistency Analysis Recovery Facility (WRRF) processes wastewater in accordance with the standards set by the Regional Water Quality Control Board (RWQCB). The WRRF is designed for an average dry weather flow capacity of 5.1 million gallons per day (MGD) and a peak wet weather flow capacity of 22 MGD. The Land Use and Circulation Elements Update EIR determined that the project, in combination with other specific plan development in the City, would generate approximately 0.32 MGD of wastewater or approximately 20 percent of the WRRF dry weather flow capacity and 1.7 percent of the WRRF wet weather flow capacity. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-39 As shown in Table 4.9-1, the project would be potentially inconsistent with San Luis Obispo City General Plan policies designed to protect historical resources, and ensure adequate multimodal transportation levels of service. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of residential, commercial, and office uses while preserving substantial areas of open space and agriculture on a 131.3-acre property. The project site is currently outside the City, but within its Sphere of Influence and Urban Reserve Line, and would require annexation. The Specific Plan and related actions would allow for the development of the San Luis Ranch area as identified in the City’s General Plan as Special Focus Area SP-2. The intent is for the project to be consistent with the development parameters described in the General Plan. The Specific Plan is potentially consistent with most principles and policies found in the City’s General Plan, with incorporation of mitigation measures included in Section 4.0, Environmental Impact Analysis. However, it is also inconsistent with some of the principles and policies, specifically Land Use Element Policy 1.10.4 (Design Standards), Land Use Element Policy 8.1.4 (SP-2, San Luis Ranch (Dalidio) Specific Plan Area), and Conservation and Open Space Element 3.3.2 (Demolitions). The physical impacts on the environment associated with Specific Plan implementation are detailed in Section 4.0, Environmental Impact Analysis. Mitigation Measures. Mitigation measures described in Section 4.0, Environmental Impact Analysis, would ensure that several potential conflicts between the San Luis Obispo City General Plan and the Specific Plan would be reduced to the maximum extent feasible. The following Mitigation Measures would apply to this impact: • Section 4.1, Aesthetics: AES-1(a) and AES-1(b) • Section 4.2, Agricultural Resources: AG-1, AG-3 • Section 4.4, Biological Resources: BIO-1(a) through BIO-1(h) and BIO-2(a) through BIO-2(c) • Section 4.5, Cultural Resources: CR-1(a) through CR-1(c) • Section 4.7, Hazards and Hazardous Materials: HAZ-4, HAZ-5(a), HAZ-5(b), HAZ-6 • Section 4.10, Noise: N-1(a) through N-1(g), N-4(a), N-4(b), N-5(a) through N-5(d) • Section 4.12, Transportation and Circulation: T-1(a) through T-1(i), T-2(a) through T-2(j), T- 3(a) through T-3(d), T-4, T-5, T-6, T-7, T-8(a) through T-8(g), T-9(a) through T-9(m), T- 10(a) through T-10(c) • Section 4.14, Issues Addressed in the Initial Study: GEO-1, GEO-3 Residual Impacts. Implementation of mitigation measures identified in Section 4 of this EIR would reduce impacts to the extent feasible. However, Specific Plan conflicts with Land Use Element Policy 1.10.4 (Design Standards), Land Use Element Policy 8.1.4 (SP-2, San Luis Ranch (Dalidio) Specific Plan Area), and Conservation and Open Space Element Policy 3.3.2 (Demolitions) would remain potentially inconsistent. The City acknowledges the importance and breadth of the potential inconsistencies associated with the Specific Plan by finding them to be Class I, significant and unavoidable impacts. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-40 Threshold 2 Would the project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including but not limited to the general plan, specific plan, local coastal program, clean air plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Impact LU-2 The Specific Plan would be potentially consistent with LAFCO policies for annexation. This impact would be Class II, less than significant with mitigation incorporated. The San Luis Obispo LAFCO is responsible for reviewing and approving proposed jurisdictional boundary changes in San Luis Obispo County, including the City’s proposed annexation of the San Luis Ranch property from the County. In addition to the requirements of the Cortese-Knox-Hertzberg Act, the San Luis Obispo LAFCO has adopted local policies that it considers in its review of projects. LAFCO policies applicable to the project pertain to the location of land to be annexed, affordable housing, agricultural resources, and public services. The San Luis Obispo LAFCO encourages cities to annex unincorporated islands, prefers urban development within cities, and favors proposals that are supported by a community’s long- range vision for its growth and development. Table 4.9-2 discusses the Specific Plan’s preliminary consistency with applicable LAFCO policies related to city annexations and agricultural land. Table 4.9-2 Preliminary Consistency with LAFCO Policies for Annexation and Agricultural Land Policy Consistency Analysis Policies for City Annexations 1. The boundaries of a proposed annexation must be definite and certain and must conform to lines of assessment whenever possible. Potentially Consistent. The proposed annexation would include the area within the existing 131-acre San Luis Ranch property, an agricultural parcel envisioned in the City Land Use Element for agricultural and urban mixed use that is surrounded by incorporated City of San Luis Obispo land 2. The boundaries of an area to be annexed will not result in any areas difficult to serve. Potentially Consistent. The project site is surrounded by urban development to the north, south, west, and east, which is served by existing City infrastructure. Therefore, the annexed area would not be difficult to serve. 3. There is a demonstrated need for governmental services and controls in the area proposed for annexation. Potentially Consistent. The proposed mixed-use development would include 580 residential units including affordable housing, 9.5 acres of commercial uses, 3.8 acres of office uses, 3.5 acres of hotel and conference center uses, and 5.7 acres of new and extended roadways. This development would require government services and controls. 4. The municipality has the resources capable of meeting the need for services in the area proposed for annexation and has submitted studies and information documenting its ability to serve. Potentially Consistent. The project applicant would be required to pay fair share development impact fees that would provide for improved services as necessary. The Specific Plan is consistent with the City’s General Plan and service facilities have been planned to meet the additional service demand. The environmental impacts of such facilities were addressed in the LUCE Update EIR. Additionally, a Fire Flow Analysis has been San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-41 Table 4.9-2 Preliminary Consistency with LAFCO Policies for Annexation and Agricultural Land Policy Consistency Analysis prepared for the project and determined that the San Luis Ranch water system would be able to meet the required fire flow and pressures throughout the site. Plans for project-related public improvement will be consistent with the key City financing policies including those concerning impact fees, debt financing, and capital improvements. 5. There is a mutual social and economic community of interest between the residents of the municipality and the proposed territory. Potentially Consistent. The Specific Plan would assist in meeting the City’s needs for market-rate and affordable housing, while providing neighborhood-serving commercial uses. 6. The proposed annexation is compatible with the municipality’s general plan. The proposed annexation represents a logical and reasonable expansion of the annexing municipality. Potentially Consistent. The proposed annexation is supported by the City’s long-range vision for its growth and development. It is intended under the City’s existing land use designation of San Luis Ranch Specific Plan for the project site, which assumes future annexation of the site. It is also compatible with Land Use Element Policies 1.13.8 and 8.1.4 in the Land Use Element, which assume the development of a mixed- use project and preservation of open space on an annexed project site. 7. The Commission shall determine if a disadvantaged unincorporated community is associated with an application. If a disadvantaged unincorporated community does exist, the procedures for processing the annexation as outlined in the CKH Act shall be implemented. Potentially Consistent. The project site does not have any existing occupied housing and is not associated with a disadvantaged unincorporated community. As described in Section 4.14, Issues Addressed in the Initial Study, no existing homes or residents would be displaced within the San Luis Ranch Specific Plan area as a result of project implementation Agricultural Policies 1. Vacant land within urban areas should be developed before agricultural land is annexed for non-agricultural purposes. 3. In general, urban development should be discouraged in agricultural areas. For example, agricultural land should not be annexed for nonagricultural purposes when feasible alternatives exist. Large lot rural development that places pressure on a jurisdiction to provide services and causes agricultural areas to be infeasible for farming should be discouraged. Potentially Consistent. While the project would involve annexation of agricultural land for development, the site is already surrounded by urban development to the north, west, and east. Furthermore, the site is not located within the City’s greenbelt, which covers agricultural land outside of the urban area. However, development within the Specific Plan Area would be clustered to preserve approximately 53 acres of the site in agricultural use by (refer to Section 4.2, Agricultural Resources). 2. Land substantially surrounded by existing jurisdictional boundaries should be annexed before other lands. Potentially Consistent. The project site is an unincorporated island that is surrounded on all sides by the City of San Luis Obispo City. 4. The Memorandum of Agreement between a city and the County should be used and amended as needed to address the impacts on and conversion of Agricultural Lands on the fringe of a city. Potentially Consistent. The property to be annexed is located within the boundaries of the City’s Sphere of Influence, as documented by the Memorandum of Agreement between the City and LAFCO which was adopted in 2005. The approach of this memorandum is to ensure close coordination and cooperation between the City and County on the future planning and development of the areas within the City’s SOI boundary. Consistent with the memorandum, developers in the Specific Plan area would be required to pay their fair share of mitigation and impact fees. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-42 Table 4.9-2 Preliminary Consistency with LAFCO Policies for Annexation and Agricultural Land Policy Consistency Analysis Mitigation described in Section 4.12, Transportation/Traffic, would require the project to pay its fair-share contribution toward the development of an interchange or overcrossing at Prado Road and U.S. 101. Development projects in the Specific Plan Area would be required to pay school impact fees established to offset potential impacts on school facilities. In addition, impact fees collected at the time building permits are issued would pay for sewer capacity at the City’s Water Recovery and Reclamation Facility (WRRF). 5. The continued productivity and sustainability of agricultural land surrounding existing communities should be promoted by preventing the premature conversion of agricultural land to other uses and, to the extent feasible, minimizing conflicts between agricultural and other land uses. Buffers should be established to promote this policy. 6. Development near agricultural land should not adversely affect the sustainability or constrain the lawful, responsible practices of the agricultural operations. Potentially Consistent. As discussed in Section 4.2, Agricultural Resources, the project would result in the direct conversion of approximately 56 59 acres of prime farmland to non-agricultural use; however, the project would contribute to the protection of agricultural land within the urban reserve by preserving approximately 53 acres of prime farmland on-site in perpetuity, as well as approximately 7.67.4 acres in parks and open space, and would be consistent with applicable General Plan Land Use Element policies related to agricultural preservation. The Specific Plan would minimize conflicts with existing adjacent agricultural land by preserving farmland adjacent to the SLO City Farm. In addition, the Specific Plan would establish a 72-foot buffer between new residences and agricultural land on the project site. While agricultural buffers are typically 100 feet wide in the County, this buffer is intended to maximize the amount of land available for agricultural cultivation. As discussed in Section 4.2, Agricultural Resources, Mitigation Measure AG-3, Agricultural Conflict Avoidance Measures, includes City-approved measures to reduce availability of public access to agricultural cultivation areas adjacent to the project site (e.g., fencing, signs, etc.). 7. In considering the completeness and appropriateness of any proposal, the Executive Officer and this Commission may require proponents and other interested parties to provide such information and analysis as, in their judgment, will assist in an informed and reasoned evaluation of the proposal in accordance with these policies. Potentially Consistent. The project applicant would provide information to LAFCO as needed to assist its evaluation of the project’s agricultural impacts. 8. No change of organization, as defined by Government Code 56021, shall be approved unless it is consistent with the Spheres of Influence of all affected agencies. Potentially Consistent. The project site is located within the City’s Sphere of Influence. 9. Where feasible, and consistent with LAFCO policies, non-prime land should be annexed before prime land. 10. The Commission will consider feasible mitigation (found in the following guidelines) if a proposal would result in the loss of agricultural land. 12. The Commission may approve annexations of prime agricultural land only if mitigation that equates to a Potentially Consistent. Although the project would convert approximately 56 59 acres of prime farmland to non-agricultural use within the proposed annexation area, it would the project would contribute to the protection of agricultural land within the urban reserve by preserving approximately 53 acres of prime farmland on-site in perpetuity, and would mitigate for the loss of prime farmland by preserving on-site and off- San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-43 Table 4.9-2 Preliminary Consistency with LAFCO Policies for Annexation and Agricultural Land Policy Consistency Analysis substitution ratio of at least 1:1 for the prime land to be converted from agricultural use is agreed to by the applicant (landowner), the jurisdiction with land use authority. The 1:1 substitution ratio may be met by implementing various measures: a. Acquisition and dedication of farmland, development rights, and/or agricultural conservation easements to permanently protect farmlands within the annexation area or lands with similar characteristics within the County Planning Area. b. Payment of in-lieu fees to an established, qualified, mitigation/conservation program or organization sufficient to fully fund the acquisition and dedication activities stated above in 12a. c. Other measures agreed to by the applicant and the land use jurisdiction that meet the intent of replacing prime agricultural land at a 1:1 ratio. site prime farmland (refer to Section 4.2, Agricultural Resources). Approximately 53 acres of prime farmland would be preserved on-site. The project also includes a commitment to procure an off-site agricultural conservation easement/deed restriction, such that the equivalent of 50 percent of the site acreage would be preserved. Mitigation Measure AG-1, Agricultural Conservation, would ensure that for every one acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that would be permanently converted to non- agricultural use as a result of project development, one acre of land of comparable agricultural productivity shall be preserved in perpetuity. 11. The Commission encourages local agencies to adopt policies that result in efficient, coterminous and logical growth patterns within their General Plan and Sphere of Influence areas and that encourage protection of prime agricultural land in a manner that is consistent with this Policy. Potentially Consistent. Because the project site is surrounded by incorporated land and bounded by urban developed to the west, north, and east, the proposed annexation would result in an efficient, coterminous, and logical growth pattern. The project would also contribute to the protection of agricultural land within the urban reserve by preserving approximately 53 acres of prime farmland on-site in perpetuity, and by mitigating for the conversion of such land to urban development. 13. Property owners of agricultural lands adjacent to a LAFCO proposal shall be notified when an application is submitted to LAFCO. Potentially Consistent. When the application for annexation is submitted to LAFCO, the property owners of SLO City Farm, which is located adjacent to the project site, would be notified. As shown in Table 4.9-2, the project would be potentially consistent with LAFCO policies for City annexations and agricultural resources, with implementation of Mitigation Measures AG-1 and AG-3 described in Section 4.2, Agricultural Resources. In addition, LAFCO requires demonstration of the availability of an adequate, reliable, and sustainable water supply. As discussed in Impact WR-1 in Section 4.13, Water Resources, it is estimated that the project would generate a water demand of 184.7 acre-feet per year (AFY), including implementation of water conservation measures. This water demand would represent 3.0 percent of the City’s current surplus of 7,201 AFY in water supply above current demand levels. Accordingly, the City currently has sufficient water supply to provide potable water to the project. Mitigative Components of the Specific Plan and Impact Conclusion. Consistent with LAFCO policies, the project site is an unincorporated island surrounded by City land and is designated for future mixed-use development under a specific plan in the City’s General Plan. LAFCO also requires consideration of impacts on affordable housing. By providing for a maximum of 80 units that are affordable by design, the Specific Plan would increase the supply of affordable housing in the City without displacing existing affordable units. In addition, the project includes a commitment to procure an off-site agricultural conservation easement/deed restriction, such that the equivalent of 50 percent of the site acreage would be preserved. Therefore, the project would be consistent with LAFCO’s applicable general policies, and this San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-44 impact would be less than significant with implementation of Mitigation Measures AG-1 and AG-3 described in Section 4.2, Agricultural Resources. Mitigation Measures. Mitigation Measures AG-1 and AG-3 described in Section 4.2, Agricultural Resources, would ensure that the Specific Plan would not result in conflicts between the San Luis Obispo LAFCO agricultural policies and the Specific Plan. No further mitigation is required in order to reduce this impact to a less than significant level. Residual Impacts. Implementation of Mitigation Measures AG-1 and AG-3 described in Section 4.2, Agricultural Resources, would ensure that this impact would remain less than significant. Threshold 2 Would the project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including but not limited to the general plan, specific plan, local coastal program, clean air plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Impact LU-3 The Specific Plan would be consistent with the land use strategy in SLOCOG’s 2014 Regional Transportation Plan/Sustainable Communities Strategy. This impact would be Class III, less than significant. Due to the 131-acre size of the project site and the scale of proposed development, the Specific Plan would be considered a “regionally significant” project that merits analysis for consistency with the regional land use strategy in SLOCOG’s 2014 RTP/SCS. The SCS element of this transportation plan describes the “preferred growth scenario” for the next two decades, as identified by the SLOCOG Board. This scenario is intended to decrease strain on natural resources, reduce the amount of travel and GHG emissions, improve air quality, and promote public health by supplying more efficient options for transportation and housing. Consistent with the preferred growth scenario, the SCS envisions focusing new growth within Target Development Areas (TDAs) in existing urbanized areas. The project site is located within the Central County TDA in the greater San Luis Obispo area, and SCS is generally consistent with the existing General Plan Land Use Element designation for the site. Mitigative Components of the Specific Plan and Impact Conclusion. The Specific Plan area is part of an existing urbanized area. As a result, the project would allow for efficient development that minimizes increases in vehicle miles traveled (VMT) and associated motor vehicle GHG emissions. The project includes mixed uses and workforce housing to balance jobs and housing. The project also emphasizes bikeways, pedestrian, and transit connections, all of which contribute to reduced VMT. Therefore, the project would be consistent with the land use strategy in the 2014 RTP/SCS, and this impact would be less than significant. Mitigation Measures. No mitigation is required. Residual Impacts. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-45 Threshold 2 Would the project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including but not limited to the general plan, specific plan, local coastal program, clean air plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Impact LU-4 The Specific Plan would allow residential and non-residential land uses consistent with density and use restrictions in the City’s Airport Safety Zones, which represent the extent of Airport-related safety hazard zones for people residing or working in these areas. The LUCE Update EIR provided substantial evidence that the development of the San Luis Ranch Specific Plan Area under the updated General Plan land use designations would be consistent with ALUP safety and noise standards. The project would not conflict with land use policies intended to prevent airport-related safety hazards. Therefore, this impact would be Class III, less than significant. As discussed in Impact HAZ-8 in Section 4.7, Hazards and Hazardous Materials, the project would result in construction of up to 580 residential units, 150,000 square feet of commercial development, 100,000 square feet of office development, and a 200-room hotel with an associated increase of 1,293 new residents in the vicinity of the approaches to Runway 11-29 at the San Luis Obispo County Regional Airport. The project site is within CALUPH Airport Safety Zones 4 and 6 and ALUP Safety Areas Safety Area S-1b and S-2 (refer to Figures 4.7-1 and 4.7-2 in Section 4.7, Hazards and Hazardous Materials). As shown in Figure 4.7-1 in Section 4.7, Hazards and Hazardous Materials, the majority of the project site (approximately 119 acres) is within Safety Area S-1b in the ALUP. Safety Area S-1b identifies an outer approach/departure zone for the airport and allows a maximum non- residential development intensity of 75 persons per acre and a maximum residential development density of 0.2 units per acre. Approximately 16 acres in the northwest portion of the project site is located within Safety Area S-2, which allows six dwelling units per acre with an approved ACOS plan. The proposed residential development within Safety Area S-1b would exceed the ALUP’s maximum development intensities for residential and non-residential uses. The 2014 Airport Land Use Compatibility Report prepared by Johnson Aviation (refer to Appendix I) in support of the City’s recent Land Use and Circulation update process and the LUCE Update EIR, analyzed potential airport hazards and includes recommendations to update safety and hazards planning around the Airport based on guidance from the CALUPH and other sources. The CALUPH describes the characteristics of “ideal” safety zones such as “easily definable geometric shapes,” a limited number of five or six zones, a distinct progression in the degree of safety risk farther from the runway, providing that “each zone should be as compact as possible.” The Land Use Element and associated Airport Safety Zones implement these suggested standards by identifying six revised safety zones that consist of clearly justified and compact geometric shapes that represent distinct progression in the degree of safety risk farther from the runway. These Airport Safety Zones are supported by Land Use Element and Circulation Element policies, programs, and development standards consistent with those guidelines. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-46 As shown in Figure 4.7-2 in Section 4.7, Hazards and Hazardous Materials, the southeast portion of the project site along U.S. 101 is located within CALUPH Airport Safety Zones 4 and 6. Airport Safety Zone 4 allows for non-residential development intensity of up to 200 persons per acre and allows for residential infill at up to the average of surrounding residential areas. The project would involve residential development similar in density to existing residential uses to the west and non-residential development similar in density to existing commercial uses to the north. Airport Safety Zone 6 has no limits for non-residential development intensity, but suggests avoidance of large stadiums and similar uses. Airport Safety Zone 6 has no limit for residential development intensity, but suggests consideration of aircraft noise during such development. Consistent with these restrictions, no residential development is proposed within the portion of the project site located in Airport Safety Zone 4 and no residential or commercial development is proposed for the portion of the site in Airport Safety Zone 6. The eastern portion of the project site along U.S. 101 that is within Airport Safety Zone 6 would be preserved for agricultural use. The remainder of the project site is not located with an Airport Safety Zone, as defined by the CALUPH. Therefore, development on the project site would be consistent with the restrictions specified in the CALUPH for the Airport Safety Zones and consistent with additional statewide safety standards for new development evaluated in the LUCE Update EIR. Although the project would conflict with the ALUP’s density standards, it is consistent with the City’s Airport Safety Zones. The reasons for this discrepancy in approach to safety zone mapping are related to use of more updated and sophisticated mapping techniques for creation of the CALUPH Airport Safety Zones compared to the ALUP Safety Areas, which were first mapped in 1973 with a limited update in 2005. The City Council found during its review of airport compatibility for the LUCE Update that the 2014 Airport Land Use Compatibility Report (Appendix I) and revised LUCE Update EIR provided substantial evidence in the record that the Airport Safety Zones accurately reflect Airport-related hazard zones as set forth in the CALUPH and supporting federal guidance, and that maps provided in the ALUP did not accurately reflect the actual extent of Airport-related safety zones (Council Agenda Report, City of San Luis Obispo 2014d). For the LUCE Update, the City Council elected to issue an overrule of the ALUP, including planned development in the San Luis Ranch Specific Plan Area, as long as such development was found to be consistent with the Land Use Element Airport policies. Therefore, even though the project would be inconsistent with the ALUP maps, it would be consistent with safety zones and land use restrictions as recommended by the CALUPH and as evaluated in the Johnson Aviation Compatibility Report (Appendix I). Mitigative Components of the Specific Plan and Impact Conclusion. Section 2.6 of the San Luis Ranch Specific Plan (Appendix B) includes various Airport Compatibility Performance Standards intended to maintain safety of the airspace of the airport and avoid potential airport- related hazards. In addition, because the project would be consistent with the CALUPH Airport Safety Zones, which the City has found represents the actual extent of Airport-related safety hazard zones consistent with direction in the State Aeronautics Act, the FAA Regulations, and guidance provided in the CALUPH, no physical Airport-related safety hazards would occur as result of project implementation. While the project would be subject to review by the ALUC for consistency with the ALUP policies for safety and operations, based on the analysis provided above and substantial evidence in the record provided by the LUCE Update EIR, which is incorporated by reference into this EIR (see Section 1.1.3 of this EIR) and 2014 Airport Land Use Compatibility Report (see Appendix I), airport land use planning impacts in the Specific Plan Area would be less than significant. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-47 Mitigation Measures. No mitigation is required. Residual Impacts. This impact would be less than significant without mitigation. d. Cumulative Impacts. The San Luis Ranch Specific Plan would include residential development, commercial uses, including office and retail development, a hotel, and park and open space uses. The Specific Plan would also preserve the equivalent of 50 percent of the Specific Plan Area acreage in agricultural use, including approximately 53 acres within the Specific Plan Area. The proposed uses are consistent with the intent of the goals and policies established within the City’s General Plan and Zoning Regulations after implementation of mitigation, and would not cumulatively contribute to the loss of open space or agricultural land beyond that already anticipated in the City’s LUCE Update and EIR. The project, in combination with planned buildout of the City of San Luis Obispo under the General Plan, including buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans or development plans, would incrementally contribute to the conversion of City land from rural and agricultural uses to urban uses, and to associated potential land use conflicts. All pending/future projects would be required to adhere by City development regulations and General Plan policies to retain character of the City and mitigate environmental impacts where feasible. In addition, all pending and future projects would be reviewed for consistency with the General Plan and all other applicable regulatory land use actions prior to approval. Furthermore, the Specific Plan is potentially inconsistent with ALUP development standards for Safety Areas, but as described in Impact LU-4, is not expected to result in airport-related safety hazards consistent with the Caltrans California Airport Land Use Planning Handbook, the 2014 Airport Land Use Compatibility Report prepared by Johnson Aviation (refer to Appendix I), and the applicable Airport Safety Zones within the Specific Plan Area. Therefore, the Specific Plan is not expected to cumulatively contribute to potential airport noise and/or safety issues. As such, cumulative land use impacts would be less than significant with incorporation of the mitigation included in this EIR. San Luis Ranch Project EIR Section 4.9 Land Use/Policy Consistency City of San Luis Obispo 4.9-48 This page intentionally left blank. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-1 4.10 NOISE 4.10.1 Setting a. Overview of Sound Measurement. Sound is technically described in terms of the loudness (amplitude) and frequency (pitch) of the sound. Noise is typically defined as unwanted sound that interferes with normal activities or otherwise diminishes the quality of the environment. Prolonged exposure to high levels of noise is known to have several adverse effects on people, including hearing loss, communication interference, sleep interference, physiological responses, and annoyance. The noise environment typically includes background noise generated from both near and distant noise sources as well as the sound from individual local sources. These can vary from an occasional aircraft or train passing by to continuous noise from sources such as traffic on a major road. The standard unit of measurement of the loudness of sound is the decibel (dB). Since the human ear is not equally sensitive to sound at all frequencies, a special frequency-dependent rating scale has been devised to relate noise to human sensitivity. The A-weighted decibel scale (dBA) is an adjustment to the actual sound pressure levels to be consistent with that of human hearing response, which is most sensitive to frequencies around 4,000 Hertz (about the highest note on a piano) and less sensitive to low frequencies (below 100 Hertz). In addition to the instantaneous measurement of sound levels, the duration of sound is important since sounds that occur over a long period of time are more likely to be an annoyance or cause direct physical damage or environmental stress. One of the most frequently used noise metrics that considers both duration and sound pressure level is the equivalent noise level (Leq). The Leq is defined as the single steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual fluctuating levels over a period of time. Typically, Leq is summed over a one-hour period. The sound pressure level is measured on a logarithmic scale with the 0 dB level based on the lowest detectable sound pressure level that people can perceive (an audible sound that is not zero sound pressure level). Decibels are summed on a logarithmic basis. Based on the logarithmic scale, a doubling of sound energy is equivalent to an increase of 3 dB and a sound that is 10 dB less than the ambient sound level would result in a negligible increase (less than 0.5 dB) in total ambient sound levels. In terms of human response to noise, studies have indicated that a noise level increase of 3 dBA is barely perceptible to most people, a 5 dBA increase is readily noticeable, and a difference of 10 dBA would be perceived as a doubling of loudness. Quiet suburban areas typically have noise levels in the range of 40 to 50 dBA, while those along arterial streets are in the 50 to 60+ dBA range. Normal conversational levels are in the 60-65 dBA range and ambient noise levels greater than that can interrupt conversations. Noise levels from stationary or point sources (such as construction equipment and industrial machinery) typically attenuate at a rate of 6 to 7.5 dB per doubling of distance over acoustically hard and soft locations, respectively. Noise from lightly traveled roads typically attenuates at a rate of about 4.5 dB per doubling of distance, while noise from heavily traveled roads typically attenuates at about 3 dB per doubling of distance. Noise levels are also reduced by intervening structures, such as building or, walls (typically referred to as “transmission loss”). Generally, a single row of buildings between the receptor and the noise source reduces the noise level by about 5 dBA, while a solid wall or earthen berm that breaks the line-of-sight reduces noise San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-2 levels by 5 to 10 dBA. The Federal Transit Administration’s (FTA) Transit Noise and Vibration Impact Assessment (2006) indicates that the manner in which newer buildings in California are constructed generally provides a reduction of exterior-to interior noise levels of about 25 dBA with closed windows (2006). Standard construction materials and techniques used for residential developments in Southern California (conventional wood frame construction consistent with current California energy conservation requirements) normally result in a minimum exterior-to-interior noise attenuation of 15 dBA with windows open and 20 dBA with windows closed. The time period in which noise occurs is also important since noise that occurs at night tends to be more disturbing than that which occurs during the daytime. To evaluate community noise on a 24-hour basis, the day-night average sound level was developed (Ldn). Ldn is the average of all A-weighted levels for a 24-hour period with a 10 dB upward adjustment added to those noise levels occurring between 10:00 PM and 7:00 AM to account for the general increased sensitivity of people to nighttime noise levels. The Community Noise Equivalent Level (CNEL) is identical to the Ldn with one exception. The CNEL adds 5 dB to evening noise levels (7:00 PM to 10:00 PM). Thus, both the Ldn and CNEL noise measures represent a 24-hour average of A- weighted noise levels with Ldn providing a nighttime adjustment and CNEL providing both an evening and nighttime adjustment. b. Groundborne Vibration. Vibration is sound radiated through the ground. The rumbling sound caused by the vibration of room surfaces is called groundborne noise. The ground motion caused by vibration is measured as particle velocity in inches per second and is referenced as vibration decibels (VdB) (FTA 2006). The background vibration velocity level in residential areas is typically around 50 VdB. The vibration velocity level threshold of perception for humans is approximately 65 VdB. A vibration velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels for many people. Most perceptible indoor vibration is caused by sources within buildings, such as operation of mechanical equipment, movement of people, or the slamming of doors. Typical outdoor sources of perceptible groundborne vibration are construction equipment, steel-wheeled trains, and traffic on rough roads. If a roadway is smooth, the groundborne vibration from traffic is rarely perceptible. The range of interest for groundborne vibration is from approximately 50 VdB, which is the typical background vibration velocity level, to 100 VdB, which is the general threshold where minor damage can occur in fragile buildings (FTA 2006). The general human response to different levels of groundborne vibration velocity levels is described in Table 4.10-1. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-3 Table 4.10-1 Human Response to Different Levels of Groundborne Vibration Vibration Velocity Level Human Reaction 65 VdB Approximate threshold of perception for many people. 75 VdB Approximate dividing line between barely perceptible and distinctly perceptible. Many people find transit vibration at this level annoying. 85 VdB Vibration acceptable only if there are an infrequent number of events per day. 90 VdB Difficulty with tasks such as reading computer screens. Source: FTA 2006. c. Existing Noise Environment. The project site is located west of U.S. Highway 101 (U.S. 101) and east of Madonna Road, with residential uses to the west, commercial uses to the north, and agricultural uses to the south. The project site is in an area characterized primarily by residential and commercial development, and is within the San Luis Obispo County Regional Airport Land Use Plan (ALUP) noise contours. Consequently, noise sources on the project site and in the site vicinity include vehicular traffic, as well as air traffic from San Luis Obispo County Regional Airport. In addition there are potential stationary noise sources from neighboring commercial activities and from the U.S. Post Office on Dalidio Drive. The project site is bordered by U.S. 101 to the east and by Madonna Road to the north. Commercial activities, including loading docks and car dealerships, are located southwest of the site across Prefumo Creek. 45dB.com prepared a Sound Level Assessment for the project site in February 2015 (refer to Appendix K). As part of the analysis, existing sound levels on the project site were measured over a 24-hour period beginning on January 16, 2015 through January 17, 2015. Four sound level measurement stations were selected to represent the various potential noise sources found on this site. Table 4.10-2 describes the sound level measurement locations and results. Figure 4.10-1 depicts the sound level measurement locations and existing sound level contours on the project site, taking into account all existing sources of noise, including noise from nearby roadways and aircraft noise. Sound Level MeterSound Level MeterStation 3Station 3Sound Level MeterStation 3Sound Level MeterSound Level MeterStation 2Station 2Sound Level MeterStation 2Sound Level MeterSound Level MeterStation 4Station 4Sound Level MeterStation 4Sound Level MeterSound Level MeterStation 1Station 1Sound Level MeterStation 1Sound Level Assessment prepared by 45dB.com, February 26, 2015Existing Sound Level Contourson the Project SiteFigure 4.10-1City of San Luis ObispoSan Luis Ranch Project EIRSection 4.10 Noise4.10-4 San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-5 Table 4.10-2 Noise Measurement Results Station Location Primary Noise Source Measured Sound Level Hourly Leq range 1 Ldn/CNEL 2 1 Located at the southeastern site boundary and 75 feet from the nearest traffic lane of U.S. 101 Vehicle traffic along U.S. 101 61-73 dBA 74 dBA 2 Located in the southwest corner of the site Aircraft departing and approaching San Luis Obispo County Regional Airport, as well as commercial operations to the west. 39-54 dBA 53 dBA 3 Located near the north boundary of the property and 120 feet from the nearest traffic lane (eastbound) of Madonna Road Vehicle traffic along Madonna Road 49-67 dBA 64 dBA 4 Located next to the north boundary of the property, adjacent to the U.S. Postal Service Facility loading and staging area Delivery, loading and unloading of mail from the facility (which may occur at all hours) 40-54 dBA 54 dBA Notes: 24-hour measurements were taken using an ANSI Type 1 integrating sound level meter. 1. Leq is the average sound level over each 1-hour period of the overall 24-hour measurement period. 2. Ldn/CNEL is the weighted average sound level over a 24-hour period Source: 45dB.com, February 2015. In addition to these 24-hour continuous sound level measurements, sound levels were spot checked around the perimeter of the site. The hourly Leq for each of the measurement sites was derived from measured sound level data. In addition, for each measurement location the 24- hour Ldn and CNEL values were calculated. The resulting sound level contours are shown in Figure 4.10-1. Complete data from each 24-hour sound level measurement station is included in Appendix K. d. Land Use Compatibility. The northern and northeastern portions of the project site are bordered by existing commercial uses and the U.S. Post Office on Dalidio Drive, neither of which are considered noise-sensitive land uses. These uses obtain vehicular access off of Madonna Road and Dalidio Drive, and noise from vehicle movement to and from these businesses is audible on the northern and eastern portions of the Specific Plan Area. The western portion of the Specific Plan Area is bordered by Prefumo Creek, with residences on the opposite side of the Creek. The southwestern portion of the Specific Plan Area is bordered by agricultural uses, and the southeastern portion of the Specific Plan Area is bordered by U.S. 101. The San Luis Obispo County Regional Airport is located approximately 1.6 miles southeast from the Specific Plan Area. The ALUP includes noise contours that indicate noise levels created by incoming and departing aircraft from the airport. Figure 4.10-2 shows the ALUP noise contours on and in the vicinity of the project site. The eastern portion of the site is within the 55 dBA CNEL airport noise contour, and the western portion of the site is within the 50 dBA CNEL £¤101 Madonna Rd Airport Land Use PlanAirport Noise Contours on the Project Site Figure 4.10-2 City of San Luis Obispo Section 4.10 NoiseSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016.Additional data provided by Airport Land Use Commission of San Luis Obispo County, May 2015. ±0 900450 Feet Site Boundary ALUP CNEL Noise Contour 50 dBA 55 dBA 60 dBA 4.10-6 San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-7 airport noise contour. The City of San Luis Obispo General Plan Noise Element depicts the airport’s noise contours from 60 dBA CNEL to 75 dBA CNEL (refer to Figure 6 of the Noise Element); however, as the Noise Element does not depict noise contours below 60 dBA CNEL, none of these contours overlay the Specific Plan Area (City of San Luis Obispo 1996). Figure 4.10-1 shows existing sound level contours on the site, taking into account all existing sources of noise, including noise from nearby roadways and aircraft noise. e. Sensitive Noise Receptors. Noise exposure goals for various types of land uses reflect the varying noise sensitivities associated with those uses. Single- and multi-family residences, schools, libraries, medical facilities, retirement/assisted living homes, health care facilities, and places of worship are most sensitive to noise intrusion and therefore have more stringent noise exposure targets than commercial or agricultural uses that are not subject to impacts such as sleep disturbance, disruption of conversations, lectures or sermons, or decreased attractiveness of exterior use areas, such as patios, backyards, or parks. Of particular concern is exposure of sensitive receptors to long-term elevated interior noise levels and sleep disturbance, which can be associated with health concerns. Noise sensitive land uses near the project site include the residential areas located approximately 75 feet to the southwest and west from the project site boundary, as well as Laguna Lake Park located approximately 110 feet to the north of the project site. The nearest residential areas are separated from the project site by Prefumo Creek and its associated riparian vegetation. Madonna Road separates Laguna Lake Park from the project site. f. Regulatory Setting. Federal. Federal Transit Administration Criteria. The FTA developed methodology and significance criteria to evaluate vibration impacts from surface transportation modes (i.e., passenger cars, trucks, buses, and rail) in the Transit Noise Impact and Vibration Assessment (FTA 2006). For residential buildings (Category 2), the threshold applicable to these projects is 80 VdB. Federal Noise Control Act (1972). Public Law 92-574 regulates noise emissions from operation of all construction equipment and facilities; establishes noise emission standards for construction equipment and other categories of equipment; and provides standards for the testing, inspection, and monitoring of such equipment. This Act gives states and municipalities primary responsibility for noise control. State. State of California’s Guidelines for the Preparation and Content of Noise Element of the General Plan (1987). These guidelines reference land use compatibility standards for community noise environments as developed by the California Department of Health Services, Office of Noise Control. Sound levels up to 65 Ldn or CNEL are determined in these guidelines to be normally acceptable for multi-family residential land uses. Sound levels up to 70 CNEL are normally acceptable for buildings containing professional offices or defined as business commercial. The guidelines recommend that a detailed analysis of noise reduction requirements be prepared when new residential development is proposed in areas where existing sound levels approach 70 CNEL. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-8 The California Administrative Code (CAC), Title 24, Noise Insulation Standards. These standards regulate interior noise levels for all new multi-family residences to 45 Ldn or below. If exterior sound levels exceed 60 Ldn, CAC Title 24 requires the preparation of an acoustical analysis showing that the proposed design would limit the sound level to, or below the 45 Ldn requirement. Local. City of San Luis Obispo General Plan Noise Element and Noise Guidebook (1996). According to State law, a noise element is a required component of all city and county general plans. The City of San Luis Obispo General Plan Noise Element uses modified land use compatibility standards recommended by the California Department of Health Services. The City’s maximum noise exposure standards for noise-sensitive land uses (specific to transportation noise sources) are shown in Table 4.10-3. Table 4.10-3 Maximum Noise Exposure for Noise-Sensitive Land Use Areas Due To Transportation Noise Sources Land Use Outdoor Activity Areas 1 Interior Spaces Ldn 2 or CNEL Ldn 2 or CNEL Leq 3 Residences, hotels, motels, hospitals, nursing homes 60 45 -- Theaters, auditoriums, music halls -- -- 35 Churches, meeting halls, office building, mortuaries 60 -- 45 Schools, libraries, museums -- -- 45 Neighborhood parks 65 -- -- Playgrounds 70 -- -- 1. If the location of outdoor activity areas is not shown, the outdoor noise standard shall apply at the property line of the receiving land use. 2. Ldn (day-night average sound level) is the energy-averaged sound level measured over a 24-hour period, with a 10-dB penalty assigned to noise events occurring between 10:00 PM and 7:00 AM and a 5-dB penalty assigned to noise events occurring between 7:00 PM and 10 PM. 3. Leq (equivalent sound level) is the constant or single sound level containing the same total energy as a time-varying sound, over a certain time. If the location of outdoor activity areas is not shown, the outdoor noise standard shall apply at the property line of the receiving land use. Source: City of San Luis Obispo General Plan, Noise Element 1996. The City requires that noise generated by new stationary sources be mitigated so as not to exceed the exposure standards shown in Table 4.10-3 for noise-sensitive uses, as measured at the property line of the receiver. The City’s Noise Element lists mitigation strategies in a descending order of preference. If preferred strategies are not implemented, it is the responsibility of the project applicant to demonstrate through a detailed noise study that the preferred approaches are either not effective or not practical, before considering other design criteria described in the General Plan. The City considers the following mitigation measures appropriate where existing sound levels significantly impact noise-sensitive land uses, or where cumulative increases in sound levels resulting from new development significantly impact existing noise-sensitive land uses: San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-9 1. Rerouting traffic onto streets that can maintain desired levels of service, consistent with the Circulation Element, and which do not adjoin noise-sensitive land uses. 2. Rerouting trucks onto streets that do not adjoin noise-sensitive land uses. 3. Constructing noise barriers. 4. Reducing traffic speeds through street or intersection design methods. 5. Retrofitting buildings with noise-reducing features. 6. Establishing financial programs, such as low-cost loans to owners of a noise-impacted property, or developer fees to fund noise-mitigation or trip-reduction programs. The City’s maximum noise exposure standards for noise-sensitive land uses (specific to stationary noise sources) are shown in Table 4.10-4. Table 4.10-4 City Maximum Noise Exposure for Noise-Sensitive Land Use Areas Due to Stationary Noise Sources Daytime (7:00 AM to 10:00 PM) Nighttime (10:00 PM to 7:00 AM) Hourly Leq in dB 1, 2 50 45 Maximum level in dB 1, 2 70 65 Maximum impulsive noise in dB 1, 3 65 60 1. As determined at the property line of the receiver. When determining effectiveness of noise mitigation measures, the standards may be applied on the receptor side of noise barriers or other property-line noise mitigation measures. 2. Sound level measurements shall be made with slow meter response. 3. Sound level measurements shall be made with fast meter response. Source: City of San Luis Obispo General Plan Noise Element, 1996. The following Noise Element policies are applicable to the project and the local noise environment: Policy 1.4. New Transportation Noise Sources. Noise created by new transportation noise sources, including road, railroad, and airport expansion projects, shall be mitigated to not exceed the levels specified in Table 4.10-3 for outdoor activity areas and indoor spaces of noise- sensitive land uses which were established before the new transportation noise source. Policy 1.6. New Development and Stationary Noise Sources. New development of noise-sensitive land uses may be permitted only where location or design allow the development to meet the standards of Table 4.10-4, for existing stationary noise sources. City of San Luis Obispo Municipal Code, Title 9, Chapter 9.12 (Noise Control). The City’s Municipal Code (§9.12.060) specifies noise standards for various categories of land use. These limits, shown in Table 4.10-5, would apply to long-term operation of the site, and are not applicable during construction. As shown in Table 4.10-6, these noise level standards are not to be exceeded more than 30 minutes in any one hour and noise levels are prohibited from exceeding the noise level standard plus 20 dBA for any period of time. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-10 Table 4.10-5 Exterior Noise Limits Zoning Designation Time Period Maximum Acceptable Noise Level (dBA 2) Low- and Medium-Density Residential (R-1 and R-2); Conservation/Open Space (C/OS) 10:00 PM – 7:00 AM 50 7:00 AM – 10:00 PM 55 Medium- and High-Density Residential (R-3 and R-4) 10:00 PM – 7:00 AM 50 7:00 AM – 10:00 PM 55 Office and Public Facility (O and PF) 10:00 PM – 7:00 AM 55 7:00 AM – 10:00 PM 60 Neighborhood, Retail, Community, Downtown and Tourist Commercial (C-N, C-R, C-C, C-D, C T) 10:00 PM – 7:00 AM 60 7:00 AM – 10:00 PM 65 Service Commercial (C-S) Any Time 70 Manufacturing (M) Any Time 75 Source: City of San Luis Obispo Municipal Code Section 9.12.060 Table 4.10-6 Maximum Time Periods for Increased Noise Levels Noise Standard for Existing Land Use Maximum Time Period Allowed +0 dBA 30 minutes/hour +5 dBA 15 minutes/hour +10 dBA 5 minutes/hour +15 dBA 1 minute/hour +20 dBA Any time Source: City of San Luis Obispo Municipal Code Section 9.12.060 Table 4.10-7 and Table 4.10-8 show the City’s maximum allowable noise levels for short-term operation of mobile equipment and long-term operation of stationary equipment at residential properties. Where technically and economically feasible, the City requires that construction activities that use mobile or stationary equipment which may result in noise at residential properties be conducted so that maximum sound levels from mobile equipment at affected San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-11 properties would not exceed 75 dBA for single-family residential, 80 dBA for multi-family residential, and 85 dBA for mixed residential/commercial land uses (Municipal Code 9.12.050). Except for emergency repair of public service utilities, or where an exception is issued by the City Community Development Department, the City prohibits operation of tools or equipment used in construction, drilling, repair, alteration, or demolition work daily between the hours of 7:00 PM and 7:00 AM, or any time on Sundays or holidays, such that the sound creates a noise disturbance across a residential or commercial property line. Table 4.10-7 Maximum Noise Levels for Nonscheduled, Intermittent, Short-Term Operation (Less than 10 Days) of Mobile Equipment at Residential Properties Zoning Category Time Period Noise Level (dBA) Single-Family Residential Daily 7:00 AM to 7:00 PM, except Sundays and legal holidays 75 dBA Multi-Family Residential 80 dBA Mixed Residential/Commercial 85 dBA Single-Family Residential 7:00 PM to 7:00 AM, all day Sunday and legal holidays 50 dBA Multi-Family Residential 55 dBA Mixed Residential/Commercial 60 dBA Source: City of San Luis Obispo Municipal Code, 2008. Table 4.10-8 Maximum Noise Levels for Repetitively Scheduled, Relatively Long-Term Operation (10 Days or More) of Stationary Equipment at Residential Properties Zoning Category Time Period Noise Level (dBA) Single-Family Residential Daily 7:00 AM to 7:00 PM, except Sundays and legal holidays 60 dBA Multi-Family Residential 65 dBA Mixed Residential/Commercial 70 dBA Single-Family Residential 7:00 PM to 7:00 AM, all day Sunday and legal holidays 50 dBA Multi-Family Residential 55 dBA Mixed Residential/Commercial 60 dBA Source: City of San Luis Obispo Municipal Code, 2008. Airport Land Use Plan for the San Luis Obispo County Regional Airport. The San Luis Obispo County Regional ALUP details restrictions on development within the airport vicinity. As described in the ALUP, residential land uses, restaurants, and public assembly areas, among other items, exist as Extremely Noise Sensitive Land Uses. Applicable ALUP policies describe San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-12 the noise conditions that may affect the project site. These conditions are shown below and described in Table 4.10-9. Policy N-1. Would permit or fail to sufficiently prohibit establishment within the projected 60-dB CNEL contour of any extremely noise-sensitive land use. Policy N-2. Would permit or fail to sufficiently prohibit any extremely noise-sensitive land use within the projected 55-dB CNEL contour, with the exception of developments which meet the criteria delineated in Section 4.3.2.3 for designation as infill. Policy N-3. Would permit or fail to sufficiently prohibit any moderately noise-sensitive land use within the projected 55-dB CNEL contour, with the exception of developments which meet the requirements for mitigation of interior noise levels specified in Table 4 and in Section 4.3.3. Policy N-4. Would permit or fail to sufficiently prohibit, in any location which is within or adjacent to an area of demonstrated noise incompatibility or in an acoustic environment substantially similar to an area of demonstrated noise incompatibility: a. Any new residential or other extremely noise-sensitive development b. Any new moderately noise-sensitive development, unless adequate, specific, and detailed provisions are set forth to mitigate noise incompatibility between allowable or proposed noise-sensitive uses (including foreseeable outdoor activities) and airport operations. Table 4.10-9 Summary of Compatibility of Land Uses with CNEL Contours Noise Environment Extremely Noise-Sensitive Land Uses Inside 60 dB CNEL contour Prohibited Between 55 and 60 dB CNEL contours Allowable only within a Designated Residential Infill Area (with appropriate noise mitigation) or as a Small-Scale Residential Project Outside 55 CNEL dB contour Allowed Source: Airport Land Use Commission, 2014. Refer to Figure 4.10-2. 4.10.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) analyzed noise impacts for the City of San Luis Obispo related to the adoption of the most recent updates to the Land Use and Circulation Elements. However, the LUCE Update EIR did not include a site- specific analysis of this noise issue for the San Luis Ranch Specific Plan Area. The LUCE Update EIR identified unavoidable and significant short-term construction noise impacts due to construction of development projects. The LUCE Update EIR included overall analyses of the impact of construction of 500 new housing units and up to 350,000 square feet of commercial and office space in the San Luis Ranch Specific Plan Area, but did not address the details of such noise impacts on and around the project site. Such development could generate short-term San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-13 construction noise levels through the use of heavy-duty construction equipment that exceed the City’s Noise Control Ordinance. The LUCE Update EIR also found that increased traffic volumes, noise from operation of new development, and construction of new noise-sensitive uses within airport noise contours could also create potentially significant impacts. However for these three issues, the LUCE Update EIR concluded that implementation of the updated Land Use and Circulation Element policies, and amendments to existing City policies, would reduce impacts to a less than significant level. 4.10.3 Impact Analysis a. Methodology and Significance Thresholds. Construction Noise. Construction noise and groundborne vibration levels were estimated based on projected construction vehicle requirements, distance between sensitive receptors and construction activities, and proposed daytime operational levels. Noise levels from typical construction equipment were estimated using data published in the Federal Highway Administration (FHWA) Construction Noise Handbook (U.S. Department of Transportation 2013). Construction noise levels would diminish with distance from the construction site, at a rate of approximately 6 dBA per doubling of distance as equipment is generally stationary or confined to specific areas during construction. It should be noted that construction noise and vibration level estimates do not account for the presence of intervening structures or topography, which would further reduce noise and vibration levels at receptor locations. Therefore, the noise and vibration levels presented herein represent a conservative estimate of actual construction noise. Vibration Levels Associated with Construction Equipment. Groundborne vibration levels associated with construction activities were estimated based on the 2013 California Department of Transportation’s (Caltrans) Transportation and Construction Vibration Guidance Manual. Potential vibration levels are identified for onsite and offsite locations that are sensitive to vibration, including nearby residences. Operational and Traffic Noise. Operational noise associated with the project includes residential and commercial operational activities. The City’s Municipal Code (§9.12.060) specifies noise standards for long-term operation of the project site, shown in Table 4.10-5 above. Noise generated from stationary sources on the project site is estimated based on the typical dBA levels generated from urban uses, such as heating, ventilation, and air conditioning (HVAC) equipment, delivery trucks, parking lot noise, and other common uses. Policy 1.4 of the City’s Noise Element sets maximum noise exposure standards for noise- sensitive land use (specific to transportation noise sources), as shown in Table 4.10-3. The future noise levels along local roadways and within the project site were calculated using the FHWA’s Traffic Noise Model (TNM v. 2.5). Noise modeling data sheets are included in Appendix K. The estimated roadway noise levels are based on traffic data from the project Traffic Impact Study (refer to Section 4.12, Transportation/Traffic and Appendix L) and Caltrans traffic counts (Caltrans 2015b and 2015c). Cumulative Year 2035 conditions correspond to two different configurations for the Prado Road/U.S. 101 improvements: Full Build Prado Road Interchange and Prado Road Overcrossing scenarios (for more detail on these two configurations and the associated traffic scenarios, refer to Section 4.12, Transportation). Future traffic volumes on U.S. 101 were estimated using a 1 percent annual growth rate. The traffic noise model was calibrated based on the 24-hour sound level measurement taken at station 3, shown in Table 4.10-2. The San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-14 measured and modeled noise levels were found to be within 1 dBA, which is within the acceptable margin-of-error of noise monitoring equipment and modeling programs. Overall onsite noise levels were calculated by standard logarithmic decibel addition. Based on logarithmic addition, a doubling of sound energy equates to an approximately 3 dBA increase in noise (e.g., an increase from 65 dBA to 68 dBA represents a doubling of sound energy). Significance Thresholds. The following criteria are based on Appendix G of the State CEQA Guidelines. Impacts would be potentially significant if the project would result in: 1. Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; 2. Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels; 3. A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project; 4. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project; 5. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, exposure of people residing or working in the project area to excessive noise levels; or 6. For a project within the vicinity of private airstrip, would the project expose people residing or working the project area to excessive noise levels. The Initial Study determined that the project would not result in exposure of persons to excessive noise levels due public or private airport operations. Therefore, Thresholds 5 and 6 are not discussed further in this section. Refer to Section 4.14, Issues Addressed in the Initial Study, for a discussion of these impacts. The maximum sound levels established by Municipal Code 9.12.050 and described in Table 4.10-7 and Table 4.10-8 in Section 4.10.1(f), Regulatory Setting, are the applicable construction noise thresholds for the proposed project. Maximum sound levels from mobile equipment at affected properties should not exceed 75 dBA for single-family residential, 80 dBA for multi- family residential, and 85 dBA for mixed residential/commercial land uses, as shown in Table 4.10-7. Maximum sound levels from stationary equipment at affected properties should not exceed 60 dBA for single-family residential, 65 dBA for multi-family residential, and 70 dBA for mixed residential/commercial land uses, as shown in Table 4.10-8. Caltrans provides thresholds of significance for vibration and methodology for calculating vibration levels at distances from generation. Table 4.10-10 indicates vibration levels at which humans would be affected by vibration levels. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-15 Table 4.10-10 California Department of Transportation Vibration Annoyance Potential Criteria Human Response Condition Maximum Vibration Level (in/sec) for Transient Sources Maximum Vibration Level (in/sec) for Continuous/Frequent Intermittent Sources Barely perceptible 0.04 0.01 Distinctly perceptible 0.25 0.04 Strongly perceptible 0.9 0.10 Severe 2.0 0.4 Source: California Department of Transportation 2013. Traffic noise impacts due to project-generated traffic would be significant if traffic-generated noise associated with development of the project would expose new sensitive receptors to unacceptable noise levels, based on the City’s standards for transportation noise sources in Table 4.10-3. For existing noise-sensitive receptors, project-generated traffic noise would be significant if it would result in a permanent increase of 3 dBA in ambient noise levels in the project vicinity above levels existing without the project. (An increase of 3 dBA or greater is typically considered a substantial increase as it is perceivable by the human ear.) b. Project Impacts and Mitigation Measures. Threshold 1: Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Threshold 4: Would the project result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? Impact N-1 Temporary construction activity would create noise that could exceed City of San Luis Obispo Municipal Code regulations. Mitigation is available to address construction noise, but it may not be feasible to reduce the impact to less than the applicable threshold. Impacts would be Class I, significant and unavoidable. Construction of the project would occur in six phases between 2017 and 2023. Phases 1, 2, and 3 – which include the proposed residential build out – would be constructed between 2017 and 2020. Phases 4 and 5 – which include office and hotel build out – would be constructed between 2018 and 2023. Phase 6 – which includes commercial build out – would be constructed between 2017 and 2020. Table 4.10-12 shows typical noise levels associated with standard stationary and mobile construction equipment at distances of 50, 100, and 125 feet from the noise source. These distances have been used because the nearest residences are a minimum of 50 feet from the project boundary, 100 feet from the nearest proposed building pad, and 125 feet from the nearest proposed roadway. Typical construction noise levels at 50 feet from the source range from about 76 to 89 dBA. Grading/excavation activities generally create the highest construction noise levels because of the continuous operation of heavy equipment, although only a limited amount of equipment can operate near a given location at a particular time. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-16 Table 4.10-11 Noise Ranges of Typical Construction Equipment Construction Equipment Typical Level (dBA) 50 feet Typical Level (dBA) 100 feet Typical Level (dBA) 125 feet Mobile Equipment Backhoe 80 74 72 Compactor 82 76 74 Grader 85 79 77 Loader 85 79 77 Paver 89 83 81 Scraper 89 83 81 Truck 88 82 80 Stationary Equipment Air Compressor 80 74 72 Concrete Mixer 85 79 77 Concrete Pump 82 76 74 Crane 83 77 75 Generator 81 75 73 Jackhammer 88 82 80 Pneumatic Impact Equipment 85 79 77 Pump 76 70 68 Notes: Machinery equipped with noise control devices or other noise-reducing design features does not generate the same level of noise emissions as that shown in this table. Noise levels assume a noise attenuation rate of 6 dBA per doubling of distance. Source: U.S. Department of Transportation 2013. The loudest pieces of equipment are the paver and scraper, which at 50 feet generate 89 dBA. These pieces of equipment would be used to construct the roads which would be a minimum of 125 feet from the nearest sensitive receptor, resulting in noise levels up to 81 dBA during road construction. The highest noise level that nearby residences would be exposed to during temporary construction activity would be 85 dBA during grading, which may occur as close as 50 feet from the nearest residence. This would exceed the single-family threshold of 60 dBA for relatively long-term construction activity (10 days or more) shown in Table 4.10-8. In addition, the project would involve approximately 817,200 cubic yards (CY) of cut and 569,200 CY of fill during project site grading and excavation, resulting in a need for approximately 248,000 CY of soil import. Trucks hauling material to and from the site would be a source of construction noise. As shown in Table 4.10-12, noise from trucks can reach up to 88 dBA at 50 feet from the source. If hauling trucks traveled through residential neighborhoods or by sensitive receptors, noise levels may exceed the 75 dBA threshold for intermittent noise shown in Table 4.10-7 and impacts would be potentially significant. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-17 Mitigative Components of the Specific Plan and Impact Conclusion. There are no components of the Specific Plan that would mitigate the impacts of construction noise. Mitigation Measures. The following mitigation measures are required to minimize construction-related noise. N-1(a) Construction Vehicle Travel Route. Construction vehicles and haul trucks shall utilize roadways which avoid residential neighborhoods and sensitive receptors where possible. The applicant shall submit a proposed construction vehicle and hauling route for City review and approval prior to grading/building permit issuance. The approved construction vehicle and hauling route shall be used for soil hauling trips prior to construction as well as for the duration of construction. N-1(b) Construction Activity Timing. Except for emergency repair of public service utilities, or where an exception is issued by the Community Development Department, no operation of tools or equipment used in construction, drilling, repair, alteration, or demolition work shall occur daily between the hours of 7:00 PM and 7:00 AM, or any time on Sundays, holidays, or after sunset, such that the sound creates a noise disturbance that exceeds 75 dBA for single family residential, 80 dBA for multi-family residential, and 85 dBA for mixed residential/commercial land uses across a residential or commercial property line. N-1(c) Construction Equipment Best Management Practices (BMPs). For all construction activity at the project site, noise attenuation techniques shall be employed to ensure that noise levels are maintained within levels allowed by the City of San Luis Obispo Municipal Code, Title 9, Chapter 9.12 (Noise Control). Such techniques shall include: • Sound blankets on noise-generating equipment. • Stationary construction equipment that generates noise levels above 65 dBA at the project boundaries shall be shielded with barriers that meet a sound transmission class (a rating of how well noise barriers attenuate sound) of 25. • All diesel equipment shall be operated with closed engine doors and shall be equipped with factory-recommended mufflers. • For stationary equipment, the applicant shall designate equipment areas with appropriate acoustic shielding on building and grading plans. Equipment and shielding shall be installed prior to construction and remain in the designated location throughout construction activities. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-18 • Electrical power shall be used to power air compressors and similar power tools. • The movement of construction-related vehicles, with the exception of passenger vehicles, along roadways adjacent to sensitive receptors shall be limited to the hours between 7:00 AM and 7:00 PM, Monday through Saturday. No movement of heavy equipment shall occur on Sundays or official holidays (e.g., Thanksgiving, Labor Day). • Temporary sound barriers shall be constructed between construction sites and affected uses. N-1(d) Neighboring Property Owner Notification and Construction Noise Complaints. The contractor shall inform residents and business operators at properties within 300 feet of the project site of proposed construction timelines and noise complaint procedures to minimize potential annoyance related to construction noise. Proof of mailing the notices shall be provided to the Community Development Department before the City issues a zoning clearance. Signs shall be in place before beginning of and throughout grading and construction activities. Noise- related complaints shall be directed to the City’s Community Development Department. Plan Requirements and Timing. Construction plans shall note construction hours, truck routes, and construction Best Management Practices (BMPs) and shall be submitted to the City for approval prior to grading and building permit issuance for each project phase. BMPs shall be identified and described for submittal to the City for review and approval prior to building or grading permit issuance. BMPs shall be adhered to for the duration of the project. The applicant shall provide and post signs stating these restrictions at construction site entries. Signs shall be posted prior to commencement of construction and maintained throughout construction. Schedule and neighboring property owner notification mailing list shall be submitted 10 days prior to initiation of any earth movement. The Community Development department shall confirm that construction noise reduction measures are incorporated in plans prior to approval of grading/building permit issuance. All construction workers shall be briefed at a pre-construction meeting on construction hour limitations and how, why, and where BMP measures are to be implemented. A workday schedule will be adhered to for the duration of construction for all phases. Monitoring. City staff shall ensure compliance throughout all construction phases. Building inspectors and permit compliance San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-19 staff shall periodically inspect the site for compliance with activity schedules and respond to complaints. Significance After Mitigation. Project construction would represent a temporary source of noise to sensitive receptors adjacent to the project site and along the route used by haul trucks. Mitigation Measures N-1(a) through N-1(g) require implementation of noise reduction devices and techniques during construction, and would reduce noise associated with on- and off-site construction activity to the maximum extent feasible. As shown in Table 4.10-12, noise from trucks can reach up to 88 dBA at 50 feet from the source. Although Mitigation Measure N- 1(a) would reduce impacts from haul trucks by requiring the haul route to avoid residential areas and noise sensitive uses where possible, haul truck noise would continue to exceed the 75 dBA threshold for intermittent noise shown in Table 4.10-7. Therefore, noise impacts from haul trucks would be minimized, but not eliminated. As a result, temporary noise impacts associated with off-site construction activity would be significant and unavoidable. As shown in Table 4.10-12, residences would be exposed to temporary noise levels of up to 85 dBA during grading activities, which would occur 50 feet from the nearest residence. The available mitigation for this, and other construction activities would not reduce the noise associated with these activities below the applicable City standards for relatively long term construction activity shown in Table 4.10-8. Therefore temporary noise impacts associated with on-site construction activity would be significant and unavoidable. Threshold 2: Would the project result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Impact N-2 Short-term construction activities would generate intermittent levels of groundborne vibration. However, the expected vibration level during construction of the project would not be perceptible at the nearest residential receptors. This impact would be Class III, less than significant. Construction activities on the project site would generate low levels of groundborne vibration. Table 4.10-13 identifies vibration velocity levels based on distance from the receptor for the types of construction equipment that would be used on the project site during construction activities. Table 4.10-12 Vibration Source Levels for Construction Equipment Construction Equipment Vibration Level (in/sec) 1 25 feet 50 feet 100 feet 125 feet Large Bulldozer 0.089 0.035 0.017 0.008 Loaded Trucks 0.076 0.031 0.011 0.007 Jackhammer 0.035 0.016 0.008 0.003 Small Bulldozer 0.003 0.001 <0.001 <0.001 1 Calculated using equation from FTA Transit Noise and Vibration Impact Assessment (2006): PPVequip = PPVref * (25/D)^1.5 Source: California Department of Transportation 2013. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-20 As shown in Table 4.10-13, periodic vibration levels could reach up to 0.035 in/sec at 50 feet from construction activity, and up to 0.017 in/sec at 100 feet from construction activity. The nearest residential uses are a minimum of 50 feet from the project site boundary and a minimum of 100 feet from the nearest proposed building pads. Therefore, the maximum vibration level that a sensitive receptor would be exposed to as a result of project construction activity would be 0.035 in/sec. Based on California Department of Transportation vibration criteria in Table 4.10-10, this level of vibration would be not be perceptible. In addition, construction activities that would result in vibration would be temporary and intermittent due to the nature of construction, and would only occur during daytime hours, when residents are generally less sensitive to vibration. Mitigative Components of the Specific Plan and Impact Conclusion. There are no components of the Specific Plan that would mitigate the impacts of groundborne vibration from construction activity. However, groundborne vibration from construction activity would not be perceptible at any nearby sensitive receptor. Therefore, this impact would be less than significant. Mitigation Measures. No mitigation is required. Significance After Mitigation. Impacts would be less than significant without mitigation. Threshold 3: Would the project result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Impact N-3 Project-generated traffic would incrementally increase traffic- related noise on study area roadway segments, except on Madonna Road near the project site, which would potentially affect existing noise-sensitive receptors along local roadways. However, the increase in traffic noise levels along area roadways would not exceed 3 dBA, which is the increase threshold typically audible to the human ear. Therefore, the effect of increased traffic noise would be Class III, less than significant. The project would generate an estimated 662 net new AM peak hour trips and 899 net new PM peak hour trips (refer to Section 4.12, Transportation/Traffic, and Appendix L). These trips would incrementally increase traffic noise on study area roadways, and would result in an increase in traffic noise at existing off-site sensitive receptors along affected roadways. (Long-term traffic noise impacts on the project site are discussed in Impact N-5.) Average daily trips (ADT) were estimated from the traffic study’s peak hour traffic values based on the standard assumption that peak hour traffic levels are typically approximately 10% of ADT. ADT was used to model the change in noise levels resulting from increased traffic on 21 roadway segments. In order to provide a conservative estimate of potential traffic noise increases over the lifetime of the project, the analysis included six scenarios – existing conditions, existing plus project conditions, cumulative (Year 2035) conditions with the Prado Road Interchange, cumulative (Year 2035) conditions with the Prado Road Overcrossing, and San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-21 both cumulative scenarios with the addition of project development and associated traffic. Modeled receptor locations are shown in Figure 4.10-3. Table 4.10-14 shows estimated traffic noise levels at sensitive receptors along Froom Way, Los Osos Road, Madonna Road, Higuera Street, Calle Joaquin, and Prado Road, as well as the location of the noise measurement on Madonna Road performed by 45dB.com (Receptor “NM3”). As described in Section 4.10.3(a), Methodology and Significance Thresholds, this noise measurement location was modeled to calibrate the model. The 24-hour noise measurement collected at this location was 64 dBA CNEL, while the TNM model estimate for the same location (NM3 in Table 4.10-14) was 65 dBA CNEL. The observed 1 dBA CNEL difference between the measured and modeled traffic noise levels is within the acceptable margin-of-error of noise monitoring equipment and modeling programs. Therefore, the TNM model results are reflective of roadway noise in the vicinity of the project site. kj !O !O!O !O !O !O !O !O !O !O !O !O !O!O !O !O !O !O !O !O!O !O !O !O !O !O !O !O NM1 SR1 SR2SR3 SR4 SR5 SR6 SR7 SR8 SR9 SR10 SR11 SR12SR13 SR14 SR15 SR16SR17 SR18 SR19 SR20SR21 PR1 PR2 PR3 PR4 PR5 PR6 PR7 £¤101 ST227 Los O s o s V alle y R d SHigueraStM adonnaRdTank Farm Rd SHigueraStElks LnPrado R d Modeled Noise Receptor Locations Figure 4.10-3 City of San Luis Obispo Section 4.10 NoiseSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. ±0 1,200600 Feet Site Boundary kj Noise MeasurementLocation !O Proposed Receptor !O Sensitive Receptor 4.10-22 San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-23 Table 4.10-13 Calculated Exterior Noise Associated with Traffic on Surrounding Roadways Receptor Number/ Roadway Projected Noise Level (dBA CNEL) Change In Noise Level (dBA CNEL) Existing [1] Existing + Project [2] Year 2035 Prado Road Interchange [3] Year 2035 Prado Road Interchange + Project [4] Year 2035 Prado Road Over- crossing [5] Year 2035 Prado Road Over- crossing + Project [6] Due to Project Traffic Under Existing+ Project Conditions [2]-[1] Due to Project Traffic Under Year 2035 Future Prado Road Interchange Conditions [4]-[3] Due to Project Traffic Under Year 2035 Future Prado Road Overcrossing Conditions [6]-[5] NM3 / Madonna Rd 65.0 64.3 64.7 64.4 64.9 64.6 -0.7 -0.3 -0.3 SR1 / Madonna Rd 70.4 71.2 69.9 70.2 70.2 70.7 0.8 0.3 0.5 SR2 / Madonna Rd 69.9 70.1 69.9 70.1 70.0 70.1 0.2 0.2 0.1 SR3 / Madonna Rd 69.8 70.0 69.9 70.0 69.9 70.1 0.2 0.1 0.2 SR4 / Los Osos Rd 71.1 71.1 71.7 71.7 71.7 71.7 0.0 0.0 0.0 SR5 / Los Osos Rd 70.0 70.1 70.7 70.7 70.6 70.7 0.1 0.0 0.1 SR6 / Froom Way 63.3 63.7 65.3 65.5 65.3 65.6 0.4 0.2 0.3 SR7 / Los Osos Rd 70.8 70.8 71.7 71.8 72.1 72.1 0.0 0.1 0.0 SR8 / Higuera St 74.0 74.0 74.9 74.9 75.4 75.4 0.0 0.0 0.0 SR9 / Higuera St 73.8 73.8 74.9 74.9 74.9 75.4 0.0 0.0 0.5 SR10 / Higuera St 73.9 73.9 75.1 75.1 75.1 75.6 0.0 0.0 0.5 SR11 / Prado Rd 68.9 69.0 75.1 75.5 75.1 75.4 0.1 0.4 0.3 SR12 / Prado Rd 67.4 67.5 74.5 74.8 74.4 74.7 0.1 0.3 0.3 SR13 / Higuera St 73.3 73.3 75.3 75.6 75.8 75.9 0.0 0.3 0.1 SR14 / Higuera St 72.0 72.1 73.9 74.1 74.3 74.4 0.1 0.2 0.1 SR15 / Calle Joaquin 72.9 72.9 73.7 73.7 73.7 73.7 0.0 0.0 0.0 SR16 / Calle Joaquin 77.0 77.0 77.8 77.8 77.8 77.8 0.0 0.0 0.0 SR17 / Calle Joaquin 72.9 72.9 73.8 73.9 73.9 73.9 0.0 0.1 0.0 SR18 / Calle Joaquin 76.5 76.5 77.3 77.3 77.3 77.3 0.0 0.0 0.0 SR19 / Calle Joaquin 74.5 74.5 75.3 75.3 75.3 75.3 0.0 0.0 0.0 SR20 / Calle Joaquin 70.8 70.8 71.6 71.6 71.6 71.7 0.0 0.0 0.1 SR21 / Calle Joaquin 70.4 70.4 71.2 71.2 71.3 71.3 0.0 0.0 0.0 Refer to Appendix K for full noise model output. Modeled receptor locations are shown in Figure 4.10-3. Noise levels presented do not account for attenuation provided by existing barriers or future barriers; therefore, actual noise levels at sensitive receptor locations influenced by study area roadways may in many cases be lower than presented herein. Source: Federal Highway Administration Traffic Noise Model 2.5 San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-24 As shown in Table 4.10-14, the highest noise level increase that would result from project-added traffic on the local roadway network would be 0.8 dBA under existing plus project conditions at the location of an existing hotel (receptor SR1 in Table 4.10-14) located on Madonna Road between El Mercado and the U.S. 101 southbound onramp. Noise levels would decrease on the project site along Madonna Road under the Existing Plus Project and Cumulative Plus Project scenarios. Roadway noise increases associated with new traffic on all roadways would be less than 1 dBA under existing and future cumulative conditions for both the Full Build Prado Road Interchange and Prado Road Overcrossing scenarios. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan emphasizes bikeways, pedestrian, and transit connections, all of which contribute to reduced vehicle trips and, correspondingly, reduced roadway noise impacts. As shown in Table 4.10-14, although the project would incrementally increase traffic noise in areas that are already above the City’s standard for transportation noise sources, the project would not increase roadway noise by 3 dBA (the level typically audible to the human ear) on any study area roadway, which is the threshold for a significant traffic-related noise increase at existing receptors. Therefore, this impact would be less than significant. Mitigation Measures. No mitigation is required. Significance After Mitigation. The project would not result in a significance noise increase along any local roadway. Therefore, this impact would be less than significant without mitigation. Threshold 1: Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Threshold 3: Would the project result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Impact N-4 Future development on the project site would generate operational noise typically associated with residential, commercial, office, and hotel development. Noise from the project would not exceed acceptable levels at existing off-site sensitive receptors. However, noise from new on-site commercial uses may exceed applicable City standards at proposed on-site residences. This impact would be Class II, less than significant with mitigation incorporated. The project includes single family and multifamily residential areas, a hotel, retail area, office area, open space areas, and an agricultural area. Each of these uses would include different sources of noise. In addition, the proposed residences would be sensitive receptors. The closest existing sensitive receptors are the residences to the west of the site. The proposed single family and multifamily residences would be closest to these existing residences. The noise generated by the proposed residences would consist of cars idling and parking, doors slamming, and children playing. These noise sources would be consist with the existing noise produced by the residences in the area. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-25 The proposed hotel would be located in the eastern half of the project site, over 1,500 feet from the existing residences which are the nearest existing sensitive receptor and at least 450 feet from proposed new residences on the project site. Noise sources associated with the hotel would include cars idling, doors slamming, people talking, and HVAC systems. Due to the distance from sensitive receptors and the fact that there would be additional structures between the hotel and the nearest noise sensitive receptors, the hotel would not result in noise conflicts. The proposed office areas would be located in the eastern half of the project site, approximately 1,000 feet from the nearest existing residences and at least 100 feet from proposed new residences on the project site. The office areas would generate noise associated with cars idling, doors slamming, people talking, and HVAC systems. Due to the distance from sensitive receptors and the fact that there would be additional structures between the office uses and the nearest existing noise sensitive receptors, these uses would not result in noise conflicts. The project site plan indicates that open space areas would be scattered throughout the site. The open space area along Prefumo Creek would be approximately 100 feet from the nearest existing residences. The noises associated with this area would include people talking, children playing, and dogs barking. These noises would be similar to those of the existing residences and would not result in a noise conflict. The agricultural area would make up the southern half of the site. The noise associated with this area would include equipment running and people working. This noise would be intermittent and would be the same as the noise currently experienced in the area since the site is currently under agricultural production. The proposed retail areas would be located in the eastern half of the project site, approximately 1,000 feet from the nearest existing residences. The retail areas would generate noise associated with HVAC systems, garbage/loading dock areas, and parking lots. Due to the distance from existing sensitive receptors and the fact that there would be additional structures between the retail uses and the nearest existing noise sensitive receptors, these uses would not result in noise conflicts. Proposed new residences on the project site would be located adjacent to the proposed retail areas on the eastern portion of the site (refer to Figure 2-6 in Section 2.0, Project Description). As indicated in Table 3-11 of the Specific Plan, retail buildings would be located as close as 25 feet from adjacent residences. Potential noise levels at on-site residence from HVAC, garbage/loading dock areas, and parking lots are discussed in the following paragraphs. HVAC. HVAC units are generally shielded for noise, resulting in noise levels that do not exceed 55 dBA at 50 feet from the source (U.S. EPA, 1971). As shown in Table 4.10-8, the maximum noise level standard for stationary equipment at single-family residences is 60 dBA during the day (between 7 AM and 7 PM) and 50 dBA during evening and night (between 7 PM and 7AM) and all day Sunday. Therefore, noise from HVAC equipment would not exceed the City’s daytime noise standards, but may exceed the City’s noise nighttime standards at proposed on-site residential receptors. Garbage/Loading Docks. Delivery and trash truck trips to the site would be a periodic source of operational noise. Maximum noise levels generated by medium-duty delivery trucks can reach 70 dBA at a distance of 25 feet, depending on the speed at which the truck is driving San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-26 (Olson, 1972). Loading and garbage areas may be located as close as 25 feet to the nearest on-site residential receptors. As shown in Table 4.10-7, the maximum noise level standard for intermittent sources of noise at single-family residences is 75 dBA during the day (between 7 AM and 7 PM) and 50 dBA during evening and night (between 7 PM and 7AM) and all day Sunday. Therefore, noise from delivery and garbage trucks would potentially exceed the City’s nighttime noise standards. Parking Lots. Typical noise sources associated with parking lots include tire squeal, doors slamming, car alarms, horns, and engine start-ups. Noise levels associated with parking lot activity at a distance of approximately 25 feet are shown in Table 4.10-16. The maximum source of parking lot noise at proposed residences would be from car horns and car alarm signals, which may reach 75 dBA at 25 feet from the source. These noise sources occur infrequently and do not occur for extended periods of time. More common noise sources include slow driving cars (autos at 14 mph), door slams and radios, and talking. As shown in Table 4.10-7, the maximum noise level standard for intermittent sources of noise at single-family residences is 75 dBA during the day (between 7 AM and 7 PM) and 50 dBA during evening and night (between 7 PM and 7AM) and all day Sunday. Depending on the final site plan and where the parking lots and buildings are placed in relation to one another, noise from parking lots may exceed the City’s nighttime noise standard at new residences on the project site. The noise level from the parking lot would be below the 50 dBA nighttime threshold if parking areas are located a minimum of 250 feet from the property line of the nearest residences to the west, or if the parking areas are located a minimum of 150 feet from the property line of the nearest residences, with a building intervening line-of-sight between the parking area and the residential property. Table 4.10-14 Parking Lot Noise Sources at 25 Feet Source Level (Lmax dBA) Autos at 14 mph 56 Car Alarm Signal 75 Car Alarm Chirp 60 Car Horns 75 Door Slams or Radios 70 Talking 42 Tire Squeals 72 Source: Gordon Bricken & Associates, 1996. Estimates are based on actual noise measurements taken at various parking lots Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan orients proposed residential development adjacent to existing residences and proposed commercial development adjacent to existing commercial uses. As such, the project’s proposed uses would be compatible with the existing noise environment of adjacent uses, and this impact would be less than significant. However, the Specific Plan does not include standards that would ensure that noise levels at on-site residences located adjacent to proposed retail uses would remain below applicable City standards. Therefore, this impact would be potentially significant. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-27 Mitigation Measures. The following mitigation measures are required to ensure that noise levels from proposed new retail uses at residences on the project site would remain below City standards. N-4(a) HVAC Equipment. Retail HVAC equipment shall be shielded and located on building rooftops, or a minimum of 100 feet from the nearest residential property line. N-4(b) Parking Lot/Loading Dock Orientation and Noise Barrier. Parking areas and loading docks within the proposed retail areas shall be located a minimum of 100 feet from the property lines of the nearest residential properties. For parking areas and loading docks located a minimum of 250 feet from the property line of residential properties to the west, or for parking areas and loading docks located a minimum of 150 feet from the property line of residential properties to the west with a building intervening line-of-sight between the parking area/loading dock and the residential property, no further mitigation would be required. If parking areas or loading docks would be located closer to the within 250 feet of the residential properties to the west than described above, a masonry noise barrier shall be installed along the eastern boundary of the proposed residences adjacent to the commercial land use area on the eastern portion of the project site. The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. Plan Requirements and Timing: These requirements shall be incorporated into project site plans submitted for approval before the issuance of grading and building permits. Monitoring: The Community Development Department shall verify compliance prior to issuance of operating permits. The Community Development Department shall site inspect to ensure development is in accordance with approved plans prior to occupancy clearance. Community Development staff shall verify compliance in accordance with approved building plans. Significance After Mitigation. Implementation of Mitigation Measures N-4(a) and N- 4(b) would ensure that HVAC and delivery/garbage truck noise would not exceed the City’s maximum noise standards at adjacent residences on the project site. Typically, a properly- designed noise barrier would attain an insertion loss of 10 dBA (FHWA 2011). Therefore, the required mitigation would ensure that noise levels at residences on the project site would not exceed the City’s standards for intermittent noise. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-28 Threshold 1: Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Impact N-5 Existing noise sources near the project site include vehicles on local roadways and U.S. 101. Development of the project would expose future residents on the project site to traffic noise from local roadways and U.S. 101. With mitigation, traffic noise levels on the project site would not exceed City standards. Therefore, this impact would be Class II, less than significant with mitigation incorporated. As discussed in Section 4.10.1(c), Existing Noise Environment, the existing noise environment on the project site was analyzed in the Sound Level Assessment completed in February 2015. The analysis included four 24-hour sound level measurements, which were taken at locations along the perimeter of the project site, selected to represent potential noise receptors on the project site. The results of the 24-hour noise measurements were used to develop sound level contours for the project site, shown in Figure 4.10-1. The existing sound environment on the majority of the project site ranges from approximately 52 dBA CNEL to 57 dBA CNEL. The existing sound environment exceeds 60 dBA CNEL along Madonna Road in the northeast area of the project site and along U.S. 101 in the southeast area of the project site. Impacts specific to airport noise were found to be less than significant in the City’s Initial Study (Appendix A), and are discussed in Section 4.14, Issues Addressed in the Initial Study. The City’s has adopted maximum noise exposure standards for residences, hotels, and office buildings affected by transportation noise sources (refer to Table 4.10-3). Table 4.10-17 shows estimated noise levels from roadway noise at the proposed residential buildings that would be located closest to new roadways on the project site (receptors PR1 through PR3, and PR7 shown on Figure 4.10-3). Table 4.10-17 also shows estimated roadway noise levels at proposed commercial retail, office, and hotel uses (receptors PR4 through PR6). Existing and future cumulative noise levels for both Year 2035 Full Build Prado Road Interchange and Year 2035 Full Build Prado Road Overcrossing scenarios were also modeled. As shown in Table 4.10-17, existing onsite noise levels at proposed residential, office, and hotel receptors on the project site would exceed the City’s exterior standard of 60 dBA CNEL for sensitive land uses exposed to transportation noise sources. Future unmitigated noise levels are also shown on Figures 4.10-4, 4.10-5, and 4.10-6. The proposed hotel may include an outdoor recreation area (such as a pool). If the hotel includes outdoor activity areas, those areas would be exposed to traffic noise from U.S. 101 and Prado Road that may exceed the City’s exterior standard of 60 dBA CNEL. !O !O !O !O !O !O !O PR1 (62.8 dBA) PR2 (63.7 dBA) PR3 (65.7 dBA) PR4 (66.3 dBA) PR5 (71.1 dBA) PR6 (71.3 dBA) PR7 (67.8 dBA) £¤101 ST227 Lo s O s o s V alle y R d SHigueraStM adonnaRdTank Farm Rd SHigueraStElks LnPrado R d Unmitigated Existing + Project On-Site Noise Levels (dBA CNEL)Figure 4.10-4 City of San Luis Obispo Section 4.10 NoiseSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. ±0 1,200600 Feet Site Boundary !O Proposed Receptor 4.10-29 !O !O !O !O !O !O !O PR1 (66.9 dBA) PR2 (67.2 dBA) PR3 (69.3 dBA) PR4 (69.5 dBA) PR5 (73.2 dBA) PR6 (76.2 dBA) PR7 (67.8 dBA) £¤101 ST227 Lo s O s o s V alle y R d SHigueraStM adonnaRdTank Farm Rd SHigueraStElks LnPrado R d Unmitigated Year 2035 Prado Road Interchange + Project On-Site Noise Levels (dBA CNEL)Figure 4.10-5 City of San Luis Obispo Section 4.10 NoiseSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. ±0 1,200600 Feet Site Boundary !O Proposed Receptor 4.10-30 !O !O !O !O !O !O !O PR1 (66.7 dBA) PR2 (66.8 dBA) PR3 (69.1 dBA) PR4 (69.5 dBA) PR5 (73.0 dBA) PR6 (74.5 dBA) PR7 (68.1 dBA) £¤101 ST227 Lo s O s o s V alle y R d SHigueraStM adonnaRdTank Farm Rd SHigueraStElks LnPrado R d Unmitigated Year 2035 Prado Road Overcrossing + Project On-Site Noise Levels (dBA CNEL)Figure 4.10-6 City of San Luis Obispo Section 4.10 NoiseSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. ±0 1,200600 Feet Site Boundary !O Proposed Receptor 4.10-31 San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-32 Table 4.10-15 Estimated Exterior Sound Levels at Proposed Receptors Associated with Traffic on Project Site and Surrounding Roadways Receptor Number / Proposed Use Nearest Roadways Projected Noise Level (dBA CNEL) Existing Existing + Project Year 2035 Prado Road Interchange + Project Year 2035 Prado Road Over-crossing + Project PR1 / Residences Froom Way Extension through Project Site 61.3 62.8 66.9 66.7 PR2 / Residences Froom Way Extension through Project Site 64.2 63.7 67.2 66.8 PR3 / Residences Froom Way Extension through Project Site 66.7 65.7 69.3 69.1 PR4 / Commercial Retail Dalidio Road 64.8 66.3 69.5 69.5 PR5 / Office Dalidio Road and U.S. 101 71.0 71.1 73.2 73.0 PR6 / Hotel Dalidio Road and U.S. 101 71.3 71.3 76.2 74.5 PR7 / Residences Madonna Road 67.9 67.8 67.8 68.1 Refer to Appendix K for full noise model output. Modeled receptor locations are shown in Figure 4.10-3. Noise levels presented do not account for attenuation provided by existing barriers or future barriers; therefore, actual noise levels at sensitive receptor locations influenced by study area roadways may in many cases be lower than presented herein. Source: Federal Highway Administration Traffic Noise Model 2.5 As described in Section 4.10.1(a), standard construction materials and techniques used for residential construction (i.e., conventional wood frame construction consistent with current California energy conservation requirements) normally result in a minimum exterior-to-interior noise attenuation of 15 dBA with windows open and 20 dBA with windows closed. The manner in which newer buildings, such as commercial and larger apartment buildings, are constructed generally provides a reduction of exterior-to interior noise levels of about 25 dBA with closed windows. Table 4.10-1816 shows the estimated interior noise levels with windows closed (CNEL). San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-33 Table 4.10-16 Calculated Interior Sound Levels at Proposed Receptors Associated with Traffic on Project Site and Surrounding Roadways Receptor Number / Proposed Use Nearest Roadways Projected Noise Level (dBA CNEL) Existing Existing + Project Year 2035 Prado Road Interchange + Project Year 2035 Over- crossing + Project PR1 / Residences Froom Way Extension through Project Site 41.3 42.8 46.9 46.7 PR2 / Residences Froom Way Extension through Project Site 44.2 43.7 47.2 46.8 PR3 / Residences Froom Way Extension through Project Site 46.7 45.7 49.3 49.1 PR4 / Commercial Retail Dalidio Road 39.8 41.3 44.5 44.5 PR5 / Office Dalidio Road and U.S. 101 46.0 46.1 48.2 48.0 PR6 / Hotel Dalidio Road and U.S. 101 46.3 46.3 51.2 49.5 PR7 / Residences Madonna Road 47.9 47.8 47.8 48.1 Refer to Appendix K for full noise model output. Noise levels presented do not account for attenuation provided by existing barriers or future barriers; therefore, actual noise levels at sensitive receptor locations influenced by study area roadways may in many cases be lower than presented herein. Note: Accounts for “windows closed” exterior-to-interior reduction for office, hotel, and commercial uses (a reduction of 25 dBA) and residences (a reduction of 20 dBA) (FTA 2006). Source: Federal Highway Administration Traffic Noise Model 2.5 With standard construction materials and techniques used for residential developments in Southern California, exterior-to-interior noise levels would not be reduced to below 45 dBA CNEL under Year 2035 cumulative conditions, and would therefore exceed the acceptable interior noise level for noise-sensitive land uses (standards are shown in Table 4.10-3). Mitigative Components of the Specific Plan and Impact Conclusion. Section 3.8.2 of the Specific Plan (Commercial, Office, Hotel Design Guidelines) requires future development on the project site to include screen walls and fences around storage areas, open work areas, or refuse collection areas on the project site to be of sufficient height and material to protect adjacent properties and public streets from visual and noise impacts. In addition, Section 2.6, Airport Compatibility Performance Standards, of the Specific Plan would require that all interior space of residential dwellings, as well as offices, meeting rooms, public reception areas, worker break rooms, and research, development, and production areas, meet the interior noise standard of 45 dBA CNEL and 60 dBA Lmax. However, the Specific Plan does not identify specific measures to achieve the interior noise standards identified in Section 2.6. Similarly, the Specific Plan does not include specific mitigative components that would San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-34 reduce future on-site traffic noise below the City’s exterior noise standard of 60 dBA CNEL (see Table 4.10-3). Therefore, impacts related to interior and exterior noise on the project site would be potentially significant. Mitigation Measures. The following mitigation measures would be required to reduce interior and exterior noise levels in outdoor activity areas of proposed residential, hotel, and office uses to a less than significant level. N-5(a) Interior Noise Reduction. The project applicant shall implement the following measures, or similar combination of measures, which demonstrate that interior noise levels in proposed residences adjacent to Froom Ranch Way and Madonna Road, hotel, and offices would be reduced below the City’s 45 dBA CNEL interior noise standard. The required interior noise reduction shall be achieved through a combination of standard interior noise reduction techniques, which may include (but are not limited to): • In order for windows and doors to remain closed, mechanical ventilation such as air conditioning shall be provided for all units (Passive ventilation may be provided, if mechanical ventilation is not necessary to achieve interior noise standards, as demonstrated by a qualified acoustical consultant). • All exterior walls shall be constructed with a minimum STC rating of 50, consisting of construction of 2 inch by 4 inch wood studs with one layer of 5/8 inch Type “X” gypsum board on each side of resilient channels on 24 inch centers and 3 ½ inch fiberglass insulation. • All windows and glass doors shall be rated STC 39 or higher such that the noise reduction provided will satisfy the interior noise standard of 45 dBA CNEL. • An acoustical test report of all the sound-rated windows and doors shall be provided to the City for review by a qualified acoustical consultant to ensure that the selected windows and doors in combination with wall assemblies would reduce interior noise levels sufficiently to meet the City’s interior noise standard. • All vent ducts connecting interior spaces to the exterior (i.e., bathroom exhaust, etc.) shall have at least two 90 degree turns in the duct. • All windows and doors shall be installed in an acoustically-effective manner. Sliding window panels shall form an air-tight seal when in the closed position and the window frames shall be caulked to the wall opening around the perimeter with a non-hardening caulking compound to prevent sound infiltration. Exterior doors shall seal air- tight around the full perimeter when in the closed position. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-35 The applicant shall submit a report to the Community Development Department by a qualified acoustical consultant certifying that the specific interior noise reduction techniques included in residential, hotel, and office components of the project would achieve interior noise levels that would not exceed 45 dBA CNEL. N-5(b) Residential Outdoor Activity Area Noise Attenuation. Outdoor activity areas (e.g., patios and hotel pool areas) associated with shared multifamily residential recreational spaces, hotel, commercial, and office uses shall be protected from sound intrusion so that they meet the City’s exterior standard of 60 dBA CNEL. Outdoor activity areas shall be oriented away from traffic noise such that intervening buildings reduce traffic noise or shall include noise barriers capable of reducing traffic noise levels to meet the City’s exterior standard. Hotel pool areas shall be located a minimum of 500 feet from the U.S. 101 right-of-way. Noise barriers may be constructed of a material such as tempered glass, acrylic glass, or masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. The applicant shall submit a report to the Community Development Department by a qualified acoustic consultant certifying that the specific outdoor noise reduction techniques in combination with the orientation of outdoor activity areas of shared multifamily residential recreational spaces, hotel, commercial, and offices would achieve exterior noise levels that would not exceed 60 dBA CNEL. N-5(c) Froom Ranch Way Noise Barrier. A masonry noise barrier or alternative barrier, such as a landscaped berm, shall be installed along the southern property line of residential lots that abut Froom Ranch Way to protect outdoor activity areas (patios and pools) at these residences from sound intrusion from traffic along Froom Ranch Way. The noise barrier or berm shall provide, at minimum, a 6 foot high barrier between Froom Ranch Way and the neighboring residences from the final grade of whichever use (i.e., Froom Ranch Way or residences) has a higher final elevation. If a masonry noise barrier is implemented, theThe noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. If an alternative material is used, the developer shall submit a report to the Community Development Department by a qualified acoustical consultant certifying that the specific exterior noise reduction techniques included would achieve exterior noise levels that would not exceed 60 dBA CNEL. N-5(d) U.S. Highway 101 Noise Barrier at Hotel. If the hotel includes an outdoor activity area (such as a patio or pool) a masonry noise barrier or alternative barrier, such as berms, landscaping, or glass, must be installed along the eastern property line of the hotel where it abuts the U.S. 101 right of way to protect these outdoor activity areas from sound intrusion from traffic along U.S. 101. If a masonry noise barrier is implemented, San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-36 The the noise barrier shall provide, at minimum, an 8 foot high barrier between U.S. 101 and the hotel from the final grade of whichever use (i.e., U.S. 101 or hotel) has a higher final elevation. Such a The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. If an alternative material is used, the developer shall submit a report to the Community Development Department by a qualified acoustical consultant demonstrating that the specific exterior noise reduction techniques included in the hotel component of the project would achieve exterior noise levels that would not exceed 60 dBA CNEL. Plan Requirements and Timing: These requirements shall be incorporated into all construction documents submitted for approval before the issuance of grading permits. Monitoring: The Community Development Department shall verify compliance prior to issuance of grading permits. The Community Development Department shall site inspect to ensure development is in accordance with approved plans prior to occupancy clearance. Community Development staff shall verify installation in accordance with approved building plans. Significance After Mitigation. Construction techniques described in Mitigation Measure N-5(a) would ensure that interior noise levels would not exceed the City’s interior standard in proposed residential, hotel, and office uses. In addition, Mitigation Measure N-5(a) requires that a report prepared by a qualified acoustic engineer certifying that the specific interior residential, hotel, and office components of the project would achieve interior noise levels that would not exceed 45 dBA CNEL be submitted to the Community Development Department. Typically, a single row of buildings between the receptor and the noise source reduces the noise level by about 5 dBA, while a properly-designed noise barrier would attain an insertion loss of approximately 10 dBA (FHWA 2011). As shown in Table 4.10-19, with implementation of Mitigation Measures N-5(a) through N-5(b), exterior noise levels would not exceed the City’s exterior standard (60 dBA CNEL) in outdoor activity areas associated with residential, hotel, and office uses. San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-37 Table 4.10-17 Mitigated Exterior Sound Levels at Proposed Receptors Associated with Traffic on Project Site and Surrounding Roadways Receptor Number / Proposed Use Nearest Roadways Projected Noise Level (dBA CNEL) Existing + Project Year 2035 Prado Road Interchange + Project Year 2035 Prado Road Over-crossing + Project PR1 / Residences 1 Froom Way Extension through Project Site 52.8 56.9 56.7 PR2 / Residences 1 Froom Way Extension through Project Site 53.7 57.2 56.8 PR3 / Residences 1 Froom Way Extension through Project Site 55.7 59.3 59.1 PR5 / Office 2, 3 Dalidio Road and U.S. 101 56.1 58.2 58 PR6 / Hotel 2, 3, 4 Dalidio Road and U.S. 101 46.3 51.2 49.5 PR7 / Residences 3 Madonna Road 57.8 57.8 58.1 Modeled receptor locations are shown in Figure 4.10-3. Noise levels reflect unmitigated traffic noise levels from Table 4.10-16 reduced based on Mitigation Measure N-5(a) through N-5(d), as described in the land-use specific footnotes. 1 Unmitigated traffic noise reduced by 10 dBA at residential receptors along Froom Ranch Way (PR1, PR2, and PR3) due to the noise barrier required by Mitigation Measure N-5(c). 2 Unmitigated traffic noise reduced by 5 dBA at office and hotel receptors (PR4 and PR5) due to building orientation required by Mitigation Measure N-5(b). 3 Unmitigated traffic noise reduced by 10 dBA at multifamily residential, office, and hotel receptors (PR5, PR6, and PR7) due to inclusion of sound barriers required by Mitigation Measures N-5(b). 4 Unmitigated traffic noise reduced by 10 dBA at hotel receptors (PR6) due to the noise barrier required by Mitigation Measure N-5(d). As shown in Table 4.10-19, Mitigation Measures N-5(b) through N-5(d) would ensure that the City’s exterior noise standard of 60 dBA CNEL would be achieved at affected land uses in the Specific Plan Area. Standard construction materials and techniques used for residential construction (i.e., conventional wood frame construction consistent with current California energy conservation requirements) normally result in a minimum exterior-to-interior noise attenuation of 15 dBA with windows open and 20 dBA with windows closed. The manner in which newer buildings, such as commercial and larger apartment buildings, are constructed generally provides a reduction of exterior-to interior noise levels of about 25 dBA with closed windows. Table 4.10- 19 shows that the exterior noise levels under the Prado Road Interchange scenario would range from 51.2 dBA CNEL to 59.3 dBA CNEL and 49.5 dBA CNEL to 59.1 dBA CNEL under the Prado Road Over-crossing scenario. The noise levels would be reduced by 20 dBA for the residences and 25 dBA for the commercial uses. Therefore, traffic noise would be reduced to 26.2 dBA CNEL to 29.3 dBA CNEL under the Prado Road Interchange scenario and 24.5 dBA CNEL to 39.1 dBA CNEL under the Prado Road Over-crossing scenario. Therefore, interior traffic noise levels would not exceed the City’s 45 dBA interior noise standard, and this impact would be less than significant. c. Cumulative Impacts. Table 4.10-14 shows cumulative noise increases along roadways near the project site due to cumulative traffic growth. Traffic noise levels along roadways in the project vicinity would not increase by more than 0.5 dBA due to cumulative traffic. This increase would not be significant based on the applicable traffic noise increase threshold of 3 San Luis Ranch Project EIR Section 4.10 Noise City of San Luis Obispo 4.10-38 dBA. Therefore, the project’s contribution to traffic noise would not be cumulatively considerable or significant. Construction and operation of other projects in the vicinity of the project site may generate noise levels in excess of existing measured noise levels and may affect sensitive receptors in the project site vicinity. As described in Impact N-1, there are residences approximately 75 feet to the southwest and west of the project site, as well as Laguna Lake Park located approximately 110 feet to the north of the site. However, construction and operational noise would is localized in nature and generally does not contribute to cumulative noise impacts. Implementation of Mitigation Measures N-1(a) through N-1(h), Mitigation Measures N-4(a) and N-4(b), and Mitigation Measures N-5(a) through N-5(d) would reduce construction noise associated with buildout of the project, and would ensure that the project’s contribution to cumulative noise impacts in the vicinity would be less than significant. San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-1 4.11 RECREATION 4.11.1 Setting a. Existing Park and Recreation Facilities. The City of San Luis Obispo currently features over 30 parks (including seven community parks, 10 neighborhood parks, and eight mini parks), one ten hole golf course, one community center, and multiple focused use facilities (such as the Senior Center, SLO Skate Park, Damon Garcia Sports Fields, Sinsheimer Stadium, and the SLO Swim Center). Currently, there are approximately 152 acres of parkland in the City, of which approximately 34 acres are neighborhood parks. In addition to developed parks, the City owns and/ or manages over 6,970 acres of open space within and adjacent to the City, providing passive recreational activities accommodate hiking and mountain biking (City of San Luis Obispo, Land Use and Circulation Element Update Environmental Impact Report [LUCE Update EIR], 2014). The general characteristics of the City’s recreational facilities are described below. Currently, the San Luis Ranch Specific Plan Area is not located within the City of San Luis Obispo and no parkland exists on the site. Community Parks. Community parks are intended to serve the entire community. Usually identified by unique features, community parks may be constructed for specialized and uses, and attract users from throughout the City whose recreational needs are not met in the community’s smaller parks. The City currently has six community parks (which includes the Jack House Gardens and Mission Plaza), totaling approximately 113 acres (City of San Luis Obispo, 2014). Neighborhood Parks. Neighborhood parks are defined as areas that are convenient and accessible for active and passive recreation to residents in adjacent and nearby neighborhoods. Neighborhood parks often include turf playfields, playground equipment, and landscaped picnic/seating areas, and may provide facilities such as hard‐surfaced courts, restrooms, group barbecues, natural or cultural features, and on‐site parking. The optimum site for a neighborhood park is in the center of a neighborhood within safe walking or bicycling distance of neighborhood residents. Playfields are sometimes a component of neighborhood parks and can provide opportunities for organized recreation activities. The City currently has ten neighborhood parks, totaling approximately 34 acres (City of San Luis Obispo, 2014). Mini Parks. Mini parks are typically small recreational sites that provide neighborhoods or commercial areas with passive or active recreational facilities. This type of park may be appropriate in areas where larger parks are not feasible or accessible to residents and employees in the immediate area. The City currently has eight mini parks, totaling approximately five acres (City of San Luis Obispo, 2014). Joint Use Sites. Joint use sites include facilities and/or properties where long-term uses are shared between the City and another agency through a formal agreement. Joint use facilities in the City include Sinsheimer Park as well as several fields and gymnasiums on San Luis Coastal Unified School District property located within the City that are available for scheduled recreation programs and public use after school hours (City of San Luis Obispo, 2014). San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-2 Special Facilities. Special facilities such as pools, civic centers, and golf courses, provide specific recreation opportunities for residents and visitors. Recreation Facilities Near the Project Site. The closest recreation facility to the San Luis Ranch project site is Laguna Lake Park and Natural Preserve. The 40-acre community park is located just northwest of the project site boundary, across Madonna Road. The locations of existing parks and open space within the City and in the vicinity of the project site are shown in Figure 4.11-1. Tables 4.11‐1 and 4.11‐2 describe the type, location, and amenities provided by parks and special facilities in San Luis Obispo. Table 4.11-1 Existing City of San Luis Obispo Parks and Recreation Facilities ID Number Park Name Address Facilities Acres Community Parks 1 Damon-Garcia Sports Fields 680 Industrial Way Four regulation soccer fields with lights (configurable for up to nine smaller fields); rentable concession stand; restrooms 20.0 2 Jack House Historic Home and Gardens 536 Marsh Street Site of Historic Jack House; patio area with fountain; kitchen and utility building; barbeque area; restrooms; Washhouse Gift Shop 0.8 3 Laguna Lake Park 504 Madonna Road. Group barbeque areas; three small picnic areas; par course fitness trail; disc golf course; restrooms; fishing, sail boating, row boating; dog park 40.0 4 Meadow Park 2333 Meadow Street Individual and group picnic/barbeque areas; horseshoe pits; sand volleyball courts; multi‐use basketball court; softball field; playground; fitness course; walking trails; community garden 14.0 5 Mission Plaza 989 Chorro Street Mission Plaza amphitheater; arbor patio area; restrooms 4.0 6 Santa Rosa Park Santa Rosa and Oak Two group barbecue areas; drop‐in picnic areas; ten lighted horseshoe pits; lighted softball field; youth baseball field; lighted multi‐use court for roller hockey, roller derby, and basketball; large playground area 11.0 7 Sinsheimer Park 900 Southwood Street Two group barbecue areas; six tennis courts; playground; nine‐hole disc golf course; sand volleyball court; Railroad Recreational Trail; horseshoe pits; SLO Stadium; Stockton Field 23.5 City Community Parks Acreage Subtotal 113.3 Neighborhood Parks 8 Anholm Park 870 Mission Street Picnic tables; play area 0.1 9 De Vaul Park 1651 Spooner Street playground; picnic tables 0.9 San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-3 Table 4.11-1 Existing City of San Luis Obispo Parks and Recreation Facilities ID Number Park Name Address Facilities Acres 10 Emerson Park 1316 Beach Street Sports field; basketball courts; bocce ball courts; children's play area; adult fitness zone; community garden; picnic tables 3.0 11 French Park 1040 Fuller Road Multi‐use court; youth baseball/softball field; sand volleyball court; tennis court; horseshoe pits; individual picnic/barbecue area; large barbecue area; children's playground 10.0 12 Mitchell Park 1400 Osos Street Playground; individual picnic tables; horseshoe pit; barbeque area; bandstand 3.0 13 Islay Hill Park 1151 Tank Farm Road Youth baseball/softball field; basketball court; tennis court; sand volleyball court; picnic areas; children's play area; restrooms 5.0 14 Johnson Park 1020 Southwood Drive Children's playground; large barbecue area; basketball courts; restrooms 4.5 15 Laguna Hills Park 890 Mirada Drive Picnic tables; play area 3.5 16 Throop Park 510 Cerro Romauldo Picnic tables; play area; softball/baseball field; restrooms 3.0 17 Vista Lago Park 1170 Vista Lago Picnic tables; play area; benches 0.5 Neighborhoods Parks Acreage Subtotal 33.5 Mini-Parks 18 Buena Vista Park 100 Block of Buena Vista Circular grass area 0.4 19 Cheng Park 1038 Marsh Street Chinese commemoration theme, benches 0.1 20 Eto Park South and Brook Street Pond; bench area 0.3 21 Ellsford Park San Luis Drive near California Two creek-side grass areas 1.0 22 Stoneridge Park 535 Bluerock Drive Small, grass-covered neighborhood lot 0.5 23 Osos/Triangle Park Santa Barbara Street at Osos Street Picnic site 0.3 24 Las Praderas Park Las Praderas and Mariposa Drive Creek-side lot, benches 1.8 25 Priolo-Martin Park Vista del Collados and Vista del Arroyo Benches; Laguna Lake Pathway 0.5 Mini-Parks Acreage Subtotal 4.9 Joint-Use Facilities (Not included towards park standard) N/A C.L. Smith Elementary School 1375 Balboa Street Baseball/softball diamonds; soccer and athletic fields; children's play area; basketball courts 4.8 N/A Sinsheimer Elementary School 2755 Augusta Street Gymnasium; youth baseball/softball field; large turf area N/A N/A Hawthorne Elementary School 2125 Story Street Gymnasium; youth baseball/softball field; large turf area N/A San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-4 Table 4.11-1 Existing City of San Luis Obispo Parks and Recreation Facilities ID Number Park Name Address Facilities Acres N/A Bishop Peak/Teach Elementary School 451 Jaycee Drive Gymnasium; large turf area N/A N/A Pacheco Elementary School 261 Cuesta Drive Gymnasium; large turf area N/A Park Acreage Total 151.7 Source: City of San Luis Obispo, General Plan Background Report, 2014 Table 4.11-2 Existing City of San Luis Obispo Special Facilities Facility Name Address/Location Amenities Laguna Lake Golf Course 11175 Los Osos Valley Road 9‐hole, 27-acre executive length golf course with additional features including small practice putting green and driving range, barbecue pit and picnic area and restrooms SLO Swim Center 900 Laurel Lane Square feet totaling 43,720 that includes a 50 x 25 meter pool, separate tot pool, restrooms, locker rooms, and a multi‐ purpose room Ludwick Community Center 664 Santa Rosa Street meeting rooms, gymnasium, preschool facility, shower facilities, and restrooms Senior Center 1445 Santa Rosa Street Multi‐use room, meeting room, small specialty meeting rooms, restrooms, and a kitchen Meadow Park Center 2333 Meadow Street Multi‐use facility and restrooms Laurel Lane Community Gardens Laurel Lane next to Fire Station 16 individual garden plots for annual rental Broad Street Community Gardens North Broad Street near U.S. 101 southbound exit 17 individual agriculture plots Meadow Park Community Gardens 2333 Meadow Street 40 agriculture plots Emerson Park Community Gardens 1316 Beach Street 39 agriculture plots SLO Skate Park Santa Rosa Park 15,500 square foot concrete skate park, amphitheater, low impact fitness path, public art, and streetscape plaza Ken Hampian Hockey Rink/Multi- Use Court Santa Rosa Park Hockey rink/multi-use court Source: City of San Luis Obispo, General Plan Background Report, 2014 b. Planned Parks and Recreation Facilities. Currently, there are a series of parks that are affiliated with new residential development proposed for the City. At this time, none of these parks are in the building permit issuance process. The current City Capital Improvement Projects that are park improvement related include the replacement of playground equipment at Sinsheimer Park during 2016 and, if approved with the 2017-19 Financial Plan, the San Luis Ranch Project EIR Section 4.11 Recreation Source: City of San Luis Obispo July 2012 City of San Luis Obispo Parks and Recreation Facilities Figure 4.11-1 City of San Luis Obispo /0 .5 1 Mile!!!! !!!!!!!!!!!!!!!!!!!!!! ! !!!!!!!! ! !! ! ! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! ! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!o £¤Ed £¤101 £¤1 South St Edna RdBroad S t £¤101 O r c u t t R d L o s O s o s V a lle y R d J o h n s o n Ave B r o a d S t California Blvd¬¬3 ¬¬8 ¬¬1 ¬¬4 ¬¬14 ¬¬6 ¬¬12 ¬¬7¬¬17 ¬¬15 ¬¬18 ¬¬11 ¬¬13 ¬¬25 ¬¬23 ¬¬10 ¬¬24 ¬¬20 ¬¬26 ¬¬21 ¬¬9 ¬¬16 ¬¬5 ¬¬2 ¬¬22 010.5 Miles Park ID Corresponds with Table 5.6-1X Legend Parks !!!City Limits Land Use and Circulation Planning Subarea Project Site Boundary 4.11-1 7 8 9 10 11 12 13 1415 16 1717 18 19 21 23 22 20 24 25 4.11-5 San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-6 construction of lights at Sinsheimer Park Tennis Courts. Having consistently been brought to the City Council’s attention, the City has determined that there is an unmet need for both tennis court and pickleball courts in the City as well as a desire by existing neighborhoods that are underserved by parks to renovate existing parks or to find locations for new parks within existing neighborhoods. c. Regulatory Setting. Quimby Act (1975). The Quimby Act gives cities and counties the authority, by ordinance, to require the dedication of land or payment of in‐lieu fees, or a combination of both, for park and recreation purposes as a condition of approval of a tract map or parcel map. The Quimby Act allows fees to be collected for up to five acres of parkland per 1,000 residents. San Luis Obispo Parks and Recreation Element and Master Plan (2001). The City’s General Plan Parks and Recreation Element and Master Plan describe existing parks and recreation facilities, activities, and financing within the City. The Master Plan identifies unmet needs, details a park vision for the future, and outlines an implementation strategy for the development of new parks and recreation facilities and programs. The following Parks and Recreation Element policies establish parkland provision standards in the City: Policy 3.13.1. The Parks System. The City shall develop and maintain a park system at a rate of 10 acres of parkland per 1,000 residents. Five acres shall be dedicated as a neighborhood park. The remaining five acres required under the 10 acres per 1,000 residents in the residential annexation policy may be located anywhere within the City’s park system as deemed appropriate. Policy 3.13.2. Parks shall be designed to meet a variety of needs depending on park size, location, natural features and user demands. Policy 3.13.8. Park site acquisition should enhance the City's recreational trails, pedestrian transportation, and open spaces in keeping with adopted policies. Policy 3.15.1. Neighborhood Parks. San Luis Obispo residents shall have access to a neighborhood park within 0.5 to 1.0 mile walking distance of their residence. Policy 3.15.3. Neighborhood Parks. All residential annexation areas shall provide developed neighborhood parks at the rate of five acres per 1,000 residents. Policy 3.15.4. Neighborhood Parks. In neighborhoods where existing parks do not adequately serve residents, mini-parks may be considered. City of San Luis Obispo Land Use Element (2014). Section 8.1.4 of the City’s General Plan Land Use Element provides direction for future development under the San Luis Ranch Specific Plan as follows: “This project site should be developed as a mixed use project that maintains the agricultural heritage of the site, provides a commercial / office transition to the existing commercial center to the north, and provides a diverse housing experience. Protection of the adjacent creek and a well- planned integration into the existing circulation system will be required.” San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-7 Although parks and recreational facilities are not explicitly mentioned in the policy framework for the site, the Land Use Element establishes a performance standard to include at least 5.8 acres of parkland within the San Luis Ranch Specific Plan Area. 4.11.2 Previous Program-Level Environmental Review The 2014 LUCE Update EIR previously analyzed overall Citywide impacts to parks and recreation facilities, including those associated with development of the San Luis Ranch Specific Plan Area, related to the adoption of the 2014 Land Use and Circulation Elements, including planned future land use development and proposed goals, policies, and programs. The LUCE Update EIR parks and recreation analysis determined that although the City’s existing per capita parkland standard is not currently achieved, General Plan buildout would provide additional areas of parkland within the City and a slightly improved parkland per capita ratio when compared to existing conditions. General Plan buildout, including development of the San Luis Ranch Specific Plan Area, would result in an improvement in the per capita parkland ratio compared to existing conditions. Furthermore, the LUCE Update EIR determined that most of the future parkland to be provided in the City would be constructed as part of the buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans, which would facilitate park planning and design opportunities to minimize environmental impacts and land use conflicts. At the time of the LUCE Update EIR, the location, and uses of parkland area to be provided in the San Luis Ranch Specific Plan Area and other proposed specific plan areas had yet to be determined. However, based on the assumed buildout of these areas and the park planning and design opportunities to be included therein, the LUCE Update EIR concluded that impacts related to parks and recreation facilities would be less than significant. 4.11.3 Impact Analysis a. Methodology and Significance Thresholds. The following criteria are based on the City’s Initial Study, and Appendix G of the State CEQA Guidelines. The effects of the project on recreation would be significant if the project would: 1. Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; 2. Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. b. Impacts and Mitigation Measures. Threshold 1 Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Threshold 2 Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Impact REC-1 The project would accommodate new residents in the City of San Luis Obispo who will use existing and planned parks and San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-8 recreation facilities. Provision of on-site parks and recreation facilities would not meet the adopted City parkland standard for the San Luis Ranch Specific Plan Area. Therefore, impacts to parks and recreational facilities would be Class II, potentially significant but mitigable. The project includes development of 3.4 acres of parkland within the San Luis Ranch Specific Plan Area. As shown in the project site plan (refer to Figure 2-6 in Section 2.0, Project Description), the parkland proposed for the project site would be within 0.5 to 1.0 mile of the proposed residential development. Therefore, the project would be consistent with Policy 3.15.1 of the Parks and Recreation Element. However, the proposed 3.4 acres of parkland would not meet the performance standard included in Policy 8.1.4 of the City’s General Plan LUE which requires 5.8 acres of parkland to be provided within the San Luis Ranch Specific Plan Area. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes requirements intended to protect open space and recreation areas. Specific Plan Policies 1.5, 4.1, 4.4, and 5.4 require the promotion and integration of parks and recreational space throughout the plan area and development components. Although the project includes development of 3.4 acres of parkland it would result in a 2.4-acre shortfall in parkland standard for the San Luis Ranch Specific Plan Area. Therefore, the project would result in potentially significant impact to parks and recreational facilities. Mitigation Measures. The following mitigation measure would be required to reduce impacts to parks and recreational facilities: REC-1 Parkland In-lieu Fees. The project applicant shall pay parkland in-lieu fees in accordance with the City’s parkland in-lieu fee program for the parkland shortage. The project’s specific fee shall be determined by the City at the time of project approval, after accounting for parkland provided within the San Luis Ranch Specific Plan Area. The in-lieu fees collected from the project shall be directed to new projects or improvements to existing parks and recreation facilities within the City of San Luis Obispo parks system. Residual Impacts. The City’s parkland in-lieu fee program assesses fees based on each new lot in a subdivision in order for the City to meet the goals included in the Parks and Recreation Element of the General Plan. The environmental effects associated with implementation of planned parkland that would be facilitated by this fee payment were addressed in the LUCE Update EIR. With payment of the City’s required parkland in-lieu fees to ensure compliance with the policies and performance standards in the City’s General Plan as part of the project, impacts associated with parks and recreational facilities would be less than significant. c. Cumulative Impacts. Buildout under the General Plan, which includes development of the project site, would potentially provide 52.4 acres of new park and recreation facilities in the City. As discussed in Section 4.11.2, the majority of the future parkland planned to be provided in the City would be constructed as part of the buildout of previously approved (Margarita and Orcutt) or proposed (San Luis Ranch, Avila Ranch, Madonna) specific plans, San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-9 which would facilitate park planning and design opportunities to minimize environmental impacts and land use conflicts. The City of San Luis Obispo has a population of 45,802 (DOF, 2015). Based on the City’s adopted parkland standard, approximately 458 acres of total parkland, including 229 acres of neighborhood parkland, should be provided in the City. There is currently approximately 152 acres of parkland in the City, of which approximately 34 acres are neighborhood parks. This results in approximately 3.3 acres of total parkland per 1,000 residents and 0.7 acre of neighborhood parks per 1,000 residents. Based on existing population and parks acreage conditions, the City needs an additional 306 acres of park land, of which 195 acres should be neighborhood parks, to meet its per capita parkland standard. Development of the project would add an estimated 1,293 residents to the City (546 new single family and multi-family dwelling units x 2.29 people/unit [Department of Finance 2015] and 34 new affordable units x 1.25 people/unit).1 Based on the City’s parkland standard of 10 acres of parkland per 1,000 residents, five acres of which must be neighborhood park (Policy 3.13.1 of the Parks and Recreation Element), the project would result in the additional need for approximately 12.9 acres of parkland, including 6.5 acres of neighborhood parkland. The project would add 3.4 acres of parkland in the City. As such, the project would not meet the Citywide parkland standards and would exacerbate the exiting shortfall of parks and recreational facilities within the City. As a result, cumulative adverse physical effects on the environment from recreational development would be potentially significant, and the project’s contribution to this impact would be cumulatively considerable. With payment of the City’s required parkland in-lieu fees to ensure compliance with the policies and performance standards in the City’s General Plan as part of the project, required by Mitigation Measure REC-1, the project contribution to cumulative impacts associated with parks and recreational facilities would be reduced to a less than significant level. 1 Population growth rate from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). San Luis Ranch Project EIR Section 4.11 Recreation City of San Luis Obispo 4.11-10 This page intentionally left blank. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-1 4.12 TRANSPORTATION 4.12.1 Executive Summary This section is based on the Multimodal Transportation Impact Study (TIS; 2016) prepared by Omni-Means, Ltd. to evaluate projected transportation impact conditions associated with development of the San Luis Ranch Project. The TIS is included as Appendix KL to this EIR. Table 4.12-1 provides a summary of the mitigation measures described throughout this section, and the transportation and circulation impacts addressed by each mitigation measure. Setting a. Roadway Network. Regional access to the project site is provided via interchanges on U.S. Highway 101 (U.S. 101) at Madonna Road and at Los Osos Valley Road. Local access is provided via Madonna and Los Osos Valley Roads, which intersect west of the project site. Direct access to the site is provided via Dalidio Drive. Figure 4.12-1 shows the roadways in the vicinity of the project site. Roadways which provide access to the project site and vicinity are described below. Due to the varying orientation of the City street network the directionality defined in this study may or may not be consistent with other studies or documents. U.S. Highway 101. U.S. 101 is functionally classified as an Urban Principal Arterial and is part of the National Truck Network. U.S. 101 is a north-south, four lane mixed flow freeway through the City of San Luis Obispo. Outside of the City, U.S. 101 provides access to the City of Paso Robles to the north and the Five Cities area to the south. It is a primary route for all truck traffic leaving from and coming to the City. Froom Ranch Way. Froom Ranch Way is an east-west roadway that connects Los Osos Valley Road to the Prefumo Creek Shopping Center on the east side and the Irish Hills Plaza on the west side. Froom Ranch Way is four lanes west of Los Osos Valley Road and two lanes east of Los Osos Valley Road with sidewalks on both sides and Class II bicycle lanes on the east side. Planned changes to Froom Ranch Way as part of the project include extension as a two- lane collector street east to Dalidio Drive. South Higuera Street. South Higuera Street is a north-south arterial within the vicinity of the project site. Higuera Street connects to downtown San Luis Obispo to the north and terminates to the south at its interchange with U.S. 101. South of Marsh Street, it provides a four-lane roadway with Class II bike lanes and continuous sidewalks. Los Osos Valley Road. Los Osos Valley Road is a north-south arterial that extends from the community of Los Osos to Higuera Street. This roadway connects with U.S. 101 ramp termini approximately 0.5 mile west of South Higuera Street and is functionally classified in the City as an Arterial or a Parkway Arterial. Los Osos Valley Road provides four lanes with Class II bike lanes and sidewalks on both sides for the majority of the study area. Since 2014, improvements associated with the Los Osos Valley Road/U.S. 101 interchange Traffic Relief Project have been constructed. Completed improvements include widening Los Osos Valley Road to four lanes from west of Calle Joaquin Road to approximately 500 feet west of South Higuera Street as well as constructing sidewalks and Class II bike lanes along both sides of Los Osos Valley Road. San Luis Ranch Project EIR Section 4.12 Transportation Source: Omni-Means, Ltd., 2016 Roadways in the Vicinity of the Project Site Figure 4.12-1 City of San Luis Obispo / 4.12-2 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-3 Table 4.12-1 Mitigation Summary Table Required Transportation Improvement Measures Required Timing Impacts Mitigated/EIR Mitigation Measures 1. Construct Prado Road Overpass & Northbound U.S. 101 Ramps Phase 2 T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(c) Intersection #5: Madonna Road & U.S. 101 Southbound Ramps T-1(f) Intersection #10: Los Osos Valley Road & Auto Park Way T-1(g) Intersection #16: S. Higuera Street & Tank Farm Road T-2: Existing & Near-Term Intersection Lane Capacity Impacts T-2(a) Intersection #1: Madonna Road & Los Osos Valley Road T-2(b) Intersection #2: Madonna Road & Oceanaire Drive T-2(d) Intersection #6: Madonna Road & U.S. 101 Northbound Ramps T-2(e) Intersection #7: Madonna Road & Higuera Street T-2(h) Intersection #13: Los Osos Valley Road & U.S. 101 Northbound Ramps T-3: Existing & Near-Term Multimodal Segment Level of Service Impacts T-3(a) Segments #1 - #6: Madonna Road (Los Osos Valley Road to Higuera Street) T-3(b) Segments #7 - #8: Higuera Street (Madonna Road to Prado Road) T-3(c) Segments #13 - #17: Los Osos Valley Road (Madonna Road to Higuera Street) 2. Widen Madonna Road & Dalidio Drive/Prado Road Intersection 1. Extend existing westbound left turn lane on Madonna Road to Dalidio Drive/Prado Road to 310’ 2. Install 2nd westbound 310’ left turn lane on Madonna Road to Dalidio Drive/Prado Road 3. Install eastbound 250’ right turn pocket on Madonna Road to Dalidio Drive/Prado Road 4. Install 2nd northbound left shared with through-lane on Prado Road/Dalidio Drive to Madonna Road 5. Prohibit westbound U-turns on Madonna Road 6. Provide split phase operations & optimize signal timing Phase 1 T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(b) Intersection #3: Madonna Road & Dalidio Drive/Prado Road T-8: Cumulative Multimodal Intersection Level of Service Impacts T-8(a) Intersection #3: Madonna Road & Dalidio Drive/Prado Road T-9: Cumulative Intersection Lane Capacity Impacts T-9(b) Intersection #2: Madonna Road & Oceanaire Drive T-9(c) Intersection #3: Madonna Road & Dalidio Drive/Prado Road T-9(d) Intersection #4: Madonna Road & El Mercado San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-4 Table 4.12-1 Mitigation Summary Table Required Transportation Improvement Measures Required Timing Impacts Mitigated/EIR Mitigation Measures 3. Widen Los Osos Valley Road & Froom Ranch Way Intersection 1. Install dedicated 230’ right turn lane on Los Osos Valley Road northbound Froom Ranch Way approach to northbound Froom Ranch Way Los Osos Valley Road 2. Extend right turn lane on Los Osos Valley Road southbound Froom Ranch Way approach to southbound Froom Ranch Way Los Osos Valley Road to 110’ 3. Install 2nd southbound left turn lane on Froom Ranch Way approach to eastbound Los Osos Valley Road With Froom Bridge Construction T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(e) Intersection #9: Los Osos Valley Road & Froom Ranch Way T-2: Intersection Lane Capacity Impacts T-2(f) Intersection #9: Los Osos Valley Road & Froom Ranch Way T-8: Cumulative Multimodal Intersection Level of Service Impacts T-8(b) Intersection #9: Los Osos Valley Road & Froom Ranch Way T-9: Cumulative Intersection Lane Capacity Impacts T-9(h) Intersection #9: Los Osos Valley Road & Froom Ranch Way 4. Signalize Los Osos Valley Road & Auto Park Way Intersection Phase 1 T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(f) Intersection #10: Los Osos Valley Road & Auto Park Way T-8: Cumulative Multimodal Intersection Level of Service Impacts T-8(c) Intersection #10: Los Osos Valley Road & Auto Park Way 5. Los Osos Valley Road & U.S. 101 Southbound Off Ramp 1. Extend off ramp left turn lane to 320 Phase 1 T-2: Existing & Near-Term Intersection Lane Capacity Impacts T-2(g) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps 6. Madonna & U.S. 101 Southbound Off Ramp 1. Extend northbound Madonna Road left turn lane to 150’ Phase 1 T-2: Existing & Near-Term Intersection Lane Capacity Impacts T-2(c) Intersection #5:Madonna Road & U.S. 101 Southbound Ramps 7. Higuera Street & Tank Farm Road 1. Extend northbound right turn pocket to 230’ and channelize movement Phase 1 T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(g) Intersection #16: S. Higuera Street & Tank Farm Road T-8: Cumulative Multimodal Intersection Level of Service Impacts T-8(g) Intersection #16: S. Higuera Street & Tank Farm San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-5 Table 4.12-1 Mitigation Summary Table Required Transportation Improvement Measures Required Timing Impacts Mitigated/EIR Mitigation Measures Road T-9: Cumulative Intersection Lane Capacity Impacts T-9(l) Intersection #16: S. Higuera Street & Tank Farm Road 8. Widen Prado Road & Higuera Street Intersection 1. Install 2nd U.S. 101 northbound left turn lane 2. Extend westbound right turn pocket to 400’ Phase 1 T-2: Intersection Lane Capacity Impacts T-2 (j) Intersection #18: Prado Road & Higuera Street T-9: Cumulative Intersection Lane Capacity Impacts T-9(m) Intersection #18: Prado Road & Higuera Street 9. Los Osos Valley Road & Higuera Street 1. Extend eastbound right turn lane to 180’ Phase 1 T-2: Intersection Lane Capacity Impacts T-2(i) Intersection #14: Los Osos Valley Road & Higuera Street 10. Install Multilane Roundabout at Prado/Dalidio & Froom Intersection With Prado/Dalidio Construction T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(h) Intersection #21:Prado Road/Dalidio Drive & Froom Ranch Way 11. Install Multilane Roundabout Control or Restricted Access at Prado Road/Dalidio Drive & Project Driveways With Prado/Dalidio Construction T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(i) Intersection #25: Prado Road/Dalidio Drive & SC Project Driveway 12. Construct Parallel Class I Multiuse Paths or Bike Boulevard 1. Madonna Road (Los Osos Valley Road to Higuera Street) 2. Higuera Street (Madonna Road to Prado Road) 3. Los Osos Valley Road (Madonna Road to Higuera Street) 4. Prado Road/Dalidio Drive (Froom Ranch Way to Higuera Street) Phase 1 -Madonna -Higuera Phase 3 -LOVR With Prado -Prado T-3: Existing & Near-Term Multimodal Segment Level of Service Impacts T-3(a) Segments #1 - #6: Madonna Road (Los Osos Valley Road to Higuera Street) T-3(b) Segments #7 - #8: Higuera Street (Madonna Road to Prado Road) T-3(c) Segments #13 - #17: Los Osos Valley Road (Madonna Road to Higuera Street) T-3(d) Segments #18 - #20: Prado/Dalidio (Froom Ranch Way to Higuera Street) San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-6 Table 4.12-1 Mitigation Summary Table Required Transportation Improvement Measures Required Timing Impacts Mitigated/EIR Mitigation Measures 13. City Transit Headway Optimization 1. Fund assessment of decreasing traffic headways to 25 min T-3(a) Ongoing By City T-3: Existing & Near-Term Multimodal Segment Level of Service Impacts T-3(a) Segments #1 - #6: Madonna Road (Los Osos Valley Road to Higuera Street) 14. City Signal Timing Optimization Ongoing By City T-1: Existing & Near-Term Multimodal Intersection Level of Service Impacts T-1(a) Intersection #1: Madonna Road & Los Osos Valley Road T-1(d) Intersection #8: Higuera Street & South Street. 15. Traffic Calming and/or Reconfiguration of New Neighborhood Streets Final Design Plans prior to issuance of grading permits T-6: Safety & Access Management Impacts T-7: Circulation Element Policy Inconsistency 16. Revise Phase of Froom Ranch Way Bridge Construction Phase 1 T-5: Froom Ranch Bridge Phasing Impact 17. Construction Traffic Management Plan Final Design Plans prior to issuance of grading permits T-4: Construction Traffic Impacts 18. Pay Fair Share of Madonna & Los Osos Valley Road 1. Extend northbound right turn pocket on Los Osos Valley Road to 295’ 2. Extend southbound left turn pocket on Madonna Road to 395’ Post Project T-9: Cumulative Intersection Lane Capacity Impacts T-9(a) Intersection #1: Madonna Road & Los Osos Valley Road 19. Pay Fair Share of Madonna Road & Oceanaire Drive 1. Extend westbound right turn land on Madonna Road to 200’ Post Project T-9: Cumulative Intersection Lane Capacity Impacts T-9(b) Intersection #2: Madonna Road & Oceanaire Drive 20. Pay Fair Share of Higuera Street & South Street 1. Extend northbound Higuera Street left turn pocket to 120’ 2. Extend eastbound South Street right turn pocket to 100’ Post Project T-9: Cumulative Intersection Lane Capacity Impacts T-9(g) Intersection #8: Higuera Street & South Street 21. Pay Fair Share of Constructing Prado Road Overpass & U.S. 101 Southbound Ramps Post Project T-8: Cumulative Multimodal Intersection Level of Service Impacts T-8(d) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps T-8(e) Intersection #13: Los Osos Valley Road & U.S. 101 Northbound Ramps T-8(f) Intersection #14: Los Osos Valley Road & S. Higuera Street T-8(g) Intersection #16: S. Higuera Street & Tank Farm Road San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-7 Table 4.12-1 Mitigation Summary Table Required Transportation Improvement Measures Required Timing Impacts Mitigated/EIR Mitigation Measures T-9: Cumulative Intersection Lane Capacity Impacts T-9(e) Intersection #5: Madonna Road & 101 Southbound Ramps T-9(f) Intersection #6: Madonna Road & U.S. 101 Northbound Ramps T-9(i) Intersection #11: Los Osos Valley Road & Calle Joaquin T-9(j) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps T-9(k) Intersection #14: Los Osos Valley Road & S. Higuera Street T-10: Cumulative Multimodal Segment Level of Service Impacts T-10(a) Segments #1 - #6: Madonna Road (Los Osos Valley Road to Higuera Street) T-10(b) Segments #15 - #16: Los Osos Valley Road (Calle Joaquin to U.S. 101 Northbound Ramps) T-10(c) Segment #24: Prado Road/Dalidio Drive (Project Driveway to Froom Ranch Way) Note: The project’s fair share proportionality for each of the identified impacts is shown in Table 4.12-19. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-8 Madonna Road. Madonna Road is an east-west roadway that extends from Devaul Ranch Road west of Los Osos Valley Road to Higuera Street. Madonna Road is functionally classified as a Local roadway west of Los Osos Valley Road and an Arterial east of Los Osos Valley Road. Throughout its span Madonna Road provides two, four or six travel lanes, and Class II bike lanes with sidewalks on one or both sides. This roadway also connects with U.S. 101 ramp termini approximately 0.5 mile west of Higuera Street. Prado Road. Prado Road is an east-west two-lane corridor that extends eastward from the U.S. 101 northbound ramps to South Higuera Street. Prado Road is functionally classified as a Highway/Regional Route. Planned changes to Prado Road include extension west from U.S. 101 to Madonna Road and east to Broad Street. Prado Road is a two-lane roadway with sidewalks on both sides and on-street parking at various locations. Tank Farm Road. Tank Farm Road is an east-west Parkway Arterial which connects South Higuera Street to Broad Street to the east, and continues as Orcutt Road east of the Orcutt Area. In the vicinity of the project site, Tank Farm Road is a four-lane roadway with Class II bike lanes and sidewalks on both sides. b. Existing Multimodal Transportation Operations at Intersections. Existing conditions establish baseline traffic conditions that currently exist in the study area. The study area is bound by Higuera Street Los Osos Valley Road, and Madonna Road. Twenty-eight study intersections and twenty-six roadway segments within the project vicinity were evaluated in the TIS for potential project specific and cumulative impacts associated with increased traffic generated by the project (see Figure 4.12-2). In order to determine existing operational characteristics and levels of congestion, traffic counts were collected at each of these intersections during February and March of 2014 (see Appendix KL). The operation of intersections and segments is measured based on methodologies established in the Transportation Research Board’s 2010 Highway Capacity Manual (2010 HCM; Fifth Edition) Multimodal Level of Service (MMLOS) criteria. MMLOS is a qualitative measure of traffic operating conditions ranging from Level of Service (LOS) A to LOS F, LOS A being the highest functioning and LOS F being the lowest functioning. Detailed traffic flow analyses focus on operating conditions of critical intersections and segments during peak travel periods, which are typically the AM and PM peak hours. The AM peak hour is defined as the highest one hour of traffic flow counted between 7:00 AM and 9:00 AM on a typical weekday, the p.m. peak hour is defined as the highest one hour of traffic flow counted between 4:00 PM and 6:00 PM on a typical weekday. Figure 4.12-3 shows the existing peak hour traffic volumes at the study intersections. Figure 4.12-4 shows the average daily traffic (ADT) volumes along the roadway segments within the project vicinity. In addition to MMLOS analysis, this analysis also addresses queue capacity as a measure of intersection performance. For intersections where the overall average intersection LOS is within acceptable thresholds, the capacities of turn pockets may still be exceeded, causing turning traffic to spill into through-lanes, which can occlude flow and increase the potential for left turn collisions. Queue capacity is analyzed by comparing the projected queue lengths to the available capacity of intersections to accommodate the projected queues. The City’s General Plan Circulation Element identifies LOS objectives and minimum standards for the various travel modes, as well as modal priorities for those levels of service. The Caltrans policy on LOS for State highways establishes LOS D as the standard for acceptable service. Source: Omni-Means, Ltd., 2016Study Area IntersectionsFigure 4.12-2City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-9 Source: Omni-Means, Ltd., 2016Existing Intersection Peak HourTraffic VolumesFigure 4.12-3City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-10 San Luis Ranch Project EIR Section 4.12 Transportation Source: Omni-Means, Ltd., 2016 Existing Segment Average Daily Traffic Volumes Figure 4.12-4 City of San Luis Obispo / 4.12-11 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-12 These objectives, standards, and modal priorities are depicted in Table 4.12-2 through Table 4.12-7. Table 4.12-2 City of San Luis Obispo Level of Service Standards and Modal Priorities Travel Mode Objective LOS Minimum LOS Standard Bicycle B D Pedestrian B C Transit C Baseline LOS or LOS D, whichever is lower Vehicle C E (Downtown), D (All Other Routes) Parameter Assumption 1. Peak Hour Factor 1. Peak Hour Factor - from counts for Existing conditions and Existing Plus Project conditions 2. Heavy Vehicle Percentage 2. Heavy Vehicle Percentage - 2 % 3. Cycle Length - Pretimed settings not changed from "Master Network" 3. Cycle Length - Pretimed settings not changed from "Master Network" 4. Total lost time per signal phase - 4 seconds (24 seconds max for 8-phase signal) 4. Total lost time per signal phase - 4 seconds (24 seconds max for 8-phase signal) 5. Grades - 2 percent or less for all intersections 5. Grades - 2 percent or less for all intersections Table 4.12-3 through Table 4.12-7 below presents the MMLOS criteria used for intersections & segments as set forth in the 2010 HCM. Table 4.12-3 Modal Priority Ranking Complete Street Areas Priority Mode Ranking Downtown & Upper Monterey Street 1. Pedestrians 2. Bicycles 3. Transit 4. Vehicles Residential Corridors & Neighborhoods 1. Pedestrians 2. Bicycles 3. Vehicles 4. Transit Commercial Corridors & Areas 1. Vehicles 2. Bicycles 3. Transit 4. Pedestrians Regional Arterial and Highway Corridors 1. Vehicles 2. Transit 3. Bicycles 4. Pedestrians San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-13 Table 4.12-4 HCM 2010 Segment Automobile LOS Travel Speed as a Percentage of Base Free Flow Speed (%) LOS by Volume-to-Capacity Ratioa ≤ ≤ >85 A F >67-85 B F >50-67 C F >40-50 D F >30-40 F F ≤30 E F a. Volume-to-Capacity Ratio of through movement at downstream boundary intersection. Table 4.12-5 HCM 2010 Pedestrian LOS Level Of Service (LOS) Criteria for Pedestrians on Segments Ped LOS Score LOS by Average Pedestrian Space (ft2/p) >60 >40-60 >24-40 >15-24 >8.0-15a <8.0a ≤2.00 A B C D E F >2.00-2.75 B B C D E F >2.75-3.5 C C C D E F >3.5-4.25 D D D D E F >4.25-5.00 E E E E E F >5.00 F F F F F F Notes: 1. Based on Highway Capacity Manual, Fifth Edition, Transportation Research Board, 2010. 2. All volume thresholds are approximate and assume ideal roadway characteristics. Actual thresholds for each LOS listed above may vary depending on a variety of factors including (but not limited to) roadway curvature and grade, intersection or interchange a In Cross-Flow situations, the LOS E/F threshold is 13 ft2/p Table 4.12-6 HCM 2010 Bicycle & Transit LOS LOS Criteria for Bicycle and Transit Modes LOS LOS SCORE A ≤2.00 B >2.00-2.75 C >2.75-3.5 D >3.50-4.25 E >4.25-5.00 F >5.00 Notes: 1. Based on Highway Capacity Manual, Fifth Edition, Transportation Research Board, 2010. 2. Also used for Ped and Bike LOS for intersections analysis San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-14 Table 4.12-7 HCM 2010 Freeway Segments LOS Density (pc/mi/ln) Segment Type A B C D E Freeway 11 18 26 35 45 Merge 10 20 28 35 45 Diverge 10 20 28 35 45 Weave 10 20 28 35 45 Note: 1. Based on Highway Capacity Manual, Fifth Edition, Transportation Research Board, 2010. MMLOS was calculated for the area intersections based on the 2010 HCM methodology. Table 4.12-8 through Table 4.12-11 provide a summary of the multimodal AM and PM peak hour intersection LOS and queueing under existing conditions. Intersections where the AM or PM LOS exceed the minimum LOS standard or where vehicle queues would exceed lane capacity during peak hours are bolded. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-15 Table 4.12-8 Existing Conditions Intersection Level of Service: Automobile Analysis AM Peak Hour PM Peak Hour # Intersection Control Type1,2 Target LOS v/c3 Delay LOS v/c3 Delay LOS 1 Madonna Road/Los Osos Valley Road Signal D 26.1 C 45.0 D 2 Madonna Road/Oceanaire Drive Signal D 19.6 B 14.2 B 3 Madonna Road/Dalidio Drive Signal D 9.7 A 2.11 56.2 E 4 Madonna Road/El Mercado Signal D 7.3 A 19.6 B 5 Madonna Road/US 101 SB Ramps/Madonna Inn Signal C 1.31 48.7 D 23.4 C 6 Madonna Road/US 101 NB Ramps Signal C 17.4 B 21.1 C 7 Madonna Road/Higuera Street Signal D 18.6 B 21.7 C 8 Higuera Street/South Street Signal D 21.4 C 1.31 63.1 E 9 Los Osos Valley Road/Froom Ranch Way Signal D 19.4 B 34.6 C 10 Los Osos Valley Road/Auto Park Way TWSC D 15.0 B 34.1 D 11 Los Osos Valley Road/Calle Joaquin Signal D 4.6 A 5.6 A 12 Los Osos Valley Road/US 101 SB Ramps Signal C 13.0 B 19.0 B 13 Los Osos Valley Road/US 101 NB Ramps Signal C 27.6 C 21.8 C 14 S. Higuera Street/Los Osos Valley Road Signal D 16.0 B 19.1 B 15 S. Higuera Street/Suburban Drive Signal D 6.3 A 11.1 B 16 S. Higuera Street/Tank Farm Road Signal D 36.2 D 21.0 C 17 S. Higuera Street/Granada Drive Signal D 8.4 A 10.5 B 18 S. Higuera Street/Prado Road Signal D 16.7 B 20.9 C 19 S. Higuera Street/Margarita Avenue Signal D 7.4 A 10.8 B 20 Prado Road/US 101 NB Ramps AWSC C 9.0 A 13.5 B Notes: 1. AWSC = All Way Stop Control; TWSC = Two Way Stop Control; RNDBT = Roundabout 2. LOS = Delay based on worst minor street approach for TWSC intersections, average of all approaches for AWSC, Signal, RNDBT 3. Volume to Capacity Ratio (v/c) is for worst movement delay, for unacceptable LOS only 4. Warrant is based on California MUTCD Warrant 3 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-16 Table 4.12-9 Existing Conditions 95th Percentile Queuing Analysis ID Location Movement No. Lanes Total Storage (ft)1 AM Peak Hour PM Peak Hour 1 Madonna Road/ Los Osos Valley Road Northbound Right 1 175 96 240 7 Madonna Road/ Higuera Street Eastbound Right 1 150 232 146 Northbound Left 1 160 107 251 8 Higuera Street/ South Street Westbound Left 2 240 219 310 Northbound Left 1 60 87 74 Northbound Right 1 60 142 136 Southbound Left 1 70 109 97 9 Los Osos Valley Road/ Froom Ranch Way Westbound Right 1 50 41 82 11 Los Osos Valley Road/Calle Joaquin Southbound Left 1 180 108 170 12 Los Osos Valley Road/ US 101 SB Ramps Westbound Left 1 150 241 224 Northbound Left 1 80 114 122 Southbound Through 1 240 297 289 13 Los Osos Valley Road/ US 101 NB Ramps Eastbound Left/Right 1 200 221 177 Northbound Left 1 140 117 181 Southbound Through 1 865 1042 822 Southbound Right 1 60 186 219 14 S. Higuera Street/ Los Osos Valley Road Eastbound Right 1 90 164 122 16 S. Higuera Street/ Tank Farm Road Northbound Right 1 100 137 134 Southbound Left 1 165 187 218 18 S. Higuera Street/ Prado Road Northbound Left 1 100 131 176 Southbound Left 1 60 116 109 19 S. Higuera Street/ Margarita Avenue Southbound Left 1 60 58 67 Notes: 1. Bolded entries indicate queues exceed available storage 2. Storage Length of " - " represents a lane which exceeds 1,000 feet, usually a through lane. 3. For Movements with more than one lane, the maximum of the 95th percentile queue is reported. 4. * Represents storage lengths for one lane; second lane is a left or right trap lane. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-17 Table 4.12-10 Existing Conditions Intersection Level of Service: Pedestrian Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswal k Score LOS Ped. Crosswal k Score LOS 1 Madonna Road/Los Osos Valley Road EB C 2.10 B 2.11 B WB C 2.90 C 3.16 C NB C 2.94 C 3.41 C SB C 3.28 C 3.18 C 2 Madonna Road/Oceanaire Drive EB C 2.69 B 2.87 C WB C 3.05 C 3.28 C NB C 1.99 A 2.07 B SB C 1.86 A 1.85 A 3 Madonna Road/Dalidio Drive EB C 2.96 C 3.24 C WB C 2.99 C 3.07 C NB C 2.06 B 2.25 B SB C 1.98 A 2.03 B 4 Madonna Road/El Mercado EB C n/a - n/a - WB C 3.07 C 3.16 C NB C 2.26 B 2.75 B SB C 1.74 A 1.74 A 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB C 3.00 C 3.16 C WB C n/a - n/a - NB C 2.75 B 2.67 B SB C 2.17 B 2.18 B 6 Madonna Road/US 101 NB Ramps EB C n/a - n/a - WB C 2.84 C 2.80 C NB C 1.99 A 2.04 B SB C n/a - n/a - 7 Madonna Road/Higuera Street EB C 3.01 C 2.91 C WB C 1.98 A 2.00 A NB C 2.70 B 2.78 C SB C n/a - n/a - 8 Higuera Street/South Street EB C 2.01 B 2.01 B WB C 2.73 B 2.77 C NB C n/a - n/a - SB C 2.48 B 2.54 B 9 Los Osos Valley Road/Froom Ranch Way EB C 2.49 B 2.84 C WB C 2.38 B 2.59 B NB C n/a - n/a - SB C 3.06 C 3.26 C 10 Los Osos Valley Road/Auto Park Way EB C n/a - n/a - WB C - - NB C - - SB C - - 11 Los Osos Valley Road/Calle Joaquin EB C 2.48 B 2.27 B WB C 2.08 B 2.16 B NB C 2.98 C 3.19 C SB C 2.88 C 3.17 C San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-18 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswal k Score LOS Ped. Crosswal k Score LOS 12 Los Osos Valley Road/US 101 SB Ramps EB C 1.90 A 2.32 B WB C 2.23 B 2.12 B NB C n/a - n/a - SB C n/a - n/a - 13 Los Osos Valley Road/US 101 NB Ramps EB C 2.44 B 2.58 B NB C n/a - n/a - SB C n/a - n/a - 14 S. Higuera Street/Los Osos Valley Road EB C 2.65 B 2.73 B NB C 2.25 B 2.30 B SB C n/a - n/a - 15 S. Higuera Street/Suburban Drive WB C 2.15 B 2.29 B NB C 2.98 C 3.60 D SB C 2.73 B 2.85 C 16 S. Higuera Street/Tank Farm Road EB C 2.01 B 2.01 B WB C 2.91 C 3.04 C NB C 3.33 C 3.27 C SB C 2.65 B 2.78 C 17 S. Higuera Street/Granada Drive WB C 2.05 B 2.13 B NB C n/a - n/a - SB C 2.60 B 2.76 C 18 S. Higuera Street/Prado Road EB C 2.35 B 2.41 B WB C 2.28 B 2.31 B NB C 2.71 B 2.95 C SB C 2.76 C 2.78 C 19 S. Higuera Street/Margarita Avenue EB C 2.22 B 2.06 B WB C 2.12 B 2.17 B NB C 2.74 B 2.79 C SB C 2.70 B 2.77 C 20 Prado Road/US 101 NB Ramps EB C n/a - n/a - WB C - - NB C - - SB C - - Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicycle perspective. 2. HCM 2010 Methodologies for the pedestrian mode at two-way stop-controlled intersections is limited to the uncontrolled crossing. No methodology exists for evaluating pedestrian performance for the stop controlled approach (cross-street). However, it is reasoned that this type of control has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-19 Table 4.12-11 Existing Conditions Intersection Level of Service: Bicycle Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswal k Score LOS Ped. Crosswal k Score LOS 1 Madonna Road/Los Osos Valley Road EB D 3.26 C 3.14 C WB D 3.37 C 3.99 D NB D 1.64 A 2.01 B SB D 2.60 B 2.49 B 2 Madonna Road/Oceanaire Drive EB D 2.72 B 2.91 C WB D 1.05 A 1.59 A NB D 2.74 B 2.70 B SB D 2.22 B 2.13 B 3 Madonna Road/Dalidio Drive EB D 2.17 B 2.08 B WB D 1.47 A 1.71 A NB D 2.99 C 3.32 C SB D 2.84 C 2.92 C 4 Madonna Road/El Mercado EB D 1.80 A 1.67 A WB D 1.67 A 1.94 A NB D 3.19 C 3.93 D SB D 3.03 C 3.03 C 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB D 2.00 A 2.05 B WB D 1.61 A 1.79 A NB D n/a - n/a - SB D 2.90 C 2.96 C 6 Madonna Road/US 101 NB Ramps EB D 2.69 B 2.33 B WB D 1.58 A 1.82 A NB D n/a - n/a - 7 Madonna Road/Higuera Street EB D 3.27 C 2.75 B WB D 2.43 B 2.58 B NB D 1.69 A 2.05 B SB D 2.14 B 2.48 B 8 Higuera Street/South Street EB D 2.70 B 2.73 B WB D 2.59 B 2.94 C NB D 2.94 C 3.18 C SB D 1.53 A 1.66 A 9 Los Osos Valley Road/Froom Ranch Way EB D 3.38 C 4.39 E WB D 1.81 A 2.49 B NB D 1.73 A 2.12 B SB D 1.72 A 1.74 A 1 0 Los Osos Valley Road/Auto Park Way EB D n/a - n/a - WB D - - NB D - - SB D - - 1 1 Los Osos Valley Road/Calle Joaquin EB D 2.99 C 2.97 C WB D 3.08 C 3.22 C NB D 1.45 A 1.87 A SB D 0.37 A 0.69 A San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-20 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswal k Score LOS Ped. Crosswal k Score LOS 1 2 Los Osos Valley Road/US 101 SB Ramps EB D n/a - n/a - WB D 2.69 B 3.04 C SB D 2.33 B 3.18 C 1 3 Los Osos Valley Road/US 101 NB Ramps EB D n/a - n/a - NB D 1.82 A 2.58 B SB D 3.45 C 3.43 C 1 4 S. Higuera Street/Los Osos Valley Road EB D 1.99 A 1.73 A NB D 1.87 A 1.63 A SB D 2.38 B 3.67 D 1 5 S. Higuera Street/Suburban Drive WB D 0.89 A 1.55 A NB D 2.20 B 1.94 A SB D 1.71 A 2.13 B 1 6 S. Higuera Street/Tank Farm Road EB D 2.70 B 2.66 B WB D 2.45 B 2.99 C NB D 2.07 B 2.01 B SB D 1.66 A 1.91 A 1 7 S. Higuera Street/Granada Drive WB D 2.63 B 2.99 C NB D 1.70 A 1.88 A SB D 1.83 A 1.98 A 1 8 S. Higuera Street/Prado Road EB D 2.37 B 2.22 B WB D 2.69 B 2.90 C NB D 1.64 A 1.99 A SB D 1.87 A 1.90 A 1 9 S. Higuera Street/Margarita Avenue EB D 2.46 B 2.53 B WB D 2.69 B 2.68 B NB D 1.57 A 1.78 A SB D 2.11 B 2.04 B 2 0 Prado Road/US 101 NB Ramps EB D n/a - n/a - WB D - - NB D - - SB D - - Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection. 2. No methodology exists for evaluating bicycle performance at two-way stop-controlled intersections. However, it is reasoned that this type of control has negligible influence on bicycle service along the segment. As shown in Table 4.12-8 through Table 4.12-11, under the baseline existing conditions evaluated in the traffic study, three intersections (Madonna Road & Dalidio Drive, Madonna Road & U.S. 101 southbound ramps, and Higuera Street & South Street) are currently exceeding the City’s minimum automobile LOS threshold. One intersection (Los Osos Valley Road & Froom Ranch Way) currently exceeds the City minimum bicycle LOS thresholds. Ten intersections have vehicle queues that exceed lane capacity during peak hours (Madonna Road & Los Osos Valley Road, Madonna Road & Higuera Street, Higuera Street & South Street, Los Osos Valley Road & Froom Ranch Way, Los Osos Valley Road & Calle Joaquin, Los Osos Valley Road & both U.S.101 Ramps, Higuera Street & Los Osos Valley Road, Higuera Street & Tank Farm, & Higuera Street & Prado Road); however queuing issues along Los Osos Valley Road have been resolved as a result of the recent Los Osos Valley Road/U.S. 101 Interchange improvements. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-21 Table 4.12-12 through Table 4.12-16 provide a summary of the multimodal AM and PM peak hour segment LOS under existing conditions. Segments where the AM or PM LOS exceed the minimum LOS standard are bolded. As shown in Table 4.12-12 through Table 4.12-16, under baseline existing conditions evaluated in the traffic study, two segments (Madonna Road from U.S. 101 Ramps to Dalidio Drive/Prado Road, Los Osos Valley Road from Calle Joaquin to U.S. 101 Ramps) are currently exceeding the City’s minimum automobile LOS threshold. Three segments (Madonna Road from Los Osos Valley Road to U.S. 101 Ramps, Higuera Street from Madonna Road to Tank Farm, and Los Osos Valley Road currently exceed pedestrian, bicycle, or transit LOS thresholds. In addition, U.S. 101 southbound south of Los Osos Valley Road currently exceeds Caltrans’ minimum LOS thresholds. However MMLOS issues along Los Osos Valley Road have been resolved as a result of the recent Los Osos Valley Road/U.S. 101 Interchange improvements. Transit Services. San Luis Obispo Regional Transit Authority (SLORTA) operates bus service within the City and throughout the County of San Luis Obispo. SLORTA Route 10 operates from the City of San Luis Obispo south to the City of Santa Maria, in Santa Barbara County, with a bus stop approximately 0.3 mile east of the project site along South Higuera Street north of Prado Road and South of Margarita Avenue. SLORTA also operates Runabout Paratransit, the county-wide Americans with Disabilities Act (ADA) transportation service, and Dial-A-Ride, an affordable curb-to-curb transportation service. In addition, the City of San Luis Obispo Transit Division (SLO Transit) bus service in the vicinity of the proposed project. SLO Transit routes 4 and 5 have stops at the SLO Promenade retail center, just north of the project site and at the intersection of Madonna Road and Oceanaire Drive just west of the site. Route 2 operates in the U.S. 101 corridor traversing Prado Road immediately east of the freeway. However, this route does not serve the site directly. Route 4 provides one-way service via a loop route beginning at City Hall using the following major streets: Osos Street, Santa Barbara Street, South Street, Madonna Road, Los Osos Valley Road, Foothill Boulevard, California Boulevard, Grand Avenue, and Mill Street. Route 5 provides service to the same locations as Route 4 but in the opposite direction. Bicycle Facilities. Bicycle facilities include bicycle paths, lanes, and routes. Class I bicycle paths are paved pathways separated from roadways. Class II bicycle lanes are lanes for bicyclists adjacent to the outside vehicle travel lanes. These lanes have special lane markings, pavement legends, and signage. Class III bicycle routes are generally located on low traffic volume streets that provide alternative routes for recreational, and in some cases, commuter and school children cyclists. These facilities are designed for bicycle use, but have no separated bicycle right-of-way or lane striping. No Class I bicycle paths are located in the vicinity of the project site. Class II bicycle lanes are striped in both directions on portions of South Higuera Street and Los Osos Valley Road, as well as the entire length of Madonna Road east of Los Osos Valley Road. The South Higuera Street bicycle lanes are striped between Los Osos Valley Road and Nipomo Street in the downtown area. The Los Osos Valley Road bicycle lanes are striped from the western City limit to South Higuera Street. The Los Osos Valley Road overpass at U.S. 101 does not have bicycle lanes, but does have narrow striped shoulders that could serve bicyclists. Class III bicycle routes are provided along frontage roads that are parallel to U.S. 101 and in areas north of Madonna Road. A bicycle route is located on Elks Lane on the east side of U.S. 101 between Prado Road and South Higuera Street. Bicycle routes are also provided along the entire length of Oceanaire Drive and throughout Laguna Lake Park. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-22 Table 4.12-12 Existing Conditions Segment Level of Service: Automobile Analysis AM Peak PM Peak Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Madonna Rd Oceanaire Dr LOVR WB D 20.8 40.1 52% C 12.7 40.1 32% E Madonna Rd LOVR Oceanaire Dr EB D 28.3 40.0 71% B 24.9 40.0 62% C Madonna Rd Dalidio Oceanaire Dr WB D 22.7 40.8 56% C 19.2 40.7 47% D Madonna Rd Oceanaire Dr Dalidio EB D 27.1 40.7 66% C 18.9 40.8 46% D Madonna Rd El Mercado Dalidio Dr WB D 21.2 34.8 61% C 14.1 34.8 41% D Madonna Rd Dalidio Dr El Mercado EB D 21.2 34.7 61% C 13.3 34.6 39% E Madonna Rd US 101 SB Ramps El Mercado WB D 32.2 37.9 85% A 21.2 37.3 57% C Madonna Rd El Mercado US 101 SB Ramps EB D 22.5 37.8 59% C 18.6 37.7 49% D Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 34.5 37.8 91% A 34.0 37.8 90% A Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 32.7 37.8 86% A 33.5 37.8 88% A Madonna Rd Higuera St US 101 NB Ramps WB D 9.2 37.2 25% F 10.6 37.2 29% F Madonna Rd US 101 NB Ramps Higuera St EB D 17.4 37.2 47% D 13.3 37.2 36% E S. Higuera St Madonna Rd Margarita Ave SB D 37.5 44.5 84% B 36.0 44.5 81% B S. Higuera St Margarita Ave Madonna Rd NB D 35.7 44.8 80% B 36.8 44.8 82% B S. Higuera St Margarita Ave Prado Rd SB D 18.6 38.9 48% D 16.5 38.9 42% D S. Higuera St Prado Rd Margarita Ave NB D 26.3 38.9 68% B 22.0 38.9 57% C S. Higuera St Prado Rd Granada Dr SB D 33.8 41.8 81% B 30.6 41.8 73% B S. Higuera St Granada Dr Prado Rd NB D 25.6 41.9 61% C 28.1 41.9 67% B S. Higuera St Granada Dr Tank Farm Road SB D 42.6 41.6 102% A 27.4 42.6 64% C S. Higuera St Tank Farm Road Granada Dr NB D 30.5 41.6 73% B 28.7 42.6 67% B S. Higuera St Tank Farm Road Suburban Drive SB D 27.3 42.4 65% C 24.9 41.2 60% C S. Higuera St Suburban Drive Tank Farm Road NB D 20.2 42.5 47% D 18.9 41.3 46% D S. Higuera St Suburban Drive Los Osos Valley Road SB D 20.6 42.1 49% D 15.9 39.1 41% D S. Higuera St Los Osos Valley Road Suburban Drive NB D 24.8 42.0 59% C 21.6 39.0 55% C Los Osos Valley Madonna Rd Froom Ranch Way SB D 24.5 41.9 58% C 18.2 41.8 43% D Los Osos Valley Froom Ranch Way Madonna Rd NB D 20.1 41.8 48% D 16.9 41.8 40% D Los Osos Valley Froom Ranch Way Calle Joaquin SB D 35.5 43.0 83% B 31.1 43.0 72% B Los Osos Valley Calle Joaquin Froom Ranch Way NB D 31.0 43.2 72% B 23.4 43.2 54% C Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 13.5 32.1 42% D 9.1 32.1 28% F Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 17.0 31.1 55% C 15.3 31.1 49% D Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 10.2 37.7 27% F 13.2 37.7 35% E Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 11.7 37.4 31% E 32.0 37.4 85% A San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-23 AM Peak PM Peak Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Los Osos Valley S. Higuera St US 101 NB Ramps WB D 29.5 39.2 75% B 25.8 39.2 66% C Los Osos Valley US 101 NB Ramps S. Higuera St EB D 21.6 39.4 55% C 18.3 39.4 46% D Prado Rd S. Higuera St US 101 NB Ramps WB D 28.0 38.3 73% B 22.2 38.3 58% C Prado Rd US 101 NB Ramps S. Higuera St EB D 23.8 38.3 62% C 21.2 38.3 55% C Froom Ranch Way Dick's Sporting Goods Drwy Los Osos Valley WB D 17.9 37.7 47% D 12.7 37.9 33% E Froom Ranch Way Los Osos Valley Dick's Sporting Goods Drwy EB D 35.5 38.1 93% A 34.6 37.4 93% A Dalidio Dr Madonna Rd Froom Ranch Rd SB D 21.5 31.2 69% B 21.5 31.2 69% B Dalidio Dr Froom Ranch Rd Madonna Rd NB D 5.5 31.1 18% F 0.4 31.1 1% F Note: 1. The Los Osos Valley Road Interchange Project was completed after existing baseline conditions were established. The results shown above reflect the LOS prior the Interchange expansion. LOS reflecting the completed Los Osos Valley Road Interchange are represented in the existing + project scenario analysis. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-24 Table 4.12-13 Existing Conditions Segment Level of Service: Pedestrian Analysis AM Peak PM Peak Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score Los Segment Score LOS Madonna Rd Oceanaire Dr LOVR WB C 6090 3.52 D 3.79 D Madonna Rd LOVR Oceanaire Dr EB C 17482 3.73 D 3.85 D Madonna Rd Dalidio Oceanaire Dr WB C 84000 3.62 D 3.92 D Madonna Rd Oceanaire Dr Dalidio EB C 26250 3.80 D 3.89 D Madonna Rd El Mercado Dalidio Dr WB C 37450 3.52 D 3.78 D Madonna Rd Dalidio Dr El Mercado EB C 52920 3.63 D 3.73 D Madonna Rd US 101 SB Ramps El Mercado WB C 26250 3.59 D 3.75 D Madonna Rd El Mercado US 101 SB Ramps EB C 27915 3.84 D 4.04 D Madonna Rd US 101 NB Ramps US 101 SB Ramps WB C No Peds 3.66 D 3.81 F Madonna Rd US 101 SB Ramps US 101 NB Ramps EB C No Peds 4.06 D 3.98 D Madonna Rd Higuera St US 101 NB Ramps WB C 25200 3.58 D 3.72 D Madonna Rd US 101 NB Ramps Higuera St EB C 19838 3.84 D 3.72 D S. Higuera St Madonna Rd Margarita Ave SB C 23247 3.80 D 3.78 D S. Higuera St Margarita Ave Madonna Rd NB C 5398 3.60 D 3.78 D S. Higuera St Margarita Ave Prado Rd SB C 40979 3.61 D 3.63 D S. Higuera St Prado Rd Margarita Ave NB C 21700 3.47 C 3.57 D S. Higuera St Prado Rd Granada Dr SB C 9292 3.55 D 3.65 D S. Higuera St Granada Dr Prado Rd NB C 8400 3.16 C 3.38 C S. Higuera St Granada Dr Tank Farm Road SB C 46305 3.54 D 3.69 D S. Higuera St Tank Farm Road Granada Dr NB C 49140 3.11 C 3.26 C S. Higuera St Tank Farm Road Suburban Drive SB C 12600 3.57 D 3.80 D S. Higuera St Suburban Drive Tank Farm Road NB C 31500 3.48 C 3.44 C S. Higuera St Suburban Drive Los Osos Valley Road SB C 39312 3.56 D 3.85 D S. Higuera St Los Osos Valley Road Suburban Drive NB C 43533 3.84 D 3.89 D Los Osos Valley Madonna Rd Froom Ranch Way SB C 21833 3.81 D 3.88 D Los Osos Valley Froom Ranch Way Madonna Rd NB C 0 3.72 F 4.04 F Los Osos Valley Froom Ranch Way Calle Joaquin SB C 27300 3.76 D 3.97 D Los Osos Valley Calle Joaquin Froom Ranch Way NB C 22050 3.67 D 3.94 D Los Osos Valley Calle Joaquin US 101 SB Ramps SB C No Peds 3.59 D 3.92 D Los Osos Valley US 101 SB Ramps Calle Joaquin NB C 63000 3.62 D 3.91 D Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB C No Peds 4.15 D 4.19 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB C 53928 3.62 D 3.85 D Los Osos Valley S. Higuera St US 101 NB Ramps WB C 1680 3.67 D 4.10 D Los Osos Valley US 101 NB Ramps S. Higuera St EB C 39393 3.77 D 3.66 D Prado Rd S. Higuera St US 101 NB Ramps WB C 56133 2.90 C 3.10 C Prado Rd US 101 NB Ramps S. Higuera St EB C 3019 3.42 C 3.32 C San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-25 AM Peak PM Peak Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score Los Segment Score LOS Froom Ranch Way Dick's Sporting Goods Drwy Los Osos Valley WB C No Peds 3.29 C 3.52 D Froom Ranch Way Los Osos Valley Dick's Sporting Goods Drwy EB C 75600 1.67 A 1.79 A Dalidio Dr Madonna Rd Froom Ranch Rd SB C 56700 1.46 A 1.56 A Dalidio Dr Froom Ranch Rd Madonna Rd NB C 73710 3.04 C 3.35 C Notes: 1. Sidewalk is present along frontage roads for segments #1 - Madonna Road and #13 - Los Osos Valley Road, and is not accounted for in this analysis. 2. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is reasoned that it has negligible influence on pedestrian service along the segment. 3. The Los Osos Valley Road Interchange Project was completed after existing baseline conditions were established. The results shown above reflect the LOS prior the Interchange expansion. LOS reflecting the completed Los Osos Valley Road Interchange are represented in the existing + project scenario analysis. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-26 Table 4.12-14 Existing Conditions Segment Level of Service: Bicycle Analysis AM Peak PM Peak Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS Madonna Rd Oceanaire Dr LOVR WB D 3.60 D 3.93 D Madonna Rd LOVR Oceanaire Dr EB D 3.73 D 3.78 D Madonna Rd Dalidio Oceanaire Dr WB D 3.15 C 3.23 C Madonna Rd Oceanaire Dr Dalidio EB D 3.57 D 3.43 C Madonna Rd El Mercado Dalidio Dr WB D 3.27 C 3.19 C Madonna Rd Dalidio Dr El Mercado EB D 3.49 C 3.39 C Madonna Rd US 101 SB Ramps El Mercado WB D 3.94 D 4.34 E Madonna Rd El Mercado US 101 SB Ramps EB D 3.62 D 3.64 D Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 3.30 C 3.35 C Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 3.38 C 3.33 C Madonna Rd Higuera St US 101 NB Ramps WB D 3.48 C 3.54 D Madonna Rd US 101 NB Ramps Higuera St EB D 3.66 D 3.53 D S. Higuera St Madonna Rd Margarita Ave SB D 3.88 D 3.87 D S. Higuera St Margarita Ave Madonna Rd NB D 4.05 D 4.14 D S. Higuera St Margarita Ave Prado Rd SB D 3.64 D 3.64 D S. Higuera St Prado Rd Margarita Ave NB D 3.87 D 3.92 D S. Higuera St Prado Rd Granada Dr SB D 3.84 D 3.87 D S. Higuera St Granada Dr Prado Rd NB D 3.42 C 3.49 C S. Higuera St Granada Dr Tank Farm Road SB D 4.10 D 4.16 D S. Higuera St Tank Farm Road Granada Dr NB D 3.48 C 3.52 D S. Higuera St Tank Farm Road Suburban Drive SB D 3.33 C 3.41 C S. Higuera St Suburban Drive Tank Farm Road NB D 3.40 C 3.39 C S. Higuera St Suburban Drive Los Osos Valley Road SB D 3.24 C 3.59 D S. Higuera St Los Osos Valley Road Suburban Drive NB D 3.90 D 3.87 D Los Osos Valley Madonna Rd Froom Ranch Way SB D 3.71 D 3.71 D Los Osos Valley Froom Ranch Way Madonna Rd NB D 3.39 C 3.46 C Los Osos Valley Froom Ranch Way Calle Joaquin SB D 3.56 D 3.58 D Los Osos Valley Calle Joaquin Froom Ranch Way NB D 3.80 D 3.88 D Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 3.33 C 3.52 D Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 3.54 D 3.60 D Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 3.75 D 3.77 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 3.61 D 3.50 C Los Osos Valley S. Higuera St US 101 NB Ramps WB D 3.30 C 3.53 D Los Osos Valley US 101 NB Ramps S. Higuera St EB D 3.35 C 3.27 C Prado Rd S. Higuera St US 101 NB Ramps WB D 3.44 C 3.50 C Prado Rd US 101 NB Ramps S. Higuera St EB D 3.94 D 3.68 D San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-27 AM Peak PM Peak Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS Froom Ranch Way Dick's Sporting Goods Drwy Los Osos Valley WB D 3.29 C 3.47 C Froom Ranch Way Los Osos Valley Dick's Sporting Goods Drwy EB D 2.87 C 3.48 C Dalidio Dr Madonna Rd Froom Ranch Rd SB D 4.30 E 4.37 E Dalidio Dr Froom Ranch Rd Madonna Rd NB D 3.77 D 4.21 D Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is incorporated into the methodology for evaluating bicycle segment performance. 2. The Los Osos Valley Road Interchange Project was completed after existing baseline conditions were established. The results shown above reflect the LOS prior the Interchange expansion. LOS reflecting the completed Los Osos Valley Road Interchange are represented in the existing + project scenario analysis. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-28 Table 4.12-15 Existing Conditions Segment Level of Service: Transit Analysis Transit Segment LOS AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D Route 4 4.17 D 4.28 E Madonna Rd LOVR Oceanaire Dr EB D Route 5 4.30 E 4.12 D 2 Madonna Rd Dalidio Oceanaire Dr WB D Route 4 4.47 E 4.58 E Madonna Rd Oceanaire Dr Dalidio EB D Route 5 4.70 E 4.51 E 3 Madonna Rd El Mercado Dalidio Dr WB D Route 4 4.24 D 4.42 E Madonna Rd Dalidio Dr El Mercado EB D Route 5 Not Analyzed N/A Not Analyzed N/A 4 Madonna Rd US 101 SB Ramps El Mercado WB D Route 4 4.31 E 4.53 E Madonna Rd El Mercado US 101 SB Ramps EB D Route 5 4.64 E 4.40 E 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D Route 4 3.89 D 3.99 D Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D Route 5 4.29 E 3.89 D 6 Madonna Rd Higuera St US 101 NB Ramps WB D Route 4 4.27 E 4.37 E Madonna Rd US 101 NB Ramps Higuera St EB D Route 5 4.50 E 4.18 D 7 S. Higuera St Madonna Rd Margarita Ave SB D Route 2 Not Analyzed N/A 3.49 C S. Higuera St Margarita Ave Madonna Rd NB D Route 2 3.65 D 3.67 D 8 S. Higuera St Margarita Ave Prado Rd SB D Route 2 Not Analyzed N/A 4.19 D S. Higuera St Prado Rd Margarita Ave NB D Route 2 4.15 D 4.24 D 9 S. Higuera St Prado Rd Granada Dr SB D Route 2 4.35 E 4.28 E S. Higuera St Granada Dr Prado Rd NB D Route 2 3.76 D 3.82 D 10 S. Higuera St Granada Dr Tank Farm Road SB D Route 2 3.75 D 3.83 D S. Higuera St Tank Farm Road Granada Dr NB D Route 2 3.51 D 3.58 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Suburban Drive Tank Farm Road NB D Route 2 3.97 D 3.96 D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Los Osos Valley Road Suburban Drive NB D - Not Analyzed N/A Not Analyzed N/A 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 4 4.49 E 4.53 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 4 4.23 D 4.38 E 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.59 E 4.38 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 5 4.37 E 4.21 D 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D Route 4 4.21 D 4.33 E Los Osos Valley Calle Joaquin Froom Ranch Way NB D Route 4 4.21 D 4.44 E 14 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.37 E 4.15 D Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 5 4.35 E 4.28 E 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 SB Ramps Calle Joaquin NB D Not Analyzed N/A Not Analyzed N/A 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D Not Analyzed N/A Not Analyzed N/A 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps S. Higuera St EB D Not Analyzed N/A Not Analyzed N/A San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-29 Transit Segment LOS AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 18 Prado Rd S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Prado Rd US 101 NB Ramps S. Higuera St EB D Route 2 3.83 D Not Analyzed N/A 19 Froom Ranch Way Dick's Sporting Goods Drwy Los Osos Valley WB D Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Los Osos Valley Dick's Sporting Goods Drwy EB D Not Analyzed N/A Not Analyzed N/A 20 Dalidio Dr Madonna Rd Froom Ranch Rd SB D Route 4 4.01 D 4.10 D Dalidio Dr Madonna Rd Froom Ranch Rd SB D Route 5 4.26 E 4.09 D Notes: 1. Route 2 Serves the Prado Day Center stop during the AM peak hour, and the DMV/Margarita stop during the PM Peak Hour. 2. Segment 20 transit is southbound for routes 4 and 5. 3. The Los Osos Valley Road Interchange Project was completed after existing baseline conditions were established. The results shown above reflect the LOS prior the Interchange expansion. LOS reflecting the completed Los Osos Valley Road Interchange are represented in the existing + project scenario analysis. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-30 Table 4.12-16 Existing Conditions Segment Level of Service: Freeway Analysis AM Peak Hour PM Peak Hour Interchange Location Target LOS Segment Type No. of Lanes Volume Density (pc/mi/ln) LOS Volume Density (pc/mi/ln) LOS US 101 at Los Osos Valley Road US 101 NB South of Los Osos Valley Road C Freeway 2 2,774 24.5 C 2,249 19.7 C US 101 SB South of Los Osos Valley Road C Freeway 2 1,406 12.3 B 3,044 27.4 D US 101 at Prado Road US 101 NB South of Prado Road C Freeway 2 2,443 21.4 C 2,137 18.8 C US 101 at Madonna Road US 101 NB South of Madonna Road C Freeway 2 2,468 21.7 C 2,497 21.9 C US 101 SB South of Madonna Road C Freeway 2 1,663 14.6 B 2,881 25.6 C San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-31 Pedestrian Facilities. Pedestrian facilities include sidewalks, crosswalks, and pedestrian signals at signalized intersections. In the vicinity of the project site, sidewalks are located on both sides of Madonna Road except for several small segments including the south side of the street adjacent to the western portion of the project site; along the north side of the road extending from the northbound on-ramp across the bridge to the Madonna Inn’s entrance driveway; and along the south side of Madonna Road from the northbound off-ramp to the entrance driveway of the Caltrans parking area. c. Regulatory Setting. Americans with Disabilities Act (ADA; 1990). Title III of the ADA (codified in Title 42 of the U.S. Code [USC]), prohibits discrimination on the basis of disability in places of public accommodation (i.e., businesses and non-profit agencies that serve the public) and commercial facilities (i.e., other businesses). This regulation includes Appendix A to Part 36, Standards for Accessible Design, which establishes minimum standards for ensuring accessibility when designing and constructing a new facility or altering an existing facility. Examples of key guidelines include detectable warning for pedestrians entering traffic where there is no curb, a clear zone of 48 inches for the pedestrian travel way, and a vibration-free zone for pedestrians. California Department of Transportation. Caltrans manages the operation of State Highways, including the U.S. 101, which passes through the San Luis Obispo area. Senate Bill (SB) 743. To further the State’s commitment to the goals of SB 375, Assembly Bill (AB) 32, and AB 1358, SB 743 adds Chapter 2.7, Modernization of Transportation Analysis for Transit-Oriented Infill Projects, to Division 13 (Section 21099) of the Public Resources Code. Key provisions of SB 743 include reforming aesthetics and parking California Environmental Quality Act (CEQA) analysis for urban infill projects and replacing the measurement of automobile delay with vehicle miles traveled as a metric that can be used for measuring environmental impacts. Under SB 743, the focus of the environmental impacts of transportation shift from driver delay to reduction of greenhouse gas (GHG) emissions, creation of multimodal networks, and promotion of a mix of land uses, and LOS standards become local policy thresholds as adopted among individual agencies. Currently official measures and significance thresholds are still being developed and have not yet been adopted under CEQA. Therefore automobile LOS is still used as a significance threshold for CEQA review. The traffic study prepared for the San Luis Ranch Specific Plan analyses both multimodal LOS and VMT; however in the absence of official significance thresholds, no findings in regarding to vehicle miles traveled are made at this time. City of San Luis Obispo General Plan. The City General Plan sets objectives and policies for all City resources. Those associated with the standards of streets and highways incorporated within the City are managed through the Circulation Element of the General Plan. The following Circulation Element policies and programs are relevant to the project: Policy 2.1.1. Multi-level Programs. The City shall support County-wide and community- based efforts aimed at substantially reducing the number of vehicle trips and parking demand. Policy 2.1.2. Flexible Work Schedules. The City shall support flex time programs and alternative work schedules to reduce peak hour traffic demand. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-32 Policy 2.1.3. Work-based Trip Reduction. The City shall encourage employers within the City limits and work with the county to work with employers outside of the City limits to participate in trip reduction programs. Policy 2.1.5. Long-term Measure. The City shall support programs that reduce traffic congestion and maintain air quality. If air quality degrades below legal standards or LOS standards are exceeded, the City will pursue more stringent measures to achieve its transportation goals. Policy 4.1.4. New Development. The City shall require that new development provide bikeways, secure bicycle storage, parking facilities and showers consistent with City plans and development standards. When evaluating transportation impacts, the City shall use a Multi-modal Level of Service (MMLOS) analysis. Policy 6.1.1. Complete Streets. The City shall design and operate City streets to enable safe, comfortable, and convenient access and travel for users of all abilities including pedestrians, bicyclists, transit users, and motorists. Policy 6.1.2. Multimodal LOS Objectives, Service Standards, and Significance Criteria. The City shall strive to achieve LOS objectives and shall maintain LOS minimums for all four modes of travel; Pedestrians, Bicyclists, Transit, & Vehicles. Policy 6.1.3. Multimodal Priorities. In addition to maintaining minimum LOSs, MMLOSs should be prioritized in accordance with the established modal priorities, such that construction, expansion, or alteration for one mode should not degrade the service level of a higher priority mode. Policy 6.1.4. Defining Significant Circulation Impact. Any degradation of the LOS shall be minimized to the extent feasible in accordance with the modal priorities established. If the LOS degrades below thresholds established in Policy 6.1.2, it shall be determined a significant impact for purposes of environmental review under CEQA. For roadways already operating below the established MMLOS standards, any further degradation to the MMLOS score will be considered a significant impact under CEQA. Where a potential impact is identified, the City in accordance with the modal priorities established, can determine if the modal impact in question is adequately served through other means e.g., another parallel facility or like service. Based on this determination, a finding of no significant impact may be determined by the City. Policy 6.1.5. Mitigation. For significant impacts, developments shall be responsible for their fair share of any improvements required. Potential improvements for alternative mode may include, but are not limited to: • Pedestrian: Provision of sidewalk, providing or increasing a buffer from vehicular travel lanes, increased sidewalk clear width, providing a continuous barrier between pedestrians and vehicle traffic, improved crossings, reduced signal delay, traffic calming, no right turn on red, reducing intersection crossing distance. • Bicycle: Addition of a bicycle lane, traffic calming, provision of a buffer between bicycle and vehicle traffic, pavement resurfacing, reduced number of access points, or provision of an exclusive bicycle path, reducing intersection crossing distance. • Transit: For transit-related impacts, developments shall be responsible for their fair share of any infrastructural improvements required. This may involve provision of street furniture at transit stops, transit shelters, and/or transit shelter amenities, pullouts for transit vehicles, San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-33 transit signal prioritization, provision of additional transit vehicles, or exclusive transit lanes. Policy 6.1.6. City Review. When new projects impact the existing circulation system, the City shall review the effectiveness and desirability of “direct fix” mitigation improvements to address MMLOS impacts. Where a significant impact is found, alternative system-wide project mitigations may be submitted for consideration to the City in accordance with the modal priorities established in Policy 6.1.2. Exceptions shall be based on the physical conditions of the right-of-way to support additional improvements. If the right-of-way in question cannot address on-site mitigation, appropriate off-site improvements that have direct nexus to and effectively address the specific impacts created by the project may be considered. Policy 7.1.1. Peak Hour and Daily Traffic. The City shall cooperate with County and State government to institute programs that reduce the levels of peak-hour and daily vehicle traffic. Policy 7.1.2. Street Network. The City shall manage to the extent feasible the street network so that the standards are not exceeded. This will require new development to mitigate the traffic impacts it causes or the City to limit development that affects streets where congestion levels may be exceeded. The standards may be met by strengthening alternative modes over the single occupant motor vehicle. Where feasible, roundabouts shall be the City’s preferred intersection control alternative due to the vehicle speed reduction, safety, and operational benefits of roundabouts. Policy 7.1.3. Growth Management & Roadway Expansion. The City shall manage the expansion of roadways to keep pace with only the level of increased vehicular traffic associated with development planned for in the Land Use Element and under the City’s growth management policies and regional transportation plans. Policy 7.1.4. Transportation Funding. In order to increase support for non-automobile travel, the City shall strive to allocate transportation funding across various modes approximately proportional to the modal split objectives for 2035 as shown in Table 1 [of the Circulation Element]. Policy 7.1.5. Vehicle Speeds. To the extent permitted under the California Vehicle Code (CVC), the City shall endeavor to maintain and reduce speeds where possible in residential neighborhoods. Policy 7.2.7. Traffic Access Management. The City shall adopt an access management policy to control location, spacing, design and operation of driveways, median openings, crosswalks, interchanges and street connections to a particular roadway including navigation routes to direct traffic in a manner that preserves the safety and efficiency of the transportation system. Navigation routing and other smart access technologies should be considered as part of the update to the Access and Parking Management plan. Policy 8.1.1. Through Traffic. The City shall design its circulation network to encourage through traffic to use Regional Routes, Highways, Arterials, Parkway Arterials, and Residential Arterial streets and to discourage through traffic use of Collectors and Local streets. Policy 8.1.2. Residential Streets. The City should not approve commercial development that encourages customers, employees or deliveries to use Residential Local or Residential Collector streets. Policy 8.1.3. Neighborhood Traffic Speeds. To the extent permitted under the CVC, the City shall endeavor to reduce and maintain vehicular speeds in residential neighborhoods. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-34 Policy 8.1.4. Neighborhood Traffic Management. The City shall ensure that neighborhood traffic management projects: • Provide for the mitigation of adverse impacts on all residential neighborhoods. • Provide for adequate response conditions for emergency vehicles. • Provide for convenient and safe through bicycle and pedestrian traffic. Policy 8.1.5. Neighborhood Traffic Management Guidelines. The City shall update its Neighborhood Traffic Management Guidelines to address voting, funding, and implementation procedures and develop an outreach program on the availability of the program. Policy 8.1.6. Non-Infill Development. In new, non-infill developments, dwellings shall be set back from Regional Routes and Highways, Parkway Arterials, Arterials, Residential Arterials, and Collector streets so that interior and exterior noise standards can be met without the use of noise walls. Program 9.2.2. Prado Road Improvements. The City shall ensure that changes to Prado Road (Projects 1, 2, and 19 on Table 5) and other related system improvements are implemented in a sequence that satisfies circulation demands caused by area development. The sponsors of development projects that contribute to the need for the Prado Road interchange or overpass (Project 19 on Table 5) will be required to prepare or fund the preparation of a Project Study Report for the interchange project. The Project Study Report shall meet the requirements of the California Department of Transportation. Program 9.2.5. San Luis Ranch/Dalidio Development. As part of any proposal to further develop the Dalidio-Madonna Area, the alignment and design of extensions of Froom Ranch Way connecting with Prado Road (west of Route 101) shall be evaluated and established if consistent with the Agricultural Master Plan for Calle Joaquin Reserve. Policy 11.1.1. Interstate Air Service. The City shall support and encourage expansion of air transportation services, as forecasted in the Airport Master Plan and approved by the Federal Aviation Administration (FAA). Policy 11.1.2. County Aircraft Operations. The City shall work with the County to continue to address aircraft operations so that noise and safety problems are not created in developed areas or areas targeted for future development by the City's Land Use Element. Policy 11.1.3. Public Transit Service. The City shall encourage improved public transit service to the County airport soon as practical. City of San Luis Obispo Bicycle Transportation Plan (BTP; 2013). The BTP was prepared and adopted by the City in 1985 and it was updated in 2013 to improve and encourage bicycle and pedestrian transportation within the City. This plan works to establish a comprehensive design and development of bikeway facilities in compliance with State, County, and City regulations and policies. 4.12.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) previously analyzed impacts to transportation and circulation in the City related to the adoption and implementation of the General Plan Land Use and Circulation Elements, including planned San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-35 future land use development and proposed goals, policies, and programs. The LUCE Update EIR identified significant impacts to transportation and traffic as a result of the increase in vehicle trips from development of planned Citywide land uses allowed under the LUCE as well as potential proposed development of the project site with up to 500 housing units and 470,000 square feet of non-residential uses. The LUCE Update EIR found that additional traffic congestion from development proposed under the updated Land Use and Circulation Elements would result in unacceptable levels of service at several roadways and intersections and may result in potential increases to traffic speed and/or traffic volumes. The LUCE Update EIR concluded that impacts could be reduced to the extent feasible with the implementation of City policies and additional mitigation measures including, but not limited to roadway widening and installation of new traffic signals (City of San Luis Obispo 2014b). However, several of the mitigation measures required in the LUCE Update EIR were found to be potentially infeasible due to the uncertainty of necessary right‐of‐way acquisition. Therefore, the LUCE Update EIR found transportation and circulation impacts associated with buildout of the City under the General Plan to be significant and unavoidable. 4.12.3 Prado Road & U.S. 101: Overpass Only vs. Full Access Interchange The City’s previously-adopted Circulation Element (1999) identified the future Prado Road & U.S. 101 interchange as a full access interchange: an overpass with ramps serving both northbound and southbound U.S. 101. During the Land Use and Circulation Element Update there was interest in reassessing the interchange to determine if an overpass only, without ramps, would provide adequate circulation while reducing the level of impact on agricultural lands and potential conflicts with Caltrans interchange spacing requirements. The LUCE Update EIR found that without ramps at the Prado Road & U.S. 101 interchange there would be significant impacts at other surrounding interchanges and City streets. However, because the LUCE Update EIR analysis was programmatic, it has not been used to completely reject the overpass-only option. As a result, the General Plan retained the full access interchange plan as well as an option to have an overpass only, depending on the outcome of the more detailed traffic analysis conducted for the San Luis Ranch Specific Plan, and required through a Project Study Report for the future interchange. The transportation and circulation impact analysis for the project below (Section 4.12.54) identifies three general designs of the Prado Road & U.S. 101 interchange, where identified transportation impacts that would result from the project trigger the need for this improvement. These three general designs include: 1. Impacts that trigger the Prado Overpass-Only 2. Impacts that trigger the Prado Overpass Plus U.S. 101 northbound ramps, and 3. Impacts that trigger the Prado Overpass Plus U.S. 101 northbound ramps and U.S. 101 southbound ramps Ultimately, these three general designs represent a tiered approach to constructing a full access interchange at Prado Road and U.S. 101. While a complete interchange could be constructed at one time, this analysis assumes that it may be necessary to build an overpass-only connection for the Prado Road extension, followed by rebuilding the northbound ramps on the east side of U.S. 101, and eventually followed by constructing new southbound ramps on the west side of U.S. 101. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-36 Existing & Near-Term Conditions. As described in detail in the impact analysis below (Section 4.12.54), the traffic study prepared for the San Luis Ranch Specific Plan (refer to Appendix KL) identified that by completion of Phase 2 of the project an overpass with northbound ramps would be needed to maintain acceptable transportation operations. The alternative to the recommended northbound ramps to maintain acceptable transportation operations under existing and near-term conditions would include: • Widening of Higuera Street at Madonna Road into the Pacific Coast Center, which would include demolition of the buildings fronting the street; and • Widening of the recently constructed Los Osos Valley Road/U.S. 101 bridge to extend the right turn pocket from Los Osos Valley Road to northbound U.S. 101. Cumulative Conditions. The traffic study identified that, in addition to the overpass and northbound ramps constructed during Phase 2 of the project, southbound ramps would eventually need to be added to maintain acceptable transportation operations. The alternative to the recommended southbound ramps to maintain acceptable transportation operations under existing and near-term conditions would include: • Expand the Higuera Street/Marsh Street & U.S. 101 Interchange; • Expand the Madonna Road & U.S. 101 Interchange; and • Expand the Los Osos Valley Road & U.S. 101 Interchange. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass are discussed in Section 4.12.54(d). 4.12.4 Impact Analysis a. Methodology and Significance Thresholds. Thresholds of Significance. The following criteria are based on Appendix G of the State CEQA Guidelines. Impacts related to transportation and circulation from the proposed project would be significant if the project would: 1. Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit; 2. Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways; 3. Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks; 4. Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment); 5. Result in inadequate emergency access; and/or 6. Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities. The Initial Study determined that the project would not result in changes to air traffic patterns and would not result in inadequate emergency access to the site. Therefore, Thresholds 3 and 5 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-37 are not discussed further in this section. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of these issues. City of San Luis Obispo Thresholds. The City of San Luis Obispo does not have a formally adopted Congestion Management Program (CMP). However, the City’s General Plan Circulation Element contains LOS policies for all modes of transportation. The City’s has established minimum LOS standards for all transportation modes with a goal to maintain established LOS objectives. Table 4.12-2 through Table 4.12-7 show the City’s established LOS objectives and minimum LOS standards by mode of transportation. Based on the City’s thresholds, the project would have a significant impact if any of the following conditions are met: Automobiles: Intersections A. Signalized Intersections: Project traffic causes minimum LOS standards to be exceeded or further degrades already exceeded LOS standards and the V/C ratio is increased by 0.01 or more. B. Unsignalized Intersections: Project traffic causes minimum LOS standards to be exceeded or further degrades already exceeded LOS standards, the V/C ratio is increased by 0.01 or more, and a traffic signal warrant analysis is satisfied. C. Project traffic causes or exacerbates 95th percentile turning movement queues exceeding available turn pocket capacity. D. The project proposes roadway geometry changes that cause minimum LOS standards to be exceeded or further degrades already exceeded LOS standards for the overall intersection or individual lane groups. Automobiles: Segments A. Project traffic causes minimum LOS standards for either direction to be exceeded or further degrades already exceeded LOS standards and the average segment speed decreases by one mph or more. B. The project proposes roadway geometry changes that cause minimum LOS standards to be exceeded or further degrades already exceeded LOS standards. Pedestrian, Bicycle, and Transit: Intersections and Segments A. Project traffic causes minimum LOS standards to be exceeded or further degrades already exceeded LOS standards and there is contextual significance to the impact. B. Pedestrians and Bicycles: The project proposes roadway geometry changes that cause minimum LOS standards to be exceeded or further degrades already exceeded LOS standards. Modal Priorities. In addition to maintaining minimum LOS, the City's Circulation Element has established priorities for various modes such that construction, expansion, or alteration of one mode should not degrade the LOS of a higher priority mode. Project impacts are considered significant if the project proposes to improve a lower priority mode resulting in the degradation of a higher priority mode. Also, if a project's mitigation would result in the degradation of higher priority mode that shall be considered a residual impact and addressed as well. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-38 Traffic Safety. A safety assessment is conducted for the study intersections and segments based on the project's potential operational and geometric affects, including turn pocket queue spillbacks and a functional area analysis of project driveways in close proximity to other intersections on collector and arterial roadways. A. Project traffic affects the operational characteristics of an existing intersection or segment such that the collision rater, per million entering vehicles for intersections and per million vehicle miles for segments, would be likely to increase. B. Project proposed significant new or modified infrastructure is predicted to have a collision rate as indicated above higher that the median collision rate as reported in the City’s most current annual traffic survey report for the same facility classification type. Neighborhood Traffic. Project impacts are considered significant if the maximum neighborhood ADT or speed thresholds established from the Circulation Element are exceeded or the project adds traffic to a neighborhood already exceeds the ADT threshold. California Department of Transportation (Caltrans) Facilities. In addition to the City’s policies, Caltrans has also established the measure of effectiveness (MOE) for the evaluation of impacts in CEQA projects on State facilities. Caltrans’ Guide for the Preparation of Traffic Impact Studies (December 2002) includes the following policy pertaining to the LOS standards within Caltrans jurisdiction: The Level of Service (LOS) for operating State highway facilities is based upon measures of effectiveness (MOEs). These MOEs describe the measures best suited for analyzing State highway facilities (i.e., freeway segments, signalized intersections, on- or off-ramps, etc.) Caltrans endeavors to maintain a target LOS at the transition between LOS "C" and LOS "D" on State highway facilities, however, Caltrans acknowledges that this may not always be feasible and recommends that the lead agency consult with Caltrans to determine the appropriate target LOS. If an existing State highway facility is operating at less than the appropriate target LOS, the existing MOE should be maintained. Impact Assessment Methodology. The amount of traffic added to the surrounding roadway system by the project was estimated by applying the applicable trip generation rates to the development proposal. Vehicular trips were estimated using the Institute of Transportation Engineers (ITE) Trip Generation Manual (9th Edition). The Shopping Center land use was used to determine the trip generation for the commercial element during the AM and PM peak hour. The ITE Trip Generation Manual does not contain adequate information for the Parks/Recreational land use. As such, San Diego Association of Government’s (SANDAG) Brief Guide to Vehicular Traffic Generation Rates for the San Diego Region (2002) was used to determine the trip generation for the Parks/Recreational land use using the City Park land use generation rate as the best available rate which is expected to have similar trip generation characteristics. Table 4.12-17 presents the ITE trip generation rates and estimates for the proposed land uses. As shown in Table 4.12-17, the project would generate approximately 914 AM peak hour vehicular trips and 1,584 PM peak hour vehicular trips, before any vehicular occupancy, modal, internal capture, or pass-by adjustments. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-39 Table 4.12-17 Project Trip Generation Land Use Category (ITE Code) Unit1 Daily Trip Rate/Unit2 AM Peak Hour Trip Rate/Unit PM Peak Hour Trip Rate/Unit Total In % Out % Total In % Out % Single Family Detached (210) DU 9.62 0.73 25% 75% 0.93 63% 37% Apartment (220) DU 6.50 0.50 20% 80% 0.61 65% 35% Shopping Center (820) KSF 58.93 1.33 62% 38% 5.24 48% 52% Hotel (310) Rooms 8.17 0.53 59% 41% 0.60 51% 49% General Office Building (710) KSF 13.13 1.91 88% 12% 1.90 17% 83% City Park3 AC 50.00 6.55 50% 50% 4.48 50% 50% City Park3 AC 50.00 6.67 50% 50% 4.44 50% 50% Project Name Quantity (Units) Daily Trips AM Peak Hour Trips PM Peak Hour Trips Total In Out Total In Out Single Family Residential (Small 30' lots)4 100 962 73 18 55 93 59 34 Single Family Residential (Traditional 40' lots)4 200 1,924 146 37 110 185 117 68 Multi-Family Residential 280 1,820 141 28 113 172 112 60 Commercial 150 8,839 200 124 76 786 377 409 Hotel 200 1,634 106 63 43 120 61 59 Office 100 1,313 191 168 23 190 32 158 Parks/Recreational 5.80 290 38 19 19 26 13 13 Agriculture Heritage and Learning Center 2.70 135 18 9 9 12 6 6 Net Project Trips 16,917 913 466 448 1,584 777 807 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-40 A volume growth increment for all travel modes was developed for 2035 conditions using the San Luis Obispo City Travel Demand Model (TDM) projections. Vehicular trips were determined using the City’s TDM and assumed buildout of the City’s General Plan without the development of the project site. Vehicle Miles Traveled. As reported by the City of San Luis Obispo’s Travel Demand Model, the forecasted 2035 Daily VMT is approximately 12 million miles for the region and approximately 3.6 million miles for the sphere of influence. The average VMT per household is 80 for the region and 54 for the sphere of influence. Project-generated VMT has been forecasted by adding the proposed land uses to the City’s travel demand model. The City’s travel demand model forecast for the project is 60,000 daily VMT, an increase of approximately 1.7% within the City sphere of influence and 0.5% within the County region. The VMT generated per household for the project is forecasted at 32 daily miles traveled per household. The proposed project VMT per household is lower than the City’s average per household VMT due to the varied characteristics of the proposed land uses. Additionally, the VMT per household for the project was estimated by converting the non- residential trips into equivalent dwelling units and adding them to the residential dwelling units. Table 4.12-18 presents these calculations. Table 4.12-18 Project Trip Generation Description Daily VMT VMT per HH1 San Luis Obispo County (Region) 12,000,000 80 San Luis Obispo City (Sphere of Influence) 3,600,000 54 San Luis Ranch Project 60,000 32 1. Reported vehicle miles traveled per household. Fair-Share of Improvement Cost Calculations. Fair-share calculations were identified in the traffic study for all intersections projected to operate at unacceptable LOS under no project conditions, and experience an increase in delay with the addition of project traffic. Table 4.12-19 lists each of the study intersections warranting improvements, the corresponding improvements that the proposed project would be required to pay a fair-share of improvement cost towards, and the proposed project’s equitable share of these improvements. The proposed project’s equitable share is calculated using the method for calculating equitable mitigation measures outlined in the Caltrans Guide for the Preparation of Traffic Impact Studies (State of California, DOT, December 2002), which is shown below: P = T / (TB – TE) where P = The equitable share for the project’s traffic impact T = The vehicle trips generated by the project during the peak hour of adjacent roadway facility in vehicles per hour (vph) TB = The forecasted traffic volume on an impacted roadway facility at the time of general plan build-out (e.g. 20 year model or the furthest model date feasible), vph TE = The traffic volume existing on the impacted roadway facility plus other approved projects that will generate traffic that has yet to be constructed/opened, vph. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-41 Table 4.12-19 Cumulative (Year 2035) Full Build Fair Share Calculations Inter- section / Segment Mode Peak Hour Fair Share Percentage Project Added Traffic Existing Volume 2035 Full Build + Project Volume INT 1 Madonna Road/Los Osos Valley Road Auto (Queue only) PM 10% 62 3263 3875 INT 2 Madonna Road/Oceanaire Drive Auto (Queue only) PM 56% 74 2100 2233 INT 3 Madonna Road/Dalidio Drive Auto PM 30% 209 2479 3178 INT 4 Madonna Road/El Mercado Auto (Queue only) PM n/a 188 2674 2519 INT 5 Madonna Road/US 101 SB Ramps/Madonna Inn Auto (Queue only) PM n/a 187 3183 2747 INT 6 Madonna Road/US 101 NB Ramps Auto (Queue only) PM n/a 166 2643 2392 INT 7 Madonna Road/Higuera Street Auto (Queue only) PM 22% 154 2937 3629 INT 8 Higuera Street/South Street Auto (Queue only) PM 18% 141 2476 3277 INT 9 Los Osos Valley Road/Froom Ranch Way Auto PM 12% 127 3401 4458 INT 10 Los Osos Valley Road/Auto Park Way Auto (Queue only) PM 11% 69 2774 3407 INT 12 Los Osos Valley Road/US 101 SB Ramps Auto (Queue only) PM 8% 50 3324 3918 INT 14 S. Higuera Street/Los Osos Valley Road Auto (Queue only) PM 4% 33 2377 3258 INT 15 S. Higuera Street/Suburban Drive Auto (Queue only) PM 2% 10 2413 2976 INT 16 S. Higuera Street/Tank Farm Road Auto AM 5% 32 1994 2701 INT 18 S. Higuera Street/Prado Road Auto (Queue only) PM 10% 258 1980 4640 INT 19 S. Higuera Street/Margarita Avenue Auto (Queue only) PM 6% 38 1450 2130 INT 20 Prado Road/US 101 NB Ramps Auto (Queue only) PM 15% 337 661 2864 SEG 2 EB Madonna Road - Oceanaire Drive to Dalidio Drive Auto AM 18% 42 1108 1341 SEG 19 WB Froom Ranch Way - Dicks Sporting Goods to Los Osos Valley Road Ped AM 23% 56 72 319 SEG 23 NB* Prado Road - US 101 SB Ramps to Froom Ranch Way Auto AM 20% 154 15 797 SEG 24 SB* Dalidio Drive - SC Project Driveway to Froom Ranch Way Auto AM 19% 163 16 880 SEG 23 NB* Prado Road - US 101 SB Ramps to Froom Ranch Way Auto PM 15% 204 71 1454 SEG 24 SB* Dalidio Drive - SC Project Driveway to Froom Ranch Way Auto PM 24% 183 36 799 SEG 24 NB* Dalidio Drive - Froom Ranch Way to SC Project Driveway Auto PM 20% 237 71 1234 *Existing directional volumes based on Intersection #26 (Dalidio Dr/Promenade) volumes San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-42 The fair-share calculations were calculated using Cumulative (Year 2035) Full Build project volumes. (Note that the percent fair-share calculated using the above formula is reported to the nearest whole number and the calculations are based on the highest fair share percentage from the two peak hour scenarios.) b. Project Impacts and Mitigation Measures – Existing & Near-Term. Existing & Near Term Scenario Background. The project traffic study (refer to Appendix KL) evaluated the project under existing and near-term conditions. Existing + project conditions reflect the potential impacts and required mitigation measures if the project were fully constructed all at once. However, the project proposes phased construction of the site’s land use and associated infrastructure. Therefore, the project has also been evaluated under near-term conditions which represent conditions that also include other planned development and new infrastructure in the City. The combination of existing and near-term analysis provides the basis for establishing phasing triggers for proposed infrastructure improvements and mitigation measures. Mitigation measures identified for existing and near-term impacts are typically required to be physically constructed prior to their trigger rather than solely based on payment of fees. The project’s proposed development and infrastructure phasing are described in Section 2.0, Project Description. Near Term Scenario Improvements. Under the near-term conditions scenario, the City’s approved, pending and potential land development projects are assumed to be in place. In addition, the following General Plan Circulation Element roadway improvements are assumed to be in place: • Los Osos Valley Road/U.S. 101 interchange improvements and widening to four lanes between Calle Joaquin and S. Higuera Street, with Class II bicycle lanes • Prado Road widening to four lanes between U.S. 101 and S. Higuera Street, with Class II bicycle lanes and an additional westbound left turn lane at S. Higuera Street • Horizon Lane extension between Avila Ranch and Suburban Drive • Southbound left turn pocket at Prado Road/S. Higuera Street extended 250 feet, with the addition of pedestrian countdown heads with audible/tactile pushbuttons • Buckley Road extension to S. Higuera Street Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Threshold 2: Would the project conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Threshold 6: Would the project conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-43 Impact T-1 Under Existing and Near-Term Plus Project conditions nine study area intersections would operate at unacceptable automobile, bicycle, or pedestrian LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at seven of these intersections to an acceptable level. However, impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections would be Class I, significant and unavoidable. MMLOS was calculated for the area intersections based on the 2010 HCM methodology. Table 4.12-20 through Table 4.12-25 provide a summary of the multimodal AM and PM peak hour intersection LOS under existing and near-term plus project conditions. Intersections where the AM or PM LOS exceed the minimum LOS standard are bolded. Figure 4.12-5 shows Project- Only peak hour traffic volumes, which is the project trip assignment for the Existing Plus Project and the Near Term Plus Project conditions. Figure 4.12-6 shows the Year 2025 Near- Term peak hour traffic volumes assuming the roadway improvements under the Near Term conditions are in place, and with buildout of the Near-Term approved and pending projects. Figure 4.12-7 shows the Near-Term Plus Project peak hour traffic volumes. As shown in Table 4.12-20 through Table 4.12-25, five intersections (Madonna Road & Dalidio Drive/Prado Road, Madonna Road & U.S. 101 southbound ramps, Higuera Street & South Street, Los Osos Valley Road & Auto Park Way, and Dalidio Drive/SC Project Driveway) would exceed the City’s minimum automobile LOS threshold under the Existing Plus Project Scenario, and seven intersections (Madonna Road & Los Osos Valley Road, Madonna Road & Dalidio Drive/Prado Road, Madonna Road & U.S. 101 southbound ramps, Higuera Street & South Street, Los Osos Valley Road & Auto Park Way, S. Higuera Street & Tank Farm Road, and Dalidio Drive/SC Project Driveway) would exceed the City’s minimum automobile LOS threshold under the Near-Term Plus Project Scenario. Two intersections (S. Higuera Street & Suburban Drive and Los Osos Valley Road & Froom Ranch Way) would exceed the City’s minimum pedestrian or bicycle LOS threshold under the Existing Plus Project Scenario, and three intersections (Madonna Road & Los Osos Valley Road, S. Higuera Street & Suburban Drive, and Los Osos Valley Road & Froom Ranch Way) would exceed the City’s minimum pedestrian or bicycle LOS threshold under the Near-Term Plus Project Scenario. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The Specific Plan also emphasizes bikeways and pedestrian connections, all of which contribute to reduced trips and VMT. However, under Existing Plus Project and Near-Term Plus Project conditions, the following nine study area intersections would operate at unacceptable automobile, bicycle, and pedestrian LOS based on adopted MMLOS standards during AM and PM peak hours. • Madonna Road & Los Osos Valley Road • Madonna Road & Dalidio Drive/Prado Road • Madonna Road & U.S. 101 Southbound Ramps • Los Osos Valley Road & Froom Ranch Way • Los Osos Valley Road & Auto Park Way • Higuera Street & South Street • S. Higuera Street & Tank Farm Road • S. Higuera Street & Suburban Drive • Dalidio Drive/SC Project Driveway Source: Omni-Means, Ltd., 2016Existing Plus Project Peak HourTraffic VolumesFigure 4.12-5City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-44 Source: Omni-Means, Ltd., 2016Year 2025 Near Term Peak Hour Traffic VolumesFigure 4.12-6City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-45 Source: Omni-Means, Ltd., 2016Year 2025 Near Term Plus Project PeakHour Traffic VolumesFigure 4.12-7City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-46 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-47 Table 4.12-20 Existing Plus Project Conditions Intersection Level of Service: Automobile Analysis # Intersection Control Type 1,2 Target LOS AM Peak Hour PM Peak Hour v/c3 Delay LOS v/c3 Delay LOS 1 Madonna Road/Los Osos Valley Road Signal D 27.3 C 49.4 D 2 Madonna Road/Oceanaire Drive Signal D 19.7 B 15.5 B 3 Madonna Road/Dalidio Drive Signal D 34.7 C 4.65 172.9 F 4 Madonna Road/El Mercado Signal D 7.3 A 21.8 C 5 Madonna Road/US 101 SB Ramps/Madonna Inn Signal C 1.36 48.8 D 23.7 C 6 Madonna Road/US 101 NB Ramps Signal C 18.1 B 21.1 C 7 Madonna Road/Higuera Street Signal D 19.7 B 24.3 C 8 Higuera Street/South Street Signal D 21.8 C 1.47 82.8 F 9 Los Osos Valley Road/Froom Ranch Way Signal D 22.3 C 40.7 D 10 Los Osos Valley Road/Auto Park Way TWSC D 15.5 C 0.39 36.6 E 11 Los Osos Valley Road/Calle Joaquin Signal D 4.7 A 5.8 A 12 Los Osos Valley Road/US 101 SB Ramps Signal C 13.2 B 22.7 C 13 Los Osos Valley Road/US 101 NB Ramps Signal C 29.1 C 22.5 C 14 S. Higuera Street/Los Osos Valley Road Signal D 16.3 B 20.0 B 15 S. Higuera Street/Suburban Drive Signal D 6.4 A 11.2 B 16 S. Higuera Street/Tank Farm Road Signal D 36.7 D 21.2 C 17 S. Higuera Street/Granada Drive Signal D 8.4 A 10.5 B 18 S. Higuera Street/Prado Road Signal D 16.7 B 21.1 C 19 S. Higuera Street/Margarita Avenue Signal D 8.3 A 12.3 B 20 Prado Road/US 101 NB Ramps AWSC C 9.0 A 13.9 B 21 Froom Ranch Road/Dalidio Drive AWSC D 8.5 A 8.4 A 22 Madonna Road/Project Driveway TWSC D 14.4 B 13.9 B 23 Froom Ranch Road/Project Driveway #2 TWSC D 9.3 A 9.7 A 25 Dalidio Drive/SC Project Driveway TWSC D 12.8 B 0.85 49.3 E 27 Froom Ranch Road/Hotel Project Driveway TWSC D 9.2 A 9.3 A 28 Froom Ranch Road/Project Driveway #3 TWSC D 8.8 A 9.0 A Notes: 1. AWSC = All Way Stop Control; TWSC = Two Way Stop Control; RNDBT = Roundabout 2. LOS = Delay based on worst minor street approach for TWSC intersections, average of all approaches for AWSC, Signal, RNDBT 3. Volume to Capacity Ratio (v/c) is for worst movement delay, for unacceptable LOS only 4. Warrant is based on California MUTCD Warrant 3 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-48 Table 4.12-21 Near-Term Plus Project Conditions Intersection Level of Service: Automobile Analysis # Intersection Control Type 1,2 Target LOS AM Peak Hour PM Peak Hour v/c3 Delay LOS v/c3 Delay LOS 1 Madonna Road/Los Osos Valley Road Signal D 28.0 C 1.05 56.3 E 2 Madonna Road/Oceanaire Drive Signal D 21.3 C 19.0 B 3 Madonna Road/Dalidio Drive Signal D 47.0 D 2.82 156.5 F 4 Madonna Road/El Mercado Signal D 7.9 A 20.0 B 5 Madonna Road/US 101 SB Ramps/Madonna Inn Signal C 1.26 44.0 D 24.9 C 6 Madonna Road/US 101 NB Ramps Signal C 19.4 B 22.2 C 7 Madonna Road/Higuera Street Signal D 33.3 C 43.6 D 8 Higuera Street/South Street Signal D 27.7 C 1.43 81.0 F 9 Los Osos Valley Road/Froom Ranch Way Signal D 22.7 C 42.8 D 10 Los Osos Valley Road/Auto Park Way TWSC D 20.2 C 0.57 59.7 F 11 Los Osos Valley Road/Calle Joaquin Signal D 9.2 A 6.6 A 12 Los Osos Valley Road/US 101 SB Ramps Signal C 21.0 C 20.0 B 13 Los Osos Valley Road/US 101 NB Ramps Signal C 16.4 B 21.5 C 14 S. Higuera Street/Los Osos Valley Road Signal D 23.1 C 32.2 C 15 S. Higuera Street/Suburban Drive Signal D 8.6 A 20.2 C 16 S. Higuera Street/Tank Farm Road Signal D 1.32 73.2 E 25.3 C 17 S. Higuera Street/Granada Drive Signal D 8.3 A 11.5 B 18 S. Higuera Street/Prado Road Signal D 20.7 C 28.0 C 19 S. Higuera Street/Margarita Avenue Signal D 15.1 B 14.8 B 20 Prado Road/US 101 NB Ramps AWSC C 10.8 B 15.6 C 21 Froom Ranch Road/Dalidio Drive AWSC D 8.4 A 8.4 A 22 Madonna Road/Project Driveway TWSC D 12.7 B 13.6 B 23 Froom Ranch Road/Project Driveway #2 TWSC D 9.3 A 9.7 A 25 Dalidio Drive/SC Project Driveway TWSC D 12.9 B 0.86 52.3 F 26 Dalidio Drive/Promenade TWSC D A A 27 Froom Ranch Road/Hotel Project Driveway TWSC D 9.2 A 9.3 A 28 Froom Ranch Road/Project Driveway #3 TWSC D 8.7 A 9.0 A Notes: 1. AWSC = All Way Stop Control; TWSC = Two Way Stop Control; RNDBT = Roundabout 2. LOS = Delay based on worst minor street approach for TWSC intersections, average of all approaches for AWSC, Signal, RNDBT 3. Volume to Capacity Ratio (v/c) is for worst movement delay, for unacceptable LOS only 4. Warrant is based on California MUTCD Warrant 3 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-49 Table 4.12-22 Existing Plus Project Conditions Intersection Level of Service: Pedestrian Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswalk Score LOS Ped. Crosswalk Score LOS 1 Madonna Road/Los Osos Valley Road EB C 2.11 B 2.11 B WB C 2.93 C 3.20 C NB C 3.06 C 3.39 C SB C 3.19 C 3.20 C 2 Madonna Road/Oceanaire Drive EB C 2.70 B 2.90 C WB C 3.11 C 3.34 C NB C 2.03 B 2.08 B SB C 1.83 A 1.88 A 3 Madonna Road/Dalidio Drive EB C 3.04 C 3.41 C WB C 3.07 C 3.17 C NB C 2.49 B 2.85 C SB C 1.98 A 2.03 B 4 Madonna Road/El Mercado EB C n/a - n/a - WB C 3.14 C 3.24 C NB C 2.27 B 2.78 C SB C 1.74 A 1.74 A 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB C 3.08 C 3.25 C WB C n/a - n/a - NB C 2.75 B 2.67 B SB C 2.18 B 2.19 B 6 Madonna Road/US 101 NB Ramps EB C n/a - n/a - WB C 2.92 C 2.90 C NB C 1.97 A 2.05 B SB C n/a - n/a - 7 Madonna Road/Higuera Street EB C 3.04 C 2.96 C WB C 1.99 A 2.01 B NB C 2.71 B 2.80 C SB C n/a - n/a - 8 Higuera Street/South Street EB C 2.01 B 2.01 B WB C 2.75 B 2.81 C NB C n/a - n/a - SB C 2.50 B 2.57 B 9 Los Osos Valley Road/Froom Ranch Way EB C 2.49 B 2.76 C WB C 2.44 B 2.65 B NB C n/a - n/a - SB C 3.07 C 3.26 C 10 Los Osos Valley Road/Auto Park Way EB C n/a - n/a - WB C - - NB C - - SB C - - 11 Los Osos Valley Road/Calle Joaquin EB C 2.48 B 2.28 B WB C 2.10 B 2.19 B NB C 2.99 C 3.21 C SB C 2.91 C 3.21 C 12 Los Osos Valley Road/US 101 SB Ramps EB C 1.91 A 2.34 B WB C 2.22 B 2.11 B NB C n/a - n/a - SB C n/a - n/a - 13 Los Osos Valley Road/US 101 NB Ramps EB C 2.45 B 2.58 B NB C n/a - n/a - SB C n/a - n/a - 14 S. Higuera Street/Los Osos Valley Road EB C 2.66 B 2.74 B NB C 2.25 B 2.30 B SB C n/a - n/a - San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-50 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswalk Score LOS Ped. Crosswalk Score LOS 15 S. Higuera Street/Suburban Drive WB C 2.15 B 2.29 B NB C 2.99 C 3.61 D SB C 2.73 B 2.85 C 16 S. Higuera Street/Tank Farm Road EB C 2.01 B 2.01 B WB C 2.92 C 3.04 C NB C 3.34 C 3.28 C SB C 2.65 B 2.78 C 17 S. Higuera Street/Granada Drive WB C 2.05 B 2.13 B NB C n/a - n/a - SB C 2.60 B 2.76 C 18 S. Higuera Street/Prado Road EB C 2.35 B 2.41 B WB C 2.28 B 2.32 B NB C 2.71 B 2.95 C SB C 2.76 C 2.78 C 19 S. Higuera Street/Margarita Avenue EB C 2.23 B 2.07 B WB C 2.13 B 2.19 B NB C 2.75 B 2.80 C SB C 2.73 B 2.80 C 20 Prado Road/US 101 NB Ramps EB C n/a - n/a - WB C - - NB C - - SB C - - Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. 2. HCM 2010 Methodologies for the pedestrian mode at two-way stop-controlled intersections is limited to the uncontrolled crossing. No methodology exists for evaluating pedestrian performance for the stop controlled approach (cross-street). However, it is reasoned that this type of control has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-51 Table 4.12-23 Near-Term Plus Project Conditions Intersection Level of Service: Pedestrian Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswal k Score LOS Ped. Crosswal k Score LOS 1 Madonna Road/Los Osos Valley Road EB C 2.11 B 2.13 B WB C 2.90 C 3.32 C NB C 3.12 C 3.52 D SB C 3.21 C 3.31 C 2 Madonna Road/Oceanaire Drive EB C 2.71 B 2.99 C WB C 3.11 C 3.39 C NB C 2.01 B 2.01 B SB C 1.82 A 1.85 A 3 Madonna Road/Dalidio Drive EB C 3.03 C 3.44 C WB C 3.05 C 3.17 C NB C 2.46 B 2.60 B SB C 2.96 C 2.00 A 4 Madonna Road/El Mercado EB C n/a - n/a - WB C 3.11 C 3.19 C NB C 2.25 B 2.51 B SB C 1.71 A 1.72 A 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB C 3.08 C 3.23 C WB C n/a - n/a - NB C 2.80 C 2.74 B SB C 2.18 B 2.19 B 6 Madonna Road/US 101 NB Ramps EB C n/a - n/a - WB C 2.96 C 2.92 C NB C 2.02 B 2.02 B SB C n/a - n/a - 7 Madonna Road/Higuera Street EB C 2.96 C 3.22 C WB C 2.01 B 2.02 B NB C 2.80 C 2.93 C SB C n/a - n/a - 8 Higuera Street/South Street EB C 2.03 B 2.06 B WB C 2.80 C 2.83 C NB C n/a - n/a - SB C 2.52 B 2.62 B 9 Los Osos Valley Road/Froom Ranch Way EB C 2.51 B 2.80 C WB C 2.45 B 2.65 B NB C n/a - n/a - SB C 3.11 C 3.34 C 10 Los Osos Valley Road/Auto Park Way EB C n/a - n/a - WB C - - NB C - - SB C - - 11 Los Osos Valley Road/Calle Joaquin EB C 2.47 B 2.28 B WB C 2.08 B 2.18 B NB C 3.03 C 3.31 C SB C 3.03 C 3.29 C San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-52 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswal k Score LOS Ped. Crosswal k Score LOS 12 Los Osos Valley Road/US 101 SB Ramps EB C 1.86 A 2.24 B WB C 2.15 B 2.08 B NB C n/a - n/a - SB C n/a - n/a - 13 Los Osos Valley Road/US 101 NB Ramps EB C 2.35 B 2.37 B NB C 2.78 C 2.79 C SB C n/a - n/a - 14 S. Higuera Street/Los Osos Valley Road EB C 3.00 C 2.92 C NB C 2.38 B 2.41 B SB C n/a - n/a - 15 S. Higuera Street/Suburban Drive WB C 2.33 B 2.57 B NB C 3.25 C 3.98 D SB C 2.88 C 3.02 C 16 S. Higuera Street/Tank Farm Road EB C 2.03 B 2.02 B WB C 3.01 C 3.20 C NB C 3.46 C 3.39 C SB C 2.77 C 2.91 C 17 S. Higuera Street/Granada Drive WB C 2.11 B 2.18 B NB C n/a - n/a - SB C 2.71 B 2.89 C 18 S. Higuera Street/Prado Road EB C 2.66 B 2.72 B WB C 2.40 B 2.49 B NB C 2.90 C 3.19 C SB C 2.86 C 2.93 C 19 S. Higuera Street/Margarita Avenue EB C 2.28 B 2.09 B WB C 2.14 B 2.22 B NB C 2.85 C 2.94 C SB C 2.78 C 2.93 C 20 Prado Road/US 101 NB Ramps EB C n/a - n/a - WB C - - NB C - - SB C - - Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. 2. HCM 2010 Methodologies for the pedestrian mode at two-way stop-controlled intersections is limited to the uncontrolled crossing. No methodology exists for evaluating pedestrian performance for the stop controlled approach (cross-street). However, it is reasoned that this type of control has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-53 Table 4.12-24 Existing Plus Project Conditions Intersection Level of Service: Bicycle Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Bicycle LOS Score LOS Bicycle LOS Score LOS 1 Madonna Road/Los Osos Valley Road EB D 3.27 C 3.15 C WB D 3.39 C 4.05 D NB D 1.65 A 2.02 B SB D 2.63 B 2.52 B 2 Madonna Road/Oceanaire Drive EB D 2.75 B 2.96 C WB D 1.08 A 1.64 A NB D 2.76 C 2.73 B SB D 2.23 B 2.15 B 3 Madonna Road/Dalidio Drive EB D 2.26 B 2.15 B WB D 1.59 A 1.85 A NB D 1.76 A 2.41 B SB D 1.34 A 1.42 A 4 Madonna Road/El Mercado EB D 1.91 A 1.81 A WB D 1.79 A 2.08 B NB D 3.19 C 3.93 D SB D 3.03 C 3.03 C 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB D 2.11 B 2.20 B WB D 1.69 A 1.89 A NB D n/a - n/a - SB D 2.91 C 2.96 C 6 Madonna Road/US 101 NB Ramps EB D 2.85 C 2.52 B WB D 1.69 A 1.95 A NB D n/a - n/a - 7 Madonna Road/Higuera Street EB D 3.46 C 3.02 C WB D 2.43 B 2.59 B NB D 1.70 A 2.07 B SB D 2.22 B 2.59 B 8 Higuera Street/South Street EB D 2.70 B 2.73 B WB D 2.67 B 3.05 C NB D 3.01 C 3.29 C SB D 1.57 A 1.71 A 9 Los Osos Valley Road/Froom Ranch Way EB D 3.40 C 4.42 E WB D 1.95 A 2.66 B NB D 1.75 A 2.15 B SB D 1.72 A 1.74 A 10 Los Osos Valley Road/Auto Park Way EB D n/a - n/a - WB D - - NB D - - SB D - - 11 Los Osos Valley Road/Calle Joaquin EB D 2.99 C 2.98 C WB D 3.08 C 3.23 C NB D 1.48 A 1.91 A SB D 0.41 A 0.74 A San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-54 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Bicycle LOS Score LOS Bicycle LOS Score LOS 12 Los Osos Valley Road/US 101 SB Ramps WB D n/a - n/a - NB D 2.71 B 3.07 C SB D 2.39 B 3.25 C 13 Los Osos Valley Road/US 101 NB Ramps EB D n/a - n/a - NB D 1.84 A 2.61 B SB D 3.49 C 3.47 C 14 S. Higuera Street/Los Osos Valley Road EB D 2.00 A 1.75 A NB D 1.87 A 1.63 A SB D 2.40 B 3.69 D 15 S. Higuera Street/Suburban Drive WB D 0.89 A 1.56 A NB D 2.21 B 1.95 A SB D 1.71 A 2.14 B 16 S. Higuera Street/Tank Farm Road EB D 2.70 B 2.66 B WB D 2.46 B 3.00 C NB D 2.07 B 2.01 B SB D 1.66 A 1.91 A 17 S. Higuera Street/Granada Drive WB D 2.63 B 2.99 C NB D 1.70 A 1.88 A SB D 1.83 A 1.98 A 18 S. Higuera Street/Prado Road EB D 2.37 B 2.22 B WB D 2.70 B 2.90 C NB D 1.64 A 1.99 A SB D 1.88 A 1.91 A 19 S. Higuera Street/Margarita Avenue EB D 2.47 B 2.55 B WB D 2.70 B 2.68 B NB D 1.58 A 1.79 A SB D 2.13 B 2.06 B 20 Prado Road/US 101 NB Ramps EB D n/a - n/a - WB D - - NB D - - SB D - - Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. 2. No methodology exists for evaluating bicycle performance at two-way stop-controlled intersections. However, it is reasoned that this type of control has negligible influence on bicycle service along the segment for stop control on the cross-street. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-55 Table 4.12-25 Near-Term Plus Project Conditions Intersection Level of Service: Bicycle Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Bicycle LOS Score LOS Bicycle LOS Score LOS 1 Madonna Road/Los Osos Valley Road EB D 3.29 C 3.18 C WB D 3.39 C 4.30 E NB D 1.70 A 2.18 B SB D 2.72 B 2.71 B 2 Madonna Road/Oceanaire Drive EB D 2.74 B 2.96 C WB D 1.17 A 1.79 A NB D 2.76 C 2.74 B SB D 2.23 B 2.23 B 3 Madonna Road/Dalidio Drive EB D 2.23 B 2.13 B WB D 1.66 A 1.94 A NB D 2.19 B 2.84 C SB D 1.77 A 1.84 A 4 Madonna Road/El Mercado EB D 1.89 A 1.84 A WB D 1.85 A 2.16 B NB D 3.23 C 3.81 D SB D 3.03 C 3.03 C 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB D 2.07 B 2.12 B WB D 1.74 A 1.96 A NB D n/a - n/a - SB D 2.91 C 2.96 C 6 Madonna Road/US 101 NB Ramps EB D 2.78 C 2.45 B WB D 1.79 A 2.09 B NB D n/a - n/a - 7 Madonna Road/Higuera Street EB D 3.56 D 3.01 C WB D 2.46 B 2.60 B NB D 1.81 A 2.29 B SB D 2.37 B 2.59 B 8 Higuera Street/South Street EB D 2.72 B 2.78 C WB D 2.83 C 2.94 C NB D 3.09 C 3.35 C SB D 1.62 A 1.80 A 9 Los Osos Valley Road/Froom Ranch Way EB D 3.44 C 4.45 E WB D 2.00 A 2.67 B NB D 1.86 A 2.31 B SB D 1.78 A 1.87 A 10 Los Osos Valley Road/Auto Park Way EB D n/a - n/a - WB D - - NB D - - SB D - - 11 Los Osos Valley Road/Calle Joaquin EB D 2.99 C 2.99 C WB D 3.08 C 3.27 C NB D 1.57 A 2.06 B SB D 0.53 A 0.84 A San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-56 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Bicycle LOS Score LOS Bicycle LOS Score LOS 12 Los Osos Valley Road/US 101 SB Ramps WB D n/a - n/a - NB D 2.89 C 3.23 C SB D 1.69 A 2.02 B 13 Los Osos Valley Road/US 101 NB Ramps EB D n/a - n/a - NB D 1.95 A 2.37 B SB D 2.88 C 2.76 C 14 S. Higuera Street/Los Osos Valley Road EB D 2.19 B 1.86 A NB D 2.20 B 1.74 A SB D 2.63 B 4.24 D 15 S. Higuera Street/Suburban Drive WB D 1.09 A 1.82 A NB D 2.43 B 2.10 B SB D 1.82 A 2.41 B 16 S. Higuera Street/Tank Farm Road EB D 2.72 B 2.67 B WB D 2.65 B 3.33 C NB D 2.39 B 2.21 B SB D 1.78 A 2.10 B 17 S. Higuera Street/Granada Drive WB D 2.63 B 3.07 C NB D 1.90 A 2.05 B SB D 1.99 A 2.17 B 18 S. Higuera Street/Prado Road EB D 2.48 B 2.30 B WB D 2.93 C 3.31 C NB D 1.76 A 2.19 B SB D 2.05 B 2.07 B 19 S. Higuera Street/Margarita Avenue EB D 2.51 B 2.58 B WB D 2.74 B 2.72 B NB D 1.68 A 2.00 A SB D 2.25 B 2.22 B 20 Prado Road/US 101 NB Ramps EB D n/a - n/a - WB D - - NB D - - SB D - - Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. 2. No methodology exists for evaluating bicycle performance at two-way stop-controlled intersections. However, it is reasoned that this type of control has negligible influence on bicycle service along the segment for stop control on the cross-street. Therefore, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and LOS standards, and transportation impacts would be potentially significant at these intersections. Mitigation Measures. The following mitigation measures identify improvements at study area facilities that are required to reduce potentially significant project-specific impacts to study area intersections under Existing and Near-Term Plus Project conditions. Each mitigation measure refers to one of the required Transportation Improvement Measures identified in Table San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-57 4.12-1 at the beginning of this section. The required timing of each required Transportation Improvement Measure is also described in Table 4.12-1. The project’s equitable share of these improvements will be calculated using the method for calculating equitable mitigation measures outlined in the Caltrans Guide for the Preparation of Traffic Impact Studies (Caltrans, December 2002). Costs above and beyond the project’s equitable share can be addressed through such options as fee credits, reimbursement agreements, or development agreements, based on City requirements. T-1(a) Intersection #1: Madonna Road & Los Osos Valley Road. • City optimize signal timing to accommodate increased project volumes (ongoing) T-1(b) Intersection #3: Madonna Road & Dalidio Drive/Prado Road. • Extend existing westbound left turn lane on Madonna Road to Dalidio Drive/Prado Road to 310’ (Phase 1) • Install 2nd westbound 310’ left turn lane on Madonna Road to Dalidio Drive/Prado Road (Phase 1) • Install eastbound 250’ right turn pocket on Madonna Road to Dalidio Drive/Prado Road (Phase 1) • Install 2nd northbound left shared with through-lane on Prado Road/Dalidio Drive to Madonna Road (Phase 1) • Prohibit westbound U-turns on Madonna Road (Phase 1) • Provide split phase operations & optimize signal timing (Phase 1) T-1(c) Intersection #5: Madonna Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass-Only, Phase 2) T-1(d) Intersection #8: Higuera Street & South Street. • Optimize Signal Timing T-1(e) Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Install dedicated 230’ right turn lane on Los Osos Valley Road northbound Froom Ranch Way approach to northbound Froom Ranch Way Los Osos Valley Road (with Froom Ranch Way bridge construction) • Extend right turn lane on Los Osos Valley Road southbound Froom Ranch Way approach to southbound Froom Ranch Way Los Osos Valley Road to 110’ (with Froom Ranch Way bridge construction) • Install 2nd southbound left turn lane on Froom Ranch Way approach to eastbound Los Osos Valley Road (with Froom Ranch Way bridge construction) T-1(f) Intersection #10: Los Osos Valley Road & Auto Park Way. • Signalization (Phase 1) • Construct Prado Road Overpass (Overpass Only, Phase 2) T-1(g) Intersection #16: S. Higuera Street & Tank Farm Road. • Construct Prado Road Overpass (Overpass Only Phase 2) San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-58 • Extend northbound right turn pocket to 230’ and channelize movement (Phase 1) T-1(h) Intersection #21: Prado Road/Dalidio Drive & Froom Ranch Way. • Install multilane roundabout control (when connection is constructed) T-1(i) Intersection #25: Prado Road/Dalidio Drive & SC Project Driveway. • Install multilane roundabout control or restricted access (when connection is constructed) Plan Requirements and Timing. Fair share traffic impact fees shall be paid upon acceptance by the City of final design plans and in accordance with the timing of improvements. Implementation of improvements shall occur by time of occupancy of the specified phase of the project. Implementation of the Prado Road/U.S. 101 overpass and associated improvements shall occur prior to occupancy of Phase 2 development. Monitoring. City Public Works staff shall confirm payment of applicable fees. City Public Works staff shall also ensure implementation of these improvements following approval of the final design plans for the Specific Plan Area. Significance After Mitigation. Implementation of the identified mitigation measures would improve LOS at most impacted intersections to acceptable levels, and impacts on these facilities would be less than significant after mitigation. However, potential right-of-way constraints at Madonna Road & Dalidio Drive (Intersection #3) and Los Osos Valley Road & Froom Ranch Way (Intersection #9) may reduce the feasibility of mitigation at these intersections. Accordingly, some of the potential impacts associated with multimodal level of service standards identified for Existing and Near-Term Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with multimodal level of service standards at these intersections under Existing and Near-Term Plus Project conditions would remain significant and unavoidable. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass (Mitigation Measures T-1[c], T-1[e], and T-1[f]) are discussed in Section 4.12.54(d). Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Impact T-2 Under Existing and Near-Term Plus Project conditions the volume of traffic at 19 study area intersections would exceed lane capacities. Mitigation would reduce impacts at 18 of these intersections to an acceptable level. However, impacts at the Los Osos Valley Road & Froom Ranch Way intersection would be Class I, significant and unavoidable. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-59 Table 4.12-26 and Table 4.12-27 provide a summary of the queueing under existing and near- term plus project conditions. Intersections where vehicle queues would exceed lane capacity during peak hours are bolded. Table 4.12-26 Existing Plus Project Conditions: Intersection Queuing Analysis Intersection Movement No. Lanes Total Storage (ft)1 95th Percentile Queue/Lane (ft) ID Location AM Peak Hour PM Peak Hour 1 Madonna Road/Los Osos Valley Road Northbound Right 1 175 92 250 2 Madonna Road/Oceanaire Drive Westbound Right 1 100 46 165 3 Madonna Road/Dalidio Drive Eastbound Left 1 115 65 125 Westbound Left 1 275 224 376 5 Madonna Road/US 101 SB Ramps/Madonna Inn Eastbound Left 1 100 72 117 6 Madonna Road/US 101 NB Ramps Northbound Left 1 185 141 192 7 Madonna Road/Higuera Street Eastbound Right 1 150 325 265 Northbound Left 1 160 121 252 8 Higuera Street/South Street Westbound Left 2 240 214 389 Northbound Left 1 60 88 72 Northbound Right 1 60 149 150 Southbound Left 1 70 130 107 9 Los Osos Valley Road/Froom Ranch Way Westbound Right 1 50 56 87 11 Los Osos Valley Road/Calle Joaquin Northbound Through 2 235 139 135 Southbound Left 1 180 217 209 Southbound Through/Right 2 - 945 722 12 Los Osos Valley Road/US 101 SB Ramps Westbound Left 1 150 242 227 Northbound Left 1 80 101 117 Southbound Through 1 240 308 279 Southbound Right 1 240 220 262 13 Los Osos Valley Road/US 101 NB Ramps Eastbound Left/Right 1 200 228 246 Northbound Left 1 140 109 200 Southbound Through 1 865 1119 811 Southbound Right 1 60 204 221 14 S. Higuera Street/Los Osos Valley Road Eastbound Right 1 90 165 136 16 S. Higuera Street/Tank Farm Road Northbound Right 1 100 194 123 Southbound Left 1 165 89 215 18 S. Higuera Street/Prado Road Northbound Left 1 100 132 170 Northbound Through/Right 2 - 134 379 Southbound Left 1 60 117 108 Southbound Through/Right 2 - 230 237 19 S. Higuera Street/Margarita Avenue Southbound Left 1 60 51 75 Notes: 1. Bolded entries indicate queues exceed available storage 2. Storage Length of " - " represents a lane which exceeds 900 feet, usually a through lane. 3. For Movements with more than one lane, the maximum of the 95th percentile queue is reported. 4. * Represents storage lengths for one lane; second lane is a left or right trap lane. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-60 Table 4.12-27 Near-Term Plus Project Conditions: Intersection Queuing Analysis Intersection Movement No. Lanes Total Storage (ft)1 95th Percentile Queue/Lane (ft) ID Location AM Peak Hour PM Peak Hour 1 Madonna Road/Los Osos Valley Road Northbound Right 1 175 100 261 2 Madonna Road/Oceanaire Drive Westbound Right 1 100 58 140 3 Madonna Road/Dalidio Drive Westbound Left 1 275 194 336 Westbound Through/Right 3 570 108 610 4 Madonna Road/El Mercado Westbound Left 2 260 50 535 5 Madonna Road/US 101 SB Ramps/Madonna Inn Eastbound Left 1 100 83 111 Westbound Left 1 260 170 539 6 Madonna Road/US 101 NB Ramps Northbound Left 1 185 156 258 7 Madonna Road/Higuera Street Eastbound Right 1 150 248 314 Northbound Left 1 160 185 376 Southbound Left/Through 2 250 159 430 Southbound Right 2 340 164 592 8 Higuera Street/South Street Eastbound Right 1 60 41 85 Westbound Left 2 240 342 1024 Northbound Left 1 60 102 44 Northbound Right 1 60 104 127 Southbound Left 1 70 116 122 9 Los Osos Valley Road/Froom Ranch Way Westbound Right 1 50 60 119 12 Los Osos Valley Road/US 101 SB Ramps Westbound Left/Through 1 180 259 216 Southbound Through 1 240 293 273 Southbound Right 1 125 188 177 13 Los Osos Valley Road/US 101 NB Ramps Southbound Right 1 130 244 248 14 S. Higuera Street/Los Osos Valley Road Eastbound Right 1 90 189 156 15 S. Higuera Street/Suburban Drive Southbound Left 1 200 149 259 16 S. Higuera Street/Tank Farm Road Northbound Right 1 100 186 170 Southbound Left 1 165 211 243 17 S. Higuera Street/Granada Drive Southbound Left 1 80 85 65 18 S. Higuera Street/Prado Road Westbound Left 1 105 110 131 Westbound Right 1 100 49 137 Northbound Left 1 100 158 186 19 S. Higuera Street/Margarita Avenue Northbound Left 1 60 78 70 Southbound Left 1 60 83 99 24 Prado Road/US 101 SB Ramps Westbound Left/Through 1 250 158 424 Notes: 1. Bolded entries indicate queues exceed available storage 2. Storage Length of " - " represents a lane which exceeds 900 feet, usually a through lane. 3. For Movements with more than one lane, the maximum of the 95th percentile queue is reported. 4. * Represents storage lengths for one lane; second lane is a left or right trap lane. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-61 Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The Specific Plan also emphasizes bikeways and pedestrian connections, all of which contribute to reduced trips and VMT. However, as shown in Table 4.12-26 and Table 4.12-27, under Existing Plus Project and Near-Term Plus Project conditions, the volume of traffic at 19 study area intersections would exceed lane capacities during peak hours. Therefore, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and vehicle queuing standards, and transportation impacts would be potentially significant at these intersections. Mitigation Measures. The following mitigation measures identify improvements at study area facilities that are required to reduce potentially significant project-specific impacts at study area intersections under Existing and Near-Term Plus Project Conditions. Each mitigation measure refers to one of the required Transportation Improvement Measures identified in Table 4.12-1 at the beginning of this section. The required timing of each required Transportation Improvement Measure is also described in Table 4.12-1. The project’s equitable share of these improvements will be calculated using the method for calculating equitable mitigation measures outlined in the Caltrans Guide for the Preparation of Traffic Impact Studies (Caltrans, December 2002). Costs above and beyond the project’s equitable share can be addressed through such options as fee credits, reimbursement agreements, or development agreements, based on City requirements. T-2(a) Intersection #1: Madonna Road & Los Osos Valley Road. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(b) Intersection #2: Madonna Road & Oceanaire Drive. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(c) Intersection #5: Madonna Road & U.S. 101 S.B Ramps. • Extend northbound Madonna Road left turn lane to 150’ (Phase 1) T-2(d) Intersection #6: Madonna Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(e) Intersection #7: Madonna Road & Higuera Street. • Construct Prado Road Overpass (Overpass Plus U.S. 101 northbound ramps, Phase 2) T-2(f) Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Install dedicated 230’ right turn lane on Los Osos Valley Road approach to northbound Froom Ranch Way (with Froom Ranch Way bridge construction) • Extend right turn lane on Los Osos Valley Road approach to southbound Froom Ranch Way to 110’ (with Froom Ranch Way Bridge construction) • Install 2nd southbound left turn lane on Froom Ranch Way approach to eastbound Los Osos Valley Road (with Froom Ranch Way bridge construction) San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-62 T-2(g) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps. • Extend off-ramp left turn pocket to 320’ (Phase 1) T-2(h) Intersection #13: Los Osos Valley Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass Only, Phase 2) T-2(i) Intersection #14: Los Osos Valley Road & Higuera Street. • Extend eastbound right turn lane to 180’ (Phase 1) T-2(j) Intersection #18: Prado Road & Higuera Street. • Install 2nd U.S. 101 northbound left turn lane (Phase 1) • Extend westbound right turn pocket to 400’ (Phase 1) Plan Requirements and Timing. Fair share traffic impact fees shall be paid upon acceptance by the City of final design plans and in accordance with the timing of improvements. Implementation of improvements shall occur by time of occupancy of the specified phase of the project. Implementation of the Prado Road/U.S. 101 overpass and associated improvements shall occur prior to occupancy of Phase 2 development. Monitoring. City Public Works staff shall confirm payment of applicable fees. City Public Works staff shall also ensure implementation of these improvements following approval of the final design plans for the Specific Plan Area. Significance After Mitigation. Implementation of the identified mitigation measures would reduce impacts to lane capacities at most impacted intersections to acceptable levels, and impacts on these facilities would be less than significant after mitigation. However, potential right-of-way constraints at Los Osos Valley Road & Froom Ranch Way (Intersection #9) may reduce the feasibility of mitigation at this intersection. Accordingly, some of the potential impacts associated with lane capacities identified for Existing and Near-Term Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts to lane capacities at this intersection under Existing and Near-Term Plus Project conditions would remain significant and unavoidable. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass (Mitigation Measures T-2[a], T-2[b], T-2[d], T-1[e], and T-2[h]) are discussed in Section 4.12.54(d). San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-63 Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Threshold 2: Would the project conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Threshold 6: Would the project conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? Impact T-3 Under Existing and Near-Term conditions four study area segment groups would operate at unacceptable automobile, bicycle, pedestrian, and transit LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at three of these segment groups to an acceptable level. However, impacts at Higuera Street roadway segments would be Class I, significant and unavoidable. MMLOS was calculated for the area intersections based on the 2010 HCM methodology. Table 4.12-28 through Table 4.12-35 provide a summary of the multimodal AM and PM peak hour segment LOS under existing and near-term plus project conditions. Intersections where the AM or PM LOS exceed the minimum LOS standard are bolded. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-64 Table 4.12-28 Existing Plus Project Conditions Segment Level of Service: Automobile Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS 1 Madonna Rd Oceanaire Dr LOVR WB D 20.4 40.1 51% C 10.7 40.1 27% F Madonna Rd LOVR Oceanaire Dr EB D 28.1 40.0 70% B 29.8 40.0 74% B 2 Madonna Rd Dalidio Oceanaire Dr WB D 22.7 40.8 56% C 24.6 40.7 60% C Madonna Rd Oceanaire Dr Dalidio EB D 15.5 40.7 38% E 13.4 40.8 33% E 3 Madonna Rd El Mercado Dalidio Dr WB D 17.1 34.8 49% D 16.0 34.8 46% D Madonna Rd Dalidio Dr El Mercado EB D 20.9 34.7 60% C 12.7 34.6 37% E 4 Madonna Rd US 101 SB Ramps El Mercado WB D 31.9 37.9 84% B 20.7 37.3 55% C Madonna Rd El Mercado US 101 SB Ramps EB D 22.3 37.8 59% C 17.5 37.7 46% D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 34.2 37.8 90% A 33.8 37.8 89% A Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 32.5 37.8 86% A 33.3 37.8 88% A 6 Madonna Rd Higuera St US 101 NB Ramps WB D 9.4 37.2 25% F 11.0 37.2 30% F Madonna Rd US 101 NB Ramps Higuera St EB D 16.5 37.2 44% D 12.9 37.2 35% E 7 S. Higuera St Madonna Rd Margarita Ave SB D 37.1 44.5 83% B 35.3 44.5 79% B S. Higuera St Margarita Ave Madonna Rd NB D 35.6 44.8 79% B 35.7 44.8 80% B 8 S. Higuera St Margarita Ave Prado Rd SB D 18.6 38.9 48% D 16.5 38.9 42% D S. Higuera St Prado Rd Margarita Ave NB D 25.4 38.9 65% C 21.0 38.9 54% C 9 S. Higuera St Prado Rd Granada Dr SB D 33.8 41.8 81% B 30.6 41.8 73% B S. Higuera St Granada Dr Prado Rd NB D 25.5 41.9 61% C 28.1 41.9 67% B 10 S. Higuera St Granada Dr Tank Farm Road SB D 42.6 41.6 102% A 27.3 42.6 64% C S. Higuera St Tank Farm Road Granada Dr NB D 30.5 41.6 73% B 28.7 42.6 67% B 11 S. Higuera St Tank Farm Road Suburban Drive SB D 27.3 42.4 65% C 24.8 41.2 60% C S. Higuera St Suburban Drive Tank Farm Road NB D 20.2 42.5 47% D 18.9 41.3 46% D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D 20.6 42.1 49% D 15.8 39.1 40% D S. Higuera St Los Osos Valley Road Suburban Drive NB D 24.7 42.0 59% C 21.5 39.0 55% C 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D 23.3 41.9 56% C 17.2 41.8 41% D Los Osos Valley Froom Ranch Way Madonna Rd NB D 20.3 41.8 49% D 16.7 41.8 40% E 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D 34.6 43.0 81% B 30.9 43.0 72% B Los Osos Valley Calle Joaquin Froom Ranch Way NB D 29.2 43.2 68% B 22.4 43.2 52% C 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 13.2 32.1 41% D 8.3 32.1 26% F Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 16.9 31.1 54% C 15.2 31.1 49% D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 11.0 37.7 29% F 12.9 37.7 34% E Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 32.6 37.4 87% A 31.8 37.4 85% B 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D 29.1 39.2 74% B 25.5 39.2 65% C Los Osos Valley US 101 NB Ramps S. Higuera St EB D 21.3 39.4 54% C 18.1 39.4 46% D 18 Prado Rd S. Higuera St US 101 NB Ramps WB D 28.0 38.3 73% B 24.7 38.3 64% C San Luis Ranch Project EIR Section 4.12 Transportation 4.12-65 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Prado Rd US 101 NB Ramps S. Higuera St EB D 23.7 38.3 62% C 21.2 38.3 55% C 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D 17.7 38.0 46% D 12.8 38.0 34% E Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D 34.7 37.4 93% A 34.5 37.4 92% A 20 Dalidio Dr Madonna Rd Froom Ranch Way SB D 29.3 39.3 74% B 29.5 39.3 75% B Dalidio Dr Froom Ranch Way Madonna Rd NB D 6.3 39.4 16% F 1.6 39.4 4% F 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 40.0 40.6 98% A 39.9 40.6 98% A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D 34.1 40.8 84% B 33.9 40.8 83% B San Luis Ranch Project EIR Section 4.12 Transportation 4.12-66 Table 4.12-29 Near-Term Plus Project Conditions Segment Level of Service: Automobile Analysis AM Peak PM PEAK ID Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS 1 Madonna Rd Oceanaire Dr LOVR WB D 21.1 40.1 53% C 10.1 40.1 25% F Madonna Rd LOVR Oceanaire Dr EB D 27.0 40.0 68% B 27.5 40.0 69% B 2 Madonna Rd Dalidio Oceanaire Dr WB D 23.6 40.8 58% C 23.8 40.7 59% C Madonna Rd Oceanaire Dr Dalidio EB D 11.5 40.7 28% F 16.3 40.8 40% E 3 Madonna Rd El Mercado Dalidio Dr WB D 14.9 34.1 44% D 14.2 34.8 41% D Madonna Rd Dalidio Dr El Mercado EB D 26.0 38.2 68% B 11.5 34.6 33% E 4 Madonna Rd US 101 SB Ramps El Mercado WB D 30.8 37.9 81% B 22.0 37.3 59% C Madonna Rd El Mercado US 101 SB Ramps EB D 20.7 37.8 55% C 17.5 37.7 46% D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 28.4 37.8 75% B 22.3 37.8 59% C Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 32.8 37.8 87% A 33.3 37.8 88% A 6 Madonna Rd Higuera St US 101 NB Ramps WB D 10.6 37.2 29% F 14.1 37.2 38% E Madonna Rd US 101 NB Ramps Higuera St EB D 12.6 37.2 34% E 8.0 37.2 21% F 7 S. Higuera St Madonna Rd Margarita Ave SB D 32.6 44.5 73% B 33.1 44.5 74% B S. Higuera St Margarita Ave Madonna Rd NB D 33.0 44.8 74% B 33.5 44.8 75% B 8 S. Higuera St Margarita Ave Prado Rd SB D 16.2 38.9 42% D 11.5 38.9 30% F S. Higuera St Prado Rd Margarita Ave NB D 21.2 38.9 55% C 19.1 38.9 49% D 9 S. Higuera St Prado Rd Granada Dr SB D 33.5 41.8 80% B 29.3 41.8 70% B S. Higuera St Granada Dr Prado Rd NB D 21.6 41.9 52% C 23.9 41.9 57% C 10 S. Higuera St Granada Dr Tank Farm Road SB D 42.3 41.6 102% A 24.7 42.6 58% C S. Higuera St Tank Farm Road Granada Dr NB D 29.7 41.6 71% B 26.8 42.6 63% C 11 S. Higuera St Tank Farm Road Suburban Drive SB D 27.1 42.4 64% C 21.5 41.2 52% C S. Higuera St Suburban Drive Tank Farm Road NB D 17.8 42.5 42% D 16.2 41.3 39% E 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D 20.4 42.1 49% D 13.4 39.1 34% E S. Higuera St Los Osos Valley Road Suburban Drive NB D 23.7 42.0 56% C 18.9 39.0 49% D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D 22.7 41.9 54% C 15.2 41.8 36% E Los Osos Valley Froom Ranch Way Madonna Rd NB D 20.5 41.8 49% D 14.8 41.8 36% E 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D 29.0 43.0 67% B 30.3 43.0 71% B Los Osos Valley Calle Joaquin Froom Ranch Way NB D 28.1 43.2 65% C 21.4 43.2 50% D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 6.2 32.1 19% F 13.1 32.1 41% D Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 16.2 31.1 52% C 13.9 31.1 45% D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 24.7 37.7 66% C 21.0 37.7 56% C Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 20.2 37.4 54% C 32.2 37.4 86% A 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D 25.0 39.4 63% C 27.8 39.4 70% B Los Osos Valley US 101 NB Ramps S. Higuera St EB D 16.9 39.4 43% D 15.6 39.4 39% E San Luis Ranch Project EIR Section 4.12 Transportation 4.12-67 AM Peak PM PEAK ID Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free- Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS 18 Prado Rd S. Higuera St US 101 NB Ramps WB D 27.4 39.1 70% B 23.9 39.1 61% C Prado Rd US 101 NB Ramps S. Higuera St EB D 23.4 39.0 60% C 21.7 39.0 56% C 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D 17.8 38.0 47% D 13.0 37.4 35% E Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D 34.7 37.4 93% A 34.9 37.9 92% A 20 Dalidio Dr Madonna Rd Froom Ranch Way SB D 29.3 39.3 74% B 29.5 39.3 75% B Dalidio Dr Froom Ranch Way Madonna Rd NB D 11.2 37.8 30% F 1.1 37.8 3% F 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 40.0 40.6 98% A 39.9 40.6 98% A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D 34.1 40.8 84% B 33.9 40.8 83% B San Luis Ranch Project EIR Section 4.12 Transportation 4.12-68 Table 4.12-30 Existing Plus Project Conditions Segment Level of Service: Pedestrian Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB C 2648 3.54 D 3.82 D Madonna Rd LOVR Oceanaire Dr EB C 17482 3.74 D 3.88 D 2 Madonna Rd Dalidio Oceanaire Dr WB C 12000 3.60 D 3.92 D Madonna Rd Oceanaire Dr Dalidio EB C 5833 3.87 D 3.97 D 3 Madonna Rd El Mercado Dalidio Dr WB C 37450 3.59 D 3.92 D Madonna Rd Dalidio Dr El Mercado EB C 52920 3.70 D 3.86 D 4 Madonna Rd US 101 SB Ramps El Mercado WB C 26250 3.66 D 3.84 D Madonna Rd El Mercado US 101 SB Ramps EB C 27915 3.93 D 4.17 D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB C No Peds 3.73 D 3.90 F Madonna Rd US 101 SB Ramps US 101 NB Ramps EB C No Peds 4.15 D 4.10 D 6 Madonna Rd Higuera St US 101 NB Ramps WB C 25200 3.65 D 3.81 D Madonna Rd US 101 NB Ramps Higuera St EB C 19838 3.90 D 3.79 D 7 S. Higuera St Madonna Rd Margarita Ave SB C 23247 3.82 D 3.80 D S. Higuera St Margarita Ave Madonna Rd NB C 5398 3.61 D 3.80 D 8 S. Higuera St Margarita Ave Prado Rd SB C 40979 3.61 D 3.63 D S. Higuera St Prado Rd Margarita Ave NB C 21700 3.45 C 3.58 D 9 S. Higuera St Prado Rd Granada Dr SB C 9292 3.55 D 3.66 D S. Higuera St Granada Dr Prado Rd NB C 8400 3.16 C 3.38 C 10 S. Higuera St Granada Dr Tank Farm Road SB C 46305 3.54 D 3.69 D S. Higuera St Tank Farm Road Granada Dr NB C 49140 3.11 C 3.26 C 11 S. Higuera St Tank Farm Road Suburban Drive SB C 12600 3.57 D 3.80 D S. Higuera St Suburban Drive Tank Farm Road NB C 31500 3.48 C 3.44 C 12 S. Higuera St Suburban Drive Los Osos Valley Road SB C 39312 3.57 D 3.85 D S. Higuera St Los Osos Valley Road Suburban Drive NB C 43533 3.85 D 3.89 D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB C 3853 3.81 D 3.88 D Los Osos Valley Froom Ranch Way Madonna Rd NB C 0 3.70 F 4.05 F 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB C 27300 3.77 D 4.01 D Los Osos Valley Calle Joaquin Froom Ranch Way NB C 22050 3.68 D 4.00 D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB C No Peds 3.61 D 3.70 D Los Osos Valley US 101 SB Ramps Calle Joaquin NB C 63000 3.63 D 3.93 D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB C No Peds 4.17 D 4.22 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB C 53928 3.63 D 3.13 C 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB C 1680 3.68 D 4.09 D Los Osos Valley US 101 NB Ramps S. Higuera St EB C 39393 3.78 D 3.69 D 18 Prado Rd S. Higuera St US 101 NB Ramps WB C 25200 2.90 C 2.90 C Prado Rd US 101 NB Ramps S. Higuera St EB C 3019 3.42 C 3.32 C San Luis Ranch Project EIR Section 4.12 Transportation 4.12-69 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score LOS Segment Score LOS 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB C 4500 3.03 C 3.28 C Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB C 7350 1.76 A 1.79 A 20 Dalidio Dr Madonna Rd Froom Ranch Way SB C 3500 1.64 A 1.61 A Dalidio Dr Froom Ranch Way Madonna Rd NB C 21000 3.14 C 3.40 C 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB C 2520 1.55 A 1.57 A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB C No Peds 1.64 A 1.64 A Notes: 1. Sidewalk is present along frontage roads for segments #1 - Madonna Road and #13 - Los Osos Valley Road, and is not accounted for in this analysis. 2. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is reasoned that it has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-70 Table 4.12-31 Near-Term Plus Project Conditions Segment Level of Service: Pedestrian Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB C 2648 3.52 D 3.86 D Madonna Rd LOVR Oceanaire Dr EB C 17482 3.91 D 4.08 D 2 Madonna Rd Dalidio Oceanaire Dr WB C 12000 3.64 D 4.00 D Madonna Rd Oceanaire Dr Dalidio EB C 5833 3.84 D 3.97 D 3 Madonna Rd El Mercado Dalidio Dr WB C 37450 3.61 D 3.99 D Madonna Rd Dalidio Dr El Mercado EB C 52920 3.74 D 3.89 D 4 Madonna Rd US 101 SB Ramps El Mercado WB C 26250 3.68 D 3.87 D Madonna Rd El Mercado US 101 SB Ramps EB C 27915 3.77 D 3.87 D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB C No Peds 3.76 D 3.95 F Madonna Rd US 101 SB Ramps US 101 NB Ramps EB C No Peds 4.12 D 4.07 D 6 Madonna Rd Higuera St US 101 NB Ramps WB C 25200 3.70 D 3.88 D Madonna Rd US 101 NB Ramps Higuera St EB C 19838 3.90 D 3.86 D 7 S. Higuera St Madonna Rd Margarita Ave SB C 23247 3.87 D 3.90 D S. Higuera St Margarita Ave Madonna Rd NB C 5398 3.68 D 3.92 D 8 S. Higuera St Margarita Ave Prado Rd SB C 40979 3.71 D 3.74 D S. Higuera St Prado Rd Margarita Ave NB C 21700 3.55 D 3.71 D 9 S. Higuera St Prado Rd Granada Dr SB C 9292 3.65 D 3.77 D S. Higuera St Granada Dr Prado Rd NB C 8400 3.26 C 3.53 D 10 S. Higuera St Granada Dr Tank Farm Road SB C 46305 3.62 D 3.80 D S. Higuera St Tank Farm Road Granada Dr NB C 49140 3.24 C 3.36 C 11 S. Higuera St Tank Farm Road Suburban Drive SB C 12600 3.66 D 3.96 D S. Higuera St Suburban Drive Tank Farm Road NB C 31500 3.66 D 3.56 D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB C 39312 3.64 D 4.02 D S. Higuera St Los Osos Valley Road Suburban Drive NB C 43533 4.00 D 4.06 D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB C 3853 3.86 D 3.99 D Los Osos Valley Froom Ranch Way Madonna Rd NB C 0 3.75 F 4.19 F 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB C 27300 3.87 D 4.08 D Los Osos Valley Calle Joaquin Froom Ranch Way NB C 22050 3.75 D 4.11 D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB C 44100 3.71 D 3.72 D Los Osos Valley US 101 SB Ramps Calle Joaquin NB C 63000 3.68 D 4.03 D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB C No Peds 3.94 D 3.92 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB C 53928 3.83 D 3.29 C 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB C 1680 3.62 D 3.81 D Los Osos Valley US 101 NB Ramps S. Higuera St EB C 39393 3.94 D 3.79 D 18 Prado Rd S. Higuera St US 101 NB Ramps WB C 25200 2.76 C 2.85 C Prado Rd US 101 NB Ramps S. Higuera St EB C 3019 3.44 C 3.42 C San Luis Ranch Project EIR Section 4.12 Transportation 4.12-71 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score LOS Segment Score LOS 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB C 4846 3.06 C 3.26 C Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB C No Peds 1.79 A 1.75 A 20 Dalidio Dr Madonna Rd Froom Ranch Way SB C 3500 1.64 A 1.60 A Dalidio Dr Froom Ranch Way Madonna Rd NB C 21000 3.10 C 3.30 C 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB C 8400 1.55 A 1.57 A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB C No Peds 1.64 A 1.64 A Notes: 1. Sidewalk is present along frontage roads for segments #1 - Madonna Road and #13 - Los Osos Valley Road, and is not accounted for in this analysis. 2. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is reasoned that it has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-72 Table 4.12-32 Existing Plus Project Conditions Segment Level of Service: Bicycle Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D 3.61 D 3.97 D Madonna Rd LOVR Oceanaire Dr EB D 3.73 D 3.80 D 2 Madonna Rd Dalidio Oceanaire Dr WB D 3.13 C 3.22 C Madonna Rd Oceanaire Dr Dalidio EB D 3.58 D 3.44 C 3 Madonna Rd El Mercado Dalidio Dr WB D 3.30 C 3.22 C Madonna Rd Dalidio Dr El Mercado EB D 3.51 D 3.41 C 4 Madonna Rd US 101 SB Ramps El Mercado WB D 3.97 D 4.36 E Madonna Rd El Mercado US 101 SB Ramps EB D 3.64 D 3.66 D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 3.32 C 3.37 C Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 3.42 C 3.36 C 6 Madonna Rd Higuera St US 101 NB Ramps WB D 3.50 D 3.56 D Madonna Rd US 101 NB Ramps Higuera St EB D 3.73 D 3.59 D 7 S. Higuera St Madonna Rd Margarita Ave SB D 3.89 D 3.80 D S. Higuera St Margarita Ave Madonna Rd NB D 4.06 D 4.15 D 8 S. Higuera St Margarita Ave Prado Rd SB D 3.64 D 3.64 D S. Higuera St Prado Rd Margarita Ave NB D 3.87 D 3.87 D 9 S. Higuera St Prado Rd Granada Dr SB D 3.84 D 3.87 D S. Higuera St Granada Dr Prado Rd NB D 3.42 C 3.50 C 10 S. Higuera St Granada Dr Tank Farm Road SB D 4.10 D 4.16 D S. Higuera St Tank Farm Road Granada Dr NB D 3.48 C 3.52 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D 3.33 C 3.41 C S. Higuera St Suburban Drive Tank Farm Road NB D 3.40 C 3.39 C 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D 3.24 C 3.60 D S. Higuera St Los Osos Valley Road Suburban Drive NB D 3.90 D 3.86 D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D 3.71 D 3.71 D Los Osos Valley Froom Ranch Way Madonna Rd NB D 3.38 C 3.46 C 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D 3.56 D 3.59 D Los Osos Valley Calle Joaquin Froom Ranch Way NB D 3.81 D 3.89 D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 3.34 C 3.54 D Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 3.54 D 3.60 D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 3.73 D 3.73 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 3.40 C 3.51 D 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D 3.29 C 3.43 C Los Osos Valley US 101 NB Ramps S. Higuera St EB D 3.39 C 3.35 C 18 Prado Rd S. Higuera St US 101 NB Ramps WB D 3.44 C 3.44 C Prado Rd US 101 NB Ramps S. Higuera St EB D 3.94 D 3.68 D 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D 3.08 C 3.55 D Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D 3.24 C 2.49 B San Luis Ranch Project EIR Section 4.12 Transportation 4.12-73 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS 20 Dalidio Dr Madonna Rd Froom Ranch Way SB D 3.35 C 3.05 C Dalidio Dr Froom Ranch Way Madonna Rd NB D 3.32 C 3.43 C 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 2.50 B 2.92 C Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D 3.42 C 3.41 C Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is incorporated into the methodology for evaluating bicycle segment performance. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-74 Table 4.12-33 Near-Term Plus Project Conditions Segment Level of Service: Bicycle Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D 3.61 D 4.17 D Madonna Rd LOVR Oceanaire Dr EB D 3.73 D 3.79 D 2 Madonna Rd Dalidio Oceanaire Dr WB D 3.15 C 3.24 C Madonna Rd Oceanaire Dr Dalidio EB D 3.57 D 3.44 C 3 Madonna Rd El Mercado Dalidio Dr WB D 3.31 C 3.24 C Madonna Rd Dalidio Dr El Mercado EB D 3.40 C 3.42 C 4 Madonna Rd US 101 SB Ramps El Mercado WB D 3.98 D 4.38 E Madonna Rd El Mercado US 101 SB Ramps EB D 3.64 D 3.65 D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 3.33 C 3.38 C Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 3.40 C 3.35 C 6 Madonna Rd Higuera St US 101 NB Ramps WB D 3.52 D 3.58 D Madonna Rd US 101 NB Ramps Higuera St EB D 3.77 D 3.59 D 7 S. Higuera St Madonna Rd Margarita Ave SB D 3.91 D 3.90 D S. Higuera St Margarita Ave Madonna Rd NB D 4.09 D 4.19 D 8 S. Higuera St Margarita Ave Prado Rd SB D 3.67 D 3.67 D S. Higuera St Prado Rd Margarita Ave NB D 3.87 D 3.97 D 9 S. Higuera St Prado Rd Granada Dr SB D 3.88 D 3.91 D S. Higuera St Granada Dr Prado Rd NB D 3.45 C 3.53 D 10 S. Higuera St Granada Dr Tank Farm Road SB D 4.13 D 4.19 D S. Higuera St Tank Farm Road Granada Dr NB D 3.52 D 3.55 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D 3.35 C 3.46 C S. Higuera St Suburban Drive Tank Farm Road NB D 3.46 C 3.43 C 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D 3.28 C 3.94 D S. Higuera St Los Osos Valley Road Suburban Drive NB D 3.94 D 3.88 D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D 3.72 D 3.74 D Los Osos Valley Froom Ranch Way Madonna Rd NB D 3.39 C 3.49 C 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D 3.57 D 3.60 D Los Osos Valley Calle Joaquin Froom Ranch Way NB D 3.83 D 3.91 D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 3.29 C 3.35 C Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 3.55 D 3.62 D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 3.72 D 3.69 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 3.71 D 3.82 D 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D 3.27 C 3.36 C Los Osos Valley US 101 NB Ramps S. Higuera St EB D 3.35 C 3.37 C 18 Prado Rd S. Higuera St US 101 NB Ramps WB D 3.14 C 3.18 C Prado Rd US 101 NB Ramps S. Higuera St EB D 3.91 D 3.86 D 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D 3.42 C 3.52 D Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D 3.33 C 3.52 D 20 Dalidio Dr Madonna Rd Froom Ranch Way SB D 3.35 C 2.93 C San Luis Ranch Project EIR Section 4.12 Transportation 4.12-75 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS Dalidio Dr Froom Ranch Way Madonna Rd NB D 3.35 C 3.42 C 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 2.49 B 2.92 C Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D 3.42 C 3.40 C Note: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is incorporated into the methodology for evaluating bicycle segment performance. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-76 Table 4.12-34 Existing Plus Project Conditions Segment Level of Service: Transit Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D Route 4 4.19 D 4.32 E Madonna Rd LOVR Oceanaire Dr EB D Route 5 4.31 E 4.01 D 2 Madonna Rd Dalidio Oceanaire Dr WB D Route 4 4.46 E 4.57 E Madonna Rd Oceanaire Dr Dalidio EB D Route 5 4.74 E 4.54 E 3 Madonna Rd El Mercado Dalidio Dr WB D Route 4 4.35 E 4.51 E Madonna Rd Dalidio Dr El Mercado EB D Route 5 Not Analyzed N/A Not Analyzed N/A 4 Madonna Rd US 101 SB Ramps El Mercado WB D Route 4 4.36 E 4.59 E Madonna Rd El Mercado US 101 SB Ramps EB D Route 5 4.67 E 4.48 E 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D Route 4 3.97 D 4.09 D Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D Route 5 4.35 E 4.04 D 6 Madonna Rd Higuera St US 101 NB Ramps WB D Route 4 4.33 E 4.44 E Madonna Rd US 101 NB Ramps Higuera St EB D Route 5 4.55 E 4.29 E 7 S. Higuera St Madonna Rd Margarita Ave SB D Route 2 Not Analyzed N/A 3.51 D S. Higuera St Margarita Ave Madonna Rd NB D Route 2 3.65 D 3.69 D 8 S. Higuera St Margarita Ave Prado Rd SB D Route 2 Not Analyzed N/A 4.19 D S. Higuera St Prado Rd Margarita Ave NB D Route 2 4.15 D 4.23 D 9 S. Higuera St Prado Rd Granada Dr SB D Route 2 4.35 E 4.28 E S. Higuera St Granada Dr Prado Rd NB D Route 2 3.76 D 3.83 D 10 S. Higuera St Granada Dr Tank Farm Road SB D Route 2 3.75 D 3.83 D S. Higuera St Tank Farm Road Granada Dr NB D Route 2 3.51 D 3.58 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Suburban Drive Tank Farm Road NB D Route 2 3.97 D 3.96 D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Los Osos Valley Road Suburban Drive NB D - Not Analyzed N/A Not Analyzed N/A 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 4 4.50 E 4.53 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 4 4.22 D 4.38 E 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.61 E 4.38 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 5 4.36 E 4.21 D 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D Route 4 4.22 D 4.35 E Los Osos Valley Calle Joaquin Froom Ranch Way NB D Route 4 4.24 D 4.49 E 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D Route 5 4.37 E 4.16 D Los Osos Valley Calle Joaquin Froom Ranch Way NB D Route 5 4.37 E 4.33 E San Luis Ranch Project EIR Section 4.12 Transportation 4.12-77 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 SB Ramps Calle Joaquin NB D Not Analyzed N/A Not Analyzed N/A 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D Not Analyzed N/A Not Analyzed N/A 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps S. Higuera St EB D Not Analyzed N/A Not Analyzed N/A 18 Prado Rd S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Prado Rd US 101 NB Ramps S. Higuera St EB D Route 2 3.83 D Not Analyzed N/A 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D Not Analyzed N/A Not Analyzed N/A 20 Dalidio Dr Madonna Rd Froom Ranch Way SB D Route 4 4.05 D 4.08 D Dalidio Dr Froom Ranch Way Madonna Rd NB D Route 5 4.20 D 4.03 D 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D Not Analyzed N/A Not Analyzed N/A Notes: Segment 20 transit is southbound for routes 4 and 5 Route 2 Serves the Prado Day Center stop during the AM peak hour, and the DMV/Margarita stop during the PM Peak Hour San Luis Ranch Project EIR Section 4.12 Transportation 4.12-78 Table 4.12-35 Near-Term Plus Project Conditions Segment Level of Service: Transit Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D Route 4 4.17 D 4.30 E Madonna Rd LOVR Oceanaire Dr EB D Route 5 4.36 E 4.04 D 2 Madonna Rd Dalidio Oceanaire Dr WB D Route 4 4.47 E 4.63 E Madonna Rd Oceanaire Dr Dalidio EB D Route 5 4.70 E 4.44 E 3 Madonna Rd El Mercado Dalidio Dr WB D Route 4 4.34 E 4.49 E Madonna Rd Dalidio Dr El Mercado EB D Route 5 Not Analyzed N/A Not Analyzed N/A 4 Madonna Rd US 101 SB Ramps El Mercado WB D Route 4 4.35 E 4.55 E Madonna Rd El Mercado US 101 SB Ramps EB D Route 5 4.60 E 4.35 E 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D Route 4 4.09 D 4.38 E Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D Route 5 4.25 D 3.83 D 6 Madonna Rd Higuera St US 101 NB Ramps WB D Route 4 4.31 E 4.43 E Madonna Rd US 101 NB Ramps Higuera St EB D Route 5 4.51 E 4.16 D 7 S. Higuera St Madonna Rd Margarita Ave SB D Route 2 Not Analyzed N/A 3.58 D S. Higuera St Margarita Ave Madonna Rd NB D Route 2 3.72 D 3.75 D 8 S. Higuera St Margarita Ave Prado Rd SB D Route 2 Not Analyzed N/A 4.21 D S. Higuera St Prado Rd Margarita Ave NB D Route 2 4.22 D 4.34 E 9 S. Higuera St Prado Rd Granada Dr SB D Route 2 4.41 E 4.33 E S. Higuera St Granada Dr Prado Rd NB D Route 2 3.77 D 3.95 D 10 S. Higuera St Granada Dr Tank Farm Road SB D Route 2 3.82 D 3.91 D S. Higuera St Tank Farm Road Granada Dr NB D Route 2 3.54 D 3.64 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Suburban Drive Tank Farm Road NB D Route 2 4.03 D 4.00 D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Los Osos Valley Road Suburban Drive NB D - Not Analyzed N/A Not Analyzed N/A 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 4 4.53 E 4.56 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 4 4.25 E 4.43 E 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.61 E 4.38 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 5 4.36 E 4.21 D 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D Route 4 4.34 E 4.37 E Los Osos Valley Calle Joaquin Froom Ranch Way NB D Route 4 4.27 E 4.54 E 14 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.45 E 4.14 D Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 5 4.38 E 4.35 E 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 SB Ramps Calle Joaquin NB D Not Analyzed N/A Not Analyzed N/A 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D Not Analyzed N/A Not Analyzed N/A 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps S. Higuera St EB D Not Analyzed N/A Not Analyzed N/A San Luis Ranch Project EIR Section 4.12 Transportation 4.12-79 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 18 Prado Rd S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Prado Rd US 101 NB Ramps S. Higuera St EB D Route 2 3.83 D Not Analyzed N/A 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D Not Analyzed N/A Not Analyzed N/A 20 Dalidio Dr Madonna Rd Froom Ranch Way SB D Route 4 3.64 D 3.65 D Dalidio Dr Madonna Rd Froom Ranch Way SB D Route 5 4.20 D 3.96 D 21 Dalidio Dr Froom Ranch Way Madonna Rd NB D 0.00 Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 0.00 Not Analyzed N/A Not Analyzed N/A Notes: 1. Segment 20 transit is southbound for routes 4 and 5 2. Route 2 Serves the Prado Day Center stop during the AM peak hour, and the DMV/Margarita stop during the PM Peak Hour San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-80 Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The Specific Plan also emphasizes bikeways and pedestrian connections, all of which contribute to reduced trips and VMT. However, as shown in Table 4.12-28 through Table 4.12-35, under Existing Plus Project and Near-Term Plus Project conditions, four study area segment groups (Madonna Road, S. Higuera Street, Los Osos Valley Road, and Dalidio Drive/Prado Road) would operate at unacceptable automobile, bicycle, pedestrian, and transit LOS based on adopted multimodal LOS standards during AM and PM peak hours. Therefore, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and vehicle queuing standards, and transportation impacts would be potentially significant at these roadway segments. Mitigation Measures. The following mitigation measures identify improvements at study area facilities that are required to reduce potentially significant project-specific impacts to study area roadway segments under Existing and Near-Term Plus Project conditions. Each mitigation measure refers to one of the required Transportation Improvement Measures identified in Table 4.12-1 at the beginning of this section. The required timing of each required Transportation Improvement Measure is also described in Table 4.12-1. The project’s equitable share of these improvements will be calculated using the method for calculating equitable mitigation measures outlined in the Caltrans Guide for the Preparation of Traffic Impact Studies (Caltrans, December 2002). Costs above and beyond the project’s equitable share can be addressed through such options as fee credits, reimbursement agreements, or development agreements, based on City requirements. T-3(a) Segments #1 - #6: Madonna Road (Los Osos Valley Road to Higuera Street) • Construct Prado Road Overpass (Overpass Only, Phase 2) • Fund assessment of decreasing transit headways to 25 min • Construct parallel Class I multiuse paths or bike boulevard (Phase 1) T-3(b) Segments #7 - #8: Higuera Street (Madonna Road to Prado Road) • Construct Prado Road Overpass (Overpass and U.S. 101 northbound ramps, Phase 2) • Construct parallel Class I multiuse paths or bike boulevard (Phase 1) T-3(c) Segments #13 - #17: Los Osos Valley Road (Madonna Road to Higuera Street) • Construct Prado Road Overpass (Overpass and U.S. 101 northbound ramps, Phase 2) • Construct parallel Class I multiuse paths or bike boulevard (Phase 3) T-3(d) Segments #18 - #20: Dalidio Drive/Prado Road (Froom Ranch Way to Higuera Street) • Construct parallel Class I multiuse paths or bike boulevard (when Prado Road is constructed/improved) Plan Requirements and Timing. Fair share traffic impact fees shall be paid upon acceptance by the City of final design plans and in accordance with San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-81 the timing of improvements. Implementation of most improvements shall occur by time of occupancy of the final phase of the project. Implementation of the Prado Road/U.S. 101 overpass and associated improvements shall occur prior to occupancy of Phase 2 development. Monitoring. City Public Works staff shall confirm payment of applicable fees. City Public Works staff shall also ensure implementation of these improvements following approval of the final design plans for the Specific Plan Area. Significance After Mitigation. Implementation of the identified mitigation measures would improve LOS at all impacted study area roadway segments to acceptable levels, and impacts on these facilities under Existing and Near-Term Plus Project conditions would be less than significant after mitigation. However, potential right-of-way constraints along Higuera Street (Segments #7 and #8) may reduce the feasibility of mitigation along these segments. Accordingly, some of the potential impacts associated with multimodal level of service standards identified for Existing and Near-Term Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with multimodal level of service standards at these roadway segments under Existing and Near-Term Plus Project conditions would remain significant and unavoidable. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass (Mitigation Measures T-3[a], T-3[b], and T-3[c]) are discussed in Section 4.12.54(d). Threshold 4: Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment)? Impact T-4 Project construction activities would create traffic impacts due to construction vehicles causing congestion and deteriorating pavement conditions. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. The location and intensity of construction-related increases in traffic would vary by construction phase. However, each phase would incrementally contribute to road or intersection congestion over the planning horizon. Increased construction traffic, particularly large haul trucks and other heavy equipment, may disrupt local traffic flows, congest limited turn lane capacities, and generally slow traffic movement. Construction activity during site preparation typically includes use of cement trucks, material and equipment delivery trucks, and worker vehicles. These vehicles would likely use U.S. 101 to travel to and from the site. Furthermore, construction activities would require parking onsite for construction workers. Construction may require temporary or extended closure of traffic lanes to accommodate parked vehicles, operation of construction equipment, installation of project improvements, including offsite trenching for utilities along surrounding roadways. Other potential construction-related impacts include idling, parked, or queued heavy trucks that could potentially obstruct visibility, traffic flows, and interfere with pedestrian and bicycle flows. This would cause delays and disrupt bicyclist and pedestrian flows, requiring travelers of the area to utilize alternative routes. Depending on final construction plan details, such lane and sidewalk closures could extend for several weeks. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-82 Mitigative Components of the Specific Plan and Impact Conclusion. The project does not include design features that would reduce construction-related traffic impacts. Construction- related traffic would be ongoing for the duration of the project buildout, and construction traffic could create potentially significant impacts. However, with preparation of a management plan to control construction transportation as well as pavement condition study before and after each phase, impacts could be minimized. Therefore, with implementation of the mitigation measure listed below, construction traffic impacts would be reduced to a less than significant level. Mitigation Measures. The following mitigation is required to reduce potentially significant construction traffic impacts. T-4 Construction Traffic Management Plan. Prior to construction, a traffic management plan shall be prepared for review and approval by the City of San Luis Obispo Public Works Department. The traffic management plan shall be based on the type of roadway traffic conditions, duration of construction, physical constraints, nearness of the work zone to traffic and other facilities (bicycle, pedestrian, driveway access, etc.). The traffic management plan shall include: • Advertisement. The project developer shall prepare an advertisement campaign informing the public of the proposed construction activities. Advertisements shall occur prior to beginning work and periodically during the course of the project construction. The advertising shall include notification of changes to bus schedules and potential changes to bus stop locations, potential impacts during school drop-off and pick-up times, and major intersections that may be impacted during construction. • Property Access. Access to parcels along the construction area shall be maintained to the greatest extent feasible. Affected property owners shall receive advance notice of work adjacent to their property access and when driveways would be potentially closed. • Schools. Any construction adjacent to schools shall ensure that access is maintained for vehicles, pedestrians, and bicyclists, particularly at the beginning and end of the school day. • Buses, Bicycles, and Pedestrians. The work zone shall provide for passage by buses, bicyclists, and pedestrians, particularly in the vicinity of schools. • Intersections. Traffic control (i.e., use of flag persons) shall be used at intersections that are determined to be unacceptably congested due to construction traffic. Plan Requirements and Timing. The project applicant shall submit the construction traffic management plan for review and approval by the City prior to the initiation of construction. Monitoring. The City shall ensure compliance with the construction traffic management plan through routine monitoring throughout all phases of project construction. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-83 Significance After Mitigation. Implementation of the identified mitigation would ensure that impacts associated with construction traffic would be less than significant after mitigation. Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Threshold 2: Would the project conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Impact T-5 Construction of the proposed Froom Ranch Way bridge during phase 3 of the Specific Plan buildout would result in significant level of service and queuing impacts at study area intersections and roadway segments. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. The project would construct the proposed Froom Ranch Way bridge, completing connectivity between the project and Los Osos Valley Road, during phase 3 of Specific Plan buildout. Under this condition, traffic volumes from the phase 1 and phase 2 land uses, which would otherwise route through the Los Osos Valley Road & Froom Ranch Way intersection, would re-route through Prado Road and Dalidio Drive until phase 3 of Specific Plan buildout. Mitigative Components of the Specific Plan and Impact Conclusion. The project proposes to defer construction of the Froom Ranch Way bridge to phase 3 of Specific Plan buildout, which would cause potentially significant LOS and queuing impacts. Changing the phase of the Froom Ranch Way bridge connection to prior to occupancy of phase 1 would mitigate these impacts. Mitigation Measures. The following mitigation is required to reduce potentially significant LOS and queuing impacts that would result from the project’s proposed infrastructure phasing. T-5 Froom Ranch Way Bridge Phasing. The Froom Ranch Way bridge connection shall be completed prior to occupancy of Phase 1 of the Specific Plan buildout. Plan Requirements and Timing. The project applicant shall adjust the proposed infrastructure phasing plan to include the Froom Ranch Way bridge as part of the final design plans for Phase 1 of the Specific Plan. Monitoring. City Public Works staff shall confirm appropriate infrastructure phasing as part of approval of final design plans for Phase 1. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-84 Significance After Mitigation. Implementation of the identified mitigation would ensure that LOS and queuing impacts associated with the project’s proposed infrastructure phasing would be less than significant after mitigation. Threshold 4: Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment)? Impact T-6 The project site plan would result in and contribute to increased access conflicts. Proposed access controls are not consistent with General Plan policy. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. The project’s proposed site plan and access was evaluated using guidelines established under the Transportation Research Board’s Access Management Manual. The project includes an internal circulation plan for vehicles and bicycles (refer to Figures 2-7 and 2-8 in Section 2.0, Project Description). The proposed street network within the Specific Plan Area consists primarily of collector and residential streets. Access to the residential areas would be provided on the south from the proposed Froom Ranch Way extension and on the north from Madonna Road. Project traffic, in addition to the extension of Prado Road/Dalidio Drive through the project site, would exacerbate conflicts associated with the existing post office driveways. In addition, the intersection of Froom Ranch Way & Prado Road/Dalidio Drive is closer than the minimum spacing of various ramp intersection design options being considered by the City for the future Prado Road/U.S. 101 overpass. Mitigative Components of the Specific Plan and Impact Conclusion. San Luis Ranch Specific Plan Policies 6.1, 6.2, and 6.3 are intended to integrate the proposed new development and associated circulation into the City’s existing circulation system by ensuring a multimodal approach to the transportation networks for the Specific Plan Area, development of a circulation system that interfaces with existing adjacent streets and paths, and development of a safe and efficient circulation system that successfully interfaces with adjacent streets and paths. The project proposes signalized control at various intersections. However, General Plan Circulation Element Policy 7.1.2 requires roundabout control unless otherwise physically infeasible. Therefore, the proposed project site intersections within the Specific Plan area would be inconsistent with General Plan Circulation Element Policy 7.1.2, which would be a potentially significant impact. Mitigation Measures. The following mitigation is required to ensure that the project would be consistent with General Plan Circulation Element Policy 7.1.2, which requires roundabout control unless otherwise physically infeasible. T-6 Project Site Intersection Roundabout Control. New roadway intersections within the Specific Plan Area shall be controlled using roundabout design, unless the City Public Works Department determines that roundabout control is infeasible. Plan Requirements and Timing. The project applicant shall include intersection controls on final design plans for development within the San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-85 Specific Plan Area. Intersection controls shall be approved by City Public Works. Monitoring. City Public Works staff shall confirm inclusion of appropriate intersection controls and approve final design plans prior to issuance of grading permits. Significance After Mitigation. Implementation of the identified mitigation would ensure that the project would be consistent with General Plan Circulation Element Policy 7.1.2. This mitigation would ensure roundabout control at all project site intersections that could feasibly accommodate it, and would ensure that transportation impacts due to access conflicts would be reduced to a less than significant level after mitigation. Threshold 4: Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment)? Impact T-7 The project site plan would result in on-site traffic volumes and speeds that may exceed General Plan policy thresholds, resulting potential traffic hazards within the project site. Mitigation would reduce these impacts to an acceptable level. This impact would be Class II, less than significant with mitigation. The proposed street network within the Specific Plan Area consists primarily of collector and residential streets. The proposed layout of San Luis Ranch Road and other roadways internal to the Specific Plan area would result in on-site neighborhood traffic speeds that would exceed General Plan thresholds. San Luis Ranch Road would provide a bypass to the intersection at Madonna Road and Dalidio Drive/Prado Road through the residential neighborhood on the project site, which may result in a high propensity for cut-through traffic and volumes that exceed General Plan thresholds. Mitigative Components of the Specific Plan and Impact Conclusion. San Luis Ranch Specific Plan Policies 6.1, 6.2, and 6.3 are intended to integrate the proposed new development and associated circulation into the City’s existing circulation system by ensuring a multimodal approach to the transportation networks for the Specific Plan Area, development of a circulation system that interfaces with existing adjacent streets and paths. The proposed layout of San Luis Ranch Road and other roadways internal to the Specific Plan area would result in on-site traffic speeds that would exceed General Plan thresholds, which may result in potential traffic hazards within the Specific Plan area. Therefore, the project may result in traffic hazards along on-site collector and residential streets, which would be a potentially significant impact. Mitigation Measures. The following mitigation is required to ensure that on-site traffic volumes and speeds would not exceed General Plan policy thresholds, and potential traffic hazards along on-site collector and residential streets would be reduced. T-7 Traffic Calming Features. New roadway intersections along San Luis Ranch Road shall include neighborhood traffic circles at key intersections, and traffic-calming features, such as diverters, along longer uninterrupted segments. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-86 Plan Requirements and Timing. The project applicant shall include neighborhood traffic circles at key intersections and traffic-calming features on final design plans for development within the Specific Plan Area. Monitoring. City Public Works staff shall confirm inclusion of neighborhood traffic circles at key intersections and traffic-calming features, and approve final design plans prior to issuance of grading permits. Significance After Mitigation. Implementation of the identified mitigation would ensure that new roadways on the project site would not result on-site neighborhood traffic speeds that would exceed General Plan thresholds. This mitigation would ensure that potential traffic hazards within the Specific Plan area would be reduced to a less than significant level after mitigation. c. Project Impacts and Mitigation Measures – Cumulative. Cumulative Scenario Background. The project traffic study (refer to Appendix KL) evaluated the project under cumulative conditions. Cumulative + project conditions reflect the potential impacts of the project within the context of the complete buildout of all planned development and infrastructure. Mitigation measures identified for impacts under the cumulative scenario would not need to be physically constructed as part of the project; these improvements would be required to be components of a fee project to which the project would be required to contribute its fair share for the eventual implementation of required measures on a schedule to be determined by the City Public Works Department. Cumulative 2035 Conditions. Under cumulative conditions, the City’s buildout circulation system is assumed to be constructed, including the improvements listed in the near- term conditions (refer to Section 4.12.54[c]), as well as the following improvements: • A new North/South Collector between Prado Road and Tank Farm Road • Prado Road extension to Broad Street • Prado Road widening to four lanes with bike lanes between S. Higuera Street, and removal parking along this roadway segment • Madonna Road at S. Higuera Street realignment to Bridge Street • New North/South Collector between Tank Farm Road and Prado Road • Restrict intersection of S. Higuera Street/Vachell Lane to be right-in right-out only • Froom Ranch Way extension to Dalidio Road • Dalidio Road widening to four lanes with Class II Bike Lanes • Prado Road Overpass Only, no U.S. 101 Access For the purposes of this study, cumulative conditions were analyzed for two different configurations for the Prado Road/U.S. 101 improvements: a full access interchange (overpass with ramps serving both northbound and southbound U.S. 101) and an overpass only. The peak hour traffic volumes for both scenarios were developed utilizing the City’s TDM to establish the networks for both potential configurations, and used the same land use inputs for both potential configurations. Figure 4.12-8 shows the Cumulative peak hour intersection traffic volumes. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-87 Cumulative traffic volume forecasts were derived for each potential configuration by applying the model’s volume growth increment to existing traffic counts. The model’s growth increment is based on the peak hour intersection turning outputs between the base year (2008) model and each of the 2035 buildout models, and factored to account for growth to existing conditions (2014). Based on existing travel patterns and counts, and to balance the volumes to account for midblock driveways, manual adjustments were made where necessary. This establishes the base forecasts for each alternative, without the proposed San Luis Ranch Specific Plan development. These base volumes are consistent with the projections for the Project Study Report for the Prado Road/U.S. 101 improvements. Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Threshold 2: Would the project conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Threshold 6: Would the project conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? Impact T-8 Under Cumulative Plus Project conditions nine study area intersections would operate at unacceptable automobile, bicycle, or pedestrian LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at seven of these intersections to an acceptable level. However, impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections would be Class I, significant and unavoidable. Source: Omni-Means, Ltd., 2016Year 2035 Full Build Prado Road InterchangePeak Hour Traffic VolumesFigure 4.12-8City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-88 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-89 Table 4.12-36 through Table 4.12-38 provide a summary of the multimodal AM and PM peak hour intersection LOS under Cumulative Plus Project conditions. Intersections where the AM or PM LOS exceed the minimum LOS standard are bolded. Figure 4.12-9 shows the Cumulative Plus Project peak hour traffic volumes. Table 4.12-36 Cumulative Plus Project Conditions Intersection Level of Service: Automobile Analysis # Intersection Control Type1,2 Target LOS AM Peak Hour PM Peak Hour v/c3 Delay LOS v/c3 Delay LOS 1 Madonna Road/Los Osos Valley Road Signal D 37.3 D 45.1 D 2 Madonna Road/Oceanaire Drive Signal D 24.2 C 17.6 B 3 Madonna Road/Dalidio Drive Signal D 4.04 258. 4 F 8.66 806. 7 F 4 Madonna Road/El Mercado Signal D 10.7 B 23.5 C 5 Madonna Road/US 101 SB Ramps/Madonna Inn Signal C 34.5 C 31.4 C 6 Madonna Road/US 101 NB Ramps Signal C 26.5 C 28.3 C 7 Madonna Road/Higuera Street Signal D 43.8 D 47.0 D 8 Higuera Street/South Street Signal D 20.8 C 28.6 C 9 Los Osos Valley Road/Froom Ranch Way Signal D 24.4 C 1.11 63.8 E 10 Los Osos Valley Road/Auto Park Way TWSC D 18.2 C 0.44 49.1 E 11 Los Osos Valley Road/Calle Joaquin Signal D 26.0 C 14.5 B 12 Los Osos Valley Road/US 101 SB Ramps Signal C 1.26 41.8 D 29.9 C 13 Los Osos Valley Road/US 101 NB Ramps Signal C 1.17 57.6 E 24.4 C 14 S. Higuera Street/Los Osos Valley Road Signal D 23.6 C 1.10 79.9 E 15 S. Higuera Street/Suburban Drive Signal D 7.5 A 16.7 B 16 S. Higuera Street/Tank Farm Road Signal D 1.48 114. 9 F 26.2 C 17 S. Higuera Street/Granada Drive Signal D 8.3 A 10.9 B 18 S. Higuera Street/Prado Road Signal D 34.9 C 32.2 C 19 S. Higuera Street/Margarita Avenue Signal D 17.9 B 13.0 B 21 Froom Ranch Road/Dalidio Drive/Prado Road Signal D 20.5 C 32.0 C 22 Madonna Road/Project Driveway TWSC D 15.8 C 13.2 B 23 Froom Ranch Road/Project Driveway #2 TWSC D 20.1 C 21.9 C 25 Dalidio Drive/SC Project Driveway Signal D 10.6 B 15.7 B 27 Froom Ranch Road/Hotel Project Driveway TWSC D 13.8 B 14.3 B 28 Froom Ranch Road/Project Driveway #3 TWSC D 11.9 B 12.2 B 1 Madonna Road/Los Osos Valley Road Signal D 37.3 D 45.1 D 2 Madonna Road/Oceanaire Drive Signal D 24.2 C 17.6 B Notes: 1. AWSC = All Way Stop Control; TWSC = Two Way Stop Control; RNDBT = Roundabout 2. LOS = Delay based on worst minor street approach for TWSC intersections, average of all approaches for AWSC, Signal, RNDBT 3. Volume to Capacity Ratio (v/c) is for worst movement delay, for unacceptable LOS only 4. Warrant is based on California MUTCD Warrant 3 Source: Omni-Means, Ltd., 2016Year 2035 Full Build Prado Road InterchangePlus Project Peak Hour Traffic VolumesFigure 4.12-9City of San Luis ObispoSan Luis Ranch Project EIRSection 4.12 Transportation/4.12-90 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-91 Table 4.12-37 Cumulative Plus Project Conditions Intersection Level of Service: Pedestrian Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswalk Score LOS Ped. Crosswalk Score LOS 1 Madonna Road/Los Osos Valley Road EB C 2.12 B 2.12 B WB C 3.05 C 3.27 C NB C 3.11 C 3.35 C SB C 3.30 C 3.34 C 2 Madonna Road/Oceanaire Drive EB C 2.89 C 2.98 C WB C 3.31 C 3.40 C NB C 2.03 B 2.02 B SB C 1.86 A 1.87 A 3 Madonna Road/Dalidio Drive EB C 3.73 D 4.23 D WB C 3.02 C 3.08 C NB C 2.72 B 2.79 C SB C 1.97 A 2.01 B 4 Madonna Road/El Mercado EB C n/a - n/a - WB C 3.09 C 3.19 C NB C 2.36 B 2.76 C SB C 1.74 A 1.74 A 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB C 3.02 C 3.15 C WB C n/a - n/a - NB C 2.83 C 2.74 B SB C 2.17 B 2.20 B 6 Madonna Road/US 101 NB Ramps EB C n/a - n/a - WB C 3.12 C 3.13 C NB C 2.03 B 2.04 B SB C n/a - n/a - 7 Madonna Road/Higuera Street EB C 2.96 C 3.10 C WB C 2.05 B 2.07 B NB C 3.05 C 3.10 C SB C n/a - n/a - 8 Higuera Street/South Street EB C 2.02 B 2.05 B WB C 2.77 C 2.84 C NB C n/a - n/a - SB C 2.64 B 2.74 B 9 Los Osos Valley Road/Froom Ranch Way EB C 2.45 B 2.66 B WB C 2.51 B 2.70 B NB C n/a - n/a - SB C 3.10 C 3.33 C 10 Los Osos Valley Road/Auto Park Way EB C n/a - n/a - WB C - - NB C - - SB C - - 11 Los Osos Valley Road/Calle Joaquin EB C 2.59 B 2.47 B WB C 2.26 B 2.33 B NB C 3.19 C 3.54 D SB C 3.08 C 3.37 C 12 Los Osos Valley Road/US 101 SB Ramps EB C 2.03 B 2.46 B WB C 2.21 B 2.14 B NB C n/a - n/a - San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-92 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Ped. Crosswalk Score LOS Ped. Crosswalk Score LOS SB C n/a - n/a - 13 Los Osos Valley Road/US 101 NB Ramps EB C 2.70 B 2.56 B NB C 2.89 C 2.97 C SB C n/a - n/a - 14 S. Higuera Street/Los Osos Valley Road EB C 3.11 C 3.68 D NB C 2.51 B 2.73 B SB C n/a - n/a - 15 S. Higuera Street/Suburban Drive WB C 2.18 B 2.60 B NB C 3.32 C 3.84 D SB C 3.00 C 3.09 C 16 S. Higuera Street/Tank Farm Road EB C 2.02 B 2.02 B WB C 2.96 C 3.24 C NB C 3.62 D 3.36 C SB C 2.82 C 3.02 C 17 S. Higuera Street/Granada Drive WB C 2.08 B 2.13 B NB C n/a - n/a - SB C 2.74 B 2.96 C 18 S. Higuera Street/Prado Road EB C 2.98 C 3.02 C WB C 3.04 C 3.20 C NB C 2.93 C 3.34 C SB C 2.92 C 3.18 C 19 S. Higuera Street/Margarita Avenue EB C 2.27 B 2.11 B WB C 2.22 B 2.28 B NB C 2.97 C 3.08 C SB C 2.92 C 3.06 C 21 Froom Ranch Road/Dalidio Drive/Prado Road EB C 2.54 B 2.47 B WB C 1.87 A 1.91 A NB C 2.65 B 2.71 B SB C 2.85 C 2.96 C 25 Dalidio Drive/SC Project Driveway EB C 1.91 A 2.01 B WB C 1.74 A 1.80 A NB C 2.57 B 2.66 B SB C 2.58 B 2.67 B Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. 2. HCM 2010 Methodologies for the pedestrian mode at two-way stop-controlled intersections is limited to the uncontrolled crossing. No methodology exists for evaluating pedestrian performance for the stop controlled approach (cross-street). However, it is reasoned that this type of control has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-93 Table 4.12-38 Cumulative Plus Project Conditions Intersection Level of Service: Bicycle Analysis # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Bicycle LOS Score LOS Bicycle LOS Score LOS 1 Madonna Road/Los Osos Valley Road EB D 3.30 C 3.16 C WB D 3.47 C 4.17 D NB D 1.70 A 2.10 B SB D 2.96 C 2.78 C 2 Madonna Road/Oceanaire Drive EB D 3.07 C 2.91 C WB D 1.32 A 1.81 A NB D 2.76 C 2.74 B SB D 2.29 B 2.25 B 3 Madonna Road/Dalidio Drive EB D 2.39 B 2.13 B WB D 1.66 A 1.73 A NB D 2.82 C 3.81 D SB D 1.79 A 1.86 A 4 Madonna Road/El Mercado EB D 1.68 A 1.78 A WB D 1.83 A 1.92 A NB D 3.39 C 3.94 D SB D 3.03 C 3.03 C 5 Madonna Road/US 101 SB Ramps/Madonna Inn EB D 1.90 A 2.08 B WB D 1.69 A 1.71 A NB D n/a - n/a - SB D 2.91 C 2.99 C 6 Madonna Road/US 101 NB Ramps EB D 2.74 B 2.41 B W B D 1.89 A 2.13 B NB D n/a - n/a - 7 Madonna Road/Higuera Street EB D 3.95 D 2.83 C WB D 2.61 B 2.78 C NB D 2.05 B 2.76 C SB D 2.52 B 2.59 B 8 Higuera Street/South Street EB D 2.71 B 2.77 C WB D 2.54 B 2.72 B NB D 3.08 C 3.62 D SB D 1.96 A 2.02 B 9 Los Osos Valley Road/Froom Ranch Way EB D 3.56 D 4.62 E WB D 2.28 B 3.18 C NB D 1.83 A 2.28 B SB D 1.84 A 1.94 A 10 Los Osos Valley Road/Auto Park Way EB D n/a - n/a - WB D - - NB D - - SB D - - 11 Los Osos Valley Road/Calle Joaquin EB D 3.08 C 3.12 C WB D 3.21 C 3.49 C NB D 1.67 A 2.17 B SB D 0.58 A 1.02 A San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-94 # Intersection Approach Target LOS AM Peak Hour PM Peak Hour Bicycle LOS Score LOS Bicycle LOS Score LOS 12 Los Osos Valley Road/US 101 SB Ramps WB D n/a - n/a - NB D 2.89 C 3.37 C SB D 1.75 A 2.29 B 13 Los Osos Valley Road/US 101 NB Ramps EB D n/a - n/a - NB D 2.00 A 2.60 B SB D 2.93 C 2.93 C 14 S. Higuera Street/Los Osos Valley Road EB D 2.45 B 2.12 B NB D 2.32 B 2.33 B SB D 2.73 B 4.14 D 15 S. Higuera Street/Suburban Drive WB D 0.95 A 1.64 A NB D 2.68 B 2.22 B SB D 1.91 A 2.50 B 16 S. Higuera Street/Tank Farm Road EB D 2.72 B 2.66 B WB D 2.43 B 3.34 C NB D 2.58 B 2.31 B SB D 1.93 A 2.24 B 17 S. Higuera Street/Granada Drive WB D 2.63 B 2.93 C NB D 1.84 A 2.17 B SB D 2.05 B 2.27 B 18 S. Higuera Street/Prado Road EB D 1.54 A 1.38 A WB D 2.63 B 2.51 B NB D 1.82 A 2.20 B SB D 2.18 B 2.11 B 19 S. Higuera Street/Margarita Avenue EB D 2.50 B 2.56 B WB D 2.74 B 2.77 C NB D 1.86 A 2.38 B SB D 2.45 B 2.26 B 21 Froom Ranch Road/Dalidio Drive/Prado Road EB D 2.17 B 2.19 B WB D 2.81 C 3.09 C NB D 1.59 A 2.05 B SB D 2.03 B 1.96 A 25 Dalidio Drive/SC Project Driveway EB D 2.70 B 2.73 B WB D 2.50 B 2.56 B NB D 2.43 B 3.03 C SB D 2.78 C 2.64 B Notes: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. 2. No methodology exists for evaluating bicycle performance at two-way stop-controlled intersections. However, it is reasoned that this type of control has negligible influence on bicycle service along the segment for stop control on the cross-street. As shown in Table 4.12-36 through Table 4.12-38, seven intersections (Madonna Road & Dalidio Drive/Prado Road, Los Osos Valley Road & Froom Ranch Way, Los Osos Valley Road & Auto Park Way, Los Osos Valley Road & U.S. 101 ramps in both directions, S. Higuera Street & Los Osos Valley Road and S. Higuera Street & Tank Farm Road) would exceed the City’s minimum automobile LOS threshold under the Cumulative Plus Project Scenario. Five intersections (Madonna Road & Dalidio Drive/Prado Road, Los Osos Valley Road & Froom Ranch Way, Los San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-95 Osos Valley Road & Calle Joaquin, S. Higuera Street & Los Osos Valley Road, S. Higuera Street & Suburban Drive, and S. Higuera Street & Tank Farm Road) would exceed the City’s minimum pedestrian or bicycle LOS threshold under the Cumulative Plus Project Scenario. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The Specific Plan also emphasizes bikeways and pedestrian connections, all of which contribute to reduced trips and VMT. However, under Cumulative Plus Project conditions, the following nine study area intersections would operate at unacceptable automobile, bicycle, and pedestrian LOS based on adopted MMLOS standards during AM and PM peak hours. • Madonna Road & Dalidio Drive/Prado Road • Los Osos Valley Road & Froom Ranch Way • Los Osos Valley Road & Auto Park Way • Los Osos Valley Road & Calle Joaquin • Los Osos Valley Road & U.S. 101 southbound ramps • Los Osos Valley Road & U.S. 101 northbound ramps • S. Higuera Street & Los Osos Valley Road • S. Higuera Street & Tank Farm Road • S. Higuera Street & Suburban Drive Therefore, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and LOS standards, and transportation impacts would be potentially significant at these intersections. Mitigation Measures. The following mitigation measures identify improvements at study area facilities that are required to reduce potentially significant cumulative impacts to study area intersections under Cumulative Plus Project conditions. Each mitigation measure refers to one of the required Transportation Improvement Measures identified in Table 4.12-1 at the beginning of this section. The project’s equitable share of these improvements will be calculated using the method for calculating equitable mitigation measures outlined in the Caltrans Guide for the Preparation of Traffic Impact Studies (Caltrans, December 2002). Costs above and beyond the project’s equitable share can be addressed through such options as fee credits, reimbursement agreements, or development agreements, based on City requirements. T-8(a) Intersection #3: Madonna Road & Dalidio Drive/Prado Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[b]) T-8(b) Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[e]/Mitigation Measure T-2[f]) T-8(c) Intersection #10: Los Osos Valley Road & Auto Park Way. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[f]) San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-96 T-8(d) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-8(e) Intersection #13: Los Osos Valley Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-8(f) Intersection #14: Los Osos Valley Road & S. Higuera Street. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-8(g) Intersection #16: S. Higuera Street & Tank Farm Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[f]) Plan Requirements and Timing. Fair share traffic impact fees shall be paid upon acceptance by the City of final design plans and in accordance with the timing of improvements. Monitoring. City Public Works staff shall confirm payment of applicable fees. City Public Works staff shall also ensure implementation of these improvements following approval of the final design plans for the Specific Plan Area. Significance After Mitigation. Implementation of the identified mitigation measures would improve LOS at most impacted intersections to acceptable levels, and impacts on these facilities would be less than significant after mitigation. However, potential right-of-way constraints at Madonna Road & Dalidio Drive (Intersection #3) and Los Osos Valley Road & Froom Ranch Way (Intersection #9) may reduce the feasibility of mitigation at these intersections. Accordingly, some of the potential impacts associated with multimodal level of service standards identified for Cumulative Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with multimodal level of service standards at these intersections under Cumulative Plus Project conditions would remain significant and unavoidable. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass (Mitigation Measures T-8[d], T-8[e], and T-8[f]) are discussed in Section 4.12.54(d). San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-97 Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Impact T-9 Under Cumulative Plus Project conditions, the volume of traffic at 18 study area intersections would exceed lane capacities. Mitigation would reduce impacts at 18 of these intersections to an acceptable level. Mitigation would reduce impacts at 17 of these intersections to an acceptable level. However, impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections would be Class I, significant and unavoidable. Table 4.12-39 provides a summary of the queueing under Cumulative Plus Project conditions. Intersections where vehicle queues would exceed lane capacity during peak hours are bolded. Table 4.12-39 Cumulative Plus Project Conditions Intersection Queue Capacity Analysis Intersection Movement No. Lanes Total Storage (ft)1 95th Percentile Queue/Lane (ft) ID Location AM Peak Hour PM Peak Hour 1 Madonna Road/Los Osos Valley Road Northbound Right 1 175 102 259 Southbound Left 2 350 393 267 2 Madonna Road/Oceanaire Drive Westbound Right 1 100 72 132 Westbound Left 1 275 703 335 3 Madonna Road/Dalidio Drive Westbound Left 2 260 317 538 Eastbound Left 1 100 77 112 Westbound Left 1 260 185 548 4 Madonna Road/El Mercado Northbound Left 1 185 202 300 5 Madonna Road/US 101 SB Ramps/Madonna Inn Eastbound Right 1 150 337 225 6 Madonna Road/US 101 NB Ramps Northbound Left 1 160 330 332 7 Madonna Road/Higuera Street Southbound Left/Through 2 250 328 668 Southbound Right 2 340 44 635 Eastbound Right 1 60 43 88 Westbound Left 2 240 179 1024 8 Higuera Street/South Street Northbound Left 1 60 89 49 Northbound Right 1 60 112 168 Southbound Left 1 70 119 126 Eastbound Through/Right 1 445 189 617 Westbound Left 1 295 143 354 Westbound Right 1 50 80 100 9 Los Osos Valley Road/Froom Ranch Way Southbound Left 2 200 134 296 Northbound Right 1 105 112 64 Southbound Right 2 80 91 153 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-98 Intersection Movement No. Lanes Total Storage (ft)1 95th Percentile Queue/Lane (ft) ID Location AM Peak Hour PM Peak Hour 10 Los Osos Valley Road/Auto Park Way Westbound Left/Through 1 180 272 255 11 Los Osos Valley Road/Calle Joaquin Southbound Through 1 240 356 358 12 Los Osos Valley Road/US 101 SB Ramps Southbound Right 1 125 194 180 Eastbound Left/Right 1 625 1365 454 Southbound Through 1 865 1069 429 13 Los Osos Valley Road/US 101 NB Ramps Southbound Right 1 130 271 231 Eastbound Right 1 90 207 202 Northbound Left 1 160 153 222 14 S. Higuera Street/Los Osos Valley Road Westbound Right 1 170 57 288 Southbound Left 1 200 92 328 15 S. Higuera Street/Suburban Drive Northbound Right 1 100 179 205 Southbound Left 1 165 261 238 16 S. Higuera Street/Tank Farm Road Southbound Left 1 80 99 66 Eastbound Right 1 140 165 92 Westbound Left 1 105 205 233 17 S. Higuera Street/Granada Drive Westbound Right 1 100 284 275 18 S. Higuera Street/Prado Road Northbound Left 1 100 101 204 Southbound Left 1 60 183 159 Northbound Left 1 60 84 73 Southbound Left 1 60 122 95 Northbound Right 1 175 102 259 Southbound Left 2 350 393 267 19 S. Higuera Street/Margarita Avenue Westbound Right 1 100 72 132 Westbound Left 1 275 703 335 Notes: 1. Bolded entries indicate queues exceed available storage 2. Storage Length of " - " represents a lane which exceeds 1,000 feet, usually a through lane. 3. For Movements with more than one lane, the maximum of the 95th percentile queue is reported. 4. * Represents storage lengths for one lane; second lane is a left or right trap lane. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The Specific Plan also emphasizes bikeways and pedestrian connections, all of which contribute to reduced trips and VMT. However, as shown in Table 4.12-39, under Cumulative Plus Project conditions, the volume of traffic at 18 study area intersections would exceed lane capacities during peak hours. Therefore, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and vehicle queuing standards, and transportation impacts would be potentially significant at these intersections. Mitigation Measures. The following mitigation measures identify improvements at study area facilities that are required to reduce potentially significant cumulative impacts at study area intersections under Cumulative Plus Project Conditions. Each mitigation measure refers to one of the required Transportation Improvement Measures identified in Table 4.12-1 at the beginning of this section. The project’s equitable share of these improvements will be calculated using the method for calculating equitable mitigation measures outlined in the San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-99 Caltrans Guide for the Preparation of Traffic Impact Studies (Caltrans, December 2002). Costs above and beyond the project’s equitable share can be addressed through such options as fee credits, reimbursement agreements, or development agreements, based on City requirements. T-9(a) Intersection #1: Madonna Road & Los Osos Valley Road. • Extend northbound right turn pocket on Los Osos Valley Road to 295’ • Extend southbound left turn pocket on Madonna Road to 395’ T-9(b) Intersection #2: Madonna Road & Oceanaire Drive. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[b]) • Extend westbound right turn land on Madonna Road to 200’ T-9(c) Intersection #3: Madonna Road & Dalidio Drive. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[b]) T-9(d) Intersection #4: Madonna Road & El Mercado. • Existing & Near-Term Plus Project Mitigation (Mitigation Measures T-1[b]) T-9(e) Intersection #5: Madonna Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(f) Intersection #6: Madonna Road & U.S. 101 Northbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(g) Intersection #8: Higuera Street & South Street. • Extend northbound Higuera Street left turn pocket to 120’ • Extend eastbound South Street right turn pocket to 100’ T-9(h) Intersection #9: Los Osos Valley Road & Froom Ranch Way. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[d]/Mitigation Measure T-2[f]) T-9(i) Intersection #11: Los Osos Valley Road & Calle Joaquin. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(j) Intersection #12: Los Osos Valley Road & U.S. 101 Southbound Ramps. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-9(k) Intersection #14: Los Osos Valley Road & S. Higuera Street. • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-100 T-9(l) Intersection #16: S. Higuera Street & Tank Farm Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 1[g]) T-9(m) Intersection #18: Higuera Street & Prado Road. • Existing & Near-Term Plus Project Mitigation (Mitigation Measure T- 2[j]) Plan Requirements and Timing. Fair share traffic impact fees shall be paid upon acceptance by the City of final design plans and in accordance with the timing of improvements. Monitoring. City Public Works staff shall confirm payment of applicable fees. City Public Works staff shall also ensure implementation of these improvements following approval of the final design plans for the Specific Plan Area. Significance After Mitigation. Implementation of the identified mitigation measures would reduce impacts to lane capacities at most impacted intersections to acceptable levels, and impacts on these facilities would be less than significant after mitigation. However, potential right-of-way constraints at Madonna Road & Dalidio Drive (Intersection #3) and Los Osos Valley Road & Froom Ranch Way (Intersection #9) may reduce the feasibility of mitigation at these intersections. Accordingly, some of the potential impacts associated with lane capacities identified for Cumulative Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts to lane capacities at these intersections under Cumulative Plus Project conditions would remain significant and unavoidable. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass (Mitigation Measures T-9[e], T-9[f], T-9[h], T-9[i], and T-9[j]) are discussed in Section 4.12.54(d). Threshold 1: Would the project conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Threshold 2: Would the project conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Threshold 6: Would the project conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-101 Impact T-10 Under Cumulative Plus Project conditions five study area segment groups, as well as mainline segments of U.S. 101, would operate at unacceptable automobile, bicycle, pedestrian, and transit LOS based on adopted multimodal level of service standards during AM and PM peak hours. Mitigation would reduce impacts at each of the five study area segment groups to an acceptable level. However, impacts at the mainline segments of U.S. 101 at Los Osos Valley Road and Madonna Road would be Class I, significant and unavoidable. Table 4.12-40 through Table 4.12-44 provide a summary of the multimodal AM and PM peak hour segment LOS under Cumulative Plus Project conditions. Intersections where the AM or PM LOS exceed the minimum LOS standard are bolded. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-102 Table 4.12-40 Cumulative Plus Project Conditions Segment Level of Service: Automobile Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS 1 Madonna Rd Oceanaire Dr LOVR WB D 19.5 40.1 49% D 14.2 40.1 35% E Madonna Rd LOVR Oceanaire Dr EB D 24.2 40.0 60% C 27.3 40.0 68% B 2 Madonna Rd Dalidio Oceanaire Dr WB D 22.2 40.8 54% C 23.5 40.7 58% C Madonna Rd Oceanaire Dr Dalidio EB D 6.1 40.7 15% F 15.9 40.8 39% E 3 Madonna Rd El Mercado Dalidio Dr WB D 14.9 34.1 44% D 15.0 34.8 43% D Madonna Rd Dalidio Dr El Mercado EB D 27.4 38.2 72% B 11.5 34.6 33% E 4 Madonna Rd US 101 SB Ramps El Mercado WB D 30.6 37.9 81% B 21.2 37.3 57% C Madonna Rd El Mercado US 101 SB Ramps EB D 10.5 37.8 28% F 16.5 37.7 44% D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 26.0 37.8 69% B 23.1 37.8 61% C Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 32.4 37.8 86% A 33.4 37.8 88% A 6 Madonna Rd Higuera St US 101 NB Ramps WB D 9.4 37.2 25% F 11.6 37.2 31% E Madonna Rd US 101 NB Ramps Higuera St EB D 11.5 37.2 31% E 9.1 37.2 25% F 7 S. Higuera St Madonna Rd Margarita Ave SB D 29.6 44.5 66% C 34.9 44.5 78% B S. Higuera St Margarita Ave Madonna Rd NB D 35.4 44.8 79% B 29.3 44.8 65% C 8 S. Higuera St Margarita Ave Prado Rd SB D 13.3 38.9 34% E 12.1 38.9 31% E S. Higuera St Prado Rd Margarita Ave NB D 20.4 38.9 53% C 18.7 38.9 48% D 9 S. Higuera St Prado Rd Granada Dr SB D 33.3 41.8 80% B 29.8 41.8 71% B S. Higuera St Granada Dr Prado Rd NB D 16.2 41.9 39% E 15.4 41.9 37% E 10 S. Higuera St Granada Dr Tank Farm Road SB D 42.1 41.6 101% A 23.5 42.6 55% C S. Higuera St Tank Farm Road Granada Dr NB D 29.6 41.6 71% B 25.6 42.6 60% C 11 S. Higuera St Tank Farm Road Suburban Drive SB D 27.0 42.4 64% C 23.0 41.2 56% C S. Higuera St Suburban Drive Tank Farm Road NB D 18.5 42.5 43% D 14.8 41.3 36% E 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D 20.3 42.1 48% D 4.3 39.1 11% F S. Higuera St Los Osos Valley Road Suburban Drive NB D 23.3 42.0 55% C 19.6 39.0 50% C 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D 22.4 41.9 54% C 12.7 41.8 30% E San Luis Ranch Project EIR Section 4.12 Transportation 4.12-103 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Travel Speed (mph) Base Free-Flow Speed BFFS (mph) Travel Speed/ BFFS (%) LOS Los Osos Valley Froom Ranch Way Madonna Rd NB D 19.2 41.8 46% D 15.7 41.8 38% E 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D 22.0 43.0 51% C 23.5 43.0 55% C Los Osos Valley Calle Joaquin Froom Ranch Way NB D 28.2 43.2 65% C 18.9 43.2 44% D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 6.4 32.1 20% F 15.4 32.1 48% D Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 6.6 31.1 21% F 14.6 31.1 47% D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 14.9 37.7 40% E 15.7 37.7 42% D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 29.8 37.4 80% B 19.7 37.4 53% C 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D 28.3 39.2 72% B 25.7 39.2 66% C Los Osos Valley US 101 NB Ramps S. Higuera St EB D 17.5 39.4 44% D 10.7 39.4 27% F 18 Prado Rd S. Higuera St Froom Ranch Way WB D 29.7 40.3 74% B 23.9 40.3 59% C Prado Rd Froom Ranch Way S. Higuera St EB D 24.7 40.1 62% C 24.0 40.1 60% C 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D 22.6 37.7 60% C 10.6 37.7 28% F Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D 35.1 38.0 92% A 34.7 38.0 91% A 20 Dalidio Dr Madonna Rd SC Project Dwy SB D 21.8 36.0 61% C 18.3 36.0 51% C Dalidio Dr SC Project Dwy Madonna Rd NB D 0.7 38.0 2% F 0.2 38.0 1% F 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 39.2 40.8 96% A 38.7 40.6 95% A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D 25.6 40.7 63% C 24.8 40.8 61% C 24 Dalidio Dr SC Project Dwy Froom Ranch Way SB D 15.5 36.4 43% D 14.0 36.4 38% E Dalidio Dr Froom Ranch Way SC Project Dwy NB D 25.7 37.9 68% B 20.6 37.9 54% C San Luis Ranch Project EIR Section 4.12 Transportation 4.12-104 Table 4.12-41 Cumulative Plus Project Conditions Segment Level of Service: Pedestrian Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB C 3045 3.58 D 3.81 D Madonna Rd LOVR Oceanaire Dr EB C 11655 4.11 D 4.06 D 2 Madonna Rd Dalidio Oceanaire Dr WB C 8400 3.76 D 4.01 D Madonna Rd Oceanaire Dr Dalidio EB C 3750 4.09 D 4.17 D 3 Madonna Rd El Mercado Dalidio Dr WB C 37450 3.52 D 3.80 D Madonna Rd Dalidio Dr El Mercado EB C 52920 3.64 D 3.88 D 4 Madonna Rd US 101 SB Ramps El Mercado WB C 26250 3.67 D 3.73 D Madonna Rd El Mercado US 101 SB Ramps EB C 27915 3.69 D 3.82 D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB C No Peds 3.72 D 3.75 F Madonna Rd US 101 SB Ramps US 101 NB Ramps EB C No Peds 4.10 D 4.02 D 6 Madonna Rd Higuera St US 101 NB Ramps WB C 25200 3.79 D 3.96 D Madonna Rd US 101 NB Ramps Higuera St EB C 19838 3.98 D 3.78 D 7 S. Higuera St Madonna Rd Margarita Ave SB C 23247 3.21 C 3.95 D S. Higuera St Margarita Ave Madonna Rd NB C 5398 3.84 D 4.13 D 8 S. Higuera St Margarita Ave Prado Rd SB C 10245 3.79 D 3.83 D S. Higuera St Prado Rd Margarita Ave NB C 21700 3.66 D 3.91 D 9 S. Higuera St Prado Rd Granada Dr SB C 9292 3.69 D 3.83 D S. Higuera St Granada Dr Prado Rd NB C 8400 3.30 C 3.56 D 10 S. Higuera St Granada Dr Tank Farm Road SB C 46305 3.69 D 3.88 D S. Higuera St Tank Farm Road Granada Dr NB C 49140 3.22 C 3.43 C 11 S. Higuera St Tank Farm Road Suburban Drive SB C 12600 3.73 D 4.02 D S. Higuera St Suburban Drive Tank Farm Road NB C 31500 3.79 D 3.60 D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB C 6552 3.70 D 4.00 D S. Higuera St Los Osos Valley Road Suburban Drive NB C 43533 4.14 D 4.07 D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB C 5458 3.90 D 4.02 D Los Osos Valley Froom Ranch Way Madonna Rd NB C 0 3.71 F 4.10 F San Luis Ranch Project EIR Section 4.12 Transportation 4.12-105 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Average Ped. Space (ft2/p) Segment Score LOS Segment Score LOS 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB C 27300 3.89 D 4.19 D Los Osos Valley Calle Joaquin Froom Ranch Way NB C 3675 3.76 D 4.10 D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB C No Peds 3.75 D 4.15 D Los Osos Valley US 101 SB Ramps Calle Joaquin NB C 12600 3.77 D 4.15 D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB C No Peds 3.98 D 4.00 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB C 10786 3.84 D 4.15 D 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB C 335 4.04 D 4.79 E Los Osos Valley US 101 NB Ramps S. Higuera St EB C 39393 4.09 D 3.91 D 18 Prado Rd S. Higuera St Froom Ranch Way WB C 9450 3.56 D 3.77 D Prado Rd Froom Ranch Way S. Higuera St EB C 8400 3.85 D 3.75 D 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB C 6852 3.69 D 3.89 D Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB C 9450 1.91 A 2.01 B 20 Dalidio Dr Madonna Rd SC Project Dwy SB C 4500 3.42 C 3.39 C Dalidio Dr SC Project Dwy Madonna Rd NB C 15750 3.30 C 3.59 D 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB C 0 1.76 F 1.79 A Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB C No Peds 3.41 C 3.41 C 24 Dalidio Dr SC Project Dwy Froom Ranch Way SB C 4500 3.49 C 3.43 C Dalidio Dr Froom Ranch Way SC Project Dwy NB C 15750 3.27 C 3.55 D Notes: 1. Sidewalk is present along frontage roads for segments #1 - Madonna Road and #13 - Los Osos Valley Road, and is not accounted for in this analysis. 2. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is reasoned that it has negligible influence on pedestrian service along the segment. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-106 Table 4.12-42 Cumulative Plus Project Conditions Segment Level of Service: Bicycle Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D 3.65 D 4.06 D Madonna Rd LOVR Oceanaire Dr EB D 3.83 D 3.78 D 2 Madonna Rd Dalidio Oceanaire Dr WB D 3.17 C 3.24 C Madonna Rd Oceanaire Dr Dalidio EB D 3.60 D 3.44 C 3 Madonna Rd El Mercado Dalidio Dr WB D 3.31 C 3.20 C Madonna Rd Dalidio Dr El Mercado EB D 3.37 C 3.41 C 4 Madonna Rd US 101 SB Ramps El Mercado WB D 3.98 D 4.33 E Madonna Rd El Mercado US 101 SB Ramps EB D 3.60 D 3.64 D 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D 3.32 C 3.33 C Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D 3.40 C 3.34 C 6 Madonna Rd Higuera St US 101 NB Ramps WB D 3.54 D 3.59 D Madonna Rd US 101 NB Ramps Higuera St EB D 3.96 D 3.54 D 7 S. Higuera St Madonna Rd Margarita Ave SB D 3.94 D 3.91 D S. Higuera St Margarita Ave Madonna Rd NB D 4.14 D 4.27 E 8 S. Higuera St Margarita Ave Prado Rd SB D 3.69 D 3.68 D S. Higuera St Prado Rd Margarita Ave NB D 3.96 D 4.03 D 9 S. Higuera St Prado Rd Granada Dr SB D 3.89 D 3.93 D S. Higuera St Granada Dr Prado Rd NB D 3.46 C 3.53 D 10 S. Higuera St Granada Dr Tank Farm Road SB D 4.16 D 4.21 D S. Higuera St Tank Farm Road Granada Dr NB D 3.51 D 3.57 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D 3.37 C 3.48 C S. Higuera St Suburban Drive Tank Farm Road NB D 3.50 C 3.45 C 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D 3.31 C 3.87 D S. Higuera St Los Osos Valley Road Suburban Drive NB D 3.99 D 3.90 D 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D 3.73 D 3.75 D Los Osos Valley Froom Ranch Way Madonna Rd NB D 3.38 C 3.47 C 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D 3.57 D 3.61 D Los Osos Valley Calle Joaquin Froom Ranch Way NB D 3.83 D 3.91 D 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D 3.30 C 3.39 C Los Osos Valley US 101 SB Ramps Calle Joaquin NB D 3.56 D 3.64 D 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D 3.74 D 3.74 D Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D 3.71 D 3.87 D 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D 3.46 C 3.48 C Los Osos Valley US 101 NB Ramps S. Higuera St EB D 3.39 C 3.39 C San Luis Ranch Project EIR Section 4.12 Transportation 4.12-107 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Segment Score LOS Segment Score LOS 18 Prado Rd S. Higuera St Froom Ranch Way WB D 3.72 D 3.80 D Prado Rd Froom Ranch Way S. Higuera St EB D 3.69 D 3.67 D 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D 3.42 C 3.71 D Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D 3.51 D 3.57 D 20 Dalidio Dr Madonna Rd SC Project Dwy SB D 3.79 D 3.76 D Dalidio Dr SC Project Dwy Madonna Rd NB D 3.56 D 3.94 D 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 2.63 B 3.04 C Froom Ranch Way Dick's Sporting Goods Dwy Dalidio EB D 3.80 D 3.81 D 24 Dalidio Dr SC Project Dwy Froom Ranch Way SB D 3.70 D 3.69 D Dalidio Dr Froom Ranch Way SC Project Dwy NB D 3.51 D 3.57 D Note: 1. HCM 2010 Methodologies do not model segments bounded by all-way stop control. Procedures have not been developed yet to address the effect of all-way stop control or yield control on intersection performance from a pedestrian or bicyce perspective. No methodology exists for evaluating two-way stop-controlled intersection performance (with the cross-street stop controlled) for pedestrians and bicycles. However, it is incorporated into the methodology for evaluating bicycle segment performance. San Luis Ranch Project EIR Section 4.12 Transportation 4.12-108 Table 4.12-43 Cumulative Plus Project Conditions Segment Level of Service: Transit Analysis AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 1 Madonna Rd Oceanaire Dr LOVR WB D Route 4 4.18 D 4.28 E Madonna Rd LOVR Oceanaire Dr EB D Route 5 4.50 E 4.04 D 2 Madonna Rd Dalidio Oceanaire Dr WB D Route 4 4.50 E 4.59 E Madonna Rd Oceanaire Dr Dalidio EB D Route 5 4.72 E 4.43 E 3 Madonna Rd El Mercado Dalidio Dr WB D Route 4 4.34 E 4.42 E Madonna Rd Dalidio Dr El Mercado EB D Route 5 4.21 D 4.26 E 4 Madonna Rd US 101 SB Ramps El Mercado WB D Route 4 4.35 E 4.52 E Madonna Rd El Mercado US 101 SB Ramps EB D Route 5 4.56 E 4.34 E 5 Madonna Rd US 101 NB Ramps US 101 SB Ramps WB D Route 4 4.15 D 4.28 E Madonna Rd US 101 SB Ramps US 101 NB Ramps EB D Route 5 4.25 E 3.82 D 6 Madonna Rd Higuera St US 101 NB Ramps WB D Route 4 4.33 E 4.44 E Madonna Rd US 101 NB Ramps Higuera St EB D Route 5 4.55 E 4.14 D 7 S. Higuera St Madonna Rd Margarita Ave SB D Route 2 Not Analyzed N/A 3.53 D S. Higuera St Margarita Ave Madonna Rd NB D Route 2 3.69 D 3.85 D 8 S. Higuera St Margarita Ave Prado Rd SB D Route 2 Not Analyzed N/A 4.22 D S. Higuera St Prado Rd Margarita Ave NB D Route 2 4.30 E 4.55 E 9 S. Higuera St Prado Rd Granada Dr SB D Route 2 4.42 E 4.40 E S. Higuera St Granada Dr Prado Rd NB D Route 2 3.85 D 4.02 D 10 S. Higuera St Granada Dr Tank Farm Road SB D Route 2 3.82 D 3.96 D S. Higuera St Tank Farm Road Granada Dr NB D Route 2 3.54 D 3.67 D 11 S. Higuera St Tank Farm Road Suburban Drive SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Suburban Drive Tank Farm Road NB D Route 2 4.06 D 4.02 D 12 S. Higuera St Suburban Drive Los Osos Valley Road SB D - Not Analyzed N/A Not Analyzed N/A S. Higuera St Los Osos Valley Road Suburban Drive NB D - Not Analyzed N/A Not Analyzed N/A 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 4 4.54 E 4.58 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 4 4.23 D 4.40 E 13 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.63 E 4.39 E Los Osos Valley Froom Ranch Way Madonna Rd NB D Route 5 4.34 E 4.19 D 14 Los Osos Valley Froom Ranch Way Calle Joaquin SB D Route 4 4.45 E 4.55 E Los Osos Valley Calle Joaquin Froom Ranch Way NB D - Not Analyzed N/A Not Analyzed N/A 14 Los Osos Valley Madonna Rd Froom Ranch Way SB D Route 5 4.55 E 4.34 E Los Osos Valley Froom Ranch Way Madonna Rd NB D - Not Analyzed N/A Not Analyzed N/A 15 Los Osos Valley Calle Joaquin US 101 SB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 SB Ramps Calle Joaquin NB D Not Analyzed N/A Not Analyzed N/A 16 Los Osos Valley US 101 SB Ramps US 101 NB Ramps SB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps US 101 SB Ramps NB D Not Analyzed N/A Not Analyzed N/A 17 Los Osos Valley S. Higuera St US 101 NB Ramps WB D Not Analyzed N/A Not Analyzed N/A Los Osos Valley US 101 NB Ramps S. Higuera St EB D Not Analyzed N/A Not Analyzed N/A San Luis Ranch Project EIR Section 4.12 Transportation 4.12-109 AM Peak PM Peak ID Roadway From To Direction LOS Threshold Route Name Segment Score LOS Segment Score LOS 18 Prado Rd S. Higuera St Froom Ranch Way WB D Not Analyzed N/A Not Analyzed N/A Prado Rd Froom Ranch Way S. Higuera St EB D Route 2 3.73 D Not Analyzed N/A 19 Froom Ranch Way Dick's Sporting Goods Dwy Los Osos Valley WB D Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Los Osos Valley Dick's Sporting Goods Dwy EB D Not Analyzed N/A Not Analyzed N/A 20 Dalidio Dr Madonna Rd SC Project Dwy SB D Route 4 4.22 D 4.25 D Dalidio Dr Madonna Rd SC Project Dwy SB D Route 5 4.27 E 4.09 D 21 Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 0.00 Not Analyzed N/A Not Analyzed N/A Froom Ranch Way Dalidio Dick's Sporting Goods Dwy WB D 0.00 Not Analyzed N/A Not Analyzed N/A 24 Dalidio Dr SC Project Dwy Froom Ranch Way SB D Route 4 4.25 E 4.22 D Dalidio Dr SC Project Dwy Froom Ranch Way SB D Route 5 4.16 D 4.40 E Notes: 1. Route 2 Serves the Prado Day Center stop during the AM peak hour, and the DMV/Margarita stop during the PM Peak Hour 2. Segment 20 transit is southbound for routes 4 and 5 San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-110 Table 4.12-44 Cumulative Plus Project Conditions Segment Level of Service: U.S. 101 # Interchange Location AM Peak Hour PM Peak Hour Target LOS Segment Type No. of Lanes Volume Density (pc/mi/ln) LOS Volume Density (pc/mi/ln) LOS US 101 at Los Osos Valley Road 1 US 101 NB South of Los Osos Valley Road C Freeway 2 3,481 33.0 D 2,723 24.0 C 2 US 101 SB South of Los Osos Valley Road C Freeway 2 1,835 16.1 B 3,911 40.4 E US 101 at Madonna Road 4 US 101 NB South of Madonna Road C Freeway 2 2,849 25.3 C 2,690 23.7 C 5 US 101 SB South of Madonna Road C Freeway 2 2,090 18.4 C 3,608 35.0 D San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-111 Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan includes a mix of commercial and residential uses, a new transit connection, and workforce housing to balance jobs and housing. The Specific Plan also emphasizes bikeways and pedestrian connections, all of which contribute to reduced trips and VMT. However, as shown in Table 4.12-40 through Table 4.12-44, under Cumulative Plus Project conditions, five study area segment groups (Madonna Road, S. Higuera Street, Los Osos Valley Road, and Dalidio Drive/Prado Road, and Froom Ranch Way), as well as mainline segments of U.S. 101 northbound and southbound at Los Osos Valley road and Madonna Road, would operate at unacceptable automobile, bicycle, pedestrian, and transit LOS based on adopted multimodal LOS standards during AM and PM peak hours. Therefore, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and vehicle queuing standards, and transportation impacts would be potentially significant at these roadway segments. Mitigation Measures. The following mitigation measures identify improvements at study area facilities that are required to reduce potentially significant project-specific impacts to study area roadway segments under Cumulative Plus Project conditions. Each mitigation measure refers to one of the required Transportation Improvement Measures identified in Table 4.12-1 at the beginning of this section. The project’s equitable share of these improvements will be calculated using the method for calculating equitable mitigation measures outlined in the Caltrans Guide for the Preparation of Traffic Impact Studies (Caltrans, December 2002). Costs above and beyond the project’s equitable share can be addressed through such options as fee credits, reimbursement agreements, or development agreements, based on City requirements. T-10(a) Segments #1 - #6: Madonna Road (Higuera Street to Los Osos Valley Road). • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-10(b)Segments #15 - #16: Los Osos Valley Road (Calle Joaquin to U.S. 101 Northbound Ramps). • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) T-10(c)Segment #24: Prado Road/Dalidio Drive (Project Driveway to Froom Ranch Way). • Construct Prado Road Overpass (Overpass with U.S. 101 northbound and southbound ramps) Plan Requirements and Timing. Fair share traffic impact fees shall be paid upon acceptance by the City of final design plans and in accordance with the timing of improvements. Monitoring. City Public Works staff shall confirm payment of applicable fees. City Public Works staff shall also ensure implementation of these improvements following approval of the final design plans for the Specific Plan Area. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-112 Significance After Mitigation. Implementation of the identified mitigation measures would improve LOS at impacted study area roadway segments to acceptable levels, and impacts on these facilities under Cumulative Plus Project conditions would be less than significant after mitigation. However, potential impacts identified for the northbound and southbound lanes of the mainline segments of U.S. 101 at Los Osos Valley Road and Madonna Road under Cumulative Plus Project conditions would not be mitigated to a less than significant level. As a result, impacts under Cumulative Plus Project conditions would remain significant and unavoidable. Potential residual impacts that may result from project mitigation that would require construction of the Prado Road & U.S. 101 overpass (Mitigation Measures T- 10[a], T-10[b], and T-10[c]) are discussed in Section 4.12.54(d). d. Residual Impacts Associated with Off-Site Improvements. Implementation of mitigation measures that require off-site improvements would generally not result in significant residual impacts, as these improvements would occur within existing roadway rights-of-way, or within urbanized paved/landscaped areas immediately adjacent to existing roadway rights-of-way. The primary exception to this is the Prado Road/U.S 101 overpass/interchange, which is required by mitigation measures in Impacts T-1, T-2, T-3, T-8, T-9, and T-10 in Sections 4.12.54(b) and 4.12.54(c). Implementation of mitigation measures that require the development of the Prado Road/U.S. 101 overpass/interchange would improve LOS at impacted intersections and roadway segments in the study area. As described in Section 4.12.54(a), the project would be required to pay a fair share contribution toward infrastructure improvements required to mitigate project impacts. As described in Section 4.12.4, the transportation and circulation impact analysis for the project identifies three general designs of the Prado Road & U.S. 101 interchange, where identified transportation impacts that would result from the project trigger the need for this improvement. These three general designs include: 1. Impacts that trigger the Prado Overpass-Only 2. Impacts that trigger the Prado Overpass Plus U.S. 101 northbound ramps, and 3. Impacts that trigger the Prado Overpass Plus U.S. 101 northbound ramps and U.S. 101 southbound ramps Ultimately, these three general designs represent a tiered approach to constructing a full access interchange at Prado Road and U.S. 101. While a complete interchange could be constructed at one time, this analysis assumes that it may be necessary to build an overpass-only connection for the Prado Road extension, followed by rebuilding the northbound ramps on the east side of U.S. 101, and eventually followed by constructing new southbound ramps on the west side of U.S. 101. Policy 9.2.2 of the Circulation Element requires the sponsors of development projects that contribute to the need for the Prado Road interchange or overpass to prepare or fund the preparation of a Project Study Report (PSR) for the interchange project. A PSR is an engineering report prepared cooperatively by Caltrans and local and regional agencies for projects on the State highway system, with the purpose of documenting agreement on the scope, schedule and estimated cost of a project so the project can be considered for inclusion in a future programming document such as the State Transportation Improvement Program (STIP). The PSR for Highway 101/Prado Road is currently being undertaken, in parallel with the review of the proposed San Luis Ranch Project. As the timing, features, design, and specific area of San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-113 disturbance of the Prado Road/U.S. 101 project comes into greater focus through preparation of the PSR, project-level CEQA review of the impacts of the improvement will be prepared. At this time, because the specific details of the improvement are not known with certainty, a generalized analysis of potential impacts is provided herein. Existing Conditions at U.S. 101 and Prado Road. The western terminus of Prado Road is located immediately east of U.S. 101, with northbound on- and off-ramps for U.S. 101, and an intersection with Elks Lane. North and east of Prado Road and Elks Lane there is an unlined drainage channel that parallels U.S. 101, Sunset drive-in movie theater, and an abandoned gas station located at 253 Elks Lane. A City of San Luis Obispo corporation yard is located south of Prado Road. Description of Potential Improvements at U.S. 101 and Prado Road. While the improvements have not been designed, the following is intended to provide a generalized description of potential characteristics of the improvements. For the purposes of this analysis, the future Prado Road/U.S. 101 overpass/interchange would include a four-lane overpass that would connect Prado Road on the east side of U.S. 101 with the proposed Prado Road Extension (Dalidio Drive) on the west side of U.S. 101, including reconstructed northbound ramps on the east side of U.S. 101 and a new southbound ramp system located primarily within the San Luis Ranch Specific Plan area west of U.S. 101. Elks Lane would be relocated to the east and the Prado Road/U.S. 101 northbound ramp system would be bounded to the east and north by the realigned Elks Lane and to the south by the existing City of San Luis Obispo corporation yard and Water Resource Recovery Facility. Potential Environmental Effects of U.S. 101 and Prado Road Overpass/Interchange. The Prado Road/U.S. 101 overpass/interchange would not involve construction of any new residential units or commercial structures, demolition of any residences or commercial space, or displacement of any residences. However, reconstruction of the northbound ramp system and relocation of Elks Lane would require removal of the U-Haul storage facility located at the northeast corner of Prado Road and Elks Lane. Constructing new southbound ramps on the west side of U.S. 101 would encroach upon existing agricultural fields west of U.S. 101. The proposed interchange would require acquisition of additional right-of-way, either through fee title (purchase of property) or by acquiring a public service easement (PSE). During construction of the overpass, northbound ramps, and southbound ramps, potential issue areas that may be temporarily affected would include air quality, cultural resources, hazards and hazardous materials, water quality, noise and transportation. Construction-related environmental impacts would be mitigated through compliance with City and Caltrans permitting and construction monitoring requirements and standard SLOAPCD dust and diesel emission control measures. Long-term impacts of the Prado Road/U.S. 101 overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. San Luis Ranch Project EIR Section 4.12 Transportation City of San Luis Obispo 4.12-114 This page intentionally left blank. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-1 4.13 WATER RESOURCES This section has been adapted from the Final SB610 Water Supply Assessment (WSA) prepared by Cannon (November 7, 2016; refer to Appendix M). The WSA was prepared for the project, pursuant to the requirements of Section 10910 of the State Water Code, as amended by Senate Bill 610, Chapter 643 (2001). Figures 2-10 and 2-11, included in Section 2.0, Project Description, show the proposed layout of the water and recycled water utility lines within the San Luis Ranch Specific Plan Area, respectively. 4.13.1 Setting a. Water Supply. The City of San Luis Obispo Utilities Department provides potable and recycled water to the community and is responsible for water supply, treatment, distribution, and resource planning. The City is the sole water provider within the City and the City’s potable water is supplied from multiple surface water sources. In addition, groundwater and recycled water are used to supplement irrigation demand. Recycled water may also be used for all approved uses consistent with the City’s Master Permit and Title 22. The Water and Wastewater Element of the City’s General Plan, updated in 2016, specifies that the City shall utilize multiple water resources to meet its water supply needs. Having several sources of water avoids dependence on any one source that may not be available during a drought or other water supply reduction or emergency. According to the Water and Wastewater Element, the City accounts for water supplies necessary to meet three specific community needs: 1) Primary water supply, 2) Reliability reserve, and 3) Secondary water supply. The primary water supply is the amount of water needed to serve the build-out population of the City as identified in the Land Use Element of the General Plan. The reliability reserve provides a buffer for future unforeseen or unpredictable long-term impacts to the City’s available water supply. The secondary water supply is the amount of water remaining from the City’s available water resources above those needed to meet the primary water supply and reliability reserve. The City’s 2015 Urban Water Management Plan (UWMP) provides detailed information on water sources for the City. Surface Water Supply. City surface water supply comes from three sources: Salinas Reservoir, Whale Rock Reservoir, and Nacimiento Reservoir. Each is described in more detail below. Salinas Dam, which created Salinas Reservoir (Santa Margarita Lake), was built in 1942 by the War Department to supply water to Camp San Luis Obispo and to meet the water needs of the City of San Luis Obispo. Salinas Reservoir captures water from a 112-square mile watershed and can store up to 23,843 acre-feet (AF). Since the late 1940s, the San Luis Obispo County Flood Control and Water Conservation District has operated this water supply for the City under a lease from the U.S. Army Corps of Engineers (USACE). Water from the reservoir is pumped through Cuesta Tunnel, a one-mile tunnel through the mountains of the Cuesta Ridge, and then flows by gravity to the City’s Water Treatment Plant on Stenner Creek Road. Whale Rock Reservoir is a 40,662 AF facility created by Whale Rock Dam, an earthen dam on Old Creek near the town of Cayucos. Whale Rock Dam captures water from a 20.3 square mile watershed, and water is delivered through 17.6 miles of 30‐inch pipeline with the assistance of two pumping stations. The City of San Luis Obispo owns 55.05 percent of the water storage San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-2 rights at the reservoir. The remaining water storage rights are divided between the two State agencies with California Polytechnic State University (Cal Poly) owning 33.71 percent and the California Men’s Colony owning 11.24 percent. Nacimiento Reservoir (Lake Nacimiento), which is owned and operated by the Monterey County Water Resources Agency, provides flood protection and groundwater recharge for the Salinas Valley. Since 1959, the San Luis Obispo County Flood Control and Water Conservation District has had an entitlement to 17,500 AFY from the reservoir for use in the County of San Luis Obispo. Approximately 1,750 AFY have been designated for uses around Lake Nacimiento, leaving 15,750 AFY for allocation to other areas within the County. The City’s contractual water right from Nacimiento Reservoir is 5,482 AFY (City of San Luis Obispo UWMP, 2016a). Recycled Water. The primary non-potable water source in the City is the Water Resource Recovery Facility (WRRF; formerly the Water Reclamation Facility), which has a design flow rate of 5,700 AFY (5.1 million gallons per day [gpd]). Water recycling has been envisioned as part of the City’s overall water supply strategy since the 1980s. In 1994, the City completed a major capital improvement project at the WRRF. The improvement project included addition of tertiary treatment and other unit processes required to meet stringent effluent quality limits, set forth by the Regional Water Quality Control Board (RWQCB) with the intention of protecting and enhancing the receiving waters of San Luis Obispo Creek. The City completed construction of the project in 2006 and recycled water deliveries began in May of the same year. The City is currently planning a series of upgrades to the WRRF, which will help the City implement its long-term strategy for resource management. The City’s WRRF effluent meets the criteria for Municipal and Domestic Water Supply (MUN). The MUN designation is the main driver for treatment upgrades at the WRRF. These new requirements have been placed in the WRRF’s recently revised National Pollutant Discharge Elimination System (NPDES) permit to meet nutrient and disinfection by-products limits. The City is required to release 1,807 AFY of flow to San Luis Creek for environmental enhancement. According to the Water and Wastewater Element of the General Plan, the City has used a market assessment, potential customer surveys, and water demand estimates for specific plan areas to estimates a City demand of approximately 1,000 AFY of recycled water. The recorded City recycled water usage for calendar year 2014 was 153 AFY and for calendar year 2015 was 187 AFY. Figure 4.13-1 shows the non-potable irrigation water sources for the proposed land uses within the project site. Groundwater. The principal source of groundwater for the City is the San Luis Obispo Groundwater Basin, and the majority of groundwater use from the basin is for agricultural purposes and private property uses. In 2011, the City relied on groundwater to supply approximately two percent of the City’s annual water demand. However, the City discontinued use of the groundwater as part of its drinking water system in April 2015 due to new regulations requiring additional treatment of the wells prior to use. Previously used wells remain in operable standby condition should the use of groundwater be required in the future to meet City needs. Although the City does not consider groundwater a source of domestic use supply due to limitations on its use, three non-potable wells remain in use for construction and irrigation purposes (City of San Luis Obispo, 2015b). Section 4.13 Water ResourcesSan Luis Ranch Project EIR Non-Potable Irrigation Water Sources Figure 4.13-1 City of San Luis Obispo 0 550275 Feet ± Non-Potable Irrigation Water Sources On-Site Existing Water Wells Reclaimed Water Source: Coastal Community Builders, Inc., March 15, 2016, Cannon, 2016 Multi-Family Residential180.077 SF(39% of Total) Community Gardens/Orchards Open Space Pockets / Corridors38.857 SF Drought TolerantParkways AgricultralHeritage Center90.497 SF Open Space359.806 SF Open SpacePockets/Corridors38.857 SF Open SpacePockets/Corridors38.857 SF Single Family Traditional212.382 SF/201 Parcels(Approx 33% of Total) CommunityPark Turf13.182 SF Community ParkDrought Tolerant19.783 SF Drought Tolerant Parkways133.537 SFDrought Tolerant Parkways133.537 SF Drought TolerantParkways Small LotAlley Loaded21.2082 SF/36 Parcels(Approx 24% of Total) Small LotFront Loaded57.670 SF/73 Parcels(Approx 33% of Total) Open SpacePockets/ Corridors Agricultural Fields2.105.795 SF AgriculturalFields Hotel16.156 SF(10% of Total) Commercial(10% of Total) 4.13-3 San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-4 Water Resource Availability. To ensure water supply reliability, the City has determined the amount of water available from the resources identified above, on an annual basis. The method to determine the available yield from each resource varies based on water right, contractual agreement, or the amount of water actually supplied to the City. “Safe annual yield” refers to the annual amount of water which can be withdrawn annually from the Salinas and Whale Rock Reservoirs under critical drought conditions. Safe annual yield analyses of water supply sources are based on rainfall, evaporation, and stream flow experienced during a historical period. The City’s safe annual yield analysis is based on data from 1943 through 1991 including drought periods in 1946-51, 1959-61, 1976-77, and 1986-91. The Nacimiento Reservoir is operated as a water supply project for Monterey County and thus, safe annual yield is not used for the City’s contractual water supply from this source. As described above, for the Nacimiento Reservoir, “dependable yield” is the City’s contractual water right from this resource. The original amount contracted from the Nacimiento Reservoir for primary supply was 3,380 AFY until March 2016 when City Council approved the addition of 2,102 AFY from Nacimiento Reservoir to the City’s secondary water supply. Recycled water is counted as part of the City’s available water resources based on the annual usage. As the City has discontinued groundwater use, this supply is not included in the estimate of available water resources to meet community needs. Table 4.13-1 provides a summary of the City’s available water resources. Table 4.13-1 City Water Resource Availability Water Resource Annual Availability (AF) Salinas and Whale Rock Reservoirs 1 6,940 Nacimiento Reservoir 2 5,482 Recycled Water 3 187 Siltation from 2010 to 2060 4 (500) Total 12,109 Source: City of San Luis Obispo 2015 Urban Water Management Plan; City of San Luis Obispo, Water Sources. Utilities Department. http://www.slocity.org/government/department-directory/utilities-department/water/water-sources, accessed June 2016. 1. Safe Annual Yield determined from computer model, which accounts for siltation loss through 2010 (per WWME Policy A 4.2.1). 2. Dependable Yield is the contractual amount of water the City has rights to from Nacimiento Reservoir 3. The quantity of recycled water is the actual prior year’s recycled water usage (calendar year 2015) per Policy A 7.2.2 of the General Plan Water and Wastewater Element. 4. Reservoir siltation is a natural occurrence that reduces storage capacity over long periods, resulting in the reduction of safe annual yield. As shown in Table 4.13-1, the City has an annual water supply availability of 12,109 AFY. Water Demand. Water use in the City includes single‐family, multi‐family, commercial (including institutional and industrial), and irrigation customers. No agricultural uses are supplied by City water and the City does not sell water to other agencies. The City does not have additional water demands such as water use for saline barriers or groundwater recharge. During 2015, 68 percent of water use in the City was for single and multi-family residential uses. In 2015, the City’s potable water use was 4,908 AF. The 2016 annual potable water availability includes the City’s primary water supply, reliability reserve, and secondary water supply, totaling 12,109 AFY. Table 4.13-2 shows the City’s current water demand and water availability. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-5 Table 4.13-2 Current Water Demand and Water Availability in the City of San Luis Obispo Water Yield and Demand AFY Primary Water Supply1 7,496 Reliability Reserve2 1,201 Secondary Water Supply3 3,412 2015 Actual Water Demand 4,908 Source: City of San Luis Obispo 2016a; 2016b. 1. Primary water supply is the amount of water needed to serve the build-out population of the City as identified in the Land Use Element of the General Plan. 2. Reliability reserve provides a buffer for future unforeseen or unpredictable long-term impacts to the City’s available water supply. 3. Secondary water supply is the amount of water remaining from the City’s available water resources above those needed to meet the primary water supply and reliability reserve. Current Agricultural Water Demand at the Project Site. Approximately 109 acres of the 131-acre project site are currently used for the production of irrigated row crops including celery, broccoli, lettuce, Asian vegetables, and peas. The 109 acres of agricultural uses on the project site rely on groundwater irrigation wells from the San Luis Obispo Groundwater Basin. Table 4.13-3 shows the property’s current demand on the groundwater basin of approximately 458 AFY based on the Santa Barbara County Environmental Thresholds and Guidelines Manual (2008), which is the best available use factor data in the vicinity of the project area. Table 4.13-3 Current Water Demand at the Project Site Land Use Area (acres) Use Factor Total (AFY) Row Crop Agriculture 109 1.4 AF/acre/season 457.8* Total 457.8 Source: Santa Maria and Lompoc Valleys average for broccoli/cabbage, Table E-9, Santa Barbara County Environmental Thresholds and Guidelines Manual, 2008. * Assumes three growing seasons per year. b. Regulatory Setting. Water Resources. Urban Water Management Planning Act – California Water Code Section 10610. The Urban Water Management Planning Act became part of the California Water Code with passage of Assembly Bill (AB) 797 in 1984. The Act requires every urban water supplier (providing water for municipal purposes to more than 3,000 customers or supplying more than 3,000 AFY of water) to adopt and submit an UWMP at least once every five years to the Department of Water Resources. The City’s most recent UWMP was adopted on June 14, 2016 by the City Council, but has not yet been adopted by the Department of Water Resources. The UWMP provides a description of the City’s service area, demographics, multi-source water supply, treatment, and conveyance/distribution facilities. The UWMP also includes historical and future water demand to serve the buildout of the City consistent with the General Plan. California SB 610 and SB 221. Senate Bill (SB) 610 became effective January 1, 2002, and requires cities and counties to review and consider water supply assessments when evaluating certain development projects to determine if projected water supplies can meet the project’s anticipated water demand. SB 610 also requires lead agencies to consider additional factors in San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-6 the preparation of UWMPs, water supply assessments, and for certain development projects that are otherwise subject to CEQA review. SB 221 requires similar analysis for subdivision maps that meet the threshold review criteria. California Water Code Section 10912. Section 10912 of the state Water Code (also contained in CEQA Guidelines Section 15155) identifies development projects that need to be reviewed and considered for impact on the water supply. Those projects are defined as: (a) a residential development of more than 500 dwelling units; (b) a shopping center or business employing more than 1,000 persons or having more than 500,000 gross square feet of floor space; (c) a commercial office building employing more than 1,000 persons or having more than 250,000 gross square feet; (d) a hotel or motel with more than 500 rooms; (e) an industrial or manufacturing establishment housing more than 1,000 persons or having more than 650,000 gross square feet or 40 acres; (f) a mixed use project containing any of the foregoing; or (g) any other project that would generate a water demand at least equal to a 500 dwelling unit residential project. Water Code Section 10912 applies to the project because it would result in buildout of 580 dwelling units and additional commercial development. As such, the project requires review and consideration of its potential impact on water supply. California SB X7‐7. Senate Bill X7‐7 was enacted in 2009, requiring that water agencies reduce per capita water use by 25 percent by 2020. SBX7‐7 requires each urban retail water supplier to develop urban water use targets to help meet this reduction goal. State and Local Emergency Drought Regulations. On July 15, 2014, the California State Water Resources Control Board (SWRCB) adopted emergency drought regulations to be implemented by all urban water suppliers who have over 3,000 water connections regardless of that community’s water supply situation. Water purveyors who do not implement the mandatory requirements face up to $10,000 per day in fines and penalties. The emergency regulations were in effect for 270 days, but could be rescinded, extended, or amended based on drought conditions. The emergency regulations specifically mandate that the City implement mandatory outdoor water restriction and water waste prohibitions or face maximum fines and no access to State grants or loans. Accordingly, in 2015 the City Council adopted Water Conservation Ordinance section 13.07.030(C) limiting the outdoor irrigation of ornamental landscape and turf with potable water three days a week, and allocated funding for education and public outreach efforts. In response to continued drought conditions, the governor issued Executive Order (EO) B-29-15 on April 1, 2015, requiring municipalities to reduce water consumption. In compliance with EO B-29-15, the SWRCB extended the 2014 emergency regulations and added new measures on March 17, 2015 to achieve a statewide 25 percent reduction in potable urban water usage through February 28, 2016. These new measures required that the City of San Luis Obispo reduce its water use by an average of 12 percent from June 2015 to February 2016. To achieve this reduction, the City Council adopted a drought response strategy in June 2015. This strategy includes: San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-7 • Adoption of a resolution declaring a drought emergency; • Adoption of a resolution to defer new landscape installation or the use of modified landscape plans during the drought emergency; • Introduction of an ordinance amending Chapter 13.07 of the City’s Municipal Code to include two-days-a-week and time-of-day restrictions for outdoor watering. • Approval of an incentive program for high efficiency toilets and washing machines; and • Adoption of a resolution establishing a permit fee for the use of the Corporation Yard groundwater well. City of San Luis Obispo General Plan. The City is the provider of water services to residents of the City. Applicable regulations that would affect the provision of city utilities are based on local policies and other regulations that place requirements on the level of service that must be provided. Established policies and regulations that would apply to the project are provided below. Land Use Element Policy 1.13.1: Water and Sewer Service. The City shall not provide nor permit delivery of City potable water or sewer services to the following areas. However, the City will serve those parties having valid previous connections or contracts with the City. A. Outside the City limits; B. Outside the urban reserve line; C. Above elevations reliably served by gravity-flow in the City water system; D. Below elevations reliably served by gravity-flow or pumps in the City sewer system. Policy 1.13.2: Recycled Water. Provision of recycled water outside of City limits may only be considered in compliance with Water and Wastewater Element Policy A 7.3.4 and the following findings: A. Non-potable/recycled water is necessary to support continued agricultural operations. B. Provision of non-potable/recycled water will not be used to increase development potential of property being served. C. Non-potable/recycled water will not be further treated to make it potable. D. Prior to provision of non-potable/recycled water, the property to be served will record a conservation, open space, Williamson Act, or other easement instrument to maintain the area being served in agriculture and open space while recycled water is being provided. Policy 3.7.4: Utility Service. The City shall require Services and Manufacturing uses to connect to the City water and sewer systems, unless other means of providing service are identified in a City-adopted plan. Water & Wastewater Management Element (WWME) Policy A 2.2.1: Multiple Water Sources. The City shall utilize multiple water resources to meet its water supply needs. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-8 Policy B 2.2.2: Service Capacity. The City's wastewater collection system and Water Reclamation Facility shall support population and related service demands consistent with the General Plan. Policy B 2.2.3: Wastewater Service for New Development. New development shall pay its proportionate or “fair share” of expanded treatment and collection system capacity and upgrades. New development will only be permitted if adequate capacity is available within the wastewater collection system and/or Water Reclamation Facility. Conservation and Open Space Element Policy 10.2.2: Ahwahnee Water Principles. - In planning for its water operations, programs and services, the City will be guided by the Ahwahnee Water Principles and will encourage individuals, organizations, and other agencies to follow these policies: A. Community design should be compact, mixed use, walkable and transit-oriented so that automobile generated urban runoff pollutants are minimized and the open lands that absorb water are preserved to the maximum extent possible. B. Natural resources such as wetlands, flood plains, recharge zones, riparian areas, open space, and native habitats should be identified, preserved and restored as valued assets for flood protection, water quality improvement, groundwater recharge, habitat, and overall long-term water resource sustainability. C. Water holding areas such as creekbeds, recessed athletic fields, ponds, cisterns, and other features that serve to recharge groundwater, reduce runoff, improve water quality and decrease flooding should be incorporated into the urban landscape. D. All aspects of landscaping from the selection of plants to soil preparation and the installation of irrigation systems should be designed to reduce water demand, retain runoff, decrease flooding, and recharge groundwater. E. Permeable surfaces should be used for hardscape. Impervious surfaces such as driveways, streets, and parking lots should be minimized so that land is available to absorb storm water, reduce polluted urban runoff, recharge groundwater and reduce flooding. F. Dual plumbing that allows grey water from showers, sinks and washers to be reused for landscape irrigation should be included in the infrastructure of new development, consistent with State guidelines. G. Community design should maximize the use of recycled water for appropriate applications including outdoor irrigation, toilet flushing, and commercial and industrial processes. Purple pipe should be installed in all new construction and remodeled buildings in anticipation of the future availability of recycled water. H. Urban water conservation technologies such as low-flow toilets, efficient clothes washers, and more efficient water-using industrial equipment should be incorporated in all new construction and retrofitted in remodeled buildings. I. Ground water treatment and brackish water desalination should be pursued when necessary to maximize locally available, drought-proof water supplies. Policy 10.3.1: Efficient Water Use. The City will do the following in support of efficient water use, and will encourage individuals, organizations, and other agencies to do likewise: San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-9 A. Landscaping: 1. Choose plants that are suitable for the climate and their intended function, with emphasis on use of native and drought-tolerant plants. 2. Prepare soils for water penetration and retention. 3. Design and operate suitable and efficient irrigation systems. 4. The City will encourage drought-tolerant landscaping, vegetable gardens and fruit trees in lieu of large expanses of lawn or other more water-demanding plantings. 5. Landscape maintenance: Landscaped areas will be properly designed for upkeep and replacement of low-flow irrigation fixtures and equipment. 6. Facilitate use of tertiary-treated water and seek to legalize use of grey water for non-potable household purposes. 4.13.2 Previous Program-Level Environmental Review The 2014 Land Use and Circulation Elements Update EIR (LUCE Update EIR) previously analyzed impacts to utilities – including water supply and infrastructure – related to the adoption and implementation of the 2014 Land Use and Circulation Elements (LUCE), including planned future land use development and proposed goals, policies, and programs. The LUCE Update EIR concluded that implementation of the General Plan policies would ensure that future land use and development under the adopted Land Use and Circulation Elements would not exceed service capacities for water supply. In particular, the City’s General Plan, Conservation and Open Space Element (COS) Policy 10.2.2 Ahwahnee Water Principles, promotes maximizing the use of recycled water for appropriate applications, including outdoor irrigation, toilet flushing, and commercial and industrial processes (City of San Luis Obispo 2014a). Accordingly, the LUCE Update EIR found water supply impacts associated with City land use buildout to be less than significant. 4.13.3 Impact Analysis a. Methodology and Significance Thresholds. To analyze impacts to water resources, the development potential under the project was compared to the available capacity of facilities that serve the project site. In accordance with Appendix G of the State CEQA Guidelines, the effects of the San Luis Ranch project on water resources would be significant if the project would: • Have insufficient water supplies available to serve the project from existing entitlements and resources, or are new and expanded entitlements needed; The Initial Study (refer to Appendix A) determined that the project would have a less than significant impact on other public services and utilities checklist items from Appendix G of the State CEQA Guidelines, including wastewater issues and infrastructure, stormwater facilities, and solid waste disposal and facilities. Refer to Section 4.14, Issues Addressed in the Initial Study, for a discussion of these less than significant impacts. The project’s potential impacts to water supply are discussed below. Project water use estimates are based on duty factors found within the General Plan as well as information provided within the WSA. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-10 b. Project Impacts and Mitigation Measures. Threshold: Would the project have sufficient water supplies available to serve the project from existing entitlements and resources, or are new and expanded entitlements needed? Impact WR-1 The project would increase water demand as a result of new residential and commercial development on the project site. However, the project’s water demand would be within the City of San Luis Obispo’s projected primary water supply. Therefore, impacts to water supply would be Class III, less than significant. Municipal Water Demand and Supply. The project would result in development of single- family and multi-family dwelling units, commercial uses including retail, office, and hotel space, and parks and open space on the project site. 40.7 percent of the site would remain in agricultural use. Table 4.13-4 shows the City’s municipal water use factors for each land use category. Table 4.13-4 City Municipal Water Use Factors for Land Use Categories Land Use Municipal Water Use Factors Single-family residences (traditional) 0.3 AFY/unit Single-family residences (small lot) 0.21 AFY/unit Apartment (multi-family/affordable) 0.18 AFY/unit Neighborhood commercial 0.3 AFY/1,000 square feet Parkland 2 AFY/acre Hotel 0.122 AF/room/day Office space 0.1 AF/day/1,000 SF Source: Cannon, 2016 (Appendix M). The municipal water use factors in Table 4.13-4 were developed in 2008 and are the basis upon which the City reviews proposed water usage. Since 2008, the City and State have implemented water conservation measures for indoor and outdoor water usage. As a result, the 2008 water duty rates are up to 30 percent higher than the City’s water usage rates in 2015. Nevertheless, these factors provide a conservative estimate of the project’s projected water use. Table 4.13-5 shows the project’s water demand, based on the City’s water use factors. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-11 Table 4.13-5 San Luis Ranch Project Water Demand: City Water Use Factors Land Use Water Use Factor Quantity Water Demand (AFY) Single-family residences (traditional) 0.3 AFY/unit 200 units 60.0 Single-family residences (small lot) 0.21 AFY/unit 100 units 21.0 Apartment (multi-family/affordable) 0.18 AFY/unit 280 units 50.4 Neighborhood commercial 0.3 AFY/1,000 SF 150,000 SF 45.0 Parkland 2 AFY/acre 3.4 acres 6.8 Hotel 0.122 AF/room/day 200 room 24.4 Office space 0.1 AF/day/1,000 SF 100,000 SF 10.0 Total (AFY) 217.6 Based on the City Water Use Factors and the Final Water Supply Assessment (Cannon, 2016; Appendix M). As shown in Table 4.13-5, based on the City’s water demand factors, the total municipal water use by the project would be 217.6 AFY. Table 4.13-6 provides a summary of the project’s water demand under each land use proposed for the project site. In contrast to projected water demand based on the City’s water use factors, the water demands presented in Table 4.13-6 reflect the implementation of measures of State and local water saving programs, created in response to recent drought conditions, into specific components of the project. The average indoor and outdoor customer water use is provided in the American Water Works Association’s A Guide to Customer Water-Use Indicators for Conservation and Financial Planning and totaled 50 GPCD. The irrigation demand (outdoor water use) was calculated and presented in the Preliminary Irrigation Water-Use Estimate (Appendix A to the WSA, which is included as Appendix M to this EIR) and totaled 13 gallons per capita per day (GPCD). The residential indoor domestic water use is the result of the average indoor and outdoor customer use of 50 GPCD minus the irrigation use of 13 GPCD from the Preliminary Irrigation Water-use Estimate, totaling 37 GPCD of water use. The indoor demand for the hotel, commercial uses, and agricultural heritage center were estimated assuming that the State and local required drought response programs would be able to reduce the water usage by approximately 30 percent from the City water use factors presented above. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-12 Table 4.13-6 San Luis Ranch Project Water Demand: Project-Specific Land Use Person Per Unit Water Use (GPCD) Irrigation Demand Potable (gal/yr) Irrigation Demand Non- Potable (gal/year) Indoor Domestic Demand (gal/year) Total 200 SFR (traditional) 2.29 37 2,155,307 6,185,291 8,340,598 100 SFR (small lot) 2.29 37 736,872 3,092,645 3,829,517 180 (MFR)/ 80 (affordable; 420 SF max) 2.29 (MF) 1.25 (Affordable) 37 1,277,991 6,846,183 8,124,174 Hotel (200 rooms) 495,325 5,070,210 5,565,535 Commercial + Office 1,723,631 8,003,979 9,727,611 Community Garden Orchards 317,056 317,056 Open Space Pocket/ Connections 12,197,892 12,197,892 Agricultural Heritage Center 2,768,937 3,423,656 6,192,593 Community Park (turf) 403,330 403,330 Community Park (drought tolerant) 605,300 605,300 Parkways (drought tolerant) 4,085,832 4,085,832 Total (gallons/year) 3,209,236 23,558,239 32,621,963 59,389,438 Total (AFY) 9.8 72.3 100.1 182.3 Source: Cannon, 2016 (Appendix M). As shown in Table 4.13-6, the estimated total water demand for the project, with implementation of water saving measures under State and local drought response programs, is 182.3 AFY. This is approximately 35 AFY lower than the estimated water demand using the City’s water demand factors (refer to Table 4.13-5). Table 4.13-7 compares the City’s available water with the project’s projected usage. Table 4.13-7 Comparison of City Water Supply to Project Use City Water Supply City Water Use City Water Availability Projected Demand (with proposed water saving measures) Project Demand (by City use factors) 7,496 AFY 4,908 AFY 2,588 AFY 182.3 AFY 217.6 AFY Source: Cannon, 2016 (Appendix M). Municipal water demand, calculated using City use factors for the uses proposed under the project, would be 217.6 AFY or 8.4 percent of the City of San Luis Obispo’s current available potable water of 2,588 AFY. The 182.3 AFY of water demand generated by the specified components of the project, including implementation of required water conservation measures, represents 7.0 percent of the City’s current available water of 2,588 AFY above current demand levels. Accordingly, the City has sufficient existing municipal water supply to provide potable water to the project. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-13 Consistent with Ahwahnee Water Principles and the City’s General Plan, Conservation and Open Space Policy 10.2.2, the project would be required to irrigate parks, open space, and landscaping with recycled water. Project irrigation design would be required to use available tools to ensure water efficiency, including utilizing dedicated landscape water meters, soil moisture sensors, central irrigation controllers and master valves combined with flow sensors as well as weather based irrigation controllers that are tied to California Irrigation Management Information System (CIMIS) weather data for the larger landscape areas. Groundwater. In addition to new development on the project site, the project would preserve approximately 52.7 acres of the site in agriculture. This is a reduction of approximately 56 acres from the 109 acres currently being used for production of irrigated row crops on the site. Ongoing agricultural uses on the project site would be irrigated using water from existing on-site groundwater wells. Using an agricultural water demand factor of 1.4 AF/acre/season (County of Santa Barbara, 2008), post-project agricultural operations on the project site would result in a water demand of approximately 221 AFY. This represents a 52 percent reduction in water demand on the San Luis Obispo groundwater basin. However, this reduction in water demand associated with agricultural uses would be isolated to the groundwater irrigation wells onsite, and would not change the project’s demand on the City’s municipal water supply. Mitigative Components of the Specific Plan and Impact Conclusion. The San Luis Ranch Specific Plan Section 7.2.1, Potable and Non-Potable Water Systems, includes water conservation measures intended to manage on-site water consumption associated with development under the Specific Plan, including: • Requirements that all landscaped areas include drought-tolerant landscape to the maximum extent possible. • Use of recycled water for exterior landscaped areas reducing the consumption of potable water. • Use of the latest technology in low-flow water fixtures, including water efficient heating appliances, in the project. • Interior reuse of gray water to the maximum extent allowed by law. • Onsite rainwater harvesting, including water storage cisterns as a means of capturing rainwater for use. • San Luis Ranch will use less water than the current agricultural use by a significant amount. Nevertheless, the project would create an additional long-term demand for City water supplies. As City water supply would be sufficient to serve the project’s estimated demands, impacts to the City’s water supply would be adverse but less than significant. Furthermore, the project proposes to use recycled water for parks, open space and landscaping, and includes measures to ensure landscaping water efficiency, consistent with the City’s General Plan policies. Development of the project site would require payment of water impact fees to the City of San Luis Obispo. Therefore, this impact would be less than significant. Mitigation Measures. No mitigation would be required. Residual Impact. This impact would be less than significant without mitigation. San Luis Ranch Project EIR Section 4.13 Water Resources City of San Luis Obispo 4.13-14 c. Cumulative Impacts. Planned buildout of the City of San Luis Obispo under the General Plan would result in increased water demand and the project would contribute to this cumulative demand. The City’s General Plan allows for the development of up to 4,904 additional dwelling units and approximately five million square feet (SF) of non-residential land uses in the City. As described in Section 2.0, Project Description, the project includes a similar extent of overall development to that which would be permitted under the General Plan performance standards. In addition, as discussed in Impact WR-1, water savings measures are not accounted for in the City’s water use factors. Therefore, the cumulative analysis of water supply impacts provided herein is conservative. Table 4.13-8 shows the total additional water demanded by buildout of allowable uses under the General Plan using the City’s water use factors. Table 4.13-8 Estimated Water Demand from Cumulative Projects in the City of San Luis Obispo Land Use Size Demand Rate Water Demand (AFY) Residential 4,904 dwelling units 0.17 AFY/unit1 834 Non-residential 5,081,708 square feet 0.30 AFY/1,000 square feet2 1,525 Total 2,359 Source: Cannon, 2016 (Appendix M); City of San Luis Obispo Land Use and Circulation Update Final Program EIR, September 2014 (City of San Luis Obispo 2014b). 1. The demand rate for single-family and multi-family residential units was averaged and applied to all residential development. 2. The neighborhood commercial rate was conservatively applied to all non-residential development. The total estimated water demand from cumulative projects in the City (including the proposed project) would be 2,359 AFY, which represents approximately 91 percent of the current City’s existing water availability of 2,588 AFY. As this figure includes the maximum development potential of the project site, the project’s impact on municipal water supply would not be cumulatively considerable such that water demand would exceed supply when combined with all possible future development within the City. In addition, the project would reduce the overall demand on the San Luis Obispo groundwater basin as a result of reduced on-site agricultural uses and, therefore, would not exacerbate potential cumulative impacts on the local groundwater basin associate with future development within the City. Accordingly, the City has sufficient existing and future water supply to provide potable water to the project in combination with planned future development in the City, and the project’s cumulative water supply impact would be less than significant. San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-1 4.14 ISSUES ADDRESSED IN THE INITIAL STUDY This section addresses the potential environmental effects of the project that were determined to be less than significant or significant but mitigable, as described in the Initial Study for the project (refer to Appendix A). The items listed below are contained in the City’s environmental checklist form and the environmental checklist form included in Appendix G of the State CEQA Guidelines. Each subsection listed below includes the checklist items from the State CEQA Guidelines that are addressed in this section. Any items not addressed in this section have been addressed in Section 4.0, Environmental Impact Analysis, of this EIR. Section 4.0 also includes an expanded discussion of the settings under each environmental issue area discussed therein. The Initial Study determined that the project, with implementation of specified mitigation measures, would not result in adverse impacts related to Geology and Soils (seismic and groundshaking hazards, and liquefaction, settlement, expansion and subsidence hazards). Mitigation measures for the issue areas are discussed below and provided in the Executive Summary. A summary of the analysis of issue areas for which no significant adverse impacts were identified is provided in this section. Please refer to the Initial Study (Appendix A) for the complete issue area analysis. 4.14.1 Agriculture Resources Would the project: • Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Williamson Act contract is in effect on the project site. No impact would occur. Impacts of the project due to conflict with existing zoning for agricultural use are addressed in detail under Impact AG-2 in Section 4.2, Agricultural Resources. 4.14.2 Air Quality Would the project: • Create objectionable odors affecting a substantial number of people? The project includes commercial, office, and residential development. None of these uses are anticipated to produce objectionable odors that would affect a substantial number of people in the area. This impact would be less than significant. 4.14.3 Biological Resources Would the project: • Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; and/or • Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-2 The project Initial Study concluded that the project would not conflict with applicable local policies or ordinances to protect biological resources (refer to Appendix A). This issue was further analyzed in Section 4.9, Land Use and Policy Consistency, which includes detailed discussions of the Specific Plan’s compliance with applicable local policies. As described therein, the project would not conflict with local policies or ordinances protecting biological resources. Refer to Section 4.9, Land Use and Policy Consistency, for detailed discussion of this issue. The project site is not part of any adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Therefore, the project would not conflict with any such plans, and no impact would occur. 4.14.4 Cultural Resources Would the project: • Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? According to the Geologic Map of California, San Luis Obispo Sheet published by the California Division of Mines and Geology (CDMG) in 1978, the site vicinity is underlain by Quaternary aged alluvium (unconsolidated deposits of sand, silt, clay, and gravel). The surrounding hills are comprised of the Franciscan and Monterey Formations and Quaternary aged non-marine terrace deposits. These geologic features are not commonly associated with paleontological resources. There are no known unique paleontological resources or sites, or unique geologic features on the project site. Therefore, impacts to such resources would be less than significant. 4.14.5 Geology and Soils Would the project: • Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving; o Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42; o Strong seismic ground shaking; o Seismic-related ground failure, including liquefaction; or o Landslides; • Result in substantial soil erosion or the loss of topsoil; • Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse; • Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property; and/or • Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-3 Seismic and Groundshaking Hazards. The nearest fault mapped in the vicinity of the project site is the Los Osos Fault, which lies approximately 0.5 mile to the southwest of the project site. According to the California Division of Mines and Geology, the Los Osos Fault is capable of a magnitude 6.8 earthquake. The nearest Alquist-Priolo Earthquake Fault Zone is located approximately 1.5 miles west-northwest of the site, along the Los Osos Fault. Due to the proximity of the site to the Los Osos Fault and Alquist-Priolo Zone, impacts associated with earthquakes and ground shaking would be potentially significant. Compliance with standard engineering requirements, including the 2010 California Building Code (CBC), City of San Luis Obispo Municipal Code as described in the Land Use and Circulation Element Update Environmental Impact Report (LUCE Update EIR), and the most recent California Department of Transportation seismic design standards would be required for the project. In addition, Mitigation Measures GEO-1 and GEO-2 below would be required to reduce potential project impacts associated with earthquakes and ground shaking to a less than significant level. Grading and Topsoil. Refer to Section 4.8, Hydrology and Water Quality, for detailed discussion of potential impacts associated with erosion. Refer to Section 4.2, Agricultural Resources, for detailed discussion of potential impacts to topsoil. Liquefaction, Settlement, Expansion, and Subsidence. According to the Safety Element of the City’s General Plan, the project site has been identified as being located in an area of very high liquefaction potential, moderate to high expansion potential, and high settlement potential. In addition, during historical drought years, groundwater levels in the site vicinity were lowered enough to cause subsidence. In response to these potential impacts, Mitigation Measures GEO-3 through GEO-8 from the Initial Study were developed and required the preparation of a site specific geotechnical study to determine the potential for a variety of soil hazards on the project site including, liquefaction, settlement, expansion, and subsidence. These measures required that the geotechnical study provide suitable measures to reduce identified potentially significant impacts related to potentially hazardous characteristics of on-site soils. In compliance with Mitigation Measures GEO-3 through GEO-8 from the Initial Study, a site specific investigation of on-site soils and Soils Engineering Report were prepared for the project by GeoSolutions, Inc. on May 29, 2015. Based on the investigation of on-site soils, it was determined that the presence of sandy soils, the relative density of in-situ soils, the depth to groundwater, and the expected ground acceleration caused by an earthquake provide high potential for seismic liquefaction on the project site. Liquefaction would be likely to occur in the sandy soil layers between the depths of 13 to 50 feet below ground surface and may manifest at the surface as seismically induced settlements. Seismically induced settlements were estimated to be on the order of 1.0 to 3.5 inches. The site specific investigation also identified the presence of expansive soil materials in the soil zone within the upper two to three feet of the site. The geotechnical investigation recommended measures to reduce these impacts to a less than significant level. In addition, on July 15, 2014 the California State Water Resources Control Board adopted emergency drought regulations, which apply to the City of San Luis Obispo’s urban water supplier. These regulations would be applicable during any future drought conditions and include measures which would also implement Mitigation Measure GEO-3 of the Initial Study and prevent soil subsidence on the project site. San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-4 Mitigation Measure GEO-3 below has been adapted from recommended measures in the Soils Engineering Report and would be required to reduce the project’s potential impacts related to on- site geology and soils to less than significant levels. Mitigation Measures. GEO-1 Earthquake and Ground Acceleration Design and Construction Measures. Design and construction of the buildings, roadway infrastructure and all subgrades shall be specifically proportioned to resist Design Earthquake Ground Motions (Design amax) of SD1=0.481 and SDS=0.832 and engineered to withstand Maximum Considered Earthquake (MCE) peak ground acceleration (PGAM) equal to 0.519 g, as described in the Soils Engineering Report for the project (GeoSolutions, Inc., 2015). The design should take into consideration the soil type, potential for liquefaction, and the most current and applicable seismic attenuation methods that are available. GEO-2 Operational Seismic Safety Requirement. For retail stores included in the project, goods for sale may be stacked no higher than 8 feet from the floor in any area where customers are present, unless provisions are made to prevent the goods from falling during an earthquake of up to 7.5 magnitude. The stacking or restraint methods shall be reviewed and approved by the City before approval of occupancy permits, and shall be a standing condition of occupancy. GEO-3 Geotechnical Design. The project plans and specifications shall include the geotechnical recommendations included in the Soils Engineering Report, prepared by GeoSolutions, Inc. on May 29, 2015. Recommendations therein that shall be incorporated into the final project building plans include specification for the following components of development preparation and design: • Building Pad Preparation • Paved Areas Preparation • Pavement Design • Interlocking Concrete Pavers • Conventional Foundations • Post-Tensioned Slabs • Slab-On-Grade Construction • Retaining Walls • Exterior Concrete Flatwork Residual Impact. With implementation of the mitigation described above, impacts related to geology and soils would be less than significant. 4.14.6 Hazards and Hazardous Materials Would the project: San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-5 • Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? • For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area; and/or • Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? The project Initial Study concluded that the project would result in a less than significant impact associated with hazards to the public or the environment due to listed hazardous materials sites. This issue has been further analyzed in Section 4.7, Hazards and Hazardous Materials, based on an updated search of applicable databases and reports for records relating to any known hazardous materials contamination within the San Luis Ranch Specific Plan Area. Based on the updated search results, the project was found to result in a potentially significant impact associated with hazardous materials sites, and would require mitigation to reduce potential impacts to a less than significant level. Refer to Section 4.7, Hazards and Hazardous Materials, for analysis detailed discussion of this issue. In November 2014, Cleath-Harris Geologists, Inc. (Cleath-Harris) prepared a Hydrogeologic Description and PCE Characterization for Dalidio Laguna Ranch, San Luis Obispo County, California report (Hydrogeology Report; refer to Appendix H), which identified tetrachloroethylene (also called perchloroethylene, or PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. The project site is located adjacent to commercial uses to the northeast and residential uses to the southwest. Dry cleaning facilities have been recorded present to the north of the site as early as the 1930s. According to the Hydrogeology Report, the identified PCE groundwater contamination is attributed to spills at these hydrologically upgradient dry cleaning facilities. Shallow groundwater at the site generally flows towards the south-southwest, and wells on the project site have exhibited PCE groundwater contamination above the United States Environmental Protection Agency (U.S. EPA)/Central Coast Regional Water Quality Control Board (RWQCB) Maximum Contaminant Level (MCL) for drinking water of 5 micro grams per liter (µg/L). Cleath-Harris Analyzed PCE concentrations in four on-site wells and two off-site City wells to the south and the east of the site. The highest concentrations of PCE were detected at wells near U.S. 101 along the eastern side of the project site. PCE contamination is within the shallow aquifer groundwater (refer to Appendix H for detailed PCE characterization results). Groundwater within the deep aquifer could not be isolated in existing wells on the project site. Therefore, the PCE concentration in the deep aquifer is unknown. The domestic water well has a PCE concentration of 1.0 µg/L, which is within the U.S. EPA/RWQCB MCL for drinking water of 5.0 µg/L. The irrigation groundwater well has a PCE concentration of 9.5 µg/L, which exceeds the U.S. EPA MCL. In July 2015, EnviroAssets, Inc. and GeoSolutions, Inc. prepared a Shallow Soil Vapor Assessment Report (Appendix H), to summarize active soil gas sampling conducted at the project site in November 2014, and February and March 2015. Concentrations of volatile organic compounds identified in soil vapor samples collected during the vapor assessment were compared with Environmental Screening Levels (ESLs) provided by the RWQCB. The RWQCB provides ESLs for residential and commercial property use scenarios because land use is a consideration in the types of exposure that are possible when environmental risks are San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-6 evaluated. No chemicals were detected in soil vapor samples above ESLs applicable to the proposed use of the sampled areas. PCE was detected in 36 of 47 analyzed samples (77 percent). All detections for PCE except from location SV-46, located at the southern tip of the project site in the proposed Agricultural area, were below residential ESLs. The maximum concentration of PCE detected in the sample collected at location SV-46 of 382.71 micrograms per cubic meter (µg/m3) is below the commercial ESL. Additionally, sampling results were not indicative of an on-site source for PCE and were consistent with passive migration of a dilute groundwater plume beneath the project site from off-site sources. In September 2015, the RWQCB reviewed the Shallow Soil Vapor Assessment Report. Based on the review of the Shallow Soil Vapor Assessment Report and the data therein, the RWQCB concludes that the project site does not pose a major threat to human health from vapor intrusion to any of the proposed development included in the project and no further action is necessary regarding solvents detected on the project site. Therefore, impacts associated with hazardous materials sites located in the vicinity of the project site are less than significant. The project site is not within the vicinity of a private air strip which could cause a potential safety hazard for people residing or working in the project area. Therefore, the project would not result in any safety impact to people living or working in the project area. The project site is an infill site, and not directly adjacent to any wildlands. Development would not interfere with any emergency evacuation routes in the event of a disaster. Project plans would be required to be evaluated by the Fire Marshal and comply with applicable Uniform Fire Code, CBC, and General Plan policies. Compliance with these requirements would ensure that the risk of injury or damage from wildland fires and impacts would remain less than significant. As discussed in the summary of potential hazards and hazardous materials in Section 4.7.1(d), there are overhead transmission lines in the vicinity of the project site. However, these lines are elevated such that they are not close enough to pose a risk to residents and other users of the project site associated with electromagnetic fields. Additionally, the project site is located approximately 10 miles east-northeast of the Diablo Canyon Nuclear Power Plant. Radiation hazards associated with Power Plant are region-wide, and not specific to this site. As such, potential radiation hazards to development in the City of San Luis Obispo are addressed in the Land Use and Circulation Element Update of the City’s General Plan. Therefore, potential impacts associated with electromagnetic fields or radiation would be less than significant. 4.14.7 Hydrology and Water Quality Would the project: • Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of preexisting nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted); • Expose people or structure to a significant risk of loss, injury, or death involving flooding, including flooding as the result of failure of a dam or levee; and/or • Expose people or structures to a significant risk of loss, injury or death involving inundation by seiche, tsunami, or mudflow? San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-7 The project Initial Study concluded that the project would result in no impact related to flooding as the result of failure of a levee or dam. This issue is also discussed in Section 4.8, Hydrology and Water Quality. Based on the discussion therein, adapted from the Final SB610 Water Supply Assessment (WSA) for the project (refer to Appendix M) and information in the City’s 2015 Urban Water Management Plan (UWMP), the project would not result in a significant impact from flooding as a result of dam or levee failure. Refer to Section 4.8, Hydrology and Water Quality, for a detailed discussion of this issue. The project would be consistent with the buildout parameters included in the General Plan, for which adequate water supply has been planned. The project would be served by the City’s sewer and water systems and would not deplete groundwater resources. This impact would be less than significant. According to the Safety Element of the General Plan, the City and the proposed development are not subject to inundation from seiche or tsunami, and the existing upslope projects do not generate significant storm water runoff such to create a potential for inundation by mudflow. Therefore, there would be no impact related to the potential for inundation by seiche, tsunami, or mudflow at the project site. 4.14.8 Land Use and Planning Would the project: • Physically divide an established community; and/or • Conflict with any applicable habitat conservation plan or natural community conservation plan? Proposed development under the project would be designed to fit among existing surrounding urban development and would not physically divide an established community. Therefore no impacts would result with regards to dividing an established community. There are no applicable natural community conservation plans that include the site, or are affected by development at that location. 4.14.9 Mineral Resources Would the project: • Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state; and/or • Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? Mining is not permitted within the City, pursuant to Section 17.08.070 of the Zoning Regulations. There are no known mineral resources on the project site. The project site is not designated by the General Plan, the proposed Specific Plan, or other land use plans as a locally important mineral recovery site. Therefore, no impacts related to mineral resources would occur. San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-8 4.14.10 Noise Would the project result in: • A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project; • A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project; • For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels; and/or • For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? Based on the program analysis for the LUCE Update EIR, the project Initial Study concluded that the project would not result in substantial increases in ambient noise levels in the project vicinity. This issue was further examined in the project-level analysis in Section 4.10, Noise, based on the specific types and level of development proposed for the San Luis Ranch Specific Plan Area under the project. Based on the project-level analysis therein, the project would result in potentially significant impacts relative to ambient noise increases due to project-related construction as well as siting new residential units in close proximity to new commercial development. Implementation of Mitigation Measures N-1(a) through N-1(g) would reduce the potential construction noise impact to the maximum extent feasible, but this impact would remain significant and unavoidable. However, Mitigation Measures N-4(a) and N-4(b) would ensure that noise levels at residences on the project site would not exceed the City’s standards for intermittent noise and, thus, reduce this potential impact to a less than significant level. Refer to Section 4.10, Noise, for the full, project-level analysis of these issues. The project would occur within the projected 50-55 dB contour from the San Luis Obispo County Regional Airport, based on the Airport Land Use Plan. Table 1 of the General Plan Noise Element states that the maximum normally acceptable noise exposure for outside residential activities is 60 dB. Residential uses included in the project would not experience noise sources that exceed significance thresholds and this impact would be less than significant. The project is not within the vicinity of a private airstrip. Therefore, there would be no impact associated with exposure to excessive noise from a private airstrip. 4.14.11 Population and Housing Would the project: • Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure); • Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere; and/or • Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-9 The City of San Luis Obispo has a population of 45,802 (DOF 2015). Development of the project would add an estimated 1,293 residents to the City (546 new single family and multi-family dwelling units x 2.29 people/unit and 34 new affordable units x 1.25 people/unit).1 When added to the existing population within the City of approximately 46,117 (California Department of Finance 2016), buildout of the Specific Plan Area would increase the City’s total population to an estimated 47,410 residents, an increase of 2.8 percent. The population projections in the City’s General Plan Land Use Element account for development of the San Luis Ranch Specific Plan Area and potential impacts have been addressed in the LUCE Update EIR. As such, the increase in the City’s population resulting from the project would be consistent with the population projections expected under the General Plan. Furthermore, the potential number of dwelling units (25,601) that could be located in the City after buildout of the Land Use Element (which includes development of the project site), would not exceed the one percent per year maximum number of dwelling units (25,762) specified by Land Use Element Policy 1.11.2 (Residential Growth Rate). Therefore, population growth that may result from the project would not conflict with local growth management policy or result in exceedance of local and regional growth projections, and impacts would be less than significant. In addition, no existing homes or residents would be displaced within the San Luis Ranch Specific Plan area as a result of project implementation. Therefore, no impacts related to the displacement of housing or people would occur. 4.14.12 Public Services Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: • Fire protection; • Police protection; • Schools; • Parks; and/or • Other public facilities? By increasing the population and the number of structures in the City of San Luis Obispo, buildout of the project site would increase the demand for fire and police protection services, and increase users of area roadways and other transportation infrastructure such that new or expanded facilities may be necessary. The project applicant would be required to pay fair share development impact fees that would provide for improved services as necessary. The proposed San Luis Ranch development is consistent with the City’s LUCE and service facilities have been planned to meet the additional service demand. The environmental impacts of such facilities were addressed in the LUCE Update EIR. Additionally, a Fire Flow Analysis was prepared for the project on March 18, 2016 by Cannon and determined that the San Luis Ranch water system would be able to meet the required fire flow and pressures throughout the site. Therefore, 1 Population growth rate from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-10 impacts to fire and police protection services associated with the project would be less than significant. The San Luis Coastal Unified School District provides educational services for the City of San Luis Obispo, City of Morro Bay, and the communities of Los Osos, Baywood, and Avila Beach. The District 2015-2016 K-12 enrollment is 7,640 students (San Luis Coastal Unified School District, Developer Fee Justification Study, 2016). Table 4.14-1 provides a summary of the number of students generated by the residential component of the project based on the District student yield rates from the 2016 Developer Fee Justification Study. Table 4.14-1 San Luis Ranch Student Generation Grade Level Student Yield Rates1 Proposed Development Student Generation SFD/SFA MF SFD/SFA MF K-6 0.302 0.116 200 380 60.4 + 44.1 = 105 7-8 0.064 0.032 12.8 + 12.2 = 25 9-12 0.119 0.066 23.8 + 25.1 = 49 Total for K-12 0.485 0.214 97 + 81.3 = 179 1. Totals may vary slightly due to rounding. Source: San Luis Coastal Unified School District, 2015 Based on Table 4.14-1, the project would add an estimated 179 students to public schools in the City of San Luis Obispo. The District’s existing school enrollments and capacities are shown in Table 4.14-2 alongside projected enrollments and capacities upon buildout of the project. Table 4.14-2 District Enrollment and Capacity Grade Level 2015/16 Capacity 2015/16 Enrollments 2014/15 Utilization of School Enrollments with Students Generated by the Project Utilization with Student Generated by the Project K-5/6 4,868 4,020 82.6% 4,125 84.7% 6/7-8 2,114 1,313 62.1% 1,338 63.3% 9-12 3,366 2,307 68.5% 2,356 70% Source: San Luis Coastal Unified School District, 2015 As shown in Table 4.14-2, buildout of the project would not result in exceedance of District school capacities. Senate Bill 50 (Government Code Section 65970) implemented school impact fee reforms in 1998 by amending the laws governing developer fees and school mitigation. Pursuant to SB 50, development projects are required to pay school impact fees established to offset potential impacts on school facilities. The project would not result in additional students that would contribute to over‐capacity at public schools, and the collection of state-mandated fees under SB 50 is considered full and complete mitigation for impacts to public schools. The project applicant would be required by State law to pay the fair share of impact mitigation fees, and impacts to public schools would be less than significant. San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-11 Impacts related to the provision of park services and facilities are discussed in Section 4.11, Recreation. 4.14.13 Transportation/ Traffic Would the project: • Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks; and/or • Result in inadequate emergency access? The LUCE Update EIR found that City-wide development, including the project, could result in deteriorated safety conditions due changes in airline traffic volumes or traffic patterns. However, as determined in the LUCE Update EIR, the City is required to ensure that buildout under the General Plan is in compliance with Circulation Element Policies 11.0.1 Interstate Air Service, 11.0.2 County Aircraft Operations, and 11.0.3 Public Transit Service. Compliance with such policies would ensure that potential impacts of the project, as well as other planned development in the City, due to changes in air traffic patterns would remain at a less than significant level. The project site is surrounded by existing City roadways and development. Circulation within the project site would be developed to allow for emergency access to the site from Dalidio Drive and a proposed extension to Froom Ranch Way. Therefore, the project would result in a less than significant impact to emergency access. 4.14.14 Utilities and Service Systems Would the project: • Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board; • Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; • Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; • Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments; • Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs; and/or • Comply with federal, state, and local statutes and regulations related to solid waste? The project would result in an incremental increase in demand on City infrastructure, including water and wastewater treatment facilities, and storm water drainage facilities. With the proposed annexation to the City, development of the site is required to be served by City sewer and water service. As described in Section 2.0, Project Description, the project includes development of water, wastewater, and storm water infrastructure to connect the project to existing City infrastructure. With the proposed infrastructure, the project would be adequately served by the City’s sewer and water systems. Existing storm water facilities exist in the vicinity San Luis Ranch Project EIR Section 4.14 Issues Addressed in the Initial Study City of San Luis Obispo 4.14-12 of the project site, and it is not anticipated the project would result in the need for new off-site facilities or expansion of existing facilities which could have significant environmental effects. Impacts associated with new water and wastewater treatment facilities would be less than significant. The City’s Water Resource Recovery Facility (WRRF) processes wastewater in accordance with the standards set by the Regional Water Quality Control Board (RWQCB). The WRRF is designed for an average dry weather flow capacity of 5.1 million gallons per day (MGD) and a peak wet weather flow capacity of 22 MGD. In 2015, average flows to the WRRF were approximately 3.5 MGD. The LUCE Update EIR determined that the project, in combination with other specific plan development in the City, would generate approximately 0.32 MGD of wastewater or approximately 20 percent of the WRRF dry weather flow capacity and 1.7 percent of the WRRF wet weather flow capacity. The developer would be required to construct private sewer facilities to convey wastewater to the nearest public sewer. The on-site sewer facilities would be required to be constructed according to the standards in the Uniform Plumbing Code and City standards. Impact fees are collected at the time building permits are issued to pay for capacity at the City’s WRRF. The fees are set at a level intended to offset the potential impacts of each new residential unit included in the project. Additionally, the project would generate wastewater within the capacity of the City’s WRRF. This impact would be less than significant. The project would be served by San Luis Garbage Company, which maintains access and standards for access and to ensure that collection is feasible, both of which would be reviewed by the Architectural Review Commission. Solid waste generated by new development in the project area would be delivered to Cold Canyon Landfill. This landfill has been recently expanded and currently has capacity to accept waste for at least 20 years at the current rate of disposal. The landfill has a total permitted capacity of 23,900,000 cubic yard (CY) with a remaining capacity of 14,500,000 CY or 61 percent (California Department of Resources Recycling and Recovery, 2016). Consistent with the City’s Source Reduction and Recycling Element, recycling facilities must be accommodated on the project site and a solid waste reduction plan for recycling discarded construction materials is required be submitted with the building permit application. The project would also be required by ordinance to include facilities for recycling to reduce the waste stream generated by operation of the project. With incorporation of recycling and reduction measures, the project would not be expected to generate waste in exceedance of the Cold Canyon Landfill remaining capacity. Additionally, compliance with the Source Reduction and Recycling Element is considered sufficient to avoid significant environmental effects related to solid waste. Therefore, impacts related to solid waste disposal would be less than significant. San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-1 5.0 OTHER CEQA-REQUIRED DISCUSSIONS This section discusses other issues for which CEQA requires analysis in addition to the specific issue areas discussed in Section 4.0, Environmental Impact Analysis. These additional issues include: (1) the potential to induce growth; (2) significant unavoidable effects of the project; and (3) significant and irreversible impacts on the environment. 5.1 GROWTH INDUCING EFFECTS Section 15126.2(d) of the State CEQA Guidelines requires that EIRs discuss the potential for projects to induce population or economic growth, either directly or indirectly. CEQA also requires a discussion of ways in which a project may remove obstacles to growth. Generally speaking, a project may be considered growth inducing if it results in one or more of the five conditions identified below: 1. Induces population growth; 2. Induces economic expansion; 3. Establishes a precedent setting action (e.g. an innovation, a radical change in zoning or general plan designation); 4. Results in development or encroachment in an isolated or adjacent area of open space (i.e. being distinct from “infill” development); or 5. Removes an impediment to growth (e.g. the establishment of an essential public service or the provision of new access to an area). The impacts identified below are based on buildout of the project which includes a Specific Plan, General Plan Amendment/Pre-Zoning, Vesting Tentative Tract Map, and development plan for the 131-acre project site, including annexation of the site into the City of San Luis Obispo. The project is intended to be consistent with the development parameters described in the City’s Land Use and Circulation Element (adopted in December 2014). The project includes a mixture of residential, commercial, office, and hotel uses, with a portion of the site preserved for agriculture and open space uses. The project is planned to be constructed in six phases, beginning in 2017 and ending in 2023. 5.1.1 Population Growth As discussed in Section 2.0, Project Description, the proposed project would result in up to 580 low-medium, medium, and high density residences that would range from detached single- family units to attached multi-family dwellings. Development of the project would add an estimated 1,293 residents to the City (546 new single family and multi-family dwelling units x 2.29 people/unit and 34 new affordable units x 1.25 people/unit).1 When added to the City’s existing population of 45,802, the City’s total population with the project would be 47,095 persons. The City’s General Plan allows the property to be developed with up to 500 dwelling units, 200,000 square feet of commercial, 150,000 square feet of office, and a 200-room hotel and conference center. In addition, as described in Section 2.0, Project Description, the project 1 Population growth rate from City’s Land Use and Circulation Element Appendix I Water Supply Assessment (page 9), as referred to in SB610 Water Supply Assessment – San Luis Ranch prepared by Cannon (2016; Appendix M). San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-2 includes an affordable housing component in accordance with City requirements. The San Luis Ranch Specific Plan proposes 34 deed-restricted affordable units on site for very low, low, and moderate income households, including 26 very low income units. Consistent with Section 17.90.040(d) of the City’s Affordable Housing Incentives, the proposed affordable housing would allow for an 80-unit density bonus, bringing the total allowable residential units in the Specific Plan Area from 500 to 580. Therefore, population growth under the project is consistent with the City’s General Plan. The potential environmental impacts associated with this population growth are analyzed throughout Sections 4.1 through 4.14 of this EIR. 5.1.2 Economic Growth The proposed project includes residential development and commercial development. Commercial uses proposed for the project may include retail anchors, neighborhood retail, restaurants, offices, and a hotel. As such, the proposed project would contribute to economic growth by providing additional space for business within the City. Additionally, residential development may indirectly contribute to economic growth. As development occurs under the proposed project, the additional population would likely contribute to the local economy as demand for general goods increases, which in turn could result in economic growth for various sectors. 5.1.3 Precedent Setting Action The San Luis Ranch property is identified in the City’s updated Land Use Element as Specific Plan Area (SP-2). The Specific Plan area is currently part of the unincorporated area of San Luis Obispo County, but is within the City’s Sphere of Influence. Policy 8.1.1 of the Land Use Element requires the completion and approval of a specific plan and associated General Plan amendment prior to annexation and development of land within the area designated SP-2. The parameters for future development within the area designated SP-2 are included in Policy 8.1.4. The San Luis Ranch Specific Plan must meet performance standards prescribed in the Land Use Element, including minimum and maximum density requirements. Annexation would be subject to approval by the San Luis Obispo Local Agency Formation Commission (LAFCo) in coordination with both the City and County of San Luis Obispo. The project, as proposed, would require discretionary approvals from the City including the San Luis Ranch Specific Plan, General Plan Amendment/Pre-Zoning, Vesting Tentative Tract Map, and development plan for the 131-acre site, including annexation of the site into the City of San Luis Obispo, and Architectural Review. Since the project would be required to be consistent with the development parameters and what is envisioned for the site in the City’s General Plan, it would not be considered precedent setting. Nevertheless, the project would be at the discretion of the City Council who may consider it on its own merits in terms of how the new proposal fulfills the City General Plan goals and objectives. Any growth inducement from these actions would occur within what is planned for the site in the City’s General Plan. 5.1.4 Development of Open Space/Vacant Land Development of open space is considered growth-inducing when it occurs outside urban boundaries or in isolated locations instead of infill areas. The City’s General Plan has identified San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-3 several specific plan areas within its boundaries that are designated for development. The San Luis Ranch Specific Plan area is designated as such and development of the site would occur in an area of the City surrounded by existing development. The Specific Plan would not involve development on existing dedicated open space or parks. As described in Section 2.0, Project Description, the project would also preserve approximately 53 acres of project site in agriculture and approximately 8 acres of the project site in open space. 5.1.5 Removal of an Impediment to Growth The project would not result in the removal of an impediment for growth, as adequate access and services are already available for the adjacent and surrounding areas, which are all within the City of San Luis Obispo. Rather, the project would facilitate a planned mixture of uses on one of the last remaining large sites and Specific Plan areas identified within the City of San Luis Obispo’s General Plan Land Use Element. As such, it would reduce the potential for uncontrolled piecemeal growth in the region and it would reduce the pressure for urban sprawl beyond the existing urban limits. The project site is contiguous to urban land uses designated for urban development, and the site is entirely surrounded by land within the limits of the City. In addition, by focusing development within already urban-designated areas, it is anticipated that implementation of the project would reduce growth pressure in undeveloped areas at the periphery of the City. This would be expected to reduce the potential for impacts relating to such issues as biological resources, regional traffic, and air quality as compared to development on lands beyond urban boundaries. No additional utility infrastructure or facilities beyond those necessary to accommodate the project would be required. Overall, the proposed project would not result in the removal of an impediment to growth. 5.2 SIGNIFICANT UNAVOIDABLE EFFECTS State CEQA Guidelines §15126(b) requires that an EIR identify those significant impacts that cannot be reduced to a less than significant level with the application of mitigation measures. The implications and reasons why the project is being proposed, notwithstanding, must be described. As discussed in Sections 4.3, 4.5, 4.9, 4.10, and 4.12, implementation of the project would result in the following significant and unavoidable impacts: • Air Quality – 2001 Clean Air Plan consistency • Cultural Resources – Relocation and removal of historic structures • Land Use/Policy Consistency – Inconsistency with City General Plan policies related to historic resource protection and multimodal level of service • Noise – Temporary construction noise • Transportation and Circulation – Near-Term Plus Project and Cumulative Plus Project traffic conditions San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-4 5.3 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL EFFECTS State CEQA Guidelines §15126.2(c) requires a discussion of any significant irreversible environmental changes which would be caused by the proposed project should it be implemented. Such significant irreversible environmental changes may include the following: • Use of non-renewable resources during the initial and continued phases of the project which would be irreversible because a large commitment of such resources makes removal or non-use unlikely; • Primary impacts and, particularly secondary impacts (such as highway improvement which provides access to a previously inaccessible area) which generally commit future generations to similar uses; or 1. Irreversible damage which may result from environmental accidents associated with the project. Project development would result in the permanent conversion of open, agricultural lands to residential and commercial uses. It would also require building materials and energy, some of which are non-renewable resources. Consumption of these resources would occur with any development in the region and are not unique to the proposed project. The addition of new residential units and commercial space would irreversibly increase local demand for non-renewable energy resources such as petroleum and natural gas. Increasingly efficient building fixtures and automobile engines, as well as implementation of policies included in the San Luis Ranch Specific Plan are expected to offset the demand to some degree. It is not anticipated that growth accommodated under the proposed project would significantly affect local or regional energy supplies. The project’s energy use and energy conservation components are discussed further in Section 5.4, Energy Use and Conservation. Growth accommodated under the proposed project would require an irreversible commitment of law enforcement, fire protection, water supply, wastewater treatment, and solid waste disposal services. In addition, the vehicle trips associated with the proposed project would incrementally contribute local traffic and noise levels and regional air pollutant emissions. Accordingly, impacts related to air quality, cultural resources, greenhouse gas emissions, land use/policy consistency, noise, and transportation and circulation were determined to be significant and unavoidable, as discussed in Sections 4.3, 4.5, 4.6, 4.9, 4.10, and 4.12 of this EIR. 5.4 ENERGY USE AND CONSERVATION Public Resources Code Section 21100(b)(2) and Appendix F of the CEQA Guidelines require that EIRs include a discussion of the potential energy consumption and/or conservation impacts of proposed projects when relevant, with particular emphasis on avoiding or reducing inefficient, wasteful, or unnecessary consumption of energy. The project’s anticipated energy use (including fuel consumption) and energy conserving components are evaluated in this section to determine whether the project would result in unnecessary or wasteful energy consumption. The discussion of the project’s anticipated energy use includes fuel consumption. State and Regional Energy Consumption. San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-5 State. California is one of the lowest per capita energy users in the United States, ranked 49th in the nation, due to its energy efficiency programs and mild climate (U.S. Energy Information Administration [EIA] 2014). California used 295,405 gigawatt-hours (GWh) of electricity in 2015 (California Department of Energy 2015) and 2,309,759 million cubic feet of natural gas in 2014 of which 401,172 million cubic feet were consumed by residential users (EIA 2015). In addition, Californians presently consume nearly 18 billion gallons of motor vehicle fuels per year (California Energy Commission [CEC] 2014). The single largest end-use sector for energy consumption in California is transportation (38.7 percent), followed by industry (24.4 percent), commercial (18.6 percent), and residential (18.3 percent) (EIA 2014). The majority of California’s electricity is generated in-state with approximately 44 percent imported from the Northwest and Southwest in 2015 (CEC 2015). In addition, approximately 26 percent of California’s electricity supply comes from renewable energy sources (CEC 2016a), such as wind (24,100 GWh), solar photovoltaic (PV) (15,100 GWh), geothermal (12,900 GWh), and biomass (8,600 GWh) (CEC 2016). Senate Bill (SB) 350, adopted in October 2015, requires that renewables supply 50 percent of retail electricity by 2030. Self-generation using rooftop solar PV and increased appliance energy efficiency has resulted in a decline in state energy total system power in 2015, a trend that is expected to continue (CEC 2016a). California’s existing natural gas supply portfolio is regionally diverse and includes supplies from California sources (onshore and offshore), Southwestern U.S. supply sources (the Permian, Anadarko, and San Juan basins), the Rocky Mountains, and Canada (California Gas and Electric Utilities 2016). California natural gas demand, including volumes not served by utility systems, is expected to decrease at a rate of 1.4 percent per year from 2016 to 2035. Residential gas demand is expected to decrease at an annual average rate of 0.5 percent due to aggressive energy efficiency programs (California Gas and Electric Utilities 2016). To reduce statewide vehicle emissions, California requires that all motorists use California Reformulated Gasoline (CaRFG), which is sourced almost exclusively from in-state refineries. Gasoline is the most used transportation fuel in California with 15.1 billions of gallons sold in 2015 and is used by light-duty cars, pickup trucks, and sport utility vehicles (CEC 2016b). Diesel is the second most used fuel in California with 4.2 billion gallons sold in 2015 and is used primarily by heavy duty-trucks, delivery vehicles, buses, trains, ships, boats and barges, farm equipment, and construction and heavy duty military vehicles (CEC 2016c). Both gasoline and diesel are primarily petroleum-based and their consumption releases greenhouse gases, including CO2 and NOX. The transportation sector is the single largest source of greenhouse gas (GHG) emissions in California, accounting for 37 percent of all inventoried emissions in 2013 (ARB 2015). The California Energy Code provides energy conservation standards for all new and renovated commercial and residential buildings constructed in California. The Code applies to the building envelope, space-conditioning systems, and water-heating and lighting systems of buildings and appliances. It provides guidance on construction techniques to maximize energy conservation and minimum efficiency standards for a variety of building elements, including appliances, heating and cooling equipment, and insulation for doors, pipes, walls and ceilings. CALGreen sets targets for: energy efficiency, water consumption, dual plumbing systems for San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-6 potable and recyclable water, diversion of construction waste from landfills, and use of environmentally sensitive materials in construction and design. Regional. Electricity service for the project would be provided by Pacific Gas & Electric (PG&E), which provides natural gas and electric service to approximately 16 million people throughout a 70,000-square mile service area in northern and central California (PG&E 2017). electricity to about 14 million people in Southern California. In 2015, SCE provided 27,581 millions of kWh (GWh) to its residential users (CEC 2016d). SCE’s power mix consists of approximately 25 percent renewable energy sources (wind, geothermal, solar, small hydroelectric, and biomass) (SCE 2015). Gas service would be provided by the Southern California Gas Company (SoCalGas), which serves 21.6 million consumers throughout Southern California. In 2015, SoCalGas provided 2,038 million therms to its residential users (CEC 2016e). According to the San Luis Obispo Council of Governments (SLOCOG) and the California Department of Transportation (Caltrans), there were a total of approximately 530,000 vehicle miles traveled (VMT) in the City of San Luis Obispo, and approximately 7,862,000 VMT in the County in 2013 (Caltrans 2015). These annual VMT contribute to the consumption of gasoline and diesel fuel in the region. San Luis Obispo County also provides a variety of public transit services, including bus and paratransit service and vanpools. San Luis Ranch Project Energy Consumption. The project would involve the use of energy during construction and operation. Energy use during the construction phase would be primarily in the form of fuel consumption to operate heavy equipment, light-duty vehicles, machinery, and generators for lighting. Temporary grid power may also be provided to construction trailers or electric construction equipment. Long-term operation of the project would require permanent grid connections for electricity and natural gas service to power internal and exterior building lighting, and heating and cooling systems. In addition, the increase in vehicle trips associated with the project would increase fuel consumption. Electricity and Natural Gas. Table 5-1 shows the project’s estimated electricity and natural gas demand compared to statewide demand. Electricity and natural gas consumption were estimated using CalEEMod, as described in Section 4.3, Air Quality and Section 4.6, Greenhouse Gas Emissions (refer to Tables 5.2 and 5.3 included in Appendix D). Based on the modeling assumptions described in Section 4.3, Air Quality and Section 4.6, Greenhouse Gas Emissions, project development would utilize approximately 58,300 megawatt hours (MWh) of electricity and approximately 23,700 million cubic feet of natural gas per year during operation. As shown in Table 5-1, the project’s electricity consumption would represent approximately 0.002 percent of statewide annual demand, and project natural gas consumption would represent approximately 0.001 percent of statewide annual demand. San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-7 Table 5-1 Project Energy Use Relative to Statewide Energy Use Form of Energy Units Annual Project-Related Energy Use Annual Statewide Energy Use Project Percent of Statewide Energy Use Electricity Megawatt hours 5,8321 295,405,0002 0.002% Natural Gas Billions of cubic feet 0.0241 2,3133 0.001% 1 CalEEMod output (provided in Appendix D) 2 California Energy Commission 2017a 3 California Energy Commission 2017b Gasoline and Diesel Fuel. A large portion of the project’s energy use would result from fuel consumption associated with project-related vehicle trips. As shown in Table 4.12-17, buildout of the Specific Plan Area would generate approximately 16,917 new daily trips. Table 5-2 shows the project’s estimated annual operational fuel consumption due to vehicle travel. Fuel consumption was estimated using the default fleet vehicle mix and the total annual mitigated annual VMT from the CalEEMod trip generation estimates, and average fuel efficiencies for each vehicle category (refer to Table 4.4 included in Appendix D, which shows the default fleet vehicle mix used by CalEEMod). Based on these assumptions, the project would result in the consumption of approximately 734,153 gallons of vehicle fuel per year during operation, which represents approximately 0.004 percent of annual statewide fuel consumption. Table 5-2 Project Operational Vehicle Fuel Consumption Vehicle Type Percent of Vehicle Trips1 Annual Vehicle Miles Traveled2 Average Fuel Efficiency (miles/gallon)3 Total Annual Fuel Consumption (gallons) Passenger Cars 54.9 7,181,775 23.3 308,231 Light/Medium Trucks 36.5 4,774,768 17.1 279,226 Heavy Trucks/Other 8.0 1,058,560 7.3 145,008 Motorcycles 0.6 73,257 43.4 1,688 Total 100% 13,088,359 -- 734,153 State Motor Vehicle Fuels 18,019,000,0004 Project Percent of Statewide Energy Use 0.004% 1 Percent of vehicle trips found in Table 4.3 “Trip Type Information” in CalEEMod outputs (see Appendix D) 2 Mitigated annual VMT found in Table 4.2 “Trip Summary Information” in CalEEMod outputs (see Appendix D). Annual VMT per vehicle type = Mitigated annual VMT * Percent of vehicle trips per vehicle type. 3 Source: US DOT, Bureau of Transportation Statistics. 2013. National Transportation Statistics 2013, Tables 4-12 and 4-13. Washington DC. Vehicle classes provided in CalEEMod do not correspond exactly to vehicle classes in USDOT fuel consumption data, except for motorcycles. Therefore, it was assumed that passenger cars correspond to the light-duty, short-base vehicle class, light/medium trucks correspond to the light-duty long-base vehicle class, and heavy trucks/ other correspond to the single unit, 2-axle 6-tire or more class. 4 California Energy Commission 2014 Note: Total may not add up due to rounding. San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-8 In addition, construction activities would also result in short-term fuel consumption from worker trips, operation of diesel-powered equipment, and hauling trips. Appendix F Requirements and Energy Conservation Standards. Appendix F of the CEQA Guidelines requires inclusion in an EIR of relevant information that addresses “potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful and unnecessary consumption of energy”(Public Resources Code Section 21100[b][3]). Although the CEQA Guidelines do not include formal thresholds for evaluating the significance of potential energy-related impacts, the following discussion addresses direct energy impacts of the project as framed in Appendix F of the CEQA Guidelines by evaluating whether the project would result in the wasteful or inefficient consumption of energy or the potential need for new energy-related infrastructure, the construction or operation of which would have significant impacts. 1. Would the project result in the wasteful and inefficient use of non-renewable resources during construction and operation of the project? Project operation would result in the annual consumption of approximately 5,832 megawatt hours of electricity, 24 million cubic feet of natural gas, and 734,153 gallons of vehicle fuel each year. Increasingly efficient building fixtures and automobile engines, as well as implementation of policies included in the San Luis Ranch Specific Plan are expected to offset the project’s energy demand to some degree. The project would be subject to energy conservation requirements in the California Energy Code (Title 24, Part 6, of the California Code of Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California Green Building Standards Code (CALGreen) (Title 24, Part 11 of the California Code of Regulations). Adherence to Title 24 requirements would ensure that the project would not result in wasteful and inefficient use of non-renewable resources due to building operation. The project includes a number of components that would reduce transportation-related energy use. These project components have been discussed in Section 2.0, Project Description, Section 4.3, Air Quality, Section 4.6, Greenhouse Gas Emissions, and Section 4.12, Transportation, and are summarized in the following discussion. First, the project’s internal circulation would include an emphasis on pedestrian and bicycle circulation. Proposed neighborhoods would be connected with a local street and trail system, and would contain recreational areas. The project would include a Class I Bike Trail and Class II bike lanes, construct a new segment of the Bob Jones Bike Trail, and provide a connection from Laguna Lake Park and nearby neighborhoods and businesses along Madonna Road to the existing segment of the Bob Jones Trail near the Target shopping center at the southern portion of the City limit at Froom Ranch Way. Second, the project would also include a transit center that would provide direct transit access between the project site and downtown San Luis Obispo. Third, the proposed project would be a mixed- use development that would locate housing near existing and proposed job opportunities. These three features would reduce the number of vehicle trips associated with the project, and, therefore, decrease fuel consumption associated with project operation. Sections 4.3, Air Quality, and 4.12, Transportation, of this EIR include mitigation measures intended to reduce air quality and traffic impacts, which would have the secondary effect of San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-9 reducing project-related energy consumption. Table 5-3 summarizes applicable EIR mitigation measures and describes their potential to reduce project-related energy consumption. Table 5-3 Summary of Mitigation Measure Energy Reduction Mitigation Measure Energy Reduction AQ-1. Encourage Telecommuting Reduce vehicle fuel consumption associated with project operation by reducing vehicle trips AQ-2(b). Standard Control Measures for Construction Equipment Reduce fuel consumption associated with project construction by improving construction vehicle fuel efficiency AQ-2(c). Best Available Control Technology (BACT) for Construction Equipment Reduce fuel consumption associated with project construction by improving construction vehicle fuel efficiency AQ-3(a). Standard Operational Mitigation Measures Reduce vehicle fuel consumption associated with project operation by promoting use of alternative transportation. Reduce use of fossil fuel-based electricity sources by accommodating renewable energy use and directly reducing energy use through building design and incorporation of energy-efficient features AQ-3(b). Off-Site Mitigation Reduce vehicle fuel consumption in SLO by reducing vehicle trips and/or improving fuel efficiency of land and marine vehicles and equipment All Transportation Mitigation (see Table 4.12-1) Reduce vehicle fuel consumption by reducing congestion and promoting alternative transportation (e.g., provide bike lanes) The project would be required to comply with applicable Title 24 building standards, would include features to promote use of alternative transportation during operation, and would incorporate required EIR mitigation that would reduce construction and operational energy use by decreasing vehicle trips, increasing fuel efficiency, increasing building energy efficiency, and facilitating use of renewable energy. Therefore, the project would not result in wasteful and inefficient use of non-renewable resources during construction and operation. 2. Would the project result in the need for new systems or substantial alterations to electrical, natural gas, or communication systems infrastructure, the construction or operation of which would have significant impacts? New construction, or substantial alteration of existing, energy infrastructure to expand capacity could result in potentially significant environmental impacts. To determine whether the project would require substantial alteration or new infrastructure, the project’s operational energy demands were estimated and compared to Statewide demand. Based on the comparisons of project electricity, natural gas, and fuel demand to statewide demand for these resources shown in Tables 5-1 and 5-2, the project’s energy demand would result in a nominal increase statewide energy demand. Furthermore, California’s use of non- renewable electricity and natural gas are expected to continue to decline as a proportion of overall energy demand due to stringent energy efficiency measures and a mandated increase in renewable energy use that would serve to offset any increase in non-renewable energy use resulting from the project. Therefore, the project would not be expected to result in the need for construction of new major facilities or substantial alteration of existing facilities to meet the project’s energy demands. San Luis Ranch Project EIR Section 5.0 Other CEQA-Required Discussions City of San Luis Obispo 5-10 This page intentionally left blank. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-1 6.0 ALTERNATIVES 6.1 INTRODUCTION The California Environmental Quality Act (CEQA) Guidelines state that an “EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives” (Section 15126.6). The State CEQA Guidelines state that “the range of alternatives required in an EIR is governed by a rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the Project (Section 15126.6). In defining feasibility of alternatives, the CEQA Guidelines state that “among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site” (Section 15126.6). 6.2 PROJECT OBJECTIVES The applicant’s objectives for the project are described in Section 2.0, Project Description, and restated below. 1. Provide infill growth for the City that is anticipated and desired by City planning decisions and guidelines; 2. Preserve agricultural land and open space on site, maintain agricultural views from U.S. 101; 3. Create significant entry-level, workforce housing opportunities within the City that is specifically “affordable by design;” 4. Implement a walkable-bikeable neighborhood design that is integrated with public transit access and open space amenities that encourage alternative modes of transportation; 5. Create new commercial, office and hotel opportunities that will accommodate and complement existing businesses in downtown San Luis Obispo; 6. Develop an Agriculture Heritage Facilities & Learning Center offering seasonal attractions and local goods that promote the region’s agricultural richness; 7. Establish an important link in the Bob Jones Regional Trail; 8. Provide fair-share financial contribution towards important public circulation improvements. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-2 6.3 SIGNIFICANT AND UNAVOIDABLE IMPACTS OF THE PROJECT The project would result in significant and unavoidable impacts to air quality, cultural resources, greenhouse gas (GHG) emissions, noise, and transportation/circulation. Air Quality Buildout of the San Luis Ranch Specific Plan Area would increase the City’s total population in 2035 by 2.6 percent over the current population. The project’s increase in total vehicle miles traveled (VMT) is projected to be 3.0 percent. The projected increase in VMT would exceed the project’s increase to population; therefore, the project would be inconsistent with the SLOAPCD’s Clean Air Plan assumptions for VMT growth. Implementation of Mitigation Measures AQ-1, AQ-3(a), and AQ-3(b) would reduce regional air pollutant emissions and ensure that the project would be consistent with the CAP transportation control measures and land use strategies. However, mitigation is not available that would reduce projected VMT such that the project’s vehicle trip rate increase would not exceed population growth in the region. Therefore, impacts related to consistency with the 2001 CAP would remain significant and unavoidable. Cultural Resources The relocation and adaptive reuse of the main residence and former spectators’ barn/viewing stand, and the demolition or off-site relocation of the remaining buildings and structures on the ranch, including the main barn, would result in adverse changes to individually identified historic structures (the main barn and main residence) as well as the historic context of the San Luis Ranch Complex, which is collectively identified as historically significant. Additionally, demolition of the historic main barn would conflict with General Plan Conservation and Open Space Element Policies 3.3.1 and 3.3.2. Implementation of Mitigation Measures CR-1(a) through CR-1(c) would reduce impacts to historic resources to the maximum extent feasible. However, impacts to historic resources on the project site would remain significant and unavoidable, even after mitigation. Land Use/Policy Consistency The Specific Plan is potentially inconsistent with General Plan Land Use Element Policy 1.10.4 (Design Standards), Circulation Element Policy 6.1.2 (Multimodal Level of Service Objectives), Conservation and Open Space Element Policy 3.3.2 (Demolitions), and Conservation and Open Space Element Policy 3.3.3 (Historical Documentation). Mitigation Measures AES-1(a), AES- 1(b), AG-1, AG-3, BIO-1(a) through BIO-1(h), BIO-2(a) through BIO-2(c), CR-1(a) through CR- 1(c), GEO-1, GEO-3, HAZ-4, HAZ-5(a), HAZ-5(b), HAZ-6, N-1(a) through N-1(g), N-4(a), N- 4(b), N-5(a) through N-5(d), T-1(a) through T-1(h), T-2(a) through T-2(j), T-3(a) through T-3(d), T-4, T-5, T-6, T-7, T-8(a) through T-8(g), T-9(a) through T-9(l), T-10(a) through T-10(c), would ensure that several potential conflicts between the City of San Luis Obispo General Plan and the San Luis Ranch Specific Plan would be reduced to the maximum extent feasible. Despite implementation of these mitigation measures, the Specific Plan would remain potentially inconsistent with these General Plan policies. Therefore, this impact would remain significant and unavoidable. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-3 Noise Construction of the project would occur in six phases between 2017 and 2023. The highest noise level that nearby residences would be exposed to during construction activity would be 85 dBA during grading. This would exceed the single-family threshold of 60 dBA for relatively long- term construction activity. Additionally, trucks hauling material to and from the site could result in noise levels that exceed the 75 dBA threshold for intermittent noise. Mitigation Measures N-1(a) through N-1(g) would reduce noise associated with on- and off-site construction activity to the maximum extent feasible. However, mitigation would not reduce the noise associated with temporary construction activities below the applicable City standards for relatively long term construction activity or intermittent noise. Although this impact would be temporary, it would remain significant and unavoidable. Transportation and Traffic Under Existing Plus Project, Near-Term Plus Project conditions and Cumulative Plus Project conditions, several study area intersections would operate at unacceptable automobile, bicycle, pedestrian, and transit multimodal levels of service (MMLOS) during AM and PM peak hours based on the City’s adopted MMLOS standards. In addition, the volume of traffic at several intersections would exceed lane capacities during AM and PM peak hours. In addition, under Cumulative Plus Project conditions, five study area segment groups, as well as mainline segments of U.S. 101 northbound and southbound at Los Osos Valley Road and Madonna Road, would operate at unacceptable automobile, bicycle, pedestrian, and transit MMLOS during AM and PM peak hours Therefore, under Existing Plus Project, Near-Term Plus Project, and Cumulative Plus Project conditions, the project would conflict with the City’s established measures of effectiveness for the performance of the circulation system and LOS standards and vehicle queueing standard. Implementation of the mitigation measures described in Section 4.12, Transportation and Circulation, would improve LOS and reduce impacts to lane capacities at most impacted intersections to acceptable levels. However, potential right-of-way constraints at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections limit the feasibility of required mitigation, and result in significant and unavoidable transportation impacts at these impacted intersections. In addition, mitigation would not be effective in reducing potential impacts identified for the northbound and southbound lanes of the mainline segments of U.S. 101 at Los Osos Valley Road and Madonna Road under Cumulative Plus Project conditions to a less than significant level. Therefore, potential impacts identified for Existing Plus Project, Near-Term Plus Project, and Cumulative Plus Project conditions may not be feasibly mitigated to a less than significant level. As a result, impacts associated with transportation and circulation would remain significant and unavoidable. 6.4 ALTERNATIVES ANALYSIS The range of alternatives required in an EIR is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant impacts of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project (CEQA Guidelines Section 15126.6[f]). San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-4 This discussion focuses on alternatives to the project, including alternatives which were considered and rejected. These alternatives have been selected for their ability to comply with the City’s General Plan and substantially reduce or eliminate the one or more of the adverse impacts associated with the Specific Plan, while still meeting basic project objectives. The EIR also includes two versions of a No Project Alternative. Consistent with the CEQA Guidelines (§15126.6[e]), the “no project” analysis will discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the project is not approved, based on current plans and consistency with available infrastructure and community services. This analysis includes only on-site alternatives, on the basis that off-site alternatives are not available that would attain the basic objectives of the project, and because the site was specifically identified in the Land Use Element Update as a Specific Plan area. The alternatives considered are as follows: • Alternative 1: No Project, No Development • Alternative 2: No Project, Measure J Entitlements • Alternative 3: Historical Resource Preservation • Alternative 4: 50% On-Site Agriculture/Open Space As required by CEQA, this section also includes a discussion of the “environmentally superior alternative” among those studied. 6.4.1 Alternatives Considered but Rejected As discussed above, CEQA Section 15126.6(c) requires that an EIR disclose alternatives that were considered and rejected and provide a brief explanation as to why such alternatives were not fully considered in the EIR. In particular, as required by the State CEQA Guidelines, the selection of alternatives included a screening process to determine a reasonable range of alternatives, which could reduce significant effects but also feasibly meet project objectives. Alternatives that do not clearly provide any environmental advantages compared to the project, meet basic project objectives, or achieve overall lead agency policy goals, have been eliminated from further consideration. For the San Luis Ranch Project, characteristics used to reject alternatives from further consideration include: • Failure to meet basic project objectives; • Limited effectiveness in reducing project environmental impacts; • Inconsistency with City policies, including the General Plan; • Potential for inconsistency with adopted agency plans and policies; and • Reasonableness of the alternative when compared to other alternatives under consideration. The following alternatives were considered but eliminated from further analysis by the City due to one or more of these factors. Project with Overpass Only Under this alternative, the site would be developed with residential, commercial, hotel and open space uses as planned under the current proposal. However, the transportation mitigation for this alternative would only require development of the Prado Road overpass connection at U.S. 101, but would not include reconstruction of the northbound ramps, or the eventual San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-5 development of the southbound ramps currently required by mitigation measures described in Section 4.12, Transportation and Circulation, and assumed in the City’s General Plan. However, this alternative would be inconsistent with the General Plan Circulation Element, which assumes future development of an overpass or full-access interchange at Prado Road and U.S. 101, based on the anticipated traffic demand that would result from future development. In addition, this alternative would not implement mitigation identified in this EIR as necessary to reduce existing, near-term, and cumulative transportation impacts, resulting in additional significant and unavoidable impacts. Therefore, this option was considered and rejected, consistent with State CEQA Guidelines Section 15126.6(c). Reduced Project, Vehicle Trip-Reducing Under this alternative, the total square footage of office and retail uses and the number of residential units would be reduced to avoid the significant and unavoidable transportation impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections. The specific reduction in planned development required to meet this criterion would be determined based on the project-specific traffic analysis. However, as shown in Section 4.12, Transportation and Circulation, the need for mitigation at these intersections (Mitigation Measures T-1[b] and T-1[d]) would be triggered under phase 1 of the project. As shown in Figure 2-14 in Section 2.0, Project Description, phase 1 of the proposed development includes approximately 200 low-medium density residential units, which is less than half of the residential development anticipated for the site under the General Plan, and does not include any of the commercial development anticipated for the site under the General Plan. Therefore, the reduction in residential and commercial uses on the project site necessary to achieve this alternative was found to be inconsistent with the General Plan Land Use Element designations for the Specific Plan Area, which assumes development of a project with 350 to 500 residential units; 50,000 to 200,000 square feet of commercial development; 50,000 to 150,000 square feet of office development; a 200-room hotel; 5.8 acres of parks; and 66 acres of agriculture and open space. In addition, this alternative would not achieve the basic project objectives to provide infill growth for the City; create workforce housing opportunities; and create new commercial, office, and hotel opportunities. As a result, this option was considered and rejected, consistent with State CEQA Guidelines Section 15126.6(c). Reduced Project, Airport Land Use Plan Consistent Under this alternative, the density of residential and non-residential development on the project site would be reduced to be consistent with the noise contours and safety zones in the adopted San Luis Obispo County Regional Airport Land Use Plan (ALUP). As described in Section 4.9, Land Use/Policy Consistency, while the project would conflict with the ALUP, it is consistent with recommended safety zones of the California Airport Land Use Planning Handbook (CALUPH) which were evaluated in the 2014 Airport Land Use Compatibility Report prepared by Johnson Aviation (refer to Appendix I) in support of the City’s recent Land Use and Circulation Element Update process and the LUCE Update EIR. The City Council found during its review of airport compatibility for the LUCE Update that the 2014 Airport Land Use Compatibility Report and revised LUCE Update EIR provided substantial evidence in the record that development under the Land Use and Circulation Element Update project would be consistent with safety and noise standards set forth in the Caltrans Handbook San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-6 and supporting federal guidance, and that maps provided in the ALUP do not reflect guidance of safety zones and land use restrictions as recommended by the CALUPH (Council Agenda Report, City of San Luis Obispo 2014d). Therefore, even though the project would be inconsistent with the ALUP, it would be consistent with safety zones and land use restrictions as recommended by the CALUPH and as evaluated in the Johnson Aviation Compatibility Report (Appendix I). In addition, this alternative would be inconsistent with the General Plan Land Use Element designations for the Specific Plan Area, which assumes development of a project with 350 to 500 residential units; 50,000 to 200,000 square feet of commercial development; 50,000 to 150,000 square feet of office development; a 200-room hotel; 5.8 acres of parks; and 66 acres of agriculture and open space. Because of the limited development that would be possible on the project site based on the adopted ALUP (refer to Section 4.9, Land Use/Policy Consistency, for a detailed discussion of the allowable densities under the ALUP Safety Areas on the project site), this alternative would not achieve the basic project objectives to provide infill growth for the City; create workforce housing opportunities; create new commercial, office, and hotel opportunities; and implement a walkable-bikeable neighborhood design. Therefore, this option was considered and rejected, consistent with State CEQA Guidelines Section 15126.6(c). 6.4.2 Alternative 1: No Project, No Development Description This alternative assumes that the San Luis Ranch Specific Plan is not adopted, that none of the proposed entitlements are implemented, including annexation to the City, and that no further development would occur on the project site. The project site would continue to support existing agricultural land uses, and the existing structures on the site would remain. Impact Analysis As proposed, the San Luis Ranch Specific Plan would have significant and unavoidable impacts related to air quality, cultural resources, GHG emissions, land use/policy consistency, noise, and transportation and circulation. Since this alternative assumes that the project site would remain under agricultural use, and that no new development would occur on the site, this alternative would avoid all of the significant and unavoidable impacts identified for the project. In addition, this alternative would not result in any of the potentially significant impacts identified for the project, and therefore would not trigger the need for any of the mitigation measures identified in this EIR. However, this alternative would fail to meet the goals of the City’s General Plan as they apply to the San Luis Ranch Specific Plan area, which describe the Specific Plan Area as a planned buildout area within the City, and would fail to meet the project objectives. Overall, Alternative 1 would result in reduced physical environmental impacts when compared to the project, but would not achieve the planning goals included in the City’s General Plan. 6.4.23 Alternative 2: No Project, Measure J Entitlements Description This alternative assumes that the San Luis Ranch Specific Plan is not adopted and that none of the proposed entitlements are implemented, including annexation to the City. Therefore, this alternative represents a project that would be processed by San Luis Obispo County, and considers what would be reasonably expected to occur in the foreseeable future based on San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-7 current plans and consistency with available infrastructure and community services. There are existing entitlements on the project site for development in the County from the voter-approved initiative known as “Measure J,” which was passed in 2006 and upheld in 2009. The Measure J entitlements include 60 multi-family dwelling units, 560,000 square feet of regional commercial and outdoor sales areas, 198,000 square feet of office space, and a 150-room hotel and ancillary facilities. Because the Measure J entitlements would leave the project site under the jurisdiction of the County, but surrounded entirely by the City limit, these entitlements would also require the use of private water from onsite wells and an onsite wastewater treatment facility. Figure 6- 1 depicts the Measure J site plan and approximate development area of this alternative. Impact Analysis Since this alternative (Alternative 2) assumes that the project site would be developed under the existing County Measure J entitlement, this alternative would not require environmental review under CEQA. In addition, although this alternative may result in similar or greater environmental impacts in comparison to the proposed project, it would not require implementation of any of the mitigation measures identified in this EIR. Agricultural Resources. Alternative 2 would retain a maximum of 13.3 acres of agricultural area on the project site, which would result in approximately 10 percent of the net site acreage being preserved in agricultural use. Since Alternative 2 would be developed under the County’s jurisdiction, it would not achieve (nor would it be required to achieve) any of the City’s agricultural planning goals and standards for the Specific Plan Area. Specifically, Alternative 2 would conflict with the City’s General Plan Land Use Element Policy 8.1.4.f, which anticipates that future development on the San Luis Ranch property would dedicate one half of the total land or easements for agricultural or open space use, and that land dedicated to agriculture would be of size, location and configuration appropriate to maintain a viable, working agricultural operation. Therefore, with respect to consistency with City General Plan policies intended to protect agricultural land in the City, Alternative 2 would have an increased impact in comparison to the project. Furthermore, other potential impacts to agricultural resources under Alternative 2, including impacts associated with the conversion of Prime agricultural land and conflicts with nearby uses would be greater than the proposed project since this alternative would convert approximately 37 more acres of Prime agricultural land to non-agricultural use, in comparison to the project. Overall, impacts to agricultural resources would be greater under Alternative 2 in comparison to the project. Air Quality. Alternative 2 would result in development of 60 multi-family dwelling units, 560,000 square feet of regional commercial and outdoor sales areas, 198,000 square feet of office space, and a 150-room hotel and ancillary facilities on approximately 115 acres of the project site. Total development under this alternative would result in an approximate 30% increase in VMT as well as an increase in associated air quality emissions (refer to Transportation discussion below). The rate of increased VMT associated with Alternative 2 would be expected to exceed the anticipated rate of increase in regional population, similar to the project. Therefore, Alternative 2 would not avoid the significant and unavoidable air quality impact identified in this EIR for the project as proposed. Overall, impacts to regional air quality would be greater than those associated with the project. £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r No Project, Measure J Entitlements Alternative Site Plan and Development Area Figure 6-1 City of San Luis Obispo Section 6.0 AlternativesSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016.Additional data provided by San Luis Ranch Specific Plan. ±0 500250 Feet Site Boundary Measure J Development Area 6-8 San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-9 In addition, Alternative 2 includes development of an on-site wastewater treatment plant. This use could result in objectionable odors at uses on and adjacent to the project site. As such, Alternative 2 may result in greater impacts associated with new sources of objectionable odors on the site in comparison to the project. Greenhouse Gas Emissions. Residential and commercial development under Alternative 2 would result in an approximate 30% increase in VMT in the City (refer to Transportation discussion below), as well as an increase in associated GHG emissions. As a result, impacts associated with GHG emissions would be greater than those associated with the project. Land Use/ Policy Consistency. Because Alternative 2 would be processed by San Luis Obispo County, rather than the City, this alternative would not be required to be consistent with the City’s General Plan, which anticipates that the project site would be annexed to the City and developed consistent with the general requirements described in Land Use Element Policy 8.1.4 (SP-2, San Luis Ranch [Dalidio] Specific Plan Area). For this reason, this alternative would make it impossible for the City to achieve the goals established for this area in the General Plan, as well as overall General Plan goals related to housing, agricultural protection, minimizing impacts to creeks, and circulation. For this reason, Alternative 2 would result in greater impacts resulting from City General Plan policy inconsistency issues when compared to the project. Transportation. Based on similar trip rates to the project, but a different overall balance of land uses (less residential, more commercial and office), total development under Alternative 2 would result in an approximate 30% increase in vehicle trips and VMT. Similar to the project, vehicle trips generated by Alternative 2 would be expected to exceed the capacity and LOS thresholds for area intersections and roadways. The Measure J entitlements include space on the project site delineated specifically for a future extension of Dalidio Drive across U.S. 101 to Prado Road, as well as future freeway on- and off-ramps. However, the Measure J entitlements do not include construction of these improvements, which, similar to the project, are anticipated to be required to accommodate future traffic from development on the project site. In addition, the Measure J entitlements do not include mitigation for construction of other off-site roadway or intersection improvements to maintain acceptable level of service. Therefore, Alternative 2 would not avoid the significant and unavoidable transportation impacts identified in this EIR for the project. Overall, impacts to transportation and circulation under Alternative 2 would be greater in comparison to the project, because this alternative does not include roadway infrastructure improvements anticipated to be required to accommodate the traffic that would result from future development of the project site. Other Environmental Topics. Aesthetics. Alternative 2 would retain a maximum of 13.3 acres of agricultural land along U.S. 101. However, Alternative 2 would involve commercial and residential development that would alter existing foreground views from U.S. 101 to a more developed condition. Potential impacts to visual scenic resources would be increased in comparison to the project since there would be more development and substantially less agricultural land along the U.S. 101 corridor and within sight from surrounding scenic roadways. Unlike the proposed project, development under Alternative 2 would not be subject to review by the City’s Architectural San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-10 Review Committee to ensure compliance with the City’s applicable design guidelines. As a result, aesthetic impacts would be greater in comparison to the project. Biological Resources. Alternative 2 would retain some of the natural habitat areas on the site, such as the existing eucalyptus grove on the northwestern portion of the site along Madonna Road, and the riparian corridor along Prefumo Creek. However, because the extent of residential and commercial development would be similar or slightly greater on other portions of the project site, potential impacts to biological resources would remain potentially significant, similar to the project. However, this alternative would not be required to undergo environmental review pursuant to CEQA and, therefore, would not be required to incorporate mitigation to avoid or minimize potential effects to biological resources. As such, the potential adverse effects of impacts to biological resources would be greater in comparison to the project. Cultural Resources. As shown in Figure 6-1, Alternative 2 would increase the overall development footprint on the project site. This alternative would result in removal of the San Luis Ranch Complex on the northwestern portion of the site near Madonna Road, similar to the project. However, unlike the project, this alternative does not include a proposal to relocate, reconstruct, or otherwise preserve or document the historic San Luis Ranch Complex or its individually historic structures. Therefore, impacts to cultural resources under Alternative 2 would be greater to the project. Hazards and Hazardous Materials. Potential impacts associated with the presence, transport, and use of hazardous materials, as well as the demolition of buildings, under Alternative 2 would be similar to the project. Potential hazards associated with the proximity of the project site to the San Luis Obispo County Regional Airport would also be similar, because this alternative, as with the project, would be consistent with the CALUPH Airport Safety Zones, which represent the extent of Airport-related safety hazard zones for people residing or working in these areas. Hydrology and Water Quality. As shown in Figure 6-1, Alternative 2 would involve a larger overall development footprint. Therefore, this alternative would result in an incrementally increased amount of on-site grading in comparison to the project. Nevertheless, the final grading plan for this alternative would be required to comply with all County requirements to maintain adequate drainage and water quality standards. However, due to the substantial increase in re-grading that would be required to ensure adequate on-site drainage, potential impacts to water quality, under Alternative 2 would be greater than the proposed project. Noise. Construction activity for Alternative 2, including trucks hauling material to and from the site, would still occur near noise sensitive receptors located approximately 75 feet to the southwest and west from the project site boundary across Prefumo Creek. As described in Section 4.10, Noise, mitigation is not available that would not reduce construction noise below the applicable City standards. Therefore, construction noise impacts under Alternative 2 would remain significant and unavoidable, similar to the project. Potential operational noise impacts associated with on-site residential and commercial development under Alternative 2 would be similar to the project. However, this alternative would not be required to incorporate additional mitigation under CEQA to avoid or minimize San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-11 potential effects of noise associated with buildout under this alternative. As such, the potential adverse effects of impacts associated with noise would be greater when compared to the project. Recreation. Alternative 2 would include an increased area of parkland within the San Luis Ranch Specific Plan Area in comparison to the proposed project, and would generate fewer residents reliant on parkland and recreational facilities in the City. Therefore, potential impacts to recreation facilities and land under Alternative 2 would be reduced when compared to the project. Utilities and Service Systems. Although the overall extent of development on-site would be generally similar to the proposed project, Alternative 2 would not rely on City utilities. Because this alternative would be a County project surrounded by the City of San Luis Obispo, this alternative includes an on-site wastewater treatment plant to serve new development on the site. Overall, potential impacts to utilities and service systems in the City under Alternative 2 would be less than the project. Water Resources. Alternative 2 would result in less residential and more commercial development in comparison to the project. Since this alternative would be under County jurisdiction, it would avoid placing additional demand on the City’s water supply, which is supplied from multiple surface water sources. However, under County jurisdiction, this alternative would be required to rely on groundwater from the existing on-site wells. As such, Alternative 2 may result in increased water use from the on-site wells and, thus, increased demand on local groundwater sources. Overall, potential impacts to local surface water supplies would be less, but potential impacts to local groundwater would be greater than the project. 6.4.34 Alternative 3: Historical Resource Preservation Description This alternative assumes that the San Luis Ranch Farm Complex, as well as associated eucalyptus trees, located in the northwest portion of the project site would be retained, and that the proposed multi-family residential development would be relocated and integrated into the proposed single-family residential development area on the central portion of the project site. This configuration would likely result in fewer single-family homes and a corresponding increase in the number of multi-family or cluster-style residential development in order to preserve the total residential unit count on the project site. Figure 6-2 depicts the approximate development area of this alternative. Impact Analysis Alternative 3 differs from the proposed San Luis Ranch Specific Plan primarily by avoiding the historically significant San Luis Ranch Farm Complex, and transferring development intensity to other portions of the site. Thus, the primary effect would be the avoidance of impacts to cultural resources and related issues of land use/policy consistency and transportation and circulation. A brief summary of other CEQA issues under Alternative 3 is presented at the end of this discussion. Cultural Resources. Under Alternative 3, no development would occur on the northwest portion of the project site near Madonna Road, where the San Luis Ranch Complex is located. The existing historic San Luis Ranch Complex, including the main residence and the main barn, £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r Historic Resource Preservation Alternative Development Area Figure 6-2 City of San Luis Obispo Section 6.0 AlternativesSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. ±0 500250 Feet Site Boundary Historic Resource PreservationAlternative Development Area 6-12 San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-13 both of which are eligible for listing in the California Register of Historical Resources (CRHR), would be retained in full. The main residence and barn/viewing stand, which are proposed for adaptive reuse within the Agricultural Heritage and Learning Center under the project, would remain in their existing location and would not be adaptively reused under Alternative 3. Therefore, Alternative 3 would not result in adverse changes to individually identified historic structures or the historic context of the San Luis Ranch Complex, which is collectively identified as historically significant. Furthermore, Alternative 3 would not conflict with Conservation and Open Space Element Policy 3.3.1, Historic Preservation, which states that significant historic and architectural resources should be identified, preserved, and rehabilitated, or Conservation and Open Space Element Policy 3.3.2, Demolitions, which prohibits demolition or substantial changes in outward appearance of historically or architecturally significant buildings, unless doing so is necessary to remove a threat to health and safety and other means to eliminate or reduce the threat to acceptable levels are infeasible. Overall, Alternative 3 would avoid the significant and unavoidable impacts to historic resources identified for the project, and impacts to cultural resources would be less than significant. Land Use/Policy Consistency. Under Alternative 3, the historic San Luis Ranch Complex located on the northwest portion of the project site would be retained in full. As a result, Alternative 3 would not conflict with General Plan Land Use Element Policy 1.10.4 (Design Standards) or Conservation and Open Space Element Policy 3.3.2 (Demolitions). In addition, Alternative 3 would provide the same amount of parkland as the project – 3.4 acres – which is lower than the minimum of 5.8 acres required by the performance standards described in Land Use Element Policy 8.1.4. (SP-2, San Luis Ranch (Dalidio) Specific Plan Area). As a result, Alternative 3 would be similarly inconsistent with this policy in the City’s General Plan. Overall, Alternative 3 would result in fewer General Plan policy inconsistencies when compared to the project, but would still result in a significant and unavoidable land use impact related to policy consistency, similar to the project. Transportation and Circulation. Under Alternative 3, no development would occur on the northwest portion of the project site near Madonna Road, where the San Luis Ranch Complex is located. The proposed roadway connection through this portion of the project site from Madonna Road (San Luis Ranch Way) would not be constructed. This would result in increased traffic loading on other access roadways into the Specific Plan area, including Froom Ranch Way, Dalidio Drive, and the proposed Prado Road extension. In addition, Alternative 3 would retain the same number of residential units in a smaller area onsite, which would result in increased residential density as compared to the project. Medium- and high-density residential uses typically have lower vehicle trip rates than single-family residential uses. Accordingly, Alternative 3 would result in incrementally reduced impacts to area intersections and roadway segments when compared to the project. Nevertheless, project-generated vehicle trips would still be expected to exceed the capacity and LOS thresholds for area intersections and roadways, particularly at the Froom Ranch Way, Dalidio Drive, and the Prado Road access routes onto the project site. Therefore, Alternative 3 would not avoid the significant and unavoidable transportation impacts identified in this EIR for the project. Overall, impacts to transportation and circulation would be similar to or slightly increased due to the loss of the proposed San Luis Ranch Way access route in comparison the project. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-14 Other Environmental Topics. Aesthetics. Alternative 3 would retain the eucalyptus trees and San Luis Ranch Complex on the northwest portion of the project site near Madonna Road. Therefore, Alternative 3 would not alter existing foreground views from Madonna Road to a more developed condition. Potential impacts to visual and aesthetic resources under Alternative 3 would be slightly reduced in comparison to the project when viewed from Madonna Road, but may be slightly increased from other viewpoints, including U.S. 101 and Prado Road, due to increased/concentrated development intensity on the central portion of the site. As with the project, development under Alternative 3 would be subject to review by the Architectural Review Committee to ensure compliance with the City’s applicable design guidelines similar to the project. Overall, aesthetic impacts would remain less than significant. Agricultural Resources. Potential impacts to agricultural resources under Alternative 3, as well as the mitigation measures that would avoid or minimize these effects, would be similar to the project. Air Quality. Alternative 3 would result in the development of the same number of residential units and amount of commercial square footage as the project. However, retaining the same number of residential units in a smaller area onsite would result in increased residential density as compared to the project. Medium- and high-density residential uses typically have lower vehicle trip rates than single-family residential uses. Accordingly, Alternative 3 would result in incrementally reduced VMT and associated air quality emissions when compared to the project. Nevertheless, the incrementally reduced VMT associated with Alternative 3 would still be expected to exceed the anticipated increase in regional population. Therefore, Alternative 3 would not avoid the significant and unavoidable air quality impact identified in this EIR for the project as proposed. Overall, impacts to air quality would be incrementally less than the project. Biological Resources. Alternative 3 would reduce the overall development footprint and retain the existing mature eucalyptus trees on the northwest portion of the project site near Madonna Road. The eucalyptus trees provide nesting habitat for raptors, great blue herons, and a variety of songbirds, roosting habitat for owls and turkey vultures, and are a historic monarch butterfly overwintering site. These trees also provide foraging habitat for birds and small mammals. As such, retaining the on-site eucalyptus trees under Alternative 3 would reduce potential impacts to biological resources as compared to the project. Because the extent of residential and commercial development would be similar on other portions of the project site, potential impacts to biological resources would remain potentially significant, and the mitigation measures that would avoid or minimize these effects, would be similar to the project. Greenhouse Gas Emissions. Alternative 3 would result in the development of the same number of residential units and amount of commercial square footage as the project. However, retaining the same number of residential units in a smaller area onsite would result in increased residential density as compared to the project. Medium- and high-density residential uses typically have lower vehicle trip rates than single-family residential uses. Accordingly, Alternative 3 would result in incrementally reduced VMT and associated GHG emissions when compared to the project. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-15 Hazards and Hazardous Materials. Potential impacts associated with the presence, transport and use of hazardous materials, the demolition of buildings, and the proximity of the San Luis Obispo County Regional Airport under Alternative 3, as well as the mitigation measures that would avoid or minimize these effects, would be similar to the project. Hydrology and Water Quality. Alternative 3 would result in a similar overall level of residential and commercial development to the project. However, since Alternative 3 would not involve development on the northwest portion of the site near Madonna Road, Alternative 3 would involve less overall on-site grading in comparison to the project. Nevertheless, the final grading plan for this alternative would be expected to show a similar overall drainage pattern to the project, with the residential and commercial development area being regraded to a higher election to raise it above the 100-year floodplain, and site drainage being conducted south and west via Cerro San Luis Channel and Prefumo Creek. Therefore, potential impacts to water quality and drainage patterns and infrastructure under Alternative 3, as well as the mitigation measures that would avoid or minimize these effects, would be slightly less or similar to the project. Noise. Alternative 3 would result in the development of the same amount of residential units and commercial square footage as the project, but in a smaller area on the project site. The revised project footprint under Alternative 3 would result in construction activity being located farther from Laguna Lake Park, which is located approximately 110 feet to the north of the project site across Madonna Road. However, construction activity for Alternative 3, including trucks hauling material to and from the site, would still occur near noise sensitive receptors located approximately 75 feet to the southwest and west from the project site boundary across Prefumo Creek. As described in Section 4.10, Noise, mitigation is not available that would not reduce construction noise below the applicable City standards. Therefore, construction noise impacts under Alternative 3 would remain significant and unavoidable, similar to the project. Alternative 3 would result in a similar overall level of residential and commercial development to the project, but would locate residential development further from Madonna Road, and would result in incrementally fewer new vehicle trips on area roadways. Mitigation required to avoid or minimize operational noise impacts would be similar to the project; however, potential operational noise impacts under Alternative 3, would be incrementally reduced in comparison to the project. Recreation. Alternative 3 would result in a similar overall level of residential and commercial development to the project. Therefore, potential impacts to recreation facilities and land under Alternative 3, and the mitigation measures that would avoid or minimize these effects, would be similar to the project. Utilities and Service Systems. Alternative 3 would result in a similar overall level of residential and commercial development to the project. Therefore, potential impacts to utilities and service systems in the City under Alternative 3 would be similar to the project and would remain less than significant. Water Resources. Alternative 3 would result in a similar overall level of residential and commercial development to the project. As such, potential impacts associated with demand on local water supply under Alternative 3, including demand on City municipal and groundwater irrigation well water supply, would be similar to the project. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-16 6.4.45 Alternative 4: 50% On-Site Agriculture/Open Space Description The intent of this alternative is to retain 50 percent of the net site acreage as on-site agricultural and open space uses to be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f. This alternative would retain the portion of land designated for commercial uses (NC) southeast of Froom Ranch Way and southwest of Prado Road in agriculture. This modification would preserve approximately 3.6 acres of additional on-site agricultural area in comparison to the proposed project. In addition, this alternative would shift the alignment of Froom Ranch Way to the northwest to retain a minimum of one additional acre of agricultural area in comparison to the proposed project. The modified alignment of Froom Ranch Way would reduce the portion of the site available for low-medium density residential (NG-10) and medium density residential (NG-23), resulting in a reduction in total residential units on the project site. For this analysis, this alternative assumes that the realignment of Froom Ranch Way would eliminate the southernmost row of low-medium density residential and medium density residential lots, resulting in a total reduction of 31 low-medium density residential units and 7 medium density residential units. Removal of these residential units would be expected to result in a corresponding reduction in the 80-unit affordable housing density bonus. Therefore, this alternative assumes that the overall residential buildout of the project site would be reduced from 580 units to 536 units. In combination, these two modifications would retain a minimum of 57.3 acres of agricultural area on the project site, which would result in a minimum of 50 percent of the net site acreage being retained in agricultural and open space uses. Figure 6- 3 depicts the approximate development area of this alternative. This alternative would be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f, which requires that future development on the San Luis Ranch property dedicate one half of the total land or easements for open space use, and that land dedicated to agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. Land Use Element Policy 8.1.4. SP-2, San Luis Ranch (Dalidio) Specific Plan Area. Purpose: This project site should be developed as a mixed use project that maintains the agricultural heritage of the site, provides a commercial/office transition to the existing commercial center to the north, and provides a diverse housing experience. Protection of the adjacent creek and a well-planned integration into the existing circulation system will be required. The specific plan for this area should consider and address the following land use and design issues. f. Maintain significant agricultural and open space resources on site (see Policy 1.13.8.B). Land dedicated to Agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. General Plan Land Use Element Policy 8.1.4.f includes the following performance standards, which include the requirement that the San Luis Ranch Specific Plan maintain a minimum of 50% of the site acreage in open space/agriculture, but notes that the City Council may consider allowing a portion of this requirement to be met through and off-site dedication. £¤101 Madonna Rd Oceanaire Dr El M e r c a d o D a l i d i o D r 50% On-Site Agriculture/Open Space Alternative Development Area Figure 6-3 City of San Luis Obispo Section 6.0 AlternativesSan Luis Ranch Project EIR Imagery provided by Google and its licensors © 2016. ±0 500250 Feet Site Boundary 50% On-Site Agriculture/Open SpaceAlternative Development Area 6-17 San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-18 Type Designations Allowed % of Site Minimum Maximum Residential LDR, MDR, MHDR, HDR 350 units 500 units Commercial NC, CC 50,000 sf 200,000 sf Office/High tech O 50,000 sf 150,000 sf Hotel/Visitor- serving 200 rooms Parks PARK 5.8 acres Open Space/ Agriculture OS, AG Minimum 50% 1 No maximum Public n/a Infrastructure n/a 1. The City Council may consider allowing a portion of required open space to be met through off-site dedication provided: a. A substantial multiplier for the amount of open space is provided for the off-site property exchanged to meet the on-site requirement; and b. Off-site land is of similar agricultural and visual value to the community; and c. Off-site land is protected through an easement, dedication or fee title in perpetuity for agriculture/ open space. Impact Analysis Alternative 4 differs from the proposed San Luis Ranch Specific Plan primarily by avoiding conversion of agricultural land to commercial and residential uses in the southeast corner of the Specific Plan Area, and reducing the number of residential units. Thus, the primary effect would be the avoidance of impacts to agricultural resources and related issues of land use/policy consistency and transportation and circulation. A brief summary of other CEQA issues under Alternative 4 is presented at the end of this discussion. Agriculture Resources. Alternative 4 would retain a minimum of 57.3 acres of agricultural area on the project site, which would result in a minimum of 50 percent of the net site acreage being preserved in agricultural and open space uses. Accordingly, Alternative 4 would be consistent with the City’s General Plan Land Use Element Policy 8.1.4.f, which requires that future development on the San Luis Ranch property dedicate one half of the total land or easements for open space use, either on-site or off-site through dedication of an off-site agricultural conservation easement/deed restriction, and that land dedicated to agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. Because Alternative 4 would convert fewer acres of Prime agricultural land to non-agricultural uses, this alternative would have a reduced impact in comparison to the project. Land Use/Policy Consistency. Alternative 4 would be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f, which requires that future development on the San Luis Ranch property dedicate one half of the total land or easements for open space use, and that land dedicated to agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. However, Alternative 4 would remain potentially inconsistent with General Plan Land Use Element Policy 1.10.4 (Design Standards), Circulation Element Policy 6.1.2 (Multimodal Level of Service Objectives), Conservation and San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-19 Open Space Element Policy 3.3.2 (Demolitions), and Conservation and Open Space Element Policy 3.3.3 (Historical Documentation), similar to the project. Overall, Alternative 4 would result in similar potential General Plan policy inconsistencies when compared to the project, and would still result in a significant and unavoidable land use impact related to policy consistency. Transportation and Circulation. Alternative 4 would result in 44 fewer residential units (a reduction of approximately 7 percent of the project’s planned residential buildout) and approximately one-third less commercial square footage than the project. Accordingly, Alternative 4 would result in incrementally reduced VMT. Nevertheless, vehicle trips generated by Alternative 4 would still be expected to exceed the capacity and LOS thresholds for area intersections and roadways, requiring similar transportation mitigation in comparison to the project. Therefore, Alternative 4 would not avoid the significant and unavoidable transportation impacts identified in this EIR for the project. Overall, impacts to transportation and circulation under Alternative 4 would be slightly reduced in comparison to the project. Other Issues. Aesthetics. Alternative 4 would retain approximately 3.6 acres of agricultural land southeast of Froom Ranch Way and southwest of Prado Drive Road, as well as approximately 1.0 acre of agricultural land along the southwestern side of Froom Ranch Way as a result of the slight realignment of this roadway. However, Alternative 4 would still involve commercial and residential development that would alter existing foreground views from U.S. 101 to a more developed condition. Potential impacts to visual scenic resources may be slightly reduced in comparison to the project, but would remain less than significant. As with the proposed project, development under Alternative 4 would be subject to review by the Architectural Review Committee to ensure compliance with the City’s applicable design guidelines similar to the project. Overall, aesthetic impacts would remain less than significant. Air Quality. Alternative 4 would result in 44 fewer residential units (a reduction of approximately 7 percent of the project’s planned residential buildout) and approximately one- third less commercial square footage than the project. Accordingly, Alternative 4 would result in incrementally reduced VMT and associated criteria pollutant emissions in comparison to the project. Nevertheless, criteria pollutant emissions associated with Alternative 4 would still exceed applicable SLOAPCD emissions thresholds, and similar mitigation would be required in comparison to the project. In addition, the incremental reduction in VMT associated with Alternative 4 would still exceed the anticipated increase in regional population. Therefore, impacts to air quality under Alternative 4 would be slightly reduced in comparison to the project, but would remain significant and unavoidable. Biological Resources. Alternative 4 would slightly reduce the overall development footprint. However, this incremental reduction in development area would occur in areas of existing agricultural development, and would not result in a substantial reduction in potential areas that may contain sensitive biological resources, such as the existing eucalyptus grove on the northwestern portion of the site along Madonna Road, or the riparian corridor along Prefumo Creek. Because the extent of residential and commercial development would be similar on other portions of the project site, potential impacts to biological resources would San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-20 remain potentially significant, and the mitigation measures that would avoid or minimize these effects, would be similar to the project. Cultural Resources. Alternative 4 would slightly reduce the overall development footprint. However, this incremental reduction in development area would occur in areas of existing agricultural development. The historic San Luis Ranch Complex, including individually historic structures, on the northwestern portion of the site near Madonna Road would be removed or relocated, similar to the project. The extent of residential and commercial development under Alternative 4 would be generally similar to the project on other portions of the project site. Therefore, impacts to cultural resources under Alternative 4 would be similar to the project and would remain significant and unavoidable. Greenhouse Gas Emissions. Alternative 4 would result in 44 fewer residential units (a reduction of approximately 7 percent of the project’s planned residential buildout) and approximately one-third less commercial square footage than the project. Accordingly, Alternative 4 would result in incrementally reduced VMT and associated GHG emissions in comparison to the project. Hazards and Hazardous Materials. Potential impacts associated with the presence, transport and use of hazardous materials, the demolition of buildings, and the proximity of the San Luis Obispo County Regional Airport under Alternative 4, as well as the mitigation measures that would avoid or minimize these effects, would be similar to the project. Hydrology and Water Quality. Alternative 4 would result in reduced overall level of residential and commercial development when compared to the project. Accordingly, Alternative 4 would involve an incrementally reduced amount of on-site grading when compared to the project. Nevertheless, the final grading plan for this alternative would be expected to show a similar overall drainage pattern to the project, with the residential and commercial development area being regraded to a higher election to raise it above the 100-year floodplain, and site drainage being conducted south and west via Cerro San Luis Channel and Prefumo Creek. Overall, potential impacts to water quality and drainage patterns and infrastructure under Alternative 4, as well as the mitigation measures that would avoid or minimize these effects, would be slightly less or similar to the project. Noise. Construction activity for Alternative 4, including trucks hauling material to and from the site, would still occur near noise sensitive receptors located approximately 75 feet to the southwest and west from the project site boundary across Prefumo Creek. As described in Section 4.10, Noise, mitigation is not available that would not reduce construction noise below the applicable City standards. Therefore, construction noise impacts under Alternative 4 would remain significant and unavoidable, similar to the project. Alternative 4 would result in 44 fewer residential units (a reduction of approximately 7 percent of the project’s planned residential buildout) and approximately one-third less commercial square footage than the project. As a result, potential operational noise impacts under Alternative 4 would be incrementally reduced when compared to the project. Nevertheless, Alternative 4 would result in the development of on-site residences located adjacent to proposed retail uses for which the Specific Plan does not include standards that would ensure that noise levels would remain below applicable City standards. Therefore, operational noise San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-21 impacts under Alternative 4, as well as the mitigation measures that would avoid or minimize these effects, would be similar to the project. Recreation. Alternative 4 would include a similar area of parkland or recreational facilities provided within the San Luis Ranch Specific Plan Area. Therefore, potential impacts to recreation facilities and land under Alternative 4, and the mitigation measures that would avoid or minimize these effects, would be similar to the project. Utilities and Service Systems. Alternative 4 would result in less residential and commercial development than the project. Therefore, potential impacts to utilities and service systems in the City under Alternative 4 would be incrementally reduced when compared to the project, and would remain less than significant. Water Resources. Alternative 4 would result in less residential and commercial development than the project. Therefore, potential impacts associated with demand on local water supply under Alternative 4, including demand on City municipal and groundwater irrigation well water supply, would be slightly reduced when compared to the project, and would remain less than significant. 6.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE Section 15126.6(e)(2) of the State CEQA Guidelines requires that an analysis of project alternatives identify an environmentally superior alternative among the alternatives evaluated in the EIR. In general, the environmentally superior alternative as defined by CEQA should minimize adverse impacts to the project site and its surrounding environment. This section evaluates the impact conclusions for the San Luis Ranch Specific Plan and the four (4) alternatives under consideration. It then identifies the environmentally superior alternative for each issue area. In accordance with the State CEQA Guidelines, if the No Project Alternative is identified as the Environmentally Superior Alternative, an alternative among the remaining scenarios which is environmentally superior must also be identified. Table 6-1 summarizes the environmental advantages and disadvantages associated with the proposed project and the analyzed alternatives. CEQA Guidelines section 15126.6 states that if the environmentally superior alternative is the No Project Alternative, the EIR shall also identify an environmentally superior alternative from among the other alternatives. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-22 Table 6-1 Alternative Impact Comparison to the San Luis Ranch Specific Plan Issue No Project Alternative 3: Historical Resource Preservation Alternative 4: 50% On-Site Agriculture/Open Space Alternative 1: No Project/No Development Alterative 2: No Project, Measure J Entitlements Major Issues (EIR identifies significant and unavoidable impacts) Air Quality Less Greater Less Less Cultural Resources Less Greater Less Similar Greenhouse Gas Emissions Less Greater Less Less Land Use/Policy Consistency Less Greater Less Similar Noise Less Greater Less Similar Transportation Less Greater Greater Less Other Issues (EIR identifies impacts that are less than significant with or without mitigation) Aesthetics Less Greater Similar Less Agricultural Resources Less Greater Similar Less Biological Resources Less Greater Less Similar Greenhouse Gas Emissions Less Greater Less Less Hazards &Hazardous. Materials Less Similar Similar Similar Hydrology & Water Quality Less Greater Less Less Recreation Less Less Similar Similar Utilities & Service Systems Less Less Similar Less Water Resources Less Both Less (Surface Water) and Greater (Groundwater) Similar Less Overall 15 Less, 0 Greater 3 Less, 12 Greater 8 Less, 1 Greater 9 Less, 0 Greater Based on the comparison provided in Table 6-1, the No Project/No Development Alternative (Alternative 1) would result in the fewest adverse environmental effects. However, since this is the “No Project” alternative, CEQA requires that a separate alternative also be identified as the Environmentally Superior Alternative. Alternative 2 would fail to meet most of the project-specific objectives. As shown in Table 6-1, Alternative 2 would result in increased physical environmental impacts when compared to the project and would not achieve many of the planning goals included in the City’s General Plan as they apply to the San Luis Ranch Specific Plan area. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-23 As described in Section 6.4.4, Alternative 4 would not reduce any of the project’s significant and unavoidable impacts to a level below significance thresholds. However, as shown in Table 6-1, Alternative 4 would result in incrementally reduced impacts to several issue areas, including air quality, GHG emissions, transportation, aesthetics, and agricultural resources. As described in Section 6.4.3, Alternative 3 would preserve the San Luis Ranch Complex, thereby avoiding the significant and unavoidable impact to historic resources identified for the project. This alternative would also reduce other potential environmental effects due to the preservation of the eucalyptus grove in the northwest portion of the project site along Madonna Road, and due to the reduced overall development footprint. As shown in Table 6-1, Alternative 3 would also result in reduced impacts to air quality, GHG emissions, noise, biological resources, land use/policy consistency, and hydrology and water quality, while resulting in slightly increased impacts to transportation (due to the loss of the proposed San Luis Ranch Way access route). Alternative 3 would also achieve the basic objectives of the project. This alternative would provide infill growth for the City, and would be generally consistent with the General Plan with the existing historic structures on the project site. A variety of housing opportunities would be available, including affordable housing opportunities. The multimodal transportation network would continue to provide accessibility via automobile, bicycle, and pedestrian amenities, including the Bob Jones Regional Trail. The alternative would be similar to the project in its adherence to sustainable development practices and design features. Therefore, Alternative 3 is identified as the environmentally superior alternative over other alternatives, as shown in Table 6-1. San Luis Ranch Project EIR Section 6.0 Alternatives City of San Luis Obispo 6-24 This page intentionally left blank. San Luis Ranch Project EIR Section 7.0 References City of San Luis Obispo 7-1 7.0 REFERENCES AND EIR PREPARERS 7.1 REFERENCES 7.1.1 Source Material Althouse and Meade, Inc. August 2014. Biological Constraints Report for San Luis Ranch. Althouse and Meade, Inc. April 2015. California Red-legged Frog Protocol Survey Site Assessment for San Luis Ranch. Althouse and Meade, Inc. May 2015. Delineation of Potential Jurisdictional Wetlands and Waters for San Luis Ranch. Angel, Myron. 1883. History of San Luis Obispo County, California. Thompson & West, Oakland, CA. Association of Environmental Professionals (AEP). March 2015. Beyond 2020: The Challenges of Greenhouse Gas Reduction Planning by Local Governments in California. Available at: https://www.califaep.org/climate-change. Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, editors. The Jepson Manual: Vascular Plants of California, second edition. 2012. University of California Press, Berkeley, CA. Bertrando and Bertrando Research Consultants. 1998. Historical Evaluation for the Froom Ranch Building Complex, San Luis Obispo County, CA. Prepared for Dennis Schmidt of Central Coast Engineering. March 14, 1998. Bertrando and Bertrando Research Consultants. 1999a. 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United States Fish and Wildlife Service. 2016a. Critical Habitat Portal. Available at: http://criticalhabitat.fws.gov. United States Fish and Wildlife Service. 2016b. Information, Planning, and Conservation System. Available at: http://ecos.fws.gov/ipac/. United States Geological Survey. 2016a. National Hydrography Dataset. Accessed through the National Map at: http://viewer.nationalmap.gov/viewer. United States Geological Survey. 2016b. StreamStats Tool for California. Available at: http://water.usgs.gov/osw/streamstats/. Water Resources Control Board (2010). 2010 Integrated Report (Clean Water Act Section 303(d) List / 305(b) Report). Available at: http://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2010.html. Western Regional Climate Center. 2010. Climate of California. Available at: http://www.wrcc.dri.edu/narratives/CALIFORNIA.htm. Western Regional Climate Center. 2016. San Luis Obispo Polytech, California – Period of Record Monthly Climate Summary. Available at: http://www.wrcc.dri.edu/cgi- bin/cliMAIN.pl?ca7851. Worland, J. December 12, 2015. What to Know About the Historic ‘Paris Agreement’ on Climate Change. Time. Retrieved from http://time.com/4146764/paris-agreement-climate-cop- 21/. World Meteorological Organization (WMO). March 2013. A summary of current and climate change findings and figures. 7.1.2 Contacts Floyd, Aaron, Deputy Direction Water Division. City of San Luis Obispo Utilities Department. July 22, 2016. 7.2 EIR PREPARERS The City of San Luis Obispo prepared this EIR with the assistance of Rincon Consultants, Inc. Rincon Consultants’ staff involved in the preparation of the EIR are listed below. Richard Daulton, MURP, Principal Colby Boggs, Principal/Senior Ecologist San Luis Ranch Project EIR Section 7.0 References City of San Luis Obispo 7-13 Chris Bersbach, MESM, Technical Services Project Manager Megan Jones, MPP, Senior Program Manager Lindsey Sarquilla, MESM, Senior Environmental Planner Jonathan Berlin, MESM, Associate Environmental Planner Jamie Deutsch, CISEC/QSP, Associate Biologist Mattie Cardenaz, Associate Environmental Planner Doug Carreiro, GIS Analyst Allysen Valencia, GIS Analyst Jon Montgomery, GIS Analyst Debra Jane Seltzer, Document Production Specialist San Luis Ranch Project EIR Section 7.0 References City of San Luis Obispo 7-14 This page intentionally left blank. San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo 8.0 RESPONSES TO COMMENTS ON THE DRAFT EIR 8.1 INTRODUCTION In accordance with Section 15088 of the State California Environmental Quality Act (CEQA) Guidelines, the City of San Luis Obispo, as the lead agency, has reviewed the comments received on the Draft Environmental Impact Report (Draft EIR) for the San Luis Ranch Project and has prepared responses to all comments received. The Draft EIR was circulated for a 52-day public review period that began December 9, 2016 and concluded on January 31, 2017. The original 45-day comment period was scheduled to end on January 23, 2017, but was extended one calendar week. The City received comment letters through January 31, 2017 which are included herein. The City held a public Planning Commission hearing on January 11, 2017, which was continued on January 25, 2017, to receive public testimony in the form of verbal comments on the Draft EIR. The City held a Cultural Heritage Committee hearing for the project on January 23, 2017 to receive public testimony in the form of verbal comments on the Draft EIR. In addition, a portion of the Draft EIR was recirculated for a 45-day public review period that began March 3, 2017 and concluded on April 17, 2017. The portion of the Draft EIR that was recirculated (“Recirculated Portions”) was Section 5.0, Other CEQA-Related Discussions, which was revised to include an updated discussion of energy use and conservation related to the project. This recirculation also included the relevant portions of Appendix D as originally contained in the Draft EIR. It should be noted that as a result of this new discussion, no new significant impacts or mitigation measures were identified. Pursuant to Section 15088.5(c) of the State CEQA Guidelines, if the revisions subject to recirculation are limited to a few portions of the Draft EIR, the lead agency need only recirculate the portions that have been modified. Responses are provided to all comments received on the recirculated portions of the Draft EIR during the additional public review period, but are not provided for additional comments on the remainder of the Draft EIR to which modifications were not made. Each written and verbal comment that the City received is included in this Responses to Comments section. Responses to these comments have been prepared to address the environmental concerns raised by the commenters and to indicate where and how the Draft EIR addresses pertinent environmental issues. The focus of the responses to comments is the disposition of environmental issues that are raised in the comments, as specified by Section 15088(c) of the State CEQA Guidelines. Detailed responses are not provided to comments on the merits of the proposed project. In addition, Section 15131 of the State CEQA Guidelines states that “economic or social effects of a project shall not be treated as significant effects on the environment.” When a comment is not directed to an environmental issue, the response indicates that the comment will be forwarded to the appropriate decision-makers for review and consideration as part of the public record. The Draft EIR and responses to comments collectively comprise the Final EIR for the project. Any changes made to the text of the Draft EIR to correct information, data, or intent, other than minor typographical corrections or minor working changes, are noted in the Final EIR as changes from the Draft EIR. Where a comment results in a change to the Draft EIR text, a 8-1 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo notation is made in the response indicating that the text is revised. Changes in the Draft EIR text are signified by strikeouts (strikeouts) where text is removed and by underline font (underline font) where text is added. If text is added where the font is already bold or underlined, additions are noted using underlined bold font (underlined bold font). 8.2 MASTER RESPONSES Responses to specific verbal and written comments on the Draft EIR are provided in Sections 8.3 (Responses to Public Testimony) and 8.4 (Responses to Written Comments). The following Section provides “Master Responses,” which are intended to address questions and concerns regarding the Draft EIR that were raised by commenters throughout the Draft EIR comment period, and are in some cases referred to in specific responses throughout Sections 8.3 and 8.4. Master Response 1 – Adequacy of Draft EIR Alternatives Several commenters raised issues regarding the adequacy of project alternatives evaluated in the Draft EIR. Several commenters also requested that the Draft EIR include a discussion of an additional alternative, evaluating the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. State CEQA Guidelines Section 15126.6(a) states that “An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” Alternatives 1 and 2 are both “no project” alternatives;” Alternative 1 would retain the site in its current condition, and Alternative 2 envisions the site being developed under the existing Measure J entitlements. Per State CEQA Guidelines Section 15126(e)(2), “the “no project” analysis shall discuss the existing conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.” Section 6.4.3, Alternative 3: Historical Resource Preservation, evaluates Alternative 3, which retains the San Luis Ranch Complex, reducing the overall development footprint on the project site. This alternative was selected to examine the effects of an alternative with a smaller footprint than the proposed project, and that both eliminated a significant impact (historic) and meets most of the project objectives. Based on the analysis of Alternative 3, the reduction in the development footprint of the project site would avoid the significant and unavoidable impact to historic resources identified for the project, and would also incrementally reduce impacts to air quality, GHG emissions, noise, biological resources, land use/policy consistency, and hydrology and water quality. Section 6.4.4, Alternative 4: 50% On-Site Agriculture/Open Space, evaluates Alternative 4, in which overall residential buildout would be reduced from 580 units to 536 units. This alternative was selected to examine the effects of an alternative that both reduced the number of units and the amount of disturbance, and met the policy objective of 50 percent agricultural preservation on-site, while meeting most of the project objectives. Based on the analysis of Alternative 4, the reduction in residential units would incrementally reduce 8-2 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo environmental impacts on the project site, including air quality, GHG emissions, transportation, aesthetics, and agricultural resources, primarily due to the reduction in VMT and development footprint on the project site. However, this alternative would not eliminate any of the significant and unavoidable impacts of the project, or eliminate the need for any of the mitigation measures included in the Draft EIR. The alternatives evaluated in the Draft EIR were found to be feasible, based on the State CEQA Guidelines Section 15126.6(a), which states that “among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” The State CEQA Guidelines Section 15126.6(a) also states that “an EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation.” Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. The project site is a designated Specific Plan under the City’s General Plan Land Use Element, and Alternatives 3 and 4 are both adaptations of what is allowable on the project site based on the General Plan, and are intended to illustrate the comparative effects of reducing the area of disturbance and the number of units on the project site. According to the City’s General Plan performance standards for the San Luis Ranch Specific Plan Area, the minimum number of residential units anticipated within the Specific Plan Area is 350 units, and the minimum square footage of non-residential development anticipated within the Specific Plan Area is 100,000 square feet (50,000 square feet of commercial and 50,000 square feet of office (refer to Section 2.5.2, Land Use Concept, and Table 2-1 in Appendix B, Draft Specific Plan). As the Draft EIR includes evaluation of alternatives that would both reduce the development footprint on the project site and the total amount of new development, the lower buildout density alternative requested by commenters would not provide significant new information otherwise not disclosed in the evaluation of Alternatives 3 or 4 in the Draft EIR. Furthermore, pursuant to CEQA Guidelines Section 15126.6(a), alternatives shall be limited to those that would avoid or substantially lessen any of the significant effects of the project. A 350-unit alternative would not reduce any identified significant environmental impacts to a less than significant level. Therefore, this potential alternative was not considered further in the Draft EIR. Master Response 2 – Prado Road Overcrossing/Interchange Mitigation for Transportation Impacts Several commenters raised questions and concerns regarding the Draft EIR project-level mitigation requiring the construction of the Prado Road Overcrossing with Northbound U.S. 101 Ramps (Mitigation Measures T-1, T-2, and T-3), and cumulative mitigation requiring construction of the Prado Road Overcrossing & U.S. 101 Southbound Ramps (Mitigation Measure T-8). Specific statements, questions, and requests regarding the Prado Road Overcrossing or Prado Road Interchange at U.S. 101 include: • Questions related to the final design for the Prado Road Overcrossing/Interchange; 8-3 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo • Requests that the Draft EIR evaluate the potential environmental effects associated with the final design or with all design options for this improvement; • Statements that the Prado Road Overcrossing/Interchange would not adequately mitigate impacts to transportation resulting from the project, and statements that this improvement does not have a nexus with the transportation impacts that the Draft EIR identifies, and that transportation impacts that the Draft EIR identifies may be feasibly mitigated through other transportation improvement measures; • Questions regarding the timing of construction of the Prado Road Overcrossing/Interchange, including requests for an explanation as to why the mitigation is not required prior to development of the project to alleviate existing traffic; • Questions regarding the sources of funding for the Prado Road Overcrossing/Interchange; • Questions regarding the Caltrans approval process for the Prado Road Overcrossing/Interchange; and • Statements that approval or construction of the Prado Road Overcrossing/Interchange may be infeasible, and that the Draft EIR should conclude that transportation impacts are significant and unavoidable. As described in Section 1.1.3, a full access interchange at U.S. 101 and Prado Road has been a component of the San Luis Obispo County Regional Transportation Plan (RTP) and City Circulation Element for several decades. Environmental review and approval of programs, services, development and projects which have since been implemented have been in part predicated on a full access interchange at U.S. 101/Prado Road. Programmatic (policy-level) analysis conducted for the San Luis Ranch Specific Plan Area as part of the Land Use and Circulation Element Update identified that without a full access interchange at U.S. 101/Prado Road under buildout conditions, City streets and intersections would operate at unacceptable levels of service. While there are existing deficiencies in the City that would be addressed by the Prado Road Overcrossing/Interchange, the project is not responsible for mitigating existing transportation deficiencies. The project would be responsible for addressing transportation impacts that would result from, or be exacerbated by, project development. The San Luis Ranch Specific Plan does not include any improvements related to either a Prado Road overpass or interchange, but accommodates the potential development of either facility, if and when these are needed. The project proposes to dedicate the necessary right-of-way and financially participate in the overpass or interchange project in accordance with an equitable share analysis. The Multimodal Transportation Impact Study (Appendix L) was developed, in part, to identify if and when implementation of the Prado Road overpass or interchange would be necessary to achieve acceptable levels of service on City roadways and intersections, in consideration of vehicle trips generated by the project, in combination with existing and anticipated development in the City. As described in Section 4.12, Transportation, project-generated traffic would result in potentially significant transportation impacts at eight project-area intersections and thirteen project-area roadway segments by Phase 2 of the project. These transportation impacts would be reduced and acceptable levels of service achieved by the Prado Road Overcrossing with Northbound U.S. 101 Ramps. Under cumulative conditions, based on the City’s General Plan buildout as included in the City’s Travel Demand Model, project-generated traffic would result in 8-4 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo potentially significant transportation impacts at seven project-area intersections and nine project-area roadway segments. These cumulative transportation impacts would be reduced and acceptable levels of service achieved by construction of the Southbound U.S. 101 Ramps at the Prado Road Overcrossing. Therefore, the Draft EIR and the Multimodal Transportation Impact Study (Appendix L) identify a full interchange at Prado Road as the most feasible long-term option for mitigation of several related project traffic impacts resulting from the project and cumulative development in the project region. While project impacts at some of these study area intersections and roadways may be reduced through implementation of other circulation improvements, the Prado Road Overcrossing/Interchange is an anticipated transportation improvement in the San Luis Obispo County RTP and the City’s Circulation Element. Implementing alternative mitigation for facilities where the Prado Road Overcrossing/Interchange would require substantial additional right-of-way acquisition in several locations that would be costly and potentially physically infeasible, including potential relocations of off-site structures. The potential residual environmental impacts of the Prado Road Overcrossing/Interchange mitigation are discussed in Section 4.12.4(d), Residual Impacts Associated with Off-Site Improvements. This analysis evaluates a reasonable worst-case for future development associated with this mitigation, which includes a four-lane overpass that would connect Prado Road on the east side of U.S. 101 with the proposed Prado Road Extension (Dalidio Drive) on the west side of U.S. 101, including reconstructed northbound ramps on the east side of U.S. 101 and a new southbound ramp system located primarily within the San Luis Ranch Specific Plan area west of U.S. 101. In addition to the environmental analysis of the residual impacts of this mitigation, the potential environmental effects of the final design of the Prado Road Overcrossing/ Interchange would be evaluated at a project level of detail by the City through the required State and federal (if applicable) environmental documentation for that project, including evaluation of various alternatives. Policy 9.2.2 of the Circulation Element requires the sponsors of development projects that contribute to the need for the Prado Road Overcrossing/Interchange to prepare or fund the preparation of a Project Study Report (PSR) for the interchange project. A PSR is an engineering report prepared cooperatively by Caltrans and local and regional agencies for projects on the State highway system, with the purpose of documenting agreement on the scope, schedule and estimated cost of a project so the project can be considered for inclusion in a future programming document such as the State Transportation Improvement Program (STIP). The PSR for the Prado Road Overcrossing/Interchange is currently being undertaken in compliance with Section 501.3 of the Caltrans Highway Design Manual, in parallel with the review of the San Luis Ranch Project. As the timing, features, design, and specific area of disturbance of the Prado Road/U.S. 101 project comes into greater focus through preparation of the PSR, project-level CEQA review of the impacts of the improvement will be prepared. Although the final design of the Prado Road Overcrossing/Interchange is not yet available, the improvement has been deemed physically feasible by the City due to the multitude of geometric design options available, including auxiliary lanes, grade separated ramps, and collector-distributor roads. The San Luis Ranch project applicant has proposed, and would be required, to dedicate right-of way sufficient to accommodate the ultimate configuration of the required improvements. 8-5 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo As described in Section 4.56.010, Transportation Impact Fees, of the City’s Municipal Code, in order to implement the goals and objectives of the City’s General Plan Circulation Element, the Short Range Transit Plan, and the Bikeway Element of the San Luis Obispo County Regional Transportation Plan, and to provide adequate transportation facilities to serve new development in the City of San Luis Obispo and to mitigate the impacts of that new development, certain public facilities and improvements must be implemented. The San Luis Obispo City Council has determined that transportation impact fees are needed in order to finance these facilities and improvements and to pay for new development’s fair share of the construction or purchase costs of these facilities and improvements. As stated in the Draft EIR, the project applicant would be required to pay their fair share of improvement cost allocation for the Prado Road Overcrossing/Interchange as identified in Table 4.12-19. The final map conditions for the project will require the City and the developer to mutually develop and have adopted a program outlining a funding mechanism capable of delivering construction of the Prado Road Overcrossing with Northbound U.S. 101 Ramps Improvements by Phase 2, independent of further funding approvals and authorizations. The development agreement for the project will prescribe the specific details of the required funding mechanism. The City will be responsible for implementing the funding program, completing project study and engineering, acquiring the necessary permits and approvals, and for construction of this improvement. The developer agrees to payment of its “fair share” of anticipated construction costs of the Prado Road Overcrossing with Northbound U.S. 101 Ramps Improvements and the offer to dedicate the right of way for the final design of the Southbound U.S. 101 Ramps as part of, or prior to, recordation of the final map. The Draft EIR specifies the required actions on the part of the project applicant, the City of San Luis Obispo, and Caltrans to comply with the Prado Road Overcrossing/Interchange mitigation. The Draft EIR concludes that changes or alterations pursuant to the required mitigation measures that are within the responsibility and jurisdiction of Caltrans and not the lead agency can and should be adopted by Caltrans, pursuant to Section 15091(a)(2) of the State CEQA Guidelines. As described above, the City has determined that the Prado Road Overcrossing/Interchange mitigation is physically and economically feasible, although these improvements would require review by Caltrans that is beyond the City’s control. Therefore, the Draft EIR concludes that impacts that would be mitigated by the Prado Road Overcrossing/Interchange mitigation are less than significant with implementation of this mitigation. Master Response 3 – Project Site Grading and Agricultural Topsoil Several commenters raised issues with the Draft EIR evaluation of the project’s proposed grading and drainage plans, and the potential impacts of the proposed grading on the agricultural viability of the project site and on the adjacent operations at the City Farm San Luis Obispo (City Farm). Specific statements, information, and requests regarding project site grading and agricultural topsoil include: • Requests that the City require the project applicant to identify alternative sources of fill that do not involve removal or disturbance of topsoil on portions of the property that are to remain in agricultural use; • Statements that Impact AG-4 and the Agricultural Suitability Memorandum (Appendix C) incorrectly conclude that the removal and redistribution of agricultural topsoil would 8-6 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo have a less than significant effect on the agricultural viability and ecology of the portion of the site that would remain in agricultural use; • Testimony from Cal Poly San Luis Obispo soil, science, crop science, and agriculture professors, as well as information from the Rodale Institute, the National Resource Conservation Service, the Food and Agriculture Organization of the United Nations, and academic technical studies that describe the role of soil organisms in agricultural topsoil for agricultural productivity; and • Testimony from Cal Poly San Luis Obispo professors Dr. Cristina Lazcano and Dr. John Phillips that the removal of topsoil on the project site would eliminate soil organisms and impact agricultural activity until the soil is able to regenerate the removed organisms. Althouse & Meade on behalf of the project applicant prepared a memorandum dated April 14, 2017, which clarifies the proposed grading and drainage within the agricultural field on the site, the historic and current farming practices on the San Luis Ranch property, the project’s proposed transition from conventional to organic farming practices, and soil microbes and their role in agricultural productivity on the site. This memorandum is included in the Final EIR as Appendix N. The project’s grading and drainage plans, which are described in Section 2.0, Project Description, and shown in Figure 2-12, Stormwater Detention Plan, and Figure 2-13, Project Grading Plan, involve re-grading the project site to elevate the portions of the site planned for residential development above the 100-year flood plain. The agricultural field would remain within the 100-year flood plain. As described in the Althouse & Meade memorandum (refer to Appendix N), drainage sheeting over the downstream end of the property would cross the southern property line in the same manner and location as it does under the current condition. The upper end of the agricultural field would be lowered approximately two feet, and the site would be graded with a smooth field slope similar to the existing profile, which would convey water across the site in a similar manner as the current condition. Total flow delivered to the downstream property line of the agricultural field would not exceed existing conditions. In smaller storms, the watershed draining to the downstream edge would be reduced, with runoff from the proposed development area of San Luis Ranch being metered by the proposed stormwater detention plan and delivered to Prefumo Creek without passing over the agricultural field boundary. In the largest storms, flood flow over the agricultural field would be primarily comprised of flood flows crossing over U.S. 101 at Prado Road and flowing onto the property. The quantity of this flood flow would be unchanged compared to storm events under existing conditions, and would exit the agricultural field as under the current condition. During periods of high rainfall, farming would be difficult, as experienced during the recent 2016-2017 rain year, but would not be exacerbated by the project site elevation and grade changes described in the proposed grading plan. Section 2.0, Project Description, has been revised to clarify the proposed grading and agricultural practices as follows: The current limits of the 100-year flood plain extend across the proposed single-family and commercial areas. The project involves re-grading the site to lower the areas of the site that would be dedicated for active agriculture by approximately six inches to two 8-7 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo feet. This grading is required to provide material for the development of the project site. Through the placement of fill from on- and off-site, these properties the proposed single- family and office and hotel sites areas would be graded such that, at a minimum, all structures would be removed from the flood plain, and the 100-year storm would be contained in the streets and the parking lots. The limits of the commercial area also lie within the 100-year flood plain and the potential office and hotel sites would also receive grading fill such that, at a minimum, structures would be removed from the flood plain. An overland drainage path would be provided via proposed on-site detention facilities, Cerro San Luis Channel, and Prefumo Creek to accommodate overland flood flows from the north. The agricultural area would remain within the 100-year floodplain, with cut grading taking place to offset the diverted flows from adjacent areas, such that no change in flood water depths or flows would occur on surrounding properties (refer to Section 4.8, Hydrology and Water Quality, for a detailed discussion of proposed grading and the post- development floodplain). Grading in the Agricultural Heritage Facilities & Learning Center area would include the placement of fill to protect the proposed structures from flooding. Grading of agricultural areas would include the preservation of active, high- quality topsoils through lifting and setting aside the top layer of soil material, and removal and stockpiling of the subsoil on the development area. The set-aside topsoil would then be redistributed back onto the graded area that would be dedicated for active agriculture stockpiling on-site during grading and excavation (refer to Section 4.2, Agricultural Resources, for a detailed discussion of proposed grading and potential effects on continued agricultural viability on the project site). In total, earthwork for buildout of the Specific Plan area is estimated to require 817,200 cubic yards (CY) of cut, and 569,200 CY of fill, resulting in a need for approximately 248,000 CY of soil import. Figure 2-13 shows the proposed grading plan. The potential impacts of the project’s proposed grading and drainage plans to agricultural resources, including the project’s location adjacent to the City Farm, are described in Section 4.2, Agricultural Resources. The project’s potential impacts associated with drainage and flooding are discussed in Section 4.8, Hydrology and Water Quality. As described in the Draft EIR, and in the Althouse & Meade memorandum (refer to Appendix N), approximately 109 of the 131 acres on the project site are presently used for production of irrigated row crops, which are grown using conventional methods, including heavy tilling of the topsoil and the application of herbicides, pesticides, and chemical fertilizers. Agricultural soil on the project site shows consistent soil texture and fertility characteristics from the surface to the three-foot level. Soil microbes are currently distributed by active farming and aerosol actions. Subsequent to the proposed project site grading, soil microbes would continue to be present one to three feet of soil, and tillage and crop row construction would continue move soil microbes throughout the field. The San Luis Ranch Specific Plan includes a proposal to change the agricultural practices on the portion of the site that would remain in agricultural use from conventional to organic (pesticide- and chemical-free) farming practices. The Althouse & Meade memorandum 8-8 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo describes the steps required to transition from conventional to certified organic farming practices, based on U.S. Department of Agriculture requirements and recommendations, including soil sampling to evaluate residual toxic residues from previous pesticide applications, microbial diversity in soil organic matter, and soil fertility indicators such as pH, mineral content, electrical conductivity, and soil texture. The addition of organic amendments will increase microbial biomass compared to conventional farming systems. As described in the Althouse & Meade memorandum, depending on residual pesticides in the soil profile and specific farming practices implemented, microbial activity in clay soil below the current near- surface layer on the project site is expected to reach or exceed pre-grading population sizes and species diversity within three years. The Althouse & Meade memorandum estimates that the transition from conventional to certified organic farming practices is achievable within a ten- year timeframe. Section 15151 of the CEQA Guidelines states the following regarding standards from which adequacy is judged: An EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among experts. The courts have not looked for perfection but for adequacy, completeness, and a good faith effort at full disclosure. When approving an EIR, an agency does not need to resolve a dispute among experts about the information in the EIR. Disagreement among experts does not make an EIR inadequate (CEQA Guidelines Section 15151). The lead agency is free to reject criticism form an expert or a regulatory agency on a given issue as long as its reasons for doing so are supported by substantial evidence (Laurel Heights Improvement Association v. Regents of University of California [1922] 47 Cal.3d 376, 408; California Native Plant Society v. City of Rancho Cordova [2009] 172 Cal.App.4th 603; Association of Irritated Residents v. County of Madera [2003] 107 Cal.App.4th 1383,1397). Section 2.0, Project Description, has been revised to clarify the future practices for ongoing agricultural activity on the project site as follows: The project would preserve approximately 52.7 53 acres of the site in agriculture adjacent to the San Luis Obispo City Farm. The project would also preserve approximately 7.4 acres of the site in open space. Collectively, this would comprise approximately 48 43 percent of the net site acreage (when acreage set aside for regional roadways and the future Prado Road interchange or overpass is discounted) and 40 percent of the gross site acreage. As the project is developed, this agricultural property would be transitioned into organic (pesticide- and chemical-free) farming. The project also includes a commitment to procure an off-site agricultural conservation easement/deed restriction to comply with the City’s General Plan Land Use Element Policy 1.13.8 and Land Use Element Policy 8.1.4, which require that future development on the San Luis Ranch property dedicate one half of the total land or easements for open space use. 8-9 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo 8.3 RESPONSES TO PUBLIC TESTIMONY ON THE DRAFT EIR On January 11, 2017 and January 25, 2017, the Planning Commission conducted a public hearing regarding the Draft EIR for the San Luis Ranch Project. The hearing provided an opportunity for members of the public to receive a summary presentation of the project as well as the major findings of the Draft EIR. The primary purpose of the public comment portion of the hearing was to receive input from interested parties regarding the adequacy of the Draft EIR. In addition to the Planning Commission staff, there were seven speakers during the January 11 hearing and 16 speakers during the January 25 hearing. Table 8-1 summarizes the topics of comments made by each speaker. The City’s response to each comment follows Table 8-1. On January 23, 2017 the Cultural Heritage Committee conducted a public hearing regarding the Draft EIR for the San Luis Ranch Project. The hearing provided an opportunity for members of the Commission and the public to receive a summary presentation of the project as well as the major findings of the Draft EIR related to cultural and historical resources. In addition to Cultural Heritage Committee staff, there was one speaker during the hearing. Table 8-1 summarizes the topics of comments made by each speaker. The City’s response to each comment follows Table 8-1. Table 8-1 Public Hearing Comment Summary Num. Speaker/Affiliation Topics Presented in Comments January 11, 2017 Planning Commission Hearing Public Comments 1 Steven Marx, Central Coast Grown Grading, loss of agricultural land 2 Maysun Wells, Private Citizen General support, traffic impacts, pedestrian access 3 Mila Vujovich-LaBarre, Private Citizen Alternatives 4 Stanley Yucikas, Private Citizen Infill development, traffic improvements 5 Brandon Schmiederberg, Private Citizen General support, agricultural buffers 6 Sarah Flickinger, Private Citizen Bike paths, noise, loss of agricultural land, cyclist and pedestrian safety 7 James Lopes, Private Citizen Loss of prime agricultural land, alternative project January 25, 2017 Planning Commission Hearing Public Comments 1 David Gibbs, Private Citizen Affordable housing, historic preservation 2 Steven Marx, Central Coast Grown Agriculture, drainage 3 Michael Manchuck, SLO Economic Vitality Corporation Affordable housing 4 Allan Cooper, Private Citizen Bio mitigation, ag preservation 5 Kevin Hauber, Mortgage House Affordable housing, reduced VMT 6 Katherine Shneid, Private Citizen Traffic 7 Theodora Jones. Private Citizen Traffic (mitigation, construction), tree preservation, grading (Valley Fever) 8 Zoe Dixon, Concerned Citizens of Laguna Lake Neighborhood Traffic, school impacts, trees and habitat 8-10 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Table 8-1 Public Hearing Comment Summary Num. Speaker/Affiliation Topics Presented in Comments 9 Lea Brooks, Bike SLO County Multimodal traffic facilities 10 Myron Amerine, Private Citizen Trees, multimodal traffic facilities, sea level rise, housing demand 11 Hanz Boeschman, Private Citizen Affordable housing, traffic (mitigation, construction) 12 Maysun Wells, Private Citizen Lower-buildout alternative - traffic 13 Mila Vujovich-LaBarre, Private Citizen, Save San Luis Obispo Water, traffic, affordable housing, noise, schools, trees, ag/soils 14 David Brodie, Private Citizen Climate change, parking 15 Sarah Flickinger, Los Verdes Park Neighborhood Traffic (Settlement Agreement inconsistency, safety, schools) 16 Paul Rys, Private Citizen Soil, traffic, economic impacts, Land Use Element consistency Planning Commissioner Comments 1 Hemalata Dandekar, Planning Commission Grading/agriculture, alternative layout/land uses 2 Kim Bisheff, Planning Commission Traffic (mitigation) 3 Charles Stevenson, Planning Commission School pedestrian safety, traffic improvements funding 4 Charles Stevenson, Planning Commission LAFCo approval (agricultural buffers/preservation) 5 Ronald Malak, Planning Commission Water, affordable housing, alternatives, electricity, flooding, topsoil January 23, 2017 Cultural Heritage Committee Hearing Cultural Heritage Commissioner Comments 1 Jaime Hill, Cultural Heritage Committee Figure/photodocumentation clarification, cumulative impacts, historic resource relocation plan, historical resources mitigation, eucalyptus trees 2 Craig Kincaid, Cultural Heritage Committee Trees 3 Leah Walthert, Cultural Heritage Committee Historical structures, alternatives 4 Shannon Larrabee, Cultural Heritage Committee Thoroughness of environmental review 5 Thom Brajkovich, Cultural Heritage Committee Historical structures Public Comments 1 Theodora Jones, Private Citizen Eucalyptus trees, historical structures, alternatives January 11, 2017 Planning Commission Hearing, Public Comments 1. Steven Marx, Central Coast Grown. The commenter expressed disappointment in the project’s proposed removal of topsoil and lack of alternative grading plans to preserve agricultural soil. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources. Specific concerns regarding impacts to prime agricultural soils, especially as related to the removal of topsoil, are discussed in the responses to Letters 3, 8, and 9. 8-11 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo 2. Maysun Wells, Private Citizen. The commenter expressed support for the concept of the proposed project and suggested that the project applicant consider a pedestrian overpass to alleviate traffic impacts and create greater pedestrian access. The Draft EIR did not identify project impacts that would be mitigated by the construction of a pedestrian overcrossing on Madonna Road. Mitigation measures for project-related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road. 3. Mila Vujovich-LaBarre, Private Citizen. The commenter stated their agreement with sentiments of previous public speakers and requested a study of alternatives to the project. Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for a discussion of the adequacy of project alternatives evaluated in the Draft EIR. 4. Stanley Yucikas, Private Citizen. The commenter urged the City to consider higher density infill development projects in conjunction with traffic improvements to utilize the existing City infrastructure. As described in Section 1.0, Introduction, the project site is identified in the City’s updated Land Use Element as Specific Plan Area (SP-2) and is envisioned to be annexed to the City with an approved Specific Plan defining how the site would be developed. To be consistent with the City’s adopted policies for the San Luis Ranch Specific Plan Area, the Specific Plan must meet performance standards prescribed in the Land Use Element, including minimum and maximum density requirements. In addition, the project is designed to accommodate the potential development of either a Prado Road overpass or interchange. Refer to Section 4.12, Transportation, for a discussion of potential transportation impacts associated with the project, and required mitigation to address these impacts. The project proposes to dedicate the necessary right-of-way and financially participate in the overpass or interchange project in accordance with an equitable share analysis. As such, the project has been designed at a density consistent with the City’s planning goals for the Specific Plan Area, and would contribute to traffic infrastructure improvements within the City. 5. Brandon Schmiederberg, Private Citizen. The commenter voiced support for the project and suggested that the project incorporate increased agricultural buffers. Refer to the response to Letter 22 for a discussion of the adequacy of agricultural buffers included in the project. 6. Sarah Flickinger, Private Citizen. The commenter urged the Planning Commission to require the project to incorporate bike paths with greater access to surrounding businesses and encouraged the Planning Commission to consider adverse noise impacts associated with the removal of agricultural land. Refer to Response 29.23 for a discussion of the project’s incorporation of bicycle trails and lanes consistent with the goals in the City’s 2013 Bicycle Transportation Plan. Section 4.10, Noise, describes the existing noise environment on and in the vicinity of the project site and includes a detailed analysis of potential noise impacts associated with the conversion of the existing agricultural uses on the site to urban development. 7. James Lopes, Private Citizen. The commenter expressed concern regarding the loss of prime agricultural soil and spoke in favor of a higher density project with a smaller environmental footprint. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources. Specific concerns regarding impacts to prime agricultural soils are discussed in the responses to letters 3, 8, and 9. Refer to Master Response 1 for a discussion of the adequacy of project alternatives evaluated in the Draft EIR. 8-12 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo January 25, 2017 Planning Commission Hearing, Public Comments 1. David Gibbs, Private Citizen. The commenter expressed support for the project and affordable housing, and stated support for preserving the historical context of the property. Specifically, the commenter stated that he doesn’t feel exact location of barn and farmhouse is as important as celebrating historical agricultural context. Refer to Section 4.5, Cultural Resources, for a discussion of the project’s potential historical resource impacts and required mitigation to reduce the identified impacts to the extent feasible. The commenter’s support for the project and affordable housing will be forwarded to the appropriate decision-makers for review and consideration. 2. Steven Marx, Central Coast Grown. The commenter stated his involvement as a representative of Central Coast Grown, which manages SLO City Farm, in discussions regarding pending project grading plan revisions intended to address his previously stated comments. The commenter indicated that he would support five new measures, including taking no more than one foot of topsoil, set aside and temporary storage of topsoil followed by restoration, ensuring that removed topsoil will not be stored for long periods of time, and providing organic supplements/compost once grading is completed. The commenter notes other drainage issues that have been highlighted by recent rain, and notes that the original purpose of moving topsoil was to provide stormwater storage. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources. Specific concerns regarding impacts to prime agricultural soils, especially as related to the proposed grading plan, drainage, and potential impacts to the agricultural productivity of the site as a result of the proposed removal of topsoil, are discussed in the responses to Letters 3, 8, and 9. 3. Michael Manchuck, SLO Economic Vitality Corporation. The commenter stated that San Luis Obispo is one of the least affordable housing cities and requested that the project provide more workforce housing. The commenter also described studies involving industry clusters as they relate to affordable housing and cost of living. Section 2.0, Project Description, describes the project’s provision of affordable housing. information provided by the commenter and the commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. 4. Allan Cooper, Private Citizen. The commenter concurred with most of the findings of the Draft EIR, but stated that the Draft EIR should include additional mitigation for tree replacements on the basis that replacement will not fully mitigate impacts on monarchs, great blue herons, and other birds. The commenter added that the relocation mitigation included in the Draft EIR is experimental, and was used for other species. The commenter also stated that the project is inconsistent with California Government Code provisions preventing prevent premature conversion of agricultural lands based on the project’s inconsistency with the City’s General Plan Housing Element. These comments are consistent with the commenter’s written letter included herein as Letter 6. For a discussion of the commenter’s concerns regarding tree replacement and mitigation for monarchs and herons, refer to Response 6.2. For a discussion of the project’s consistency with California Government Code relative to the conversion of prime soils to urban development, refer to Response 6.3. 5. Kevin Hauber, Mortgage House. The commenter noted the need for affordable, energy- efficient homes in the City and expressed support for the project on the basis that it would reduce excessive commuting times by locating homes near jobs. Refer to Section 2.0, Project Description, for a description of the project’s proposed affordable housing. This commenter’s 8-13 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo support and recommendations will be forwarded to the appropriate decision-makers for review and consideration. 6. Katherine Shneid, Private Citizen. The commenter urged the City Planning Commission to support affordable housing and expressed support for the project on the basis that it would reduce residents’ need to commute into San Luis Obispo from outside the City, reducing congestion during peak commute periods. Refer to Section 2.0, Project Description, for a description of the project’s proposed affordable housing. Refer to Section 4.12, Transportation, for a description of the project’s potential impacts to regional transportation and circulation, and associated mitigation measures. The commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. 7. Theodora Jones. Private Citizen. The commenter stated that some of the mitigation for traffic impacts, such as adding turn lane on Froom Ranch Way, wouldn’t work. The commenter recommended that ingress/egress to U.S. 101 from the project should be provided during construction, stating that construction truck access from Froom Ranch Way turning left onto Los Osos Valley Road wouldn’t work. The commenter requested that eucalyptus trees be kept in place during construction as a screen for visual, noise, and dust impacts. The commenter also stated that there has been a recent influx of Valley Fever, noting that fill soil will be from outside the area. Mitigation measures are provided for significant transportation and circulation impacts that are identified as part of the traffic impact analysis, which are described in Section 4.12, Transportation. Table 4.12-1 in Section 4.12, Transportation, lists the required transportation improvements measures required for the project to avoid and/or reduce potential traffic impacts, including potential transportation impacts associated with temporary construction traffic. Other short-term impacts associated with construction activity, including dust and noise are discussed in Sections 4.3, Air Quality, and 4.10, Noise. In addition, refer to Response 6.2 for a discussion of the project’s potential impacts to biological resources associated with eucalyptus tree removal. The San Luis Obispo Department of Public Health has identified low rates of Coccidioidomycosis (Valley Fever) in the City of San Luis Obispo, and as described in Section 2.0, Project Description, the project would primarily use fill soil from on-site, although some off-site soil import would be required. Off-site soil is planned to be sourced from locations no more than 30 miles from the site, and would not be expected to be imported from more distant locations in the County where Valley Fever is a more common concern for soil disturbing activities. 8. Zoe Dixon, Concerned Citizens of Laguna Lake Neighborhood. The commenter notes that they have provided a written letter from the Laguna Lake Community which expresses community concerns with the project, which include impacts to traffic, schools, and trees and habitat. Specifically, the commenter states that Madonna Road and Los Osos Valley Road are already overburdened, and that the Prado Road overpass will not be sufficient to alleviate this existing burden, and that more traffic mitigation is needed. The commenter also states that there will be impacts to student safety associated with safe routes to schools and the new students that would be walking to school as a result of the project. The commenter also states that there would be impacts on trees and habitat, and that the project should be designed to preserve agricultural land and natural views from Madonna Road and Oceanaire Drive. The written letter from the Laguna Lake Community is included herein as Letter 35, and the written comments in that letter are addressed in Responses 35.1 through 35.5. The project’s potential transportation and circulation impacts, and associated mitigation measures, including impacts to pedestrian facilities, are discussed in Section 4.12, Transportation. Mitigation measures for project-related impacts to multimodal circulation include construction of 8-14 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo parallel Class I facilities to accommodate pedestrians, including schoolchildren, and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel.. Section 4.4, Biological Resources, discusses the project’s potential impacts to trees and habitat, Section 4.1, Aesthetics, discusses the project’s potential impacts on public views, and Section 4.2, Agricultural Resources, discusses the project’s potential impacts to agricultural land. 9. Lea Brooks, Bike SLO County. The commenter supports dense housing and mitigation to encourage alternative modes of transportation, and noted that the Draft EIR emphasizes bikeways, which reduce trips and VMT. The commenter states that the mitigation extending lane queues for motor vehicles can create hazards for bicyclists, and that the a safe crossing of U.S. 101 is needed because the existing Madonna Road bike paths are hazardous. Mitigation measures are provided for significant transportation and multimodal circulation impacts, including impacts to bicycle facilities, identified as part of the traffic impact analysis and described in Section 4.12, Transportation. Mitigation measures for project-related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road as well as the Prado Overcrossing. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. The City’s Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. The commenter’s support and recommendations will be forwarded to the appropriate decision-makers for review and consideration. 10. Myron Amerine, Private Citizen. The commenter stated that eucalyptus trees are not water- sucking plants, and that the existing grove of trees provides wildlife habitat. The commenter stated that the Draft EIR doesn’t address the need for a sidewalk between Oceanaire Drive and the Post Office, and that there is no convenient and safe crossing of U.S. 101 for bicyclists, pedestrians, or disabled persons. The commenter stated that requiring the applicant to provide the Froom Ranch Road connection in Phase 1 of the project is commendable. The commenter stated that the City’s adopted Climate Action Plan notes that sea levels will rise 216 feet, and that the project will be underwater. Section 4.4, Biological Resources, discusses the project’s potential impacts and associated mitigation for biological resources, including tree removal and wildlife habitat. In addition, refer to Response 6.2 for a discussion of the project’s potential impacts to biological resources associated with eucalyptus tree removal. As discussed in Section 4.12, Transportation, mitigation measures for project-related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. These improvements would provide the infrastructure needed to connect to existing and planned facilities as presented in the City’s Bicycle Transportation Plan, and incentivize the use of alternative transportation modes. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. The project’s phasing of infrastructural improvements is discussed in Section 2.0, Project Description. Draft EIR mitigation requiring specific timing of infrastructural improvements, including the Froom Ranch Way bridge, are discussed in Section 4.12, Transportation. Section 4.6, Greenhouse Gas Emissions, discusses the project’s consistency with the City’s 2012 Climate Action Plan. 8-15 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo 11. Hanz Boeschman, Private Citizen. The commenter expressed general support for the project and requested that there be more workforce and affordable housing in the area, but recommended additional traffic mitigation and stated that the Draft EIR needs to address traffic during construction. Refer to Section 2.0, Project Description, for details about the project’s provision of affordable housing. Mitigation measures are provided for significant transportation and circulation impacts that are identified as part of the traffic impact analysis, which are described in Section 4.12, Transportation. Table 4.12-1 in Section 4.12, Transportation, lists the required transportation improvement measures required for the project to avoid and/or reduce potential traffic impacts, including potential transportation impacts associated with temporary construction traffic. Other short-term impacts associated with construction activity, including dust and noise are discussed in Sections 4.3, Air Quality, and 4.10, Noise. The commenter’s support of the project and recommendations will be forwarded to the appropriate decision-makers for review and consideration. 12. Maysun Wells, Private Citizen. The commenter voiced general support for the project. The commenter also stated concerns over traffic impacts and noted that the City’s Land Use Element established a lower and upper buildout level on property. The commenter suggested further consideration be given to project alternatives, recommending that the lower buildout level discussed in the Land Use Element be studied as alternative to reduce traffic. As described in Section 4.12, Transportation, mitigation measures are provided to reduce and/or avoid significant transportation and circulation impacts identified as part of the traffic impact analysis to the maximum extent feasible. Section 6.0, Alternatives, describes the project alternatives evaluated in the Draft EIR. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for a discussion of the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. 13. Mila Vujovich-LaBarre, Private Citizen, Save San Luis Obispo. The commenter noted that they have provided written comments for the record. These comments are consistent with the commenter’s written letters included herein as Letters 18 and 41. Refer to responses to the commenter’s written comments contained in Letters 18 and 41. 14. David Brodie, Private Citizen. The commenter asked for more information about the affordability of proposed housing and preparation for climate change, and voiced concerns over insufficient parking. Refer to Section 2.0, Project Description, for a discussion of the project’s provision of affordable housing. Also refer to Response 18.3 for a discussion of parking included in the project and the response to Letter 15 for a discussion of impacts related to climate change. 15. Sarah Flickinger, Los Verdes Park Neighborhood. The commenter noted that they have provided written comments for the record. These comments are consistent with the commenter’s written letters included herein as Letters 20 and 21. Refer to responses to the commenter’s written comments contained in Letters 20 and 21. 16. Paul Rys, Private Citizen. The commenter expressed feasibility concerns regarding the removal of prime topsoil to address flooding, and suggested the City utilize an underground tunnel to convey water to preserve agricultural land rather than moving topsoil. The commenter expressed concerns regarding traffic, and stated that the Draft EIR should discuss the preamble to the Land Use Element and resident surveys mentioned in Land Use Element, which place quality of life and environmental quality as top priorities. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources. Specific concerns regarding impacts to prime topsoil, especially as related to the proposed grading plan, drainage, and 8-16 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo potential impacts to the agricultural productivity of the site as a result of the proposed removal of topsoil, are discussed in the responses to Letters 3, 8, and 9. The project’s potential traffic impacts are discussed in Section 4.12, Transportation. The commenter recommended that the Commission consider the economic impact of the project, including ongoing road maintenance. The project’s consistency with the General Plan Land Use Element is discussed in Section 4.9, Land Use/Policy Consistency. The commenters concerns about the economic impacts of the project will be forwarded to the appropriate decision-makers for review and consideration. January 25, 2017 Hearing, Planning Commissioner Comments 1. Hemalata Dandekar, Planning Commission. The commenter expressed concern with grading and agricultural issues, but supported the concept that the project applicant and Central Coast Grown are coordinating to resolve the potential conflict. The commenter suggested consolidation of the project footprint and stated a preference for a different mix of residential to be included in the project. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources. Specific concerns regarding impacts to prime agricultural soils, especially as related to grading and the removal of topsoil are discussed in the responses to Letters 3, 8, and 9. The Draft EIR discusses a reasonable range of alternatives to the project in Section 6.0, Alternatives. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR and the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. 2. Kim Bisheff, Planning Commission. The commenter expressed concerns about traffic and traffic mitigation, and requested information regarding the potential for alternative traffic mitigation that focuses on safe pedestrian movements and gaps in sidewalks. The project’s potential impacts regarding transportation and multimodal circulation, including pedestrian circulation, are discussed in Section 4.12, Transportation. Mitigation measures for project- related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel.. 3. Charles Stevenson, Planning Commission. The commenter expressed concern for pedestrian safety at Laguna Middle School and C.L. Smith Elementary School. The commenter stated that there needs to be a realistic picture of when Prado Road could feasibly be constructed, and questioned what the funding variables are for the overpass/interchange. Funding for the Prado Road overpass improvements would be derived from a combination of City traffic impact fees and a Development Agreement between the City and the project applicant to develop a new funding program. As described in Section 2.0, Project Description, the Development Agreement/Memorandum of Understanding is not an entitlement, but is considered part of potential project approval. For a discussion of the project phasing requirements in relation to the required mitigation measures refer to Response 1.1. The multimodal analysis for the project is consistent with City General Plan policy, CEQA, and HCM methodologies. The HCM methodologies take into consideration the affects to vehicular volume on pedestrian and bicycle modes. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Also refer to Response 30.2, which address the 8-17 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo validity of the City’s Travel Demand Model as used in the Multimodal Transportation Impact Study (Appendix L) and the Draft EIR. As discussed in Section 4.12, Transportation, mitigation measures for project-related impacts to multimodal circulation include preparation of a traffic management plan to ensure safe access to and from schools during project construction (Mitigation Measure T-4) and construction of parallel Class I facilities to accommodate pedestrians, including schoolchildren, and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street (Mitigation Measures T- 2(a) through T-3(d)). The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. 4. Charles Stevenson, Planning Commission. The commenter stated that annexation of the project site will require LAFCo approval, and notes that LAFCo has strong policies for agricultural protection. With reference to the 72-foot agricultural buffer included in the project, the commenter states that there should be conditions of approval or mitigation included in the Draft EIR that provide assurances that organic farming won’t use pesticides. The commenter references the agricultural buffer policies and practices from San Luis Obispo, Ventura, and Santa Cruz Counties. The commenter also states that moving the proposed Agricultural Heritage Center onto prime farmland is not sensible, and that the Agricultural Heritage Center should be located in a developed area. As described in Section 2.0, Project Description, the project is designed to be consistent with LAFCo policies, including the requirement that the annexation be compatible with the City’s General Plan and supportable by the City’s infrastructure. Response 29.44 describes the project applicant’s commitment to transitioning the agricultural practices on the site to organic farming, which would not involve pesticide or chemical fertilizer use on the site. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources, and Section 4.9, Land Use/Policy Consistency, discusses applicable General Plan and Specific Plan policies related to the preservation of agricultural heritage at the project site. The development of the Agricultural Heritage and Learning Center is potentially consistent with policies related to cultural heritage, conservation and open space, and land use. The Draft EIR identifies this loss of Prime Farmland as a significant impact, and requires Mitigation Measure AG-1, which requires that impacts to Prime Farmland be mitigated at a 1:1 ratio (acres of Prime Farmland converted to acres of Prime Farmland preserved in perpetuity). Mitigation Measure AG-1 allows for the required mitigation to be achieved through dedication of an on- and/or off-site easement(s) or deed restriction(s) located within or contiguous to the City’s Urban Reserve Line or Greenbelt. In addition, Mitigation Measure CR-1(c) requires that the Agriculture Heritage Facilities & Learning Center include interpretive signage detailing the history of the San Luis Ranch Complex and the project site, its significance, and its important details and features, including images and details from the HABS documentation described in Mitigation Measure CR-1(b) and any collected research pertaining to the historic property. 5. Ronald Malak, Planning Commission. The commenter submitted written correspondence for the record. Refer to responses for written comments to the commenters specific concerns contained in Letter 19. January 23, 2017 Cultural Heritage Commissioner Comments 1. Jamie Hill, Cultural Heritage Committee. The commenter states that Figure 10 in the Cultural Resources Survey and Evaluation (Appendix G to the Draft EIR) should be clarified to describe 8-18 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo which structures would be relocated or removed. The commenter requests that the discussion of cumulative impacts should be expanded to include the Bonetti Ranch, Froom Ranch, and San Luis Ranch complexes. The commenter asks whether there are historical photographs of the eucalyptus trees on the site, and requests that photographs be added to the Draft EIR, if available. The commenter states that the Draft EIR needs more analysis of the historic value of the eucalyptus trees, and their potential significance as a cultural landscape for the San Luis Ranch Complex. The commenter states that the plan to relocate two existing on-site structures is inadequate mitigation for impacts to the San Luis Ranch Complex, and recommends that the main barn be included in Mitigation Measure CR-1(a). The commenter states that there would be better public access to the San Luis Ranch Complex in its current location, rather than the proposed relocation, adding that it is more important that the complex be visible to people in town, not freeway travelers. Figure 10 in the Cultural Resources Survey and Evaluation depicts the location and name of the structures in the San Luis Ranch Complex. The structures are described in detail on pages 58 through 67 of the Cultural Resources Survey and Evaluation. Proposed changes on the project site, including existing structures that would be relocated or removed, and the resulting impacts to the build environment resources are described on pages 72 through 74 of the Cultural Resources Survey and Evaluation. The Draft EIR cumulative impact analysis is based on City-wide cumulative projections that establish conditions that would exist due to the build- out of the City’s General Plan. Table 3-1 in the Draft EIR shows the potential future development in the Land Use Element Planning Subarea at buildout as envisioned by the Land Use Element (including the San Luis Ranch Specific Plan area) and includes the ‘Madonna Site on Los Osos Valley Road,’ which includes the Froom Ranch Way Complex as a potential development area in the City. The Tank Farm Center project, which includes the Long-Bonetti Farm Complex, began construction in February 2015 and, as such, was not included as a “Planned or Recently Approved Project” in Table 3-1. Nonetheless, this project is included in the City’s General Plan Buildout projection. As such, the analysis of cumulative impacts considers the cumulative effects of the project in combination with other projects and historical resources in the City, and finds that the project would result in a significant and unavoidable cumulative impact to historical resources. Historical photographs of the eucalyptus trees on the project site were not identified during the preparation of the Draft EIR or the Cultural Resources Study (Appendix G). Trees on the project site, and their relationship with the project site history and the cultural landscape for the San Luis Ranch Complex, are described in the Cultural Resources Study. The eucalyptus trees on the site are a part of the historic setting and contribute to the significance of the San Luis Ranch Complex. However, the trees were not found to be an individually significant historic resource in the Cultural Resources Study or the Draft EIR. As described in Section 4.5, Cultural Resources, the potential impact to the San Luis Ranch Complex as a historic district remains significant and unavoidable as a result of the permanent removal and relocation of the structures that comprise the historically significant district. Because the project proposes to construct a new barn in the project’s proposed Agricultural Heritage and Learning Center using salvageable materials from the historically significant main barn, the commenter’s recommendation that the main barn be included in Mitigation Measure CR-1(a) has been addressed with the following revision: 8-19 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo CR-1(a) Historical Structure Relocation and Reconstruction Plan. In order to implement Specific Plan Policy 2.5, a relocation and reconstruction plan for the former spectator’s barn/viewing stand, and main residence, and main barn shall be developed by a qualified historic architect. The plan shall include a structural/architectural report documenting existing integrity and conditions and include detailed treatment methods and measures to ensure that historic integrity is retained and that all identified character defining features will be preserved. The commenter’s preference that the San Luis Ranch Complex structures be retained in their current location will be forwarded to the appropriate decision-makers for review and consideration. The potential impacts to these historic resources is described in Section 4.5, Cultural Resources, and Alternative 3, which would retain these resources in their current location, is evaluated in Section 6.0, Alternatives. 2. Craig Kincaid, Cultural Heritage Committee. The commenter states that the Draft EIR evaluation is a thorough first step, and that the CHC will provide additional comments on the project when the time comes. The commenter asks whether the project will be considered by the City’s Tree Committee. The project is not required to be reviewed by the City’s Tree Committee since removals associated with development projects are reviewed through the City review process along with the overall consideration of the Specific Plan. The Draft EIR requires in-kind replacement of riparian trees four inches or greater measured at diameter-at- breast-height (DBH) at a ratio of 10:1 (replaced: removed), and in-kind replacement of riparian trees 24 inches or greater measured at diameter-at-breast-height (DBH) at a ratio of 10:1. The Draft EIR also includes mitigation for sensitive species that use on-site trees for roosting or nesting habitat, including great blue heron, monarch butterfly, bats, and nesting birds. 3. Leah Walthert, Cultural Heritage Committee. The commenter recommends that the existing San Luis Ranch Complex be retained in its current state, and states that its original location better indicates the agricultural heritage of the complex. The commenter states that they support Alternative 3. The commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. Section 4.5, Cultural Resources, describes the potential historical resource impact from the proposed relocation and removal of the existing San Luis Ranch Complex structures. Project alternatives, and their relative impacts on cultural and historic resources, are discussed in Section 6.0, Alternatives. 4. Shannon Larrabee, Cultural Heritage Committee. The commenter states that the Draft EIR evaluation is a thorough first step, and that the CHC will provide additional comments on the project when the time comes. The commenter’s support of the Draft EIR evaluation and statement regarding providing additional comments will be forwarded to the appropriate decision-makers for review and consideration. 5. Thom Brajkovich, Cultural Heritage Committee. The commenter states that they support the proposal to retain some of the existing structures associated with the San Luis Ranch Complex and the relocation of these structures to the proposed new location. The commenter states that they do not identify any large flaws with the Draft EIR, and recommends that the adaptive reuse of materials from existing structures be done carefully. The commenter’s support for the proposed relocation of structures within the San Luis Ranch Complex and support for the conclusions of the Draft EIR will be forwarded to the appropriate decision-makers for review and consideration. As described in Section 4.5, Cultural Resources, the specific requirements 8-20 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo of the proposed relocation, reuse, and reconstruction associated with the San Luis Ranch Complex and the proposed Agricultural Heritage Facilities and Learning Center, will be described in a Historical Structure Relocation and Reconstruction Plan, consistent with the requirements of Mitigation Measure CR-1(a). January 23, 2017 Cultural Heritage Committee Hearing, Public Comments 1. Theodora Jones, Private Citizen. The commenter states that the eucalyptus trees on the site are part of the historic agricultural landscape, and that they must be preserved. The commenter states that the proposed Agriculture Heritage Facilities & Learning Center is more of a market than a learning center, and recommends that historical buildings be retained in their current locations to preserve history. The commenter states that Alternative 3 is the most realistic. Refer to the response to Comment 1 under the Cultural Heritage Commissioner Comments, which addresses concerns related to the relationship of the eucalyptus trees on the project site to the cultural landscape. Section 4.2, Agricultural Resources, and Section 4.5, Cultural Resources, analyze and discuss the significance of the San Luis Ranch Complex, and the development of an Agricultural Heritage and Learning Center as part of the project. Section 4.9, Land Use/Policy Consistency, discusses relevant General Plan and Specific Plan policies pertaining to the preservation of agricultural heritage on the project site. The development of the Agricultural Heritage and Learning Center is potentially consistent with policies pertaining to cultural heritage, conservation and open space, and land use. Mitigation Measure CR-1(c) requires that the Agriculture Heritage Facilities & Learning Center include interpretive signage detailing the history of the San Luis Ranch Complex and the project site, its significance, and its important details and features, including images and details from the HABS documentation described in Mitigation Measure CR-1(b) and any collected research pertaining to the historic property. Also, refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. The commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. 8.4 RESPONSES TO WRITTEN COMMENTS ON THE DRAFT EIR Each written comment on the Draft EIR that the City of San Luis Obispo received is listed in Table 8-2. The comment letters included herein were submitted by public agencies, local interest groups, private companies, and private citizens. Each comment letter has been numbered sequentially and each separate issue raised by the commenter, if more than one, has also been assigned a number. Each comment letter is reproduced in its entirety with the issues of concern numbered in the right margin. Responses to these comments have been prepared to address the environmental concerns raised by the commenters and to indicate where and how the Draft EIR addresses pertinent environmental issues. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 2.1, for example, indicates that the response is for the first comment raised in Letter 2). 8-21 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Table 8-2 Comments Received on the Draft EIR Letter No. Commenter and Affiliation Date Received Comments Received During the Draft EIR Circulation Period – December 9, 2017 through January 31, 2017 1 Mark Sullivan, Private Citizen December 30, 2016 2 Sylvia Steverson, Private Citizen January 4, 2017 3 Board of Directors, Central Coast Grown January 6, 2017 4 Dennis Vavrek, Private Citizen January 10, 2017 5 Farid Shahid, Private Citizen January 11, 2017 6 Allan Cooper, Private Citizen January 11, 2017 7 Cheryl McClean, Private Citizen January 11, 2017 8 Cristina Lazcano, Ph.D., California Polytechnic State University January 16, 2017 9 Steven Marx, Central Coast Grown January 18, 2017 10 Michael Sullivan, Private Citizen January 23, 2017 11 Dennis Vavrek, Private Citizen January 23, 2017 12 James Lopes, Private Citizen January 23, 2017 13 James Lopes, Private Citizen January 23, 2017 14 Scott Morgan, Director, State Clearinghouse January 24, 2017 15 David Brodie, Private Citizen January 24, 2017 16 Carolyn Smith, Private Citizen January 25, 2017 17 Joe Grimes, California Polytechnic State University January 25, 2017 18 Mila Vujovich-LaBarre, Private Citizen January 25, 2017 19 Ron Malak, Planning Commissioner January 26, 2017 20 Sarah Flickinger, Los Verdes Parks 1 and 2 Homeowners Associations January 27, 2017 21 Sarah Flickinger, Los Verdes Parks 1 and 2 Homeowners Associations January 27, 2017 22 Lynda Auchinachie, County of San Luis Obispo Department of Agriculture/Weights & Measures January 27, 2017 23 Brett Cross, Private Citizen January 29, 2017 24 Brett Cross, Private Citizen January 30, 2017 25 Melissa Guise, San Luis Obispo County Air Pollution Control District January 30, 2017 26 Anne Wyatt, Private Citizen January 30, 2017 27 Dianna Beck, Private Citizen January 30, 2017 28 Melissa Streder, California Department of Transportation January 30, 2017 29 Laurie Tamura, AICP, Principal Planner, Urban Planning Concepts, Inc. January 30, 2017 30 Andrew Smith, Private Citizen January 30, 2017 31 Gary Smith, Private Citizen January 30, 2017 32 Gary Smith, Private Citizen January 30, 2017 33 Maysun Wells, Private Citizen January 30, 2017 34 Raquel Smith, Private Citizen January 30, 2017 35 Zoya Dixon, The Laguna Lake Community January 30, 2017 36 Audrey Bigelow, Private Citizen January 31, 2017 37 Carl Dudley, Private Citizen January 31, 2017 8-22 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Table 8-2 Comments Received on the Draft EIR Letter No. Commenter and Affiliation Date Received 38 Jeff Brubaker, Transportation Planner, Geoffrey Chiapella, Transportation Planner, San Luis Obispo Council of Governments January 31, 2017 39 Healthy Communities Work Group, HEAL SLO January 31, 2017 40 Lea Brooks, Bike SLO County January 31, 2017 41 Mila Vujovich-LaBarre, Private Citizen January 31, 2017 Comments Received During the Draft EIR Recirculation Period – March 3, 2017 through April 17, 2017 42 C.R. Flores, Private Citizen Undated 43 Mike Bennett, Executive Director, Bike SLO County April 17, 2017 8-23 From: Mark Sullivan  Sent: Friday, December 30, 2016 11:46 AM  To: Leveille, Brian <bleveille@slocity.org>  Subject: San Luis Ranch Draft EIR ‐ Question  Mr. Leveille: In reviewing Table 40A on Page 63 of Appendix L (see attachment), I noticed that the existing WB LOS would be reduced to an "F" rating with the existing PM traffic flows with the additional load generated by the proposed project. I see the mitigation for this unacceptable level of service is stated to be sometime in the future if the Post-Project interchange is built connecting the project to US 101. I'll believe it when I see it. I've lived near the Madonna Road / Oceanaire intersection for thirty-six (36) years. One problem is having the main Madonna road providing access to the Madonna frontage road on the lake side. I know, that when I happen to be the first in line at the Madonna Road Oceanaire intersection, I hold up traffic in the right hand turn pocket until the light turns green for me so I can proceed onto the frontage road to my house. I can't tell you how many times I've been honked at, flipped off and just the other day, some guy pulled out of the right turn pocket, squeezed into the right through-fare lane then proceeded to make a right turn around the front of my vehicle onto Oceanaire. I guess he thought I was stalled or something. I'm glad the light didn't turn green because I probably would have run into him. A long time ago, I'd say longer than 25 years, a survey was sent out regarding the possibility of blocking of the Madonna frontage road on the lake side with some sort of barricade that would still allow emergency vehicle access. Never heard the 8-24 results. Was this ever considered an option to reduce the impact at this intersection? Maybe, at least until the interchange is built, closing down access to the Madonna frontage road and vice versa to all but emergency vehicles might help the situation. I'd be interested in your comments. If this email is to be made part of the public record, please redact my phone number and email address. Thanks, ======================================= Mark Sullivan 1174 Madonna Road San Luis Obispo, CA 93405 8-25 8-26 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 1 COMMENTER: Mark Sullivan, Private Citizen DATE: December 30, 2016 Response 1.1 The commenter states that they do not believe the mitigation for impacts related to the unacceptable level of service (LOS) on the westbound segment of Madonna Road from Oceanaire Drive to Los Osos Valley Road under Existing Plus Project conditions would be implemented prior to development of the project. As described in Section 4.12, Transportation, potential impacts at this segment of Madonna Road would be addressed through the development of Class I multiuse paths or a bike boulevard and City transit headway optimization under Existing Plus Project conditions and through the development of the Prado Road Overpass & U.S. 101 Southbound Ramps under Cumulative Plus Project conditions. The required timing of the mitigation for these improvements is described in Section 4.12, Transportation. Also refer to Master Response 2 for a discussion of the Prado Road Overcrossing/Interchange Mitigation for Transportation Impacts and transportation mitigation requirements in relation to the phasing of the project. Response 1.2 The commenter states that access to the Madonna Frontage Road via Madonna Road on the lake side causes safety and driver temperament issues at the Madonna Road/Oceanaire Drive intersection. The commenter does not raise any specific concerns with the methods or conclusions of the Draft EIR traffic analysis or required mitigation. However, the commenter’s concern with the operation of this intersection will be forwarded to the appropriate decision- makers for review and consideration. Response 1.3 The commenter states that approximately 25 years ago a survey was sent out regarding the possibility of blocking of the Madonna Frontage Road on the lake side with a barricade that would only allow emergency vehicle access. The commenter questions whether this design was ever considered as an option to reduce the impact at the Madonna Road/Oceanaire Drive intersection. The commenter suggests closing down access to the Madonna Frontage Road to all but emergency vehicles until the Prado Road Overpass/Interchange is built. Access changes to the Madonna Frontage Road were not included in the Draft EIR mitigation, as the Draft EIR analysis did not identify traffic impacts resulting from the project associated with this access. However, the commenter’s question and suggestion will be forwarded to the appropriate decision-makers for review and consideration. 8-27 Meeting. P& I- ll'I1 Item: I I v RECEIVED CITY OF SAN LUIS OBISPO JAN 0 4 2017 I COMMUNITY DEVELOPMENT r - ti,tN 1.11,115 i)lilS14?t- 1 Ccnisic Peaks that lmtureEt Crtwn7rr 'rwh kxcuo wt Mom Rock. 8-28 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 2 COMMENTER: Sylvia Steverson DATE: January 4, 2017 Response The commenter states opposition to the San Luis Ranch and Avila Ranch Projects. This comment does not address the adequacy of the Draft EIR. However, the commenter’s concern will be forwarded to the appropriate decision-makers for review and consideration. 8-29 Meeting:,PC/ l I -- Item: .121- From: 2 From: Wendy Brown [ Sent: Friday, January 6, 2017 3:49 PM To: Leveille, Brian <bieveille@slocity.org> Subject: Central Coast Grown comments re SLR DEIR Hello Brian, RECEIVED CITY OF SAN LUIS OBISPO JAN 0 6 2017 COMMUNITY DEVELOPMENT We have another comment which we'd like to get to the Planning Commission before the Jan. 11 hearing. Please see attached documents. I will also try the address on the SLO Planning Commission web site. Regards, Wendy Brown, Treasurer Central Coast 1/ 5/2017 To the Planning Commission: Central Coast Grown Comments on San Luis Ranch DEIR — Agricultural Set -Aside Acreage The Draft EIR recommends Alternative 3 as the most preferred. The only description in this alternative to describe potential impacts to agricultural resources is a one word reference to the original project on page 6-14 in Section 6.0 Alternatives. Agricultural Resources. Potential impacts to agricultural resources under Alternative 3, as well as the mitigation measures that would avoid or minimize these effects, would be similar to the project." The executive summary for the DEIR, on page ES -17, refers to an exact set-aside of agricultural land for each acre of Prime Farmland that is developed, 59.3 acres, It does not include open space in this set- aside. Table ES -2 Class II, Significant but Mitigable Environmental Impacts Impact Mitigation Measure Residual Impact AGRICULTURAL RESOURCES Impact AG -1. The project would result in the direct conversion of 59.3 acres of Prime Farmland, as mapped by the FMMP, to non-agricultural uses. Therefore, impacts would be Class II, significant but mitigable. 8-30 AG -1. Agricultural Conservation. Prior to issuance of any grading permits the project proponent shall provide that for every one (1) acre of Important Farmland Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to non-agricultural use as a result of project development, one (1) acre of land of comparable agricultural productivity shall be preserved in perpetuity. The land dedicated to agriculture pursuant to this measure shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. The acreage required to meet the 1:1 ratio may be met by the off-site agricultural conservation easement/deed restriction proposed by the project applicant, as long as this land meets the conditions outlined in this measure. Said mitigation shall be satisfied by the applicant through: 1) Granting a perpetual conservation easement(s), deed restriction(s), or other farmland conservation mechanism(s) to the City or qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, for the purpose of permanently preserving agricultural land. The required easement(s) area or deed restriction(s) shall therefore total a minimum of 59.3 acres of Prime Farmland. The land covered by said off-site easement(s) or deed restriction(s) shall be located within the City's Urban Reserve Line or Greenbelt; or 2) Making an in -lieu payment to a qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, to be applied toward the future purchase of a minimum of 59.3 acres of Prime Farmland in San Luis Obispo County, together with an endowment amount as may be required. The payment amount shall be determined by the qualifying entity or a licensed appraiser- or 3) Making an in -lieu payment to a qualifying entity which has been approved by the City and that is organized for conservation purposes, to be applied toward a future perpetual conservation easement, deed restriction, or other farmland conservation mechanism to preserve a minimum of 59.3 acres of Prime Farmland in San Luis Obispo County. The amount of the payment shall be determined by the qualifying entity or a licensed appraiser; or 4) Any combination of the above. With implementation of Mitigation Measure AGA, this impact would be reduced to a less than significant level. The original SLR Draft Specific plan includes open spaces and creeks in the total set-aside acreage, resulting in 50 acres of agricultural land. Please see attached pages from the Plan describing this in detail. We are requesting that you determine the exact amount of agricultural only acreage to be set aside, not including open space, and whether it should be on site or off-site as described in the Executive Summary. In addition, if some of the set-aside is to be at another location, whether there will be a multiplier of those acres, as discussed by the Planning Commission in past hearings. It is only fair to neighbors on all sides, and the people of San Luis Obispo, who are counting on a true set-aside of 50% of the agricultural land on the current SLR site. Central Coast Grown Board of Directors Steven Marx John Philips Jerusha Greenwood Wendy Brown Terry Hooker Brian Engleton Josh Carmichael 8-31 Table 2-1 General Plan San Luis Ranch Performance Standards Residential LDR, MDR, MHDR, HDR 350 units Commercial INC, CC 50,000 sq. ft. Office O 50,000 sq. ft. Hotel ' n/ a - n/ a Parks PARK - 5.8 ac. Open Space/Agriculture OS, AG 50% LDR- Low Density Residential - Maximum Density 7 du/ac MDR - Medium Density Residential - Maximum Density 12 du/ac MHDR - Medium High Density Residential - Maximum Density 20 du/ac HDR - High Density Residential - Maximum Density 24 du/ac INC - Neighborhood Commercial - Maximum Density 12 du/ac; Max FAR 2.0 CC - Community Commercial - Maximum Density 36 du/ac; Max FAR 2.0 O - Office - Maximum Density 12 du/ac; Max FAR 1.5 PARK - Park Os - Open Space AG -Agriculture Maximum density figure not inclusive of affordable housing units 2.1.2 San Luis Ranch Land Use Distribution Table 2- 2 illustrates how the San Luis Ranch meets the fifty percent requirement for open space and agriculture as established under the City's General Plan. To calculate the amount of open space and agriculture required, the net site area was first determined. The net site area is the gross site area less the right-of-ways for Froom Ranch Way, Dalidio Drive, Prado Road extension, and the Madonna Road improvements. The local streets were not deducted to calculate the net site area. (See Chapter 6, for additional information on street and road improvements.) The net site area was multiplied by fifty percent to calculate the acreage required to be set aside for open space and agriculture (approximately 62 acres). The set aside includes 50 acres of agriculture. Interim Open Space (4.41 acres) is the existing heron habitat. If the herons naturally relocate or this habitat can be mitigated offsite, the area may be open for development. Chapter 4 provides more information on open space and agriculture. 500 units 200,000 sq. ft. 150,000 sq. ft. 200 rooms San Luis Ranch's site design provides a traditional neighborhood street layout that matches the adjacent existing home tracts. Open space is integrated into a central neighborhood park around which roads, walking and bicycle paths, and multi -use areas circumnavigate the center. The City encourages mixed-use projects that mix residential and commercial on the same site. Mixed-use projects play an increasingly important role in providing additional housing, without sacrificing opportunities for commercial and office spaces. The City has entitled several mixed-use projects in the Downtown core." Climate Action Plan P. 28-29 SAN LUIS RANCH I SPECIFIC PLAN I City of San Luis Obispo, CA I August 28, 2015 Preliminary Draft 2-7 8-32 Table 2-2 San Luis Ranch Land Use Distribution Gross Site Area Less Right -of Ways Includes Froom Ranch Way, Dalidio Drive, Prado Road extension, and Madonna Road improvements Net Site Area Development Area Agriculture and Open Space 2.1.3 Infill Development and Design Constraints This infill project has several major constraints. On the east side is U.S. Highway 101. The Plan recognizes the importance of preserving the view looking west from the Highway (see Chapter 4 for more information on the protection of scenic resources). On half of the south perimeter lies the SLO City farm. As a high priority, the Plan was designed so that San Luis Ranch agriculture is contiguous with the SLO City farm to maximize agriculture viability and views. On the southwest border is Prefumo Creek. There is also a water drainage channel that bisects the Plan Area and runs north alongside the Post Office. This is an important area for stormwater drainage, and it provides an excellent area for open space. The most westerly border is adjacent to Madonna Road. About two thirds of the property adjacent to Madonna Road will be multi -family. The other one third of the area along Madonna is designated as Interim Open Space as there are limited wildlife issues on this area. However, the open space could be appropriate for additional multi -family housing in the future (see Section 4.5.2 for future use of interim open space). The northern border is adjacent to Dalidio Road and existing commercial. It is the most appropriate area for commercial uses. The Prado Road overpass will bypass this area and provide regional access to the existing and proposed commercial uses, The City shall support the location of mixed- use projects and community and neighborhood commercial centers near major activity nodes and transportation corridors/transit opportunities where appropriate." General Plan Policy 2.3. 6 131.38 7.46 123.92 100% 61.96 50% 61.96 50% Lastly, Froom Ranch Way, if required, would bisect the entire property from north to south. If Froom Ranch Way is not required, the natural flood plain boundary provides a natural split between agriculture and residential area. Any conflicts with existing easements will be accounted for in the final site design, including those respecting the Calle Joaquin Agricultural Master Plan, utilities easements, and the existing billboard. Table 2-3 San Luis Ranch Land Use Designations and Acreage DEVELOPMENT LAND USES ITEM ITEM ACREAGE DENSITY Single -Family Res. 350 UNITS 35.33 9.9 du Multi -Family Res. 150 UNITS 6.52 23.0 du Commercial 150,000 SF 9.45 Hotel 200 ROOMS 3.50 Office 100,000 SF 3.77 Parks* 3.39 TOTAL 61.96 AGRICULTURE AND OPEN SPACE ITEM ACREAGE Agricultural 50.00 Interim Open Space 4.41 Parks, Creeks, Basins, Internal Open Spaces 7.55 TOTAL 61.96 The City General Plan requires 5. 8 acres of parks that is comprised of the above 3.39 acres and a 2.41 acre credit for the Bob Jones Trail. 2- 8 SAN LUIS RANCH I SPECIFIC PLAN I City of San Luis Obispo, CA I August 28,.2015 Preliminary Draft 8-33 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 3 COMMENTER: Central Coast Grown Board of Directors DATE: January 5, 2017 Response 3.1 The commenter states that the Draft EIR describes Alternative 3 as the most preferred, and that the only description in this alternative to describe potential impacts to agriculture is a reference to the original project in Section 6.0, Alternatives. The Draft EIR describes Alternative 3 as the “environmentally superior alternative,” consistent with the requirements of Section 15126.6(e)(2) of the State CEQA Guidelines. Section 6.4.4 of the Draft EIR evaluates the potential impacts of this alternative relative to the proposed project, and determines that the potential impacts to agricultural resources associated with this alternative would be similar to the project. The project’s potential impacts to agricultural resources are discussed in Section 4.2, Agricultural Resources. The potential impacts of other alternatives relative to the proposed project are discussed in Section 6.0, Alternatives. Refer to Master Response 1 for a discussion of project alternatives. Response 3.2 The commenter states that the Draft EIR Executive Summary refers to a set-aside of agricultural land for each acre of Prime Farmland that would be developed – totaling 59.3 acres – and that open space is not included in this set-aside. The commenter states that the original San Luis Ranch Draft Specific Plan includes open spaces and creeks in the total set-aside acreage, resulting in 50 acres of agricultural land. The commenter requests that the Draft EIR determine the exact amount of agricultural-only acreage to be set aside, excluding open space, and whether this acreage would be on the project site or off-site as described in the Draft EIR Executive Summary. The commenter further requests that the Draft EIR describe whether a multiplier would apply to off-site set-aside acreage. As described in Section 4.2, Agricultural Resources, the project would result in the conversion of approximately 59.3 acres of on-site Prime Farmland (revised to 56 acres in the Final EIR based on changes to the Draft EIR text discussed in Response 29.33 and Responses 29.40 through 29.42) being converted to non-agricultural use. The Draft EIR identifies this loss of Prime Farmland as a significant impact, and requires Mitigation Measure AG-1, which requires that impacts to Prime Farmland be mitigated at a 1:1 ratio (acres of Prime Farmland converted to acres of Prime Farmland preserved in perpetuity). Mitigation Measure AG-1 allows for the required mitigation to be achieved through dedication of an on- and/or off-site easement(s) or deed restriction(s) located within or contiguous to the City’s Urban Reserve Line or Greenbelt. The Specific Plan proposes to preserve approximately 53 acres of Prime Farmland on the project site. Therefore, the project applicant would be required by Mitigation Measure AG-1 to preserve a minimum of 3 acres of Prime Farmland off-site within or contiguous to the City’s Urban Reserve Line or Greenbelt. In addition, as described in Section 4.2, Agricultural Resources: 8-34 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo “Land Use Element Policy 8.1.4 includes a performance standards table, which states that ‘a substantial multiplier for the amount of open space is provided for the off-site property exchanged to meet the on-site requirement.’ The project applicant has an existing option-to-purchase agreement on a parcel located within the City’s Greenbelt, and the City has provided the applicant with preliminary approval for this site as an off- site agricultural conservation easement/deed restriction to satisfy Land Use Element Policy 8.1.4.f. However, the specific location of potential off-site agricultural conservation easement land has not been formally identified through a final approval. The “substantial multiplier” required by the City for the San Luis Ranch Specific Plan would be determined by the City at the time that final approval for off-site property exchanged to meet the on-site requirement is considered. To ensure that the final off-site agricultural conservation easement/deed restriction satisfies the requirements of Land Use Element Policy 8.1.4, the project applicant would be required to establish performance measures for the off-site agricultural conservation easement/deed restriction.” Therefore, the total acreage that the project application may be required to preserve off-site through easement(s) or deed restriction(s) would be determined by the City at the time that final approval for off-site property exchanged to meet the on-site requirement is considered, and the final determination of the project’s consistency with City policy rests with City Council. 8-35 Meeting: p I I • 11 - From: Dennis Vavrek <Item:, 1 Sent: Tuesday, January 10, 2017 7:01 AM To: Advisory Bodies Cc: Subject: Avila ranch & San Luis ranch ....approval Dear Planning Review, Re:: Strategizing Our Future These 2 projects (above) are the growth -devices of SLO, Simply, No residencies , no fuel.' We go 'nowhere', We learn even less. How (?) these residencies are devised, is the central -riddle * * facing your public -review task The Drafting of the tale of a town ever -transitioning from: Ranching to : Residencies Wishing all well... w/ the SLO process. Dennis Vavrek @ Dyabode® P.S. Peter Drucker might weigh in here w/ A Reminder: In Biz (success), All that matters is innovation & sales.... Everything else is cost.' 1 RECEIVED CITY OF SAN LUIS OBISPO JAN 10 2017 COMMUNITY DEVELOPMENT + 8-36 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 4 COMMENTER: Dennis Vavrek, Private Citizen DATE: January 10, 2017 Response The commenter expresses support for the project. This comment will be forwarded to the appropriate decision-makers for review and consideration. 8-37 Meeting From: M. Farid Shahid <item: 1`4 2 Sent: Wednesday, January 11, 2017 1:39 AM To: Advisory Bodies RECEIVED Subject: In Support Of San Luis Ranch & Avila Ranch - Jan I lth PC Meeting CITY OF SAN LUIS OBISPO Importance: High Dear Planning Commission, JAN 1 1 2017 COMMUNITY DEVELOPMENT I support both Avila Ranch & San Luis Ranch. Both communities have well designed masterplans that will add much needed housing. This is an urgent matter and we don't have time to delay crucial projects like this. They both fit into the long term vision of our city and all of the young professionals and families that I know absolutely love and want these projects. The locations are perfect and are not a major environmental issue like some opponents claim. Please approve and expedite both projects for the happiness of SLO. Best, M. Farid Shahid Active SLO millenniel, 6 yr resident 8-38 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 5 COMMENTER: Farid Shahid, Private Citizen DATE: January 11, 2017 Response The commenter expresses support for the project, and recommends that the Planning Commission approve this project and the Avila Ranch Project. This comment will be forwarded to the appropriate decision-makers for review and consideration. 8-39 Meeting:PL 1. t, I -- Item: ?i To: City of SLO Planning Commission From: Allan Cooper, San Luis Obispo Re: Review of San Luis Ranch Draft EIR Date: January 10, 2017 RECEIVED CITY OF SAN LUIS OBISPO JAN 1 1 2017 - COMMUNITY DEVELOPMENT I You will be evaluating on January 11, 2017 the adequacy of the San Luis Ranch Development Draft EIR. I concur with the findings in this draft EIR which states that air quality', cultural resources (historic resources and cumulative historic resources), land use/policy consistency (General Plan policy consistency), noise (construction noise), and transportation (existing and near-term intersection operations, existing and near-term lane capacities, existing and near-term segment operations, cumulative intersection operations, cumulative lane capacities, and cumulative segment operations) created by this project will be significant and unavoidable. This project at the time of buildout will also place unavoidable adverse impacts on the City's current sewer, water, school, law enforcement and fire protection capacities. However, the proposed tree replacements, particularly along the riparian corridor, will result in not only significant but unavoidable adverse impacts - not mitigable impacts as the draft EIR states. The mitigations involving replacement in-kind minimum ratios, particularly with regards to the proposed removal of the mature eucalyptus trees, will hardly mitigate the permanent loss of the monarch overwintering grove and active great blue heron nest habitat. Monarchs need tall trees (of at least 60 feet) because they roost in the intermediate level of the canopy where wind protection is greatest. Tall Eucalyptus trees are hugely important as habitat trees as they provide cover and nest sites for Great Blue Herons as well as for Double - Crested Cormorants, hawks and Great Horned Owls. The report notes that 1 Often during the Spring, an area of high pressure will build at the surface over the western United States and produce Santa Lucia (northeasterly) winds, also referred to as "offshore winds" because they flow from the land out to sea especially during the night and morning hours. Severe temperature differences in the vertical plane occur resulting in an inversion. A temperature inversion occurs when a warmer, less dense air mass covers cooler, denser air at the surface. The temperature changes are because of cool moisture -laden northwesterly onshore) winds from the Pacific Ocean blowing through Los Osos Valley while hot and dry Santa Lucia northeasterly (offshore) winds move from the Santa Lucia Mountains through Avila Valley. 8-40 one mitigation - creating new offsite nesting habitat for great blue herons - is experimental and that the relocation techniques described in Crouch et al. (2002) were used to relocate black -crowned night heron (Nycticorax nycticorax), not great blue herons. Finally, the California Government Code - Gov Title 7. Planning And Land Use [65000 - 66499.58] ) "...recognizes that premature and unnecessary development of agricultural lands for urban uses continues to have adverse effects on the availability of those lands for food and fiber production and on the economy of the state. Furthermore, it is the policy of the state that development should be guided away from prime agricultural lands..." This project involves conversion of 68 acres of prime soils to urban development. Therefore, your certification of this draft EIR should note that, per the City of San Luis Obispo's Housing Element2, this project is "inconsistent with State Planning Law". Thank you for your time and consideration. 2 City of San Luis Obispo Housing Element 1.30 Consistency with State Planning Law California cities and counties must prepare housing elements as required by State law set forth in Sections 65580 to 65589.8 of the California Government Code. The law mandates that housing elements include "identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives and scheduled programs for the preservation, improvement and development of housing." This Element fulfills that requirement and provides a detailed strategy for implementing the City's housing goals through 2019. State housing goals rely on the effective implementation of housing policies at the local level. To ensure local housing policies are consistent with State law, the State Department of Housing and Community Development (HCD) reviews local housing elements and reports its written findings to the local government. Housing elements must also be consistent with the jurisdiction's other general plan elements and must address several specific requirements regarding the element's scope and content." 8-41 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 6 COMMENTER: Allan Cooper, Private Citizen DATE: January 10, 2017 Response 6.1 The commenter states that they concur with the significant and unavoidable impacts identified in the Draft EIR. The commenter states that the project would also result in unavoidable impacts on the City’s sewer, water, school, law enforcement, and fire protection capacities. Potential impacts associated with water availability are described in Section 4.12, Water Resources. Potential impacts associated with sewer, school, law enforcement, and fire protection services are described in Section 4.14, Issues Addressed in the Initial Study. Section 5.3, Significant Irreversible Environmental Effects, also includes a discussion of the commitment of law enforcement, fire protection, supply, wastewater treatment, and solid waste disposal services that would be required by project-related growth; however, as described in Sections 4.12, Water Resources and 4.14, Issues Addressed in the Initial Study. Section 5.3, Significant Irreversible Environmental Effects, these issues are not identified as significant environmental impacts in the Draft EIR. Response 6.2 The commenter states that the tree replacements described in Mitigation Measure BIO-1(f) would result in significant and unavoidable adverse impacts, and would not adequately mitigate the permanent loss of the monarch overwintering grove and great blue heron nest habitat. The commenter notes that Mitigation Measure BIO-1(f) states that creating offsite nesting habitat for great blue herons is experimental, and that the relocation techniques described in Crouch et al. (2002) were used to relocate black-crowned night heron (Nycticorax nycticorax), not great blue herons. Mitigation Measure BIO-1(f) requires overwintering monarch surveys and/or nesting great blue heron surveys to be conducted within one week of habitat disturbance in the event that construction activities must be conducted during monarch butterfly overwintering season or while great blue heron nests are active. If clustering monarchs and/or nesting great blue herons are located, no construction activities would be allowed to occur within 100 feet of the edge of the overwintering grove and/or active nest(s) until the qualified biologist determines that no more monarchs are overwintering in the grove or the nest(s) are no longer active. This measure would avoid potential impacts to overwintering monarch butterflies and nesting blue herons. In the event that surveys do not locate clustering monarchs or nesting great blue herons and construction activities result in tree removal, Mitigation Measure BIO-1(f) requires that new nesting habitat be created following methods detailed in Crouch et al. (2002). Since creating offsite nesting habitat for great blue herons is experimental and that the relocation techniques described in Crouch et al. (2002) were used to relocate black-crowned night heron (Nycticorax nycticorax), an agreement with the City would be required prior to implementation of the offsite habitat relocation strategy. In addition, Mitigation Measure BIO-1(f) requires that a habitat enhancement plan be prepared and implemented by a qualified biologist prior to issuance of grading permits to enhance and restore overwintering and nesting habitat that is to be preserved. Furthermore, Mitigation Measure BIO-1(g) outlines requirements to avoid and minimize potential impacts to nesting birds, including nesting bird surveys, establishment of necessary buffer zones, and 8-42 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo implementation of proper timing for vegetation removal. Accordingly, Mitigation Measures BIO-1(f) and BIO-1(g) ensure that project’s potential impacts to monarch butterflies and great blue herons are reduced to a less than significant level. No further revisions to the Draft EIR are required in response to this comment. Response 6.3 The commenter states that the project is inconsistent with the California Government Code Section 65589.5(c), because the project involves conversion of prime soils to urban development, and because the City’s Housing Element requires that local housing policies are consistent with State law. Section 4.2, Agricultural Resources, describes the applicable State legislation and local policies related to agricultural resources, including prime soils. Section 4.9, Land Use/Policy Consistency, describes the project’s consistency with applicable State legislation and General Plan Housing Element policies. California Government Code Section 65589.5(c) states “The Legislature also recognizes that premature and unnecessary development of agricultural lands for urban uses continues to have adverse effects on the availability of those lands for food and fiber production and on the economy of the state. Furthermore, it is the policy of the state that development should be guided away from prime agricultural lands. Therefore, in implementing this section, local jurisdictions should encourage, to the maximum extent practicable, in filling existing urban areas.” As stated, the California Government Code Section cited by the commenter discourages, but does not prohibit, conversion of prime soils to urban development. No revisions to the Draft EIR are required. 8-43 Meeting; w(- Item: 2 Dear Planning Commissioners, RECEIVED CITY OF SAN LUIS OBISPO JAN 1 1 2017 COMMUNITY DEVELOPMENT I cannot believe that I'm writing my second email to you about another development that you will review tonight that will destroy and pave over PRIME farmland, violating State of California laws and common sense. My previous email was regarding Avila Ranch and this one is about San Luis Ranch, a double loss for our town is on your plate tonight. In San Luis Obispo's mad rush to grow it seems that we are totally ignoring the history of cities to the North and South of us that were once as lovely as San Luis. There are so many permitted projects and ones in the pipeline that we are now in a spot where it is impossible to envision our future and the quality of life and the impacts we are creating for future generations and the environment. In five years our wonderful town will be unrecognizable. The San Luis Ranch project is simply unacceptable and no amount of mitigation" will ever make up for what will be lost. Please help us to slow down and consider the negative health and safety aspects in terms of infrastructure, traffic/circulation, flight path location, air quality (low inversion layer), water use, Climate Change and history. The negative impacts of the loss of large trees (habitat/nesting birds) and the land with its topsoil and potential for sustainability of our food source into the future is just plain wrong. Please have the fortitude to carefully examine this project and help to protect the future of San Luis Obispo. Thank you for your consideration. Sincerely, Cheryl McLean San Luis Obispo 8-44 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 7 COMMENTER: Cheryl McClean, Private Citizen DATE: January 11, 2017 Response The commenter states a concern regarding the potential impacts of the project, and requests that the Planning Commission consider the negative health and safety aspects in terms of infrastructure, traffic, flight path location, air quality, water use, climate, and history. The commenter specifically states that the project would have adverse impacts related to the loss of large trees and impacts to topsoil and agricultural sustainability. Each of these issues are discussed in the following sections of the Draft EIR: 4.1, Aesthetics, 4.2, Agricultural Resources, 4.3, Air Quality, 4.4, Biological Resources, 4.8, Hydrology and Water Quality, 4.5, Cultural Resources, 4.6, Greenhouse Gas Emissions, 4.9, Land Use/Policy Consistency, and 4.12, Transportation. Specifically, Section 4.2, Agricultural Resources, describes the project’s impacts associated with conversion of prime agricultural soils and degradation of viability of on-site agricultural land, and indicates that the project’s potential impacts associated with conversion of prime agricultural soils to urban uses would be significant, but mitigable. Mitigation Measure AG-1 requires the project proponent to provide that for every acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to non-agricultural use as a result of project development, one acre of land of comparable agricultural productivity shall be preserved in perpetuity. Section 4.4 Biological Resources, describes the project’s potential impacts associated with the loss of trees as nesting/roosting habitat, and indicates that this impact would be significant, but mitigable. Mitigation Measure BIO-1(f) requires construction practices to avoid and minimize potential impacts to overwintering monarch butterflies and nesting great blue herons, and Mitigation Measure BIO-1(g) describes construction practices to avoid and minimize potential impacts to nesting birds. The commenter does not provide specific concerns that are applicable to be addressed outside of the broad issue areas presented. The commenter requests that the Planning Commission carefully examine the project to protect the future of San Luis Obispo. The commenter’s concerns will be forwarded to the appropriate decision-makers for review and consideration. 8-45 Meeting: 1 2 Item: To: City of SLO Planning Commission (bleveille@slocity.org) From: Cristina Lazcano PhD, Asst. Professor of Soil Science, Cal Poly Re: Review of San Luis Ranch Draft Environmental Impact Report (DEIR) Date: January 16, 2017 To the Commissioners: RECEIVED CITY OF SAN LUIS OBISPO JAN 18 2017 COMMUNITY DEVELOPMENT I write to comment on the section of the DEIR addressing agricultural impacts of the project as proposed, specifically in regard to Impact AG -4, which states " Re -grading of the project site would not result in significant degradation of viability of on-site agricultural land. Therefore, this impact would be Class 11I, less than significant." Through my teaching and research, I aim to understand the role of-belowground_biological interactions and management strategies in soil nutrient cycling and the consequences for plant productivity and environmental quality across natural and managed soil systems. In particular, my research focuses on the interactions between plants and microorganisms, and their role in N and C cycling across different soil moisture conditions and management strategies. I have experience in a wide range of agricultural systems together with natural systems such as grasslands, forests and peatlands. I am the author of 23 published articles and referee for more than 20 scientific journals in the field. The importance of soil organisms and their ecological interactions in the top 30 centimeters of topsoil has recently become recognized as crucial for agricultural productivity, regenerative fertility and general environmental health, including carbon sequestration that mitigates greenhouse gas emissions. This recognition has come along with the realization of the limits and long term dangers of excessive inputs of synthetic fertilizers. On the basis of my knowledge and research and that of colleagues in my field, I must strongly disagree with the idea that any removal of topsoil, let alone to the depth two and a half feet, would be without serious long term negative consequences for the farmland in question. Were such removal undertaken it would require massive inputs of compost and many years of intensive soil restoration practice to recover soil fertility, before the soil could be considered suitable for organic farming. I strongly urge you to require the applicant to find alternative sources of fill for construction on sections of the property in question not reserved for agriculture and to find alternative solutions for drainage that will not involve the waste of precious soil resources now to be found there. Sincerely, J s CALPOLY Cristina Lazcano, Ph.D. Assistant Professor Natural Resources Soil Ecology Management & Environmental Sciences College of Agriculture, Food & Environmental Sciences soilecology.weebly.com nres.calpoly.edu 8-46 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 8 COMMENTER: Cristina Lazcano, Ph.D., California Polytechnic State University DATE: January 16, 2017 Response 8.1 The commenter describes their research, experience, and qualifications for commenting the agricultural resources analysis in the Draft EIR. The commenter describes the importance of soil organisms and their interactions in the top 30 centimeters of topsoil for agricultural productivity, regenerative fertility, and general environmental health. The commenter notes the limits and long-term dangers of excessive inputs of synthetic fertilizers. The commenter states that the potential removal of up to two-and-a-half feet of topsoil would have serious long-term negative consequences for the farmland on the project site. The commenter states that the proposed re-grading of the site would necessitate inputs of compost and many years of intensive soil restoration practice to recover soil fertility before the soil could be considered suitable for organic farming. Refer to Master Response 3 for a discussion of the historic and current farming practices on the project site, the proposed grading and drainage plans for the project site, a description of the proposed organic farming practices for future agricultural use of the site, and the anticipated long-term effects on soil microbial activity and agricultural productivity. Response 8.2 The commenter recommends that the City require the project applicant to identify alternative sources of fill for construction on sections of the property not reserved for agriculture and to find alternative solutions for drainage that would not involve the use of existing agricultural soil for fill. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site. The commenter’s recommendations will be forwarded to the appropriate decision-makers for review and consideration. 8-47 8-48 Central Coast Grown’s Comment on San Luis Ranch’s December 2016 DEIR on Proposed Topsoil Grading I. Introduction This comment expresses the views of Central Coast Grown(CCG), the non-profit organization selected by the SLO City Council to manage City Farm San Luis Obispo under the terms of 1) a 20-year nominal-fee lease and 2) of the 2011 Master Plan for the Calle Joaquin Agricultural Reserve (www.slocity.org/home/showdocument?id=1916). City Farm SLO is a 20-acre parcel zoned Agricultural Open Space and owned by the City, adjacent to San Luis Ranch CCG has a strong interest in the development plans for the Agricultural Land belonging to San Luis Ranch for several reasons. As an immediate neighbor, City Farm’s operations are directly impacted by the treatment of soil and water resources on the adjoining property, in particular by any grading activities affecting land contours and soil conditions. As custodian of City Farm and a continuous onsite presence, CCG has a responsibility to uphold the intentions and terms of the Calle Joaquin Agricultural Reserve under which it operates and to which the agricultural land of San Luis Ranch will be subject, if and when it is annexed into the City. Those terms include: The City General Plan's "50% preservation" requirement also extends to the third and largest property in the area, known as the Dalidio property (approximately 130 acres). Upon development of that property, an additional 65 acres wll be potentially added to the Agricultural Reserve. The ultimate size of the Reserve is therefore anticipated to be approximately 90 acres. According to the United States Department of Agriculture Natural Resource Conservation Service's Soil Survey of San Luis Obispo County (Coastal Part), the Master Plan area is composed of mostly Cropley clay and Salinas silty clam loam. The Cropley clay is a Class II soil and the Salinas silty clay loam is a Class I soil. Both of these soils are considered "prime" soils, and the City of San Luis Obispo considers their loss to be a significant environmental impact requiring mitigation. Preservation of an approximately equal area of such soils in perpetuity was considered to be appropriate mitigation in the City's 1994 General Plan Update and is the legal basis for the requirement of such preservation in conjunction with development of the surrounding land with urban uses. http://www.slocity.org/home/showdocument?id=1916 CCG has been following the development plans of the San Luis Ranch and has offered suggestions and comments at each stage. CCG is particularly concerned about the developer’s proposal to remove up to two feet of topsoil from up to 52 acres of the land it is required by the General Plan to place into the Calle Joaquin Agricultural Reserve. From the outset we have found this proposal unacceptable for reasons presented earlier and elaborated below. At this point we are disappointed that this proposal continues to be reaffirmed in the DEIR, despite our objections and those expressed by the Planning Commission. CCG urges that the applicant be required to offer alternative plans for providing fill to raise the elevation of portions of its site and for dealing with possible floodwater drainage and/or detention requirements 8-49 that does not involve either removal or disturbance of topsoil on portions of the property that are to remain in Agricultural Reserve. II. CCG Testimony and Planning Commission Responses to Previous Proposal In both verbal and written presentations to the SLO Planning Commission in March 2016, CCG Treasurer Wendy Brown requested alteration in project’s cut & fill procedures, as well as other changes protecting water resources and requesting clarification of offsite mitigation proposals. The Planning Commission Minutes for that meeting record that Commissioner Fowler commented on …shared concerns about topsoil and drainage issues; Commissioner Malak shared concerns about 18-inches of topsoil and considered the idea of garnering fill from elsewhere. Acting Chair Draze… discouraged moving Class 1 soils and recommending consulting heavily with City Resource Manager…(opengov.slocity.org/weblink/1/doc/59501/Page1.aspx) In a letter to Tyler Corey responding to CEQA Scoping Suggestions dated November 16, 2016, Steven Marx, CCG President, commented: “- According to the Preliminary Specific Plan dated August 28, 2015, p. 7-13, the developer proposes a conceptual grading plan in which “The agricultural area will be lowered to offset the diverted flows from Areas 2 and 3…” Determine what impacts such cutting will have on soil quality and on water pooling on SLR agricultural land and on neighboring City Farm. A similar cut and fill operation, moving subsoil from Calle Joaquin Ag Reserve to raise the level of adjoining commercial lots, has had considerable unanticipated negative consequences.” In addition he requested, “conformity with City requirements of City Farm for organic standards on farmland.” III. San Luis Ranch’s December 2016 DEIR’s Inadequate Responses to CCG Testimony and to Planning Commission Responses to Previous Proposal The grading proposal in the Project DEIR does not adequately address these concerns. Rather than reconsidering the grading plan as requested earlier by Central Coast Grown, the DEIR presents their hired consultant’s lengthy “Agricultural Suitability Memorandum” justifying such removal: Project grading activities may remove up to two feet of soil at the north end of the agricultural area proposed to be retained with the project. However, on-site farmland would remain viable even if up to 2.5 feet of topsoil were removed, on-site soils will retain prime agricultural soils status… As such, agricultural viability will be retained after removal of topsoil resulting from implementation of the proposed grading and drainage plan for the project site. Therefore, potential impacts to the agricultural viability of on-site soils would be less than significant. http://www.slocity.org/Home/ShowDocument?id=14317 We take issue with the findings of this Agricultural Suitability Memorandum and on the statement of absence of Agricultural Impacts of the project it supports on several counts. 8-50 First, it does not specify how much acreage will be affected and where on the project site it is to be located. However, a diligent search produces this information from section 4.8: “In total, earthwork for buildout of the Specific Plan area is estimated to require 817,200 cubic yards (CY) of cut, and 569,200 CY of fill, resulting in a need for approximately 248,000 CY of soil import.” Without further explanation, these figures don't make sense: why would the larger amount of cut than fill require additional soil import? In any case, this is a projection of the removal of an unacceptably large quantity of topsoil. Another significant absence is created by the lack of any response to this passage in the DEIR: “Section 4.14 Issues Addressed in the Initial Study -- 4.14.5 Geology and Soils Would the project result in substantial soil erosion or the loss of topsoil;” IV. Rejection of the applicant’s claim that the removal of the top two feet of topsoil has no Deleterious Effects on Agriculture and Ecology. Of most concern about this proposal is the claim that removal of the top two feet of topsoil on class 1 farmland will have no effect on agricultural viability: Impact AG-4: Re-grading of the project site would not result in significant degradation of viability of on-site agricultural land. Therefore, this impact would be Class III, less than significant. (4.23) This claim appears implausible on the face of it. However, the applicant presents a lengthy “Agricultural Sustainability Memorandum” from its hired consultant to justify it, a report approved and certified by retired Cal Poly Soils Science Professor Tom Rice, PhD(1981). We believe that the evidence and arguments presented to support the conclusion of this memorandum are fragmentary, contradictory, based on antiquated and discredited science and don't take into account the organic agricultural practices that are required once the land falls under a conservation easement. In what follows we present testimony from a wide variety of sources to refute the Agricultural Sustainability Memorandum’s general claims that the removal of the top two feet of topsoil has no Deleterious Effects on Agriculture and Ecology. Unpaid testimony from local experts: Dr. Cristina Lazcano, PhD (2010), current Assistant Professor of Soil Science at Cal Poly (http://nres.calpoly.edu/personnel.ldml?email=lazcano), author of 23 published articles and referee for more than 20 journals in the field (https://www.researchgate.net/profile/Cristina_Lazcano), in a separately submitted letter to the Planning Commission. The importance of soil organisms and their ecological interactions in the top 30 centimeters of topsoil has recently become recognized as crucial for agricultural productivity, regenerative fertility and general environmental health, including carbon sequestration that mitigates greenhouse gas emissions. This recognition has come along with the realization of the limits and long term dangers of excessive inputs of synthetic fertilizers. On the basis of my knowledge and research and that of colleagues in my field, I must strongly disagree with the idea 8-51 that any removal of topsoil, let alone to the depth two and a half feet, would be without serious long term negative consequences for the farmland in question. Were such removal undertaken it would require massive inputs of compost and many years of intensive soil restoration practice to recover soil fertility, before the soil could be considered suitable for organic farming. I strongly urge you to require the applicant to find alternative sources of fill for construction on sections of the property in question not reserved for agriculture and to find alternative solutions for drainage that will not involve the waste of precious soil resources now to be found there. John Phillips, Ph.D. Professor Emeritus of Crop Science Cal Poly “While it may be true that the soil in the flood plain there is several feet deep, to assume that removal of 2.5 feet of the topsoil will have no adverse effect on crop production ignores the reality that the organic matter and the living organism component of the soil exists in a stratified manner, with aerobic organisms, bacteria, mycorrhizal fungi, actinomycetes, protozoa, nematodes, arthropods, and earthworms occupying the several inches near the soil surface. These creatures living in the soil are critical to soil health. They affect soil structure and therefore soil erosion and water availability. They can protect crops from pests and diseases. They are central to decomposition and nutrient cycling and therefore affect plant growth. Thus, this living component of soil contributes to agricultural productivity and air and water quality. The proposed grading at San Luis Ranch would eliminate the vast majority of this living component of the soil. Following the removal of 2.5 feet of topsoil, one could expect that at least a few years would be needed for the living component of the soil to regenerate, even with management specifically aimed at promoting soil health.” Tim LaSalle, Ph.D. Former CEO of Rodale Institute (http://www.csuchico.edu/vpaa/documents- short/mpp-job-postings/lasalle_cv.pdf) “The top foot of any topsoil has the most life, organic matter, and fertility because of the oxygen, microbiome, and vegetation that is deposited back…. It is impossible to take topsoil and not do permanent damage. Anyone who then says just bring in fertilizers is coming from a decades old soils class that is chemical based not a biological living soils education that teaches us how whole systems work. How fungi bring needed elements to the plant, how they liberate minerals like P, how the whole system fixes N without the need for fertilizers that will leach into the water ways, let alone significantly contribute to climate change.” Rob Rutherford, Professor Emeritus, College of Agriculture Cal Poly 8-52 “ANYTIME we disturb topsoil - we increase the release of CO2. A massive movement of that portion of the soil which contains the most carbon (organic matter) will send a significant amount of greenhouse gases to the atmosphere - and that doesn't even count the emissions of the vehicles that are doing the earthwork.” From National and International authorities: The National Resource Conservation Service of the U.S. Department of Agriculture on the loss of topsoil (https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_053285.pdf) The loss of topsoil, either by actual removal with heavy equipment or erosion by wind and water, is the worst on-site damage in urban areas. This layer of soil has the highest biological activity, organic matter, and plant nutrients—all key components of healthy soil. The on-site loss of this upper layer of soil nearly eliminates the soil’s natural ability to provide nutrients, regulate water flow, and combat pests and disease. Loss of nutrients and nutrient holding capacity, results in a less fertile environment for lawns and landscape plants. The organic matter and finer soil particles are responsible for soil fertility and are washed away first, leaving larger, less reactive particles such as sand and gravel. As organic matter is lost, soil density increases and compaction occurs. Compaction lowers the infiltration rate of water and reduces the available water holding capacity. This results in poorer growth of lawns, gardens, flowerbeds, shrubs, and trees, as well as making the site more susceptible to drought and requiring more frequent watering. Additionally, soil amendments such as fertilizer and pesticides cannot move into the soil and, instead, run off into nearby lakes and streams. Lower organic matter levels are also associated with weaker soil aggregates and therefore greater risk of further erosion and soil crusting. The surface organic matter is also the food source and habitat for beneficial microorganisms and insects. The loss of this material drastically reduces the soils natural ability to control disease and pest outbreaks, increasing the need for pesticides. These microorganisms are also key to removing or buffering toxic elements or contaminants. NRCS graphic representation showing how microbial life diminishes with depth. 8-53 https://www.nrcs.usda.gov/Internet/FSE_MEDIA/stelprdb1237708.jpg The Food and Agriculture Organization of the United Nations (FAO). FAO Soils bulletin 50, “Soil erosion - its causes and cures.” (http://www.fao.org/docrep/t0389e/t0389e00.htm) Soil teems with life All soil is full of life, and good soils are teeming with it. Plants and animals help keep the soil fertile. Plant roots tunnel through the soil and break it up, and decaying plants form humus. Burrowing animals mix the soil; the excrete of animals contribute nutrients and improve soil structure. Besides the soil's more obvious inhabitants, which include rodents, insects, mites, slugs and snails, spiders, and earthworms, there are countless microscopic residents, some helpful to man and his crops, some harmful. Good soils seem to hold the greatest populations of bacteria. Almost without exception, bacteria are involved in basic enzyme transformations that make possible the growth of higher plants, including our food crops. From man's point of view, bacteria may well be the most valuable of the life forms in soil. Chemical reactions occur in the soil as a result of exchange of positive ions, or cations. More exchanges take place in clay soils than in any other type. These chemical reactions are also essential to plant growth and development and are a good index of soil fertility. From Academic Technical Studies: Soil erosion and crop productivity: topsoil thickness (Integrated Crop Management News) http://www.ipm.iastate.edu/ipm/icm/2001/1-29-2001/topsoilerosion.html “Many studies have been conducted on the effect of depth of topsoil on corn yields in the Corn Belt states. Figure 1 (from Stallings, J.H. 1964. Phosphorus and water pollution. Journal of Soil 8-54 Water and Conservation 22: 228-231) summarizes the relationship between topsoil depth and crop productivity. There is a direct relationship between topsoil depth and yield. The decline in yield with the reduction in topsoil depth can be related to A horizon thickness.” Immediate effects of topsoil removal on crop productivity loss and its restoration with commercial fertilizers http://www.sciencedirect.com/science/article/pii/S0167198798000919 Abstract: A field experiment was conducted on a Typic Cryoboroll (Site 1) and a Typic Cryoboralf (Site 2) in north-central Alberta, Canada, to determine the influence of simulated erosion (artificial topsoil removal) on loss in yield of hard-red spring wheat (Triticum aestivum L. cv. `Roblin'), and to determine to which extent fertilizers N and P will restore the lost crop productivity of two artificially-eroded soils. There were three depths of topsoil removal (0, 10, and 20 cm) as main plot treatments, and a factorial combination of four levels of N (0, 50, 100, and 150 kg N ha−1) and three levels of P (0, 9, and 18 kg P ha−1) as sub-plot treatments. Wheat yields at both sites were markedly reduced by increasing depth of topsoil removal. The erosion effects were more pronounced at Site 2 where average yield on the 20 cm cut decreased to less than half of that obtained under non-eroded conditions. At both sites, additions of fertilizer N and P to eroded soil increased wheat yield, but the yields did not match those obtained in non-eroded soil under the same fertilizer treatment. Plants growing on eroded soil responded differently to application of fertilizers N and P, not only in terms of yield but also in N and P concentration and uptake. The implication of these findings is that fertilization programs for fields with varying degree of erosion would require optimization of rates so as to restore yield and, at the same time, minimize nutrient losses (e.g., N leaching) and improve soil tilth. V. The Agricultural Sustainability Memorandum uses ambiguous, obscure and contradictory language. The claim that “on-site farmland would remain viable” is ambiguous. The present soil makes for much more than viability—this farmland is exceptionally productive and maintaining viability and continuation in its present soil classification doesn't take that into account. In addition, the Memorandum assumes that viability after topsoil removal will be provided by substantial inputs of chemical fertilizer. This assumption ignores the provision of the City’s 20-year lease with Central Coast Grown stating that “the purpose of this agreement is to put the majority of the Premises into active sustainable agricultural use” and the language contained in all subleases at City Farm: “CCG will not require organic certification, but Lessee must manage the site in such a way so as to not preclude future tenants from seeking certification.” While acknowledging that “Organic matter and phosphorus concentrations drop significantly between the surface and sub-surface horizons,” the Memorandum maintains that the “surface horizon of a typical Cropley clay profile is 36 inches,” without indicating where in between those horizons the drop occurs or whether the typical profile applies to specific locations on this site. The study also asserts that “The northern field proposed as a floodway near U.S. Highway 101 may be farmed on the subsoil material,” again using the ambiguous 8-55 language, “may be farmed,” which ignores the present exceptional agricultural productiveness of the land and refers to subsoil rather than topsoil. VI. Previous Activity at the Calle Joaquin Agricultural Reserve to remove subsoil and replace topsoil has had deleterious effects on agriculture, requiring expensive remediation by the City. Removal of topsoil without replacement at San Luis Ranch would have more extensive and more serious effects. As detailed in the Agricultural Master Plan for the City of San Luis Obispo's Calle Joaquin Agricultural Reserve, As part of the development plan for the McBride property, the 13-acre open space portion was graded to avoid displacement of flood capacity. This was a City requirement imposed upon the project. This grading was performed in a manner that retained the top three feet of soil while removing approximately two feet of subsoil, and was done to retain a slope of 2% or less, 2% being the maximum slope considered acceptable for farming soils. Outcomes of that grading have since had two serious consequences. Pooling of water in the lower section of the fields in Winter 2015-2016 made farming impossible for several months for subtenants, Green Gold Organics, at City Farm and created a major factor for their terminating their lease and moving operations elsewhere. In an effort to remediate this condition on its property, the City of San Luis Obispo undertook the construction of a swale in order to drain pooled water away from the fields,improve its quality and conduct it toward Prefumo Creek, at a cost of $25,500. The success of this remediation effort remains to be seen. 8-56 This example demonstrates the high environmental impact of changing the contours of agricultural fields in order to mine them for subsoil fill to raise the elevation of nearby land for the purpose of development. It does not take into account the much greater impact of using topsoil for that purpose, as proposed in the DEIR. VI. Conclusion According the prospectus and Preliminary Specific Plan for San Luis Ranch, Everything about San Luis Ranch grows from the project’s foundation in four guiding principles identified as the CORE 4: The first of these guiding principles is stated as follows: San Luis Ranch will maintain and promote San Luis Obispo’s agricultural heritage. From continued cultivation to “u-pick-it” farming and an agricultural education center, San Luis Ranch will offer residents and visitors an opportunity to connect with agriculture and continue to enjoy the views of this pastoral setting. (http://www.slocity.org/home/showdocument?id=8013) We hope that this principle will serve to guide the developer to avoid the serious mistake of following the present plan to use the irreplaceable agricultural resource of fertile, living, precious topsoil as mere dirt. If not, we hope the City’s regulatory bodies will have the wisdom to prevent that from happening. 8-57 Meeting: F G 1 - I 1 _ _] Item: Z_ Central Coast Grown's Comment on San Luis Ranch's December 2016 DEIR on Proposed Topsoil Grading Introduction This comment expresses the views of Central Coast Grown(CCG), the non-profit organization selected by the SLO City Council to manage City Farm San Luis Obispo under the terms of 1) a 20 -year nominal -fee lease and 2) of the 2011 Master Plan for the Calle Joaquin Agricultural Reserve www.slocit .or 7/home/showdocument?id=1916. City Farm SLO is a 20 -acre parcel zoned Agricultural Open Space and owned by the City, adjacent to San Luis Ranch CCG has a strong interest in the development plans for the Agricultural Land belonging to San Luis Ranch for several reasons. As an immediate neighbor, City Farm's operations are directly impacted by the treatment of soil and water resources on the adjoining property, in particular by any grading activities affecting land contours and soil conditions. As custodian of City Farm and a continuous onsite presence, CCG has a responsibility to uphold the intentions and terms of the Calle Joaquin Agricultural Reserve under which it operates and to which the agricultural land of San Luis Ranch will be subject, if and when it is annexed into the City. Those terms include: The City General Plan's "50% preservation" requirement also extends to the third and largest property in the area, known as the Dalidio property (approximately 130 acres). Upon development of that property, an additional 65 acres wll be potentially added to the Agricultural Reserve. The ultimate size of the Reserve is therefore anticipated to be approximately 90 acres. According to the United States Department of Agriculture Natural Resource Conservation Service's Soil Survey of San Luis Obispo County (Coastal Part), the Master Plan area is composed of mostly Cropley clay and Salinas silty clam loam. The Cropley clay is a Class II soil and the Salinas silty clay loam is a Class I soil. Both of these soils are considered "prime" soils, and the City of San Luis Obispo considers their loss to be a significant environmental impact requiring mitigation. Preservation of an approximately equal area of such soils in perpetuity was considered to be appropriate mitigation in the City's 1994 General Plan Update and is the legal basis for the requirement of such preservation in conjunction with development of the surrounding land with urban uses. http://www.slocifv.oiTlhomelshowdocument?id=1916 CCG has been following the development plans of the San Luis Ranch and has offered suggestions and comments at each stage. CCG is particularly concerned about the developer's proposal to remove up to two feet of topsoil from up to 52 acres of the land it is required by the General Plan to place into the Calle Joaquin Agricultural Reserve. From the outset we have found this proposal unacceptable for reasons presented earlier and elaborated below. At this point we are disappointed that this proposal continues to be reaffirmed in the DEIR, despite our objections and those expressed by the Planning Commission. CCG urges that the applicant be required to offer alternative plans for providing fill to raise the elevation ofportions of its site and for dealing with possible floodwater drainage and/or detention requirements 8-58 that does not involve either removal or disturbance of topsoil on portions of the property that are to remain in Agricultural Reserve. CCG Testimony and Planning Commission Responses to Previous Proposal In both verbal and written presentations to the SLO Planning Commission in March 2016, CCG Treasurer Wendy Brown requested alteration in project's cut & fill procedures, as well as other changes protecting water resources and requesting clarification of offsite mitigation proposals. The Planning Commission Minutes for that meeting record that Commissioner Fowler commented on ... shared concerns about topsoil and drainage issues; Commissioner Malak shared concerns about 18 -inches of topsoil and considered the idea of garnering fill from elsewhere. Acting Chair Draze... discouraged moving Class 1 soils and recommending consulting heavily with City Resource Manager...(ol2engov.slocity.or /weblink/1/doc/ 59501/PageLaspx) In a letter to Tyler Corey responding to CEQA Scoping Suggestions dated November 16, 2016, Steven Marx, CCG President, commented: "- According to the Preliminary Specific Plan dated August 28, 2015, p. 7-13, the developer proposes a conceptual grading plan in which "The agricultural area will be lowered to offset the diverted flows from Areas 2 and 3..." Determine what impacts such cutting will have on soil quality and on water pooling on SLR agricultural land and on neighboring City Farm. A similar cut and fill operation, moving subsoil from Calle Joaquin Ag Reserve to raise the level of adjoining commercial lots, has had considerable unanticipated negative consequences." In addition he requested, "conformity with City requirements of City Farm for organic standards on farmland." SLR December 2016 DEIR's Inadequate Responses to CCG Testimony and Planning Commission Responses to Previous Proposal The grading proposal in the Project DEIR does not adequately address these concerns. Instead it restates the intention to remove up to two feet of topsoil from a large portion of the site: "The proposed grading and drainage plan for the site would require grading of topsoils to offset the diverted flows from adjacent areas, such that no change in flood water depths or flows would occur on surrounding properties." Agricultural impacts AG -4) Rather than reconsidering the grading plan, the DEIR presents their hired consultant's lengthy Agricultural Suitability Memorandum" justifying such removal: Project grading activities may remove up to two feet of soil at the north end of the agricultural area proposed to be retained with the project. However, on-site farmland would remain viable even if up to 2. 5 feet of topsoil were removed, on-site soils will retain prime agricultural soils status... As such, agricultural viability will be retained after removal of topsoil resulting from implementation 8-59 of the proposed grading and drainage plan for the project site. Therefore, potential impacts to the agricultural viability of on-site soils would be less than significant. We take issue with the findings of this Agricultural Suitability Memorandum and on the statement of absence of Agricultural Impacts of the project it supports on several counts. First, it does not specify how much acreage will be affected and where on the project site it is to be located. However, a diligent search produces this information from section 4.8: "In total, earthwork for buildout of the Specific Plan area is estimated to require 817,200 cubic yards (CY) of cut, and 569,200 CY of fill, resulting in a need for approximately 248,000 CY of soil import." One can only assume that the amount of topsoil to be removed from agricultural land and used as fill to raise elevation elsewhere is between the first and second figures. Another significant absence is created by the lack of any response to this passage in the DEIR: "Section 4.14 Issues Addressed in the Initial Study -- 4.14.5 Geology and Soils Would the project: Result in substantial soil erosion or the loss of topsoil;" Of most concern about this proposal is the claim that removal of the top two feet of topsoil on class 1 farmland will have no effect on agricultural viability. In what follows we present testimony from a wide variety of sources to refute this assertion. Removal of Two Feet of Topsoil has Deleterious Effects on Agriculture and Ecology From National and International authorities: The National Resource Conservation Service of the U.S. Department of Agriculture on the loss of topsoil https://www.nrcs.usda.gov/lntertict/FSE DOCUMENTS/nrcsl42122 053285. d The loss of topsoil, either by actual removal with heavy equipment or erosion by wind and water, is the worst on-site damage in urban areas. This layer of soil has the highest biological activity, organic matter, and plant nutrients—all key components of healthy soil. The on-site loss of this upper layer of soil nearly eliminates the soil's natural ability to provide nutrients, regulate water flow, and combat pests and disease. Loss of nutrients and nutrient holding capacity, results in a less fertile environment for lawns and landscape plants. The organic matter and finer soil particles are responsible for soil fertility and are washed away first, leaving larger, less reactive particles such as sand and gravel. As organic matter is lost, soil density increases and compaction occurs. Compaction lowers the infiltration rate of water and reduces the available water holding capacity. This results in poorer growth of lawns, gardens, flowerbeds, shrubs, and trees, as well as making the site more susceptible to drought and requiring more frequent watering. Additionally, soil amendments such as fertilizer and pesticides cannot move into the soil and, instead, run off into nearby lakes and streams. Lower organic matter levels are also associated with weaker soil aggregates and therefore greater risk of further erosion and soil crusting. 8-60 The surface organic matter is also the food source and habitat for beneficial microorganisms and insects. The loss of this material drastically reduces the soils natural ability to control disease and pest outbreaks, increasing the need for pesticides. These microorganisms are also key to removing or buffering toxic elements or contaminants. The Food and Agriculture Organization of the United Nations (FAO). FAO Soils bulletin 50, "Soil erosion - its causes and cures." (b=://www.fao.orgLocrep/t0389e/t0389e00.htin) Soil teems with life All soil is full of life, and good soils are teeming with it. Plants and animals help keep the soil fertile. Plant roots tunnel through the soil and break it up, and decaying plants form humus. Burrowing animals mix the soil; the excrete of animals contribute nutrients and improve soil structure. Besides the soil's more obvious inhabitants, which include rodents, insects, mites, slugs and snails, spiders, and earthworms, there are countless microscopic residents, some helpful to man and his crops, some harmful. Good soils seem to hold the greatest populations of bacteria. Almost without exception, bacteria are involved in basic enzyme transformations that make possible the growth of higher plants, including our food crops. From man's point of view, bacteria may well be the most valuable of the life forms in soil. Chemical reactions occur in the soil as a result of exchange of positive ions, or cations. More exchanges take place in clay soils than in any other type. These chemical reactions are also essential to plant growth and development and are a good index of soil fertility. From Academic Technical Studies: Soil erosion and crop productivity: topsoil thickness (Integrated Crop Management News) http://www.ipm. iastate.edu/ipm/icm/2001 / 1-29-2001 /topsoilerosion. htm 1 Many studies have been conducted on the effect of depth of topsoil on corn yields in the Corn Belt states. Figure 1 (from Stallings, J.H. 1964. Phosphorus and water pollution. Journal of Soil Water and Conservation 22: 228-231) summarizes the relationship between topsoil depth and crop productivity. There is a direct relationship between topsoil depth and yield. The decline in yield with the reduction in topsoil depth can be related to A horizon thickness." Immediate effects of topsoil removal on crop productivity loss and its restoration with commercial fertilizers http://www.sciencedirect.com/science/article/pii/50167198798000919 Abstract: A field experiment was conducted on a Typic Cryoboroll (Site 1) and a Typic Cryoboralf (Site 2) in north -central Alberta, Canada, to determine the influence of simulated erosion (artificial topsoil removal) on loss in yield of hard -red spring wheat (Triticum aestivum L. cv. 'Roblin'), and to determine to which extent fertilizers N and P will restore the lost crop productivity of two artificially -eroded soils. There were three depths of topsoil removal (0, 10, and 20 cm) as main plot treatments, and a factorial combination of four levels of N (0, 50, 100, and 150 kg N hal) and three levels of P (0, 9, and 18 kg P ha -1) as sub -plot treatments. Wheat yields at both sites were markedly reduced by increasing depth of topsoil removal. The erosion effects 8-61 were more pronounced at Site 2 where average yield on the 20 cm cut decreased to less than half of that obtained under non -eroded conditions. At both sites, additions of fertilizer N and P to eroded soil increased wheat yield, but the yields did not match those obtained in non -eroded soil under the same fertilizer treatment. Plants growing on eroded soil responded differently to application of fertilizers N and P, not only in terms of yield but also in N and P concentration and uptake. The implication of these findings is that fertilization programs for fields with varying degree of erosion would require optimization of rates so as to restore yield and, at the same time, minimize nutrient losses (e.g., N leaching) and improve soil tilth. From local experts: John Phillips, Ph.D. Professor Emeritus of Crop Science Cal Poly While it may be true that the soil in the flood plain there is several feet deep, to assume that removal of 2.5 feet of the topsoil will have no adverse effect on crop production ignores the reality that the organic matter and the living organism component of the soil exists in a stratified manner, with aerobic organisms, bacteria, mycorrhizal fungi, actinomycetes, protozoa, nematodes, arthropods, and earthworms occupying the several inches near the soil surface. These creatures living in the soil are critical to soil health. They affect soil structure and therefore soil erosion and water availability. They can protect crops from pests and diseases. They are central to decomposition and nutrient cycling and therefore affect plant growth. Thus, this living component of soil contributes to agricultural productivity and air and water quality. The proposed grading at San Luis Ranch would eliminate the vast majority of this living component of the soil. Following the removal of 2.5 feet of topsoil, one could expect that at least a few years would be needed for the living component of the soil to regenerate, even with management specifically aimed at promoting soil health." Tim LaSalle, Ph.D. Former CEO of Rodale Institute The top foot of any topsoil has the most life, organic matter, and fertility because of the oxygen, microbiome, and vegetation that is deposited back." Rob Rutherford, Professor Emeritus, College of Agriculture Cal Poly ANYTIME we disturb topsoil - we increase the release of CO2. A massive movement of that portion of the soil which contains the most carbon (organic matter) will send a significant amount of greenhouse gases to the atmosphere - and that doesn't even count the emissions of the vehicles that are doing the earthwork." Previous Activity at the Calle Joaquin Agricultural Reserve to remove subsoil and replace topsoil has had deleterious effects on agriculture, requiring expensive remediation by the City. Removal of topsoil without replacement at San Luis Ranch would have more extensive and more serious effects. As detailed in the Agricultural Master Plan for the City of San Luis Obispo's Calle Joaquin Agricultural Reserve, 8-62 As part of the development plan for the McBride property, the 13 -acre open space portion was graded to avoid displacement of flood capacity. This was a City requirement imposed upon the project. This grading was performed in a manner that retained the top three feet of soil while removing approximately two feet of subsoil, and was done to retain a slope of 2% or less, 2% being the maximum slope considered acceptable for farming soils. Outcomes of that grading have since had two serious consequences. Pooling of water in the lower section of the fields in Winter 2015-2016 made farming impossible for several months for subtenants, Green Gold Organics, at City Farm and created a major factor for their terminating their lease and moving operations elsewhere. In an effort to remediate this condition on its property, the City of San Luis Obispo undertook the construction of a swale in order to drain pooled water away from the fields,improve its quality and conduct it toward Prefumo Creek, at a cost of $25,500. The success of this remediation effort remains to be seen. This example demonstrates the high environmental impact of changing the contours of agricultural fields in order to mine them for subsoil fill to raise the elevation of nearby land for the purpose of development. It does not take into account the much greater impact of using topsoil for that purpose, as proposed in the DEIR. 8-63 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 9 COMMENTER: Steven Marx, Central Coast Grown DATE: January 18, 2017 Response 9.1 The commenter notes that this letter provides a revised and enlarged comment from Central Coast Grown regarding the grading proposal described in the Draft EIR. The commenter’s original letter was submitted on January 5, 2017. This revised and enlarged letter replaces the original letter submitted by Central Coast Grown. Response 9.2 The commenter notes that this letter expresses the views of Central Coast Grown, which manages the City Farm San Luis Obispo (City Farm) under the terms of the 2011 Master Plan for the Calle Joaquin Agricultural Reserve. The commenter notes that City Farm is located adjacent to the San Luis Ranch Specific Plan Area, and that City Farm’s operations are directly impacted by the treatment of soil and water resources on the San Luis Ranch property. The commenter notes the terms of the Calle Joaquin Agricultural Reserve that would apply to the agricultural land on the San Luis Ranch property, if it is annexed into the City, which includes the City General Plan’s “50 percent preservation” requirement. The commenter notes that Central Coast Grown is opposed to the proposal to remove up to two feet of topsoil from up to 52 acres of the project site. The commenter states that they have suggestions and comments on this proposal to the Planning Commission, and states that they are disappointed that this proposal is reaffirmed in the Draft EIR. The commenter recommends that the project applicant offer alternative plans for providing fill to raise the elevation of portions of the project site and for addressing possible floodwater drainage and/or detention requirements that does not involve removal or disturbance of topsoil on portions of the property that are to remain in agricultural use. The project’s proposed grading and drainage plans are described in Section 2.0, Project Description. The project’s potential impacts to agricultural resources, including the project’s location adjacent to the City Farm are described in Section 4.2, Agricultural Resources. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site, a description of the proposed organic farming practices for future agricultural use of the site, and the anticipated long-term effects on soil microbial activity and agricultural productivity. The commenter’s recommendations will be forwarded to the appropriate decision-makers for review and consideration. Response 9.3 The commenter states that Central Coast Grown has requested alteration of the project’s cut and fill procedures at presentations to the Planning Commission, as well as changes intended to protect water resources and clarification of off-site mitigation proposals. The commenter notes that the Planning Commission hearing minutes reflect concerns about topsoil, drainage, and the source of fill soil from Commissioners. The commenter reiterates comments made to City Community Development Department staff recommending alteration of the project’s cut and fill procedures. The project’s proposed grading and drainage plans are described in Section 2.0, 8-64 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Project Description. The project’s potential impacts to agricultural resources are described in Section 4.2, Agricultural Resources. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site, a description of the proposed organic farming practices for future agricultural use of the site, and the anticipated long-term effects on soil microbial activity and agricultural productivity. The commenter’s recommendations will be forwarded to the appropriate decision-makers for review and consideration. Response 9.4 The commenter states that the project’s grading proposal does not adequately address the concerns expressed by Central Coast Grown staff. The commenter takes issue with the findings of the Agricultural Suitability Memorandum (Appendix C). The commenter states that the Agricultural Suitability Memorandum does not specify how much acreage will be affected and where on the project site it is to be located. The commenter refers to the Draft EIR description of the proposed cut and fill, and states that the removal of the described volume of topsoil is unacceptable. The commenter states that the Draft EIR fails to address the Initial Study checklist question “Would the project result in substantial soil erosion or the loss of topsoil?” in Section 4.14, Issues Addressed in the Initial Study. The project’s proposed grading and drainage plans are described in Section 2.0, Project Description. Figure 2-13 depicts the project grading plan. The project’s potential impacts to agricultural resources are described in Section 4.2, Agricultural Resources. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site, a description of the proposed organic farming practices for future agricultural use of the site, and the anticipated long-term effects on soil microbial activity and agricultural productivity. The text of Section 4.14, Issues Addressed in the Initial Study, has been revised to more clearly refer to the appropriate locations in the Draft EIR for discussion of potential impacts related to erosion and topsoil. Seismic and Groundshaking Hazards. The nearest fault mapped in the vicinity of the project site is the Los Osos Fault, which lies approximately 0.5 mile to the southwest of the project site. […] Grading and Topsoil. Refer to Section 4.8, Hydrology and Water Quality, for detailed discussion of potential impacts associated with erosion. Refer to Section 4.2, Agricultural Resources, for detailed discussion of potential impacts to topsoil. Response 9.5 The commenter states that Central Coast Grown rejects the applicant’s claim that the removal of the top two feet of topsoil would have no deleterious effects on agriculture and ecology. The commenter refers to the analysis in Impact AG-4 and the Agricultural Suitability Memorandum (Appendix C), and states that the evidence and arguments are based on antiquated and discredited science, and don’t account for the organic agricultural practices that are required once the land falls under a conservation easement. The commenter presents testimony from Cal Poly soil, science, crop science, and agriculture professors, as well as information from the Rodale Institute, the National Resource Conservation Service, the Food and Agriculture Organization of the United Nations, and academic technical studies that describe the role of soil organisms in agricultural topsoil for agricultural productivity. In addition, the testimony from Cal Poly professors Dr. Cristina Lazcano and Dr. John Phillips states that the removal of topsoil on the project site would eliminate soil organisms and impact agricultural activity until the soil 8-65 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo is able to regenerate the removed organisms. The project’s proposed grading and drainage plans are described in Section 2.0, Project Description. The project’s potential impacts to agricultural resources are described in Section 4.2, Agricultural Resources. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site, a description of the proposed organic farming practices for future agricultural use of the site, and the anticipated long-term effects on soil microbial activity and agricultural productivity. It should be noted that the quoted comments from Dr. Cristina Lazcano are identical to those raised in Letter 8, which are addressed in Responses 8.1 and 8.2. Response 9.6 The commenter states that the Draft EIR conclusion that on-site farmland would remain viable is ambiguous, and that the existing farmland is exceptionally productive, and maintaining viability and continuation of its present soil classification doesn’t fully account for the existing condition. The commenter states that the Agricultural Suitability Memorandum (Appendix C) assumes that viability after topsoil removal would be provided by substantial inputs of chemical fertilizer, which is inconsistent with the City’s current lease with Central Coast Grown for the City Farm property adjacent to the project site. The commenter states that the Agricultural Suitability Memorandum is unclear about the depth of the surface horizon of the soils on the project site, and that the Memorandum is ambiguous about whether the remaining agricultural area on the project site would continue to be farmed. The project’s proposed grading and drainage plans, as well as the Specific Plan’s commitment maintain a portion of the project site in active agricultural production, and to transition agricultural activity into organic (pesticide- and chemical-free) farming, are described in Section 2.0, Project Description. The project’s potential impacts to agricultural resources, including the project’s location adjacent to the City Farm are described in Section 4.2, Agricultural Resources. The Agricultural Suitability Memorandum discusses potential soil additions, including acidifying materials, calcium, nitrogen, and potash, but does not recommend or assume the use of soil additions. The Agricultural Suitability Memorandum describes the existing on site soil types, and notes the presence of nitrate and the pesticide DDE in existing topsoil. The Agricultural Suitability Memorandum describes cone penetration test (CPT) data that indicate clay and/or silty clay on the project site to a depth of over 5 feet. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site, a description of the proposed organic farming practices for future agricultural use of the site, and the anticipated long-term effects on soil microbial activity and agricultural productivity. Response 9.7 The commenter states that previous activity on the McBride property within the Calle Joaquin Agricultural Reserve to remove subsoil and replace topsoil has resulted in pooling of water in the lower section of the fields in winter 2015 – 2016, impacting agricultural productivity on that property, and requiring remediation by the City. The commenter states that removal of topsoil from the project site without replacement would have more extensive and more serious effects. The project’s proposed grading and drainage plans are described in Section 2.0, Project Description. As described, the agricultural area would remain within the 100-year flood plain. The upper end of the agricultural field would be lowered approximately two feet, and the site would be graded with a smooth field slope similar to the existing profile, which would convey water across the site similarly to the current condition, rather than detaining water in active 8-66 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo agricultural areas. The project’s potential impacts to agricultural resources are described in Section 4.2, Agricultural Resources. The project’s potential impacts associated with drainage and flooding are discussed in Section 4.8, Hydrology and Water Quality. Refer to Master Response 3 for a discussion of the proposed grading and drainage plans for the project site. Response 9.8 The commenter notes that the San Luis Ranch Specific Plan states that the project will maintain and promote San Luis Obispo’s agricultural heritage, and expresses hope that this principal will serve to guide the developer to avoid using agricultural topsoil as fill soil. The commenter’s recommendations will be forwarded to the appropriate decision-makers for review and consideration. 8-67 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 1 of 12  28 Jan 2017 Sent on 30 Jan 2017 via e-mail to the following persons: To: City of San Luis Obispo, Calif. c/o Brian Leveille, Community Development Dept. bleveille@slocity.org (805-781-7166 c/o City Clerk - Carrie Gallagher cgallagher@slocity.org (805) 781-7102 From: Michael C. Sullivan Mailing address: 9557 Coosa St., Ventura, CA 93004 Property address in San Luis Obispo: 1127 Seaward St., San Luis Obispo, CA 93405 (Property at 1127 Seaward St. is owned by the Walter E. Sullivan and Louise F. Sullivan Trust, Michael C. Sullivan, Trustee) Phone: 805-441-6981 (cell / text); Phone: 805-647-4101 (home message machine) E-mail: mcsgday@yahoo.com   COMMENTS OF MICHAEL C. SULLIVAN REGARDING DRAFT EIR - SAN LUIS RANCH PROJECT AND ANNEXATION TO THE CITY OF SAN LUIS OBISPO Abbreviations commonly used CEQA- California Environmental Quality Act DEIR - Draft Environmental Impact Report EIR - Environmental Impact Report SLO - San Luis Obispo SP - Specific Plan (for San Luis Ranch annexation) Summary of issues 1. Alternatives as presented in DEIR are not adequate for purposes of CEQA. REF: DEIR part 1 (Executive summary); DEIR part 2 (Project description); DEIR part 25 (Alternatives). The DEIR examines 4 alternatives: • Alternative 1: No Project, No Development • Alternative 2: No Project, Measure J Entitlements • Alternative 3: Historical Resource Preservation • Alternative 4: 50% On-Site Agriculture/Open Space The number of viable alternatives is insufficient, because according to the DEIR, at least two of them (ALTERNATIVE 1 and ALTERNATIVE 2) do not fit the City’s General Plan and therefore are infeasible. ALTERNATIVE 3 is the environmentally superior alternative. ALTERNATIVE 4 would 8-68 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 2 of 12  result in less residential and commercial development than the Specific Plan, and therefore it is likely that the City’s decision-makers would reject ALTERNATIVE 4 because it is not close enough to the goals and objectives of the Specific Plan currently adopted. Therefore, only one alternative, Alternative 3, remains feasible. This improperly limits the discussion of a broad enough range of feasible alternatives. I have proposed ALTERNATIVE 3A, which is discussed below. It should be reviewed and evaluated by the city, so that a reasonable number of feasible alternatives is considered and evaluated in comparison with the proposed Specific Plan. ISSUE # 1 1. Alternatives are not adequate for purposes of CEQA As required by Section 15126(d) of the State CEQA Guidelines, this EIR examines a range of reasonable alternatives to the project that could feasibly achieve similar objectives. The alternatives offered in the Draft EIR (DEIR) are insufficient. ALTERNATIVE 1- No project / No Development “Based on the comparison provided in Table 6-1, the No Project/No Development Alternative (Alternative 1) would result in the fewest adverse environmental effects. However, since this is the “No Project” alternative, CEQA requires that a separate alternative also be identified as the Environmentally Superior Alternative.” (DEIR at p. 6-22 through 6-23.) Comments on Alternative 1 The City of San Luis Obispo General Plan anticipates that this particular project site shall be developed under a Specific Plan as a regional mixed-use commercial center. Alternative 1 does not achieve that objective. Listing of this alternative does nothing to provide some alternative which could meet the City of San Luis Obispo General Plan goals for this project site as a mixed-use development. - “The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the Project (Section 15126.6).” DEIR, at p. 6-1, Alternatives. - “In defining feasibility of alternatives, the CEQA Guidelines state that “among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site” (Section 15126.6).” DEIR at p. 6-1, Alternatives. Because the No Project Alternative (Alternative 1) provides no economic viability for the project proponent, and because it does not attain the basic objectives of the project as envisioned by the proponent and the City, this alternative (Alternative 1) serves no useful purpose. ALTERNATIVE 2 - No Project, Measure J Entitlements 6.4.2 Alternative 2: No Project, Measure J Entitlements Description 8-69 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 3 of 12  “This alternative assumes that the San Luis Ranch Specific Plan is not adopted and that none of the proposed entitlements are implemented, including annexation to the City. Therefore, this alternative represents a project that would be processed by San Luis Obispo County, and considers what would be reasonably expected to occur in the foreseeable future based on current plans and consistency with available infrastructure and community services. There are existing entitlements on the project site for development in the County from the voter-approved initiative known as “Measure J,” which was passed in 2006 and upheld in 2009. The Measure J entitlements include 60 multi-family dwelling units, 560,000 square feet of regional commercial and outdoor sales areas, 198,000 square feet of office space, and a 150-room hotel and ancillary facilities. Because the Measure J entitlements would leave the project site under the jurisdiction of the County, but surrounded entirely by the City limit, these entitlements would also require the use of private water from onsite wells and an onsite wastewater treatment facility. Figure 6- 1 depicts the Measure J site plan and approximate development area of this alternative.” DEIR, p. 6-6 to 6-7. “Alternative 2 would fail to meet most of the project-specific objectives. As shown in Table 6-1, Alternative 2 would result in increased physical environmental impacts when compared to the project and would not achieve many of the planning goals included in the City’s General Plan as they apply to the San Luis Ranch Specific Plan area. “ DEIR at p. 6-22. Comments on Alternative 2. For the reasons below, Alternative 2 is not a reasonable alternative. - A part of the project description states, “The project is intended to be consistent with the development parameters described in the City’s Land Use and Circulation Element (LUE) (adopted in December 2014).” DEIR, Executive Summary, p. ES-1. Alternative 2 is not at all consistent with the development parameters described in the City’s LUE. The DEIR states, “Alternative 2 would fail to meet most of the project-specific objectives. As shown in Table 6-1, Alternative 2 would result in increased physical environmental impacts when compared to the project and would not achieve many of the planning goals included in the City’s General Plan as they apply to the San Luis Ranch Specific Plan area.” DEIR, p. 6-22. - The Alternative section of the DEIR states, “Since this alternative (Alternative 2) assumes that the project site would be developed under an existing entitlement, this alternative would not require environmental review under CEQA.” That is not necessarily true or valid. It has been 7 years since Measure J entitlements were approved by voters. In the interim, there have been significant changes with baseline conditions, such as traffic, housing, new developments, etc. - Furthermore, Measure J as it stands remains inconsistent with the General Plan of the County of San Luis Obispo, because Measure J exempts itself from the normal constraints of the County’s General Plan. As far as I know, this particular legal point has not yet faced scrutiny in the courts. - It also remains uncertain whether the Local Agency formation Commission would allow such a project as described by Measure J, for example, because of the uncertainty of water supply and sewage treatment and traffic mitigation. - Alternative 2 is not feasible at all, because it is inconsistent with the existing General Plan Land Use Element of the City of San Luis Obispo in various ways. Such an alternative would leave the project site entirely in County jurisdiction, surrounded by the City of San Luis Obispo. This would be 8-70 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 4 of 12  inconsistent with the intention of the City of San Luis Obispo that this “island” should be annexed to the City, which is rationale for the San Luis Ranch project. Examples of inconsistencies of Alternative 2 with City of SLO General Plan: SLO City Land Use Element: (LUE) Approach to Planning (LUE at 1-19) San Luis Obispo should: 1. Choose its future, rather than let it happen. San Luis Obispo should be proactive in implementing its vision of the future, and should work with other agencies and institutions to create our desired mutual future. Inconsistency: Adoption of Alternative 2 interferes directly with the City implementing its own vision of the future. Instead, it would require adoption of a much different plan, proposed 7 years ago as a County initiative. Society and economy (LUE at p. 1-20) 34. Where appropriate, create compact, mixed-use neighborhoods that locate housing, jobs, recreation, and other daily needs in close proximity to one another, while protecting the quality of life in established neighborhoods. Inconsistency: Measure J does not provide the housing, open space, and mixed-use quality of the project site which is envisioned by the General Plan. Land-use Map. (LUE Map at p. 1-23) The existing Dalidio project site is already designated by the City as a Specific Plan area. See Sec. 8.1, below. Inconsistency: Alternative 2, if implemented, would permanently remove the possibility of a City-approved Specific Plan for this site. 1.1.2. Development Capacity and Services (LUE at p. 1-34) The City shall not designate more land for urban uses than its resources can be expected to support. Inconsistency: Because various characteristics of the Measure J proposal (e.g. traffic problems, growth- inducing impact, etc.) are not known (because no Initial Study, or Negative Declaration, or EIR has been prepared for that project), it is unknown if Alternative 2 can be handled within city constraints on development capacity and services. 1.5. Jobs/Housing Relationship (LUE at p. 1-34) The gap between housing demand (due to more jobs and college enrollment) and supply should not increase. Inconsistency: Apparently the City-proposed Specific Plan provides more housing than the Measure J plan. The Measure J plan would not satisfy the goal of improving the amount of housing as compared with the Specific Plan. 1.9.1. Agricultural Protection (LUE at p. 1-36) The City shall support preservation of economically viable agricultural operations and land within the urban reserve and city limits. The City should provide for the continuation of farming through steps such as provision of appropriate general plan designations and zoning. Inconsistency: Alternative 2 protects less agricultural land than the City-approved San Luis Ranch plan. 8.1. Specific Plan Areas (LUE at p. 1-82 and Figure 10 at p. 1-83) 8.1.1. Specific Plan / General Plan Amendment The City shall require the completion and approval of a specific plan and associated General Plan Amendment prior to annexation (if applicable) and development of land within an area designated as a Specific Plan Area on Figure 10. The required General Plan Amendment will modify the General Plan Land Use Diagram to reflect the land use diagram from the approved specific plan, based on the land uses listed under “Performance Standards” for each site. 8-71 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 5 of 12  Inconsistency: Alternative 2, if implemented, would permanently remove the possibility of a City-approved Specific Plan for this site which meets the unique standards of the City’s General Plan. 12. Implementation policies (LUE at p. 1-102) Inconsistency: If Alternative 2 is adopted, the City cannot fulfill certain critical implementation policies, such as Zoning Regulations, Subdivision Regulations, Community Design Guidelines, Public Planning, Environmental Review, etc. CONCLUSION: Because of these various constraints, above, and because of various inconsistencies of Alternative 2 with the City of San Luis Obispo General Plan, Alternative 2 is not a feasible or proper or legal or reasonable alternative, and so Alternative 2 must be discarded. ALTERNATIVE 3 - Historical Resource Preservation (See DEIR at p. 6-12, Fig. 6.2) “As described in DEIR Section 6.4.3, Alternative 3 would preserve the San Luis Ranch Complex, thereby avoiding the significant and unavoidable impact to historic resources identified for the project. This alternative would also reduce other potential environmental effects due to the preservation of the eucalyptus grove in the northwest portion of the project site along Madonna Road, and due to the reduced overall development footprint. As shown in Table 6-1, Alternative 3 would also result in reduced impacts to air quality, GHG emissions, noise, biological resources, land use/policy consistency, and hydrology and water quality, while resulting in slightly increased impacts to transportation (due to the loss of the proposed San Luis Ranch Way access route).” “Alternative 3 would also achieve the basic objectives of the project. This alternative would provide infill growth for the City, and would be generally consistent with the General Plan with the existing historic structures on the project site. A variety of housing opportunities would be available, including affordable housing opportunities. The multimodal transportation network would continue to provide accessibility via automobile, bicycle, and pedestrian amenities, including the Bob Jones Regional Trail. The alternative would be similar to the project in its adherence to sustainable development practices and design features. Therefore, Alternative 3 is identified as the environmentally superior alternative over other alternatives, as shown in Table 6-1.” Comments on Alternative 3. The City of SLO should look at the feasibility of a variant of Alternative 3, in which more of the land adjacent to Prefumo Creek and more of the eucalyptus grove in the northwest portion of the project site is protected by being undeveloped. My proposal, which I call ALTERNATIVE 3A, would eliminate a moderate amount of housing (50 units total), but otherwise the project would be nearly the same as it is in the Specific Plan. Such a new alternative (“Alternative 3A”) is proposed by me and discussed below under “OTHER FEASIBLE ALTERNATIVES.” Alternative 4: 50% On-Site Agriculture/Open Space (See Fig. 6-3) The DEIR states: Alternative 4 would retain 50 percent of the net site acreage as on-site agricultural and open space uses to be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f. This alternative would retain the portion of land designated for commercial uses (NC) southeast of Froom Ranch Way and southwest of Prado Road in agriculture. This alternative would reduce the portion of the site available for residential and commercial development on the project site. 8-72 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 6 of 12  Comments on Alternative 4: It is likely that the City of SLO would consider Alternative 4 infeasible, because it does not include the same land use plan as envisioned for the Specific Plan. Therefore Alternative is not a viable alternative for purposes of CEQA. OTHER FEASIBLE ALTERNATIVES Additional “Alternative 3A” - Proposed herein by Michael Sullivan in response to this Draft EIR for San Luis Ranch Alternative 3 A as proposed by me would be nearly identical to the Specific Plan, but would remove 50 housing units, as shown in the table below, “TABLE 01 - Compare “ALTERNATIVE 3A” with Specific Plan as proposed in DEIR, Table 2-1.” Extra open space could be added to the Specific Plan, as a result of this reduction in housing. I propose that this extra open space (additional 2.6 acres, yielding 6.0 acres total of open space) could be used in a widening of the parkway along the east bank of Prefumo Creek, from Madonna Road to Froom Ranch Road, to include a widening of some of the open space area within the eucalyptus grove and habitat area, as envisioned in DEIR part 25, Fig. Fig. 6-1 (Measure J plan). TABLE 01 - Compare “ALTERNATIVE 3A” with Specific Plan as proposed in DEIR, Table 2-1 LAND USE TYPE (See DEIR, Fig. 2-4, Fig. 2-5, Fig. 2-6, and Table 2- 1) Specific Plan >>>>> Specific Plan ZONE Specific Plan >>>>> UNITS Specific Plan >>>>> ACREAGE ALT. PLAN 3A Specific Plan ZONE ALT. PLAN 3A UNITS ALT. PLAN 3A APPROX. ACREAGE REQUIRED Net gain of usable acreage Low- medium density residential (Medium density SFR, as in Fig. 2-6) NG-10 200 16.0 acres Density = 0.08 Acres / unit) = 3484 sq ft / unit NG-10 170 13.6 acres 16.0 - 13.6. = 2.4 acres for NG-10 Medium- density residential (Medium- high density SFR, as in Fig. 2-6) NG-23 100 6.8 acres Density = 0.068 acres / unit = 2962 sq ft / unit NG-23 100 6.8 acres High- density residential (MFR, and NG-30 200 10.4 acres Density = 0.052 acres / NG-30 180 Pertains to MFR land, adjacent to 9.36 acres 10.4 - 9.36 = +1.0 8-73 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 7 of 12  TABLE 01 - Compare “ALTERNATIVE 3A” with Specific Plan as proposed in DEIR, Table 2-1 LAND USE TYPE (See DEIR, Fig. 2-4, Fig. 2-5, Fig. 2-6, and Table 2- 1) Specific Plan >>>>> Specific Plan ZONE Specific Plan >>>>> UNITS Specific Plan >>>>> ACREAGE ALT. PLAN 3A Specific Plan ZONE ALT. PLAN 3A UNITS ALT. PLAN 3A APPROX. ACREAGE REQUIRED Net gain of usable acreage High Density MFR, as in Fig. 2-6) unit = 2265 sq ft / unit Madonna Road and Prefumo Creek ) acre for NG-30 Affordable housing density bonus 80 n/a 80 Commercial (NC) NC up to 150,000 SF 9.7 acres NC up to 150,000 SF 9.7 acres Office NC up to 150,000 SF 3.9 acres NC up to 150,000 SF 3.9 acres Hotel and conference center NC 200 rooms 3.6 acres NC 200 rooms 3.6 acres Public parks 3.4 acres 6.0 acres +2.6 acres Regional and local roads 8.1 acres 8.1 acres Local roads 9.4 acres 9.4 acres Agriculture and open space Agriculture A 52.7 acres 52.7 acres Internal open spaces P/OS 7.4 acres P / OS 7.4 + 3.4 = 10.0 acres Total 3.4 add’l. acres for P / OS 8-74 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 8 of 12  Advantages of “ALTERNATIVE 3A” 1. ALTERNATIVE 3A retains all the features of the proposed Specific Plan except for a modest reduction of 50 housing units. 2. Larger corridor of available space (a net gain of 2.6 acres) for protection of park / open space. This extra land could be used for - Better protection of biological resources / habitat / wildlife corridor along the eastern bank of Prefumo Creek and extending into the eucalyptus grove nearby which is in need of protection for bird nesting sites, wildlife corridor, etc. - A larger area for human recreation uses or open spaces uses such as strolling, sitting, bird- watching, etc. - More area available for on-site flood detention - Alternative 3A would provide about 6.0 acres of park land, ant that meets the standards of the General Plan. See: Land Use Element Policy 8.1.4. (SP-2, San Luis Ranch (Dalidio) Specific Plan Area). 3. ALTERNATIVE 3A has environmental advantages similar to those in ALTERNATIVE 3: Alternative 3A would reduce other potential environmental effects because a reduction in the footprint of Multi-family Residential use in the northwest corner of the project site (i.e. adjacent to Madonna Road and Prefumo Creek) would allow more preservation of the eucalyptus grove in the northwest portion of the project site along Madonna Road, and reduced overall development footprint. Because of a reduced number of residential units, Alternative 3A would likely have benefits similar to those of Alternative 3, i.e. reduced impacts to air quality, GHG emissions, noise, biological resources, land use/policy consistency, and hydrology and water quality. In Alternative 3A, San Luis Ranch Way access route would remain. In Alternative 3A, as in the approved Specific Plan, some of the historic Dalidio ranch buildings would be moved to the other site near the agriculture use area. “..... Alternative 3 would provide the same amount of parkland as the project – 3.4 acres– which is lower than the minimum of 5.8 acres required by the performance standards described in Land Use Element Policy 8.1.4. (SP-2, San Luis Ranch (Dalidio) Specific Plan Area). As a result, Alternative 3 would be similarly inconsistent with this policy in the City’s General Plan.” DEIR at p. 6-13. In contrast, proposed ALTERNATIVE 3A would provide about 6.0 acres of on-site public park area, which meets the performance standards of minimum parks area of Land Use Element Policy 8.1.4. (SP-2, San Luis Ranch (Dalidio) Specific Plan Area). Overall, Alternative 3A could result in fewer General Plan policy inconsistencies when compared to the project. As discussed below, Alternative 3A could have somewhat smaller environmental problems compared to the Specific Plan. Alternative 3A could provide potential decrease in severity of certain impacts such as: - Improved Air quality (because of the reduction in number of housing units by 50 total units) - Better conformance with General Plan Land Use element part 1.10.4. Design Standards (because of preservation of more of the land adjacent to Prefumo Creek and land in the existing eucalyptus grove near there): 8-75 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 9 of 12  “The City shall require cluster development to: A. Be screened from public views by land forms or vegetation... C. Prohibit building sites and roads within stream corridors and other wetlands, on ridge lines, rock outcrops, or visually prominent or steep hillsides, or other sensitive habitats or unique resources as defined in the Conservation and Open Space Element.” LUE 1.10.4. - Better conformance with General Plan Land Use Element requirements for internal open space (because ALTERNATIVE 3A provides an additional 3.4 acres for P/OS (parks / open space), i.e. total of 10.0 acres for P/O (parks/open space) which could be applied to widen the strip of P/OS land adjacent to the east side of Prefumo Creek from Madonna Road to Froom Ranch Way. ALTERNATIVE 3A would have an open space plan similar to that in Figure 6-1 (DEIR at p. 6-8) shows the open space / park plan in the strip of land adjacent to the east side of Prefumo Creek, with added open space land within the eucalyptus grove. The San Luis Ranch Draft EIR states, “the project includes a commitment to procure an off-site agricultural conservation easement/deed restriction such that one half of total land on-site is preserved for agricultural and open space use. In addition, the project would provide restored and enhanced wildlife habitat areas.” DEIR at p. 4.9-11, Table 4.9-1. - If the additional on-site 3.4 acres of P/OS (parks/open space) land of ALTERNATIVE 3A were available, less dedication of off-site land would be needed. Problems in the Project Design 1. Insufficient parks/open space (P/OS) area (7.4 acres total). Public parks: 3.4 acres within P/OS areas. As shown on Figure 2-6, the proposed open space would be located on the northwestern portion of the project site along Prefumo Creek, as well as along Cerro San Luis Channel, which is a permanent surface drainage that traverses the property from east to west. The open space areas would also include a link in the Bob Jones Regional Trail. (Where is that Bob Jones Trail link shown on Figure 2.6? Is it the strip of green at the northeast side of the commercial area in the north part of the site?) DEIR Figure 2-4 shows proposed types of land use at the project site. The largest NC area (north part of the site) shows a P/OS strip of land (about 40 or 50 feet wide, based on Fig. 2-9, northeast of that NC area, adjacent to Dalidio Drive. That strip of land should not be counted as P/OS (park / open space)_area because it is merely a very narrow strip squeezed between a busy street and the commercial use. It is actually more of a landscaped frontage and not a true park / open space. It should remain landscaped, but it should not be counted as P/OS area. That is deceptive. Instead, the P/OS strip adjacent to Prefumo Creek / Oceanaire Drive should be widened to better provide P/OS area that serves several important functions: (a) Preservation of a wider buffer between the existing residences (Oceanaire Drive) and the residential NG-30 and NG-10 uses. A wider buffer of P/OS adjacent to Prefumo Creek / Oceanaire residences can provide: (a) larger wildlife corridor and habitat area, (b) less intrusion of development on bird nesting areas in the eucalyptus forest area, (c) larger area for pedestrian uses e.g. sitting, strolling, enjoying the creek, for people living in the various residential use areas on the project site as well as for people living in nearby residential neighborhoods outside of the project site, (d) a more pleasing visual border, and more feeling of open-ness, 8-76 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 10 of 12  (e) a wider creek floodplain area, yielding better flood control protection of adjacent on-site residences 2. No P/OS buffer between residential use (medium high-density SFR) and commercial use. (DEIR, Fig. 2-6). A P/OS buffer between these uses, even if relatively narrow, greatly enhances the living experiences for the residential use. Alternative 3A would enhance the achievement of the following parts of the Land Use Element of the General Plan: SLO City Gen Plan - Land Use element 6.6. Creeks Wetlands, and Flooding Policies San Luis Obispo's aquatic ecosystems consist of creeks, Laguna Lake, floodplains, marshes, wetlands, serpentine seeps, and springs. These aquatic ecosystems provide habitat, recreation, water purification, groundwater recharge, and soil production as well as natural flood protection by reducing the force of floodwaters as they spread and decelerate over floodplains. Creeks, which are the most obvious of these systems because they flow under and through the City, provide wildlife habitat, backyard retreats, and viewing and hiking pleasures, in addition to carrying storm water runoff. When some creeks overflow during major storms, they flood wide areas beyond their channels (Figure 8). San Luis Obispo wants to avoid injury or substantial property losses from flooding, while keeping or improving the creeks' natural character, scenic appearance, recreational value, and fish and wildlife habitat. 6.6.1. Creek and Wetlands Management Objectives The City shall manage its lake, creeks, wetlands, floodplains, and associated wetlands to achieve the multiple objectives of: A. Maintaining and restoring natural conditions and fish and wildlife habitat; B. Preventing loss of life and minimizing property damage from flooding; C. Providing recreational opportunities which are compatible with fish and wildlife habitat, flood protection, and use of adjacent private properties. D. Recognizing and distinguishing between those sections of creeks and Laguna Lake which are in urbanized areas, such as the Downtown core, and sections which are in largely natural areas. Those sections already heavily impacted by urban development and activity may be appropriate for multiple use whereas creeks and lakeshore in a more natural state shall be managed for maximized ecological value. 6.6.2. Citywide Network The City shall include the lake, creeks, and wetlands as part of a citywide and regional network of open space, parks, and – where appropriate – trails, all fostering understanding, enjoyment, and protection of the natural landscape and wildlife. 6.6.6. Development Requirements The City shall require project designs that minimize drainage concentrations and impervious coverage. Floodplain areas should be avoided and, where feasible, any channelization shall be designed to provide the appearance of a natural water course. 8-77 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 11 of 12  2. The Specific Plan lacks a connection from the project site to Laguna Lake park that is safe for pedestrians and bicyclists. Two key intersections on Madonna Road (at Oceanaire Dr. and at Dalidio Dr.) provide access from the SP project site to the Laguna Lake park. However, both of these intersections will be heavily impacted with traffic because of the project. These very busy intersections would likely have long wait times for pedestrian crossing (at the signals). And, there is a danger to bicyclists at these two intersections, especially at dusk and night time and during rush hours (7 am - 8:30 am and 4:30 pm - 6:30 pm). The population size of residents living at San Luis Ranch SP are will be significant. People living there will want more outdoor recreational opportunities than those provided on-site. Many of these people will wish to use Laguna Lake park for various activities, e.g. hiking (in the park and beyond the park in the hills), walking the dog, canoeing, fishing, using the par course, playing outdoor games, bar- b-que, picnics, larger group activities, etc. Many of these activities are not possible within the Specific Plan site, so there will be a significant need for access to Laguna Lake park from the SP site. The City should consider the option of a pedestrian bridge, either at Oceanaire Dr., or at Dalidio Dr., crossing Madonna Road. The city should provide information about the probable cost of such a bridge and funding mechanisms, and who would be responsible for paying for it. 3. The Specific Plan does not consider the whole-city bicycle plan. What are the standards for bicycle paths from the Prado Road / US 101 intersection to Broad Street (via the Santa Margarita area and Damon Garcia Sports Fields?) As the Margarita Area and Airport Area planning areas are developed, there will be more of a need for bicycle connection between those areas and the San Luis Ranch residences and commercial areas. Damon Garcia Sports Fields also are an attraction for residents of San Luis Ranch. The best possible solution would be class 1 bike paths along the whole length of Prado Road, between Prado Rd. / US 101 intersection and Prado Rd. / Broad St. intersection. Is that being considered by the City? Would such a scheme be incorporated as part of conditions of approval of San Luis Ranch Specific Plan, or otherwise incorporated into the General Plan of SLO City? 4. The housing plan of the Specific Plan is not optimized for several issues: (a) Parking - For example, as discussed below, some of the single-family residential units have difficult series parking (2 cars parked head to tail) rather than parallel parking (2 cars parked parallel to each other. This makes it difficult to park. (b) Screening / buffers - Buffers and/or screening between certain residential uses and commercial uses are inadequate. For example, the single-family housing area adjacent to the commercial areas is directly adjacent. It could have at least a narrow strip of vegetation and/or fencing. (c) Amount of area for internal parks within the site. This is addressed in Alternative 3A, below. (d) Insufficient storage. Do the housing units with carports instead of garages have sufficient storage? Probably not. 8-78 2017‐01‐23_Comments_M_Sullivan_San_Luis_Ranch_DEIR_c Page 12 of 12  5. San Luis Ranch Specific Plan (including land use plan) is probably inconsistent with General Plan of City of San Luis Obispo for various reasons. A. Amount of required open space / agricultural land for Specific Plan is probably inconsistent with General Plan. The General Plan requires approximately 50 % open space / agricultural use for the San Luis Ranch Specific Plan site. It is my understanding that the original intent of the General Plan was that this 50% requirement applies to the whole site area (131 acres total) and not to a reduced area remaining after accounting for roadways, on-ramps, off-ramps, etc. This means about 65.5 acres would be required for agriculture / open space use at San Luis Ranch Specific Plan site. Therefore, apparently the amount of agriculture / open space in that plan is insufficient. If the proper standard for amount of agriculture / open space is not 65.5 acres (50% of the total 131 acres site area), but rather some smaller acreage based on a smaller computed net site acreage, what is the documentation for such an interpretation? Was such an interpretation officially approved by City Council action? Please explain. B. Housing affordability for “workforce” people - Is such housing as proposed truly affordable for workforce people? - How is “workforce” defined? What is their median and average income per person and per household assumed to be? How is this determined? - What are the assumptions of current (January 2017) housing costs for all types of housing in the SLO area, for comparison? Is there also comparison of housing costs in other nearby communities for comparison, e.g. Los Osos, Santa Margarita, Grover City, Oceano, etc.? - For condominium or other types of multi-family housing, or for single family housing areas: What Homeowner Association (HOA) Fees are anticipated? How is the Homeowners Association governed? What are the approximate anticipated monthly fees for HOA fees when the first units are completed? Is there any mechanism to regulate how rapidly the HOA fees may be increased from year to year? - What about “workforce” people who at the lowest end of the range of monthly gross income? Is there any chance they will also qualify for the affordable housing units? 8-79 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 10 COMMENTER: Michael Sullivan, Private Citizen DATE: January 28, 2017 Response 10.1 The commenter states that the alternatives evaluated in the Draft EIR are not adequate for CEQA on the basis that they are not consistent with the City’s General Plan, or that they may be rejected by City decision-makers. The commenter suggests consideration of an additional alternative. The Draft EIR discusses a reasonable range of alternatives to the project in Section 6.0, Alternatives. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. The commenter’s detailed comments regarding each of the alternatives included in the Draft EIR are discussed in Responses 10.2 through 10.5. The commenter’s recommended additional alternative is discussed in Responses 10.6 through 10.11. Response 10.2 The commenter states that the Draft EIR does not evaluate a reasonable range of alternatives. The commenter notes that the City of San Luis Obispo General Plan anticipates that the project site will be developed as a regional mixed-use commercial center, and states that Alternative 1 does not achieve that objective, and should not be considered as an alternative since it “provides no economic viability for the project proponent” and “serves no useful purpose.” Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. According to the State CEQA Guidelines §15126.6(e), and referenced in Section 6.0, Alternatives, a “no project” alternative must be evaluated to allow decision-makers to compare impacts of approving and not approving the proposed project. Refer also to Response 10.3 regarding Alternative 2, which addresses a regional mixed-use commercial center, and Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. Response 10.3 The commenter states that Alternative 2 (No Project, Measure J Entitlements) is inconsistent with the County of San Luis Obispo General Plan, and disagrees with the Draft EIR’s conclusion that the Measure J entitlements would not require environmental review under CEQA. Section 6.0, Alternatives, provides a brief summary of Measure J, which was passed in 2006 and upheld in 2009. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. Because Measure J represents an existing entitlement on the project site, it represents a feasible and reasonably foreseeable development outcome on the project site, if the City does not annex the site. In addition, because Measure J is a voter-approved measure, rather than a discretionary development, the associated entitlements did not require environmental review under CEQA at the time of the passage of the measure, nor would future development under these existing entitlements. Response 10.4 The commenter recommends a modification to Alternative 3, in which more of the land adjacent to Prefumo Creek and more of the eucalyptus grove in the northwest portion of the project site 8-80 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo remains undeveloped. Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. Additionally, CEQA requires that alternatives are selected for evaluation based on their ability to “avoid or substantially lessen any of the significant effects of the project.” Feasible mitigation is available to reduce project impacts related to Prefumo Creek and the eucalyptus grove to a less than significant level. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. Refer to Master Response 1 for a discussion of the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. In addition, the information provided by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 10.5 The commenter states that Alternative 4 is infeasible “because it does not use the same land use plan as envisioned for the Specific Plan.” The State CEQA Guidelines Section 15126.6 states that “among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” A reasonable range of alternatives was selected for evaluation based on the ability of each alternative to feasibly attain most of the basic objectives of the project, and to avoid or substantially lessen any of the significant effects of the project. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. Response 10.6 The commenter recommends a modification to Alternative 3 that would remove 50 housing units and increase open space in comparison to the project. The commenter states the assumption that the recommended alternative would reduce project environmental impacts, including air quality, General Plan consistency, and agricultural resources. The Draft EIR discusses a reasonable range of alternatives to the project in Section 6.0, Alternatives. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. In addition, the information provided by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 10.7 The commenter states that the project design does not include sufficient parks/open space area and suggests changes to the Specific Plan to expand parks/open space areas. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. The suggestions provided by the commenter will be forwarded to the appropriate decision- makers for review and consideration. In the event that any of the suggested changes are included in the Specific Plan, such changes would require evaluation for consistency with the analysis included in the Final EIR. Response 10.8 The commenter states that the Specific Plan does not include a safe pedestrian and bicycle connection between the Specific Plan Area and Laguna Lake Park and suggests that a 8-81 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo pedestrian bridge and the funding for a bridge be considered in the Specific Plan. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. The suggestions provided by the commenter will be forwarded to the appropriate decision- makers for review and consideration. In the event that any of the suggested changes are included in the Specific Plan, such changes would require evaluation for consistency with the analysis included in the Final EIR. Response 10.9 The commenter states that the Specific Plan does not consider the citywide bicycle plan. The commenter questions if bicycle connections between other current City projects are being considered and whether necessary connections will be incorporated into the Specific Plan or City’s General Plan. This comment pertains to the Specific Plan and City’s General Plan, which does not reflect on the adequacy or content of the Draft EIR. The questions raised by the commenter will be forwarded to the appropriate decision-makers for review and consideration. In the event that such considerations result in changes to the Specific Plan, changes would require evaluation for consistency with the analysis included in the Final EIR. Response 10.10 The commenter states the housing plan included in the Specific Plan is not optimized. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. This comment will be forwarded to the appropriate decision-makers for review and consideration. In the event that the comment results in changes to the Specific Plan, changes would require evaluation for consistency with the analysis included in the Final EIR. Response 10.11 The commenter states that the Specific Plan and land use plan included therein may be inconsistent with the City’s General Plan. The commenter states that potential inconsistencies are related to the City’s open space/agricultural land requirement and housing affordability. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. The information provided by the commenter will be forwarded to the appropriate decision-makers for review and consideration. In the event that this information results in changes to the Specific Plan, changes would require evaluation for consistency with the analysis included in the Final EIR. 8-82 From: Dennis Vavrek < Sent: Monday, January 23, 2017 2:37 PM To: Advisory Bodies Cc: Subject: San Luis Ranch / SLR Dear SLO Commissioners: Please approve SLR eir in this wed. meeting. Be reassured, The pros are deeply @ work on this one! CAUTION: Politics & Shelter makes for a wicked brew... bitterness.' Just a thought exercise : I sometimes wonder how different our Neighborhoods would function if, instead offirst pre -planning & then selling/leasing our Future Residencies as we now do, we might once in awhile try to first pre -sell/ -lease our Future Residencies & then plan the project ? The Product outcome might be more consumer relevant and of more commercial value; The Policy mandate might be more interesting & innovative; i.e., You get the abode you 'vote' for.' Like Amazon, like Uber, like, well, most modernly -trending consumer products/services. That would be a more 'organic' product -process to NeighborhoodBuilding. Maybe? Just a thought exercise . Meeting: t 1I - Item: 3 RECEIVED CITY OF SAN LUIS OBISPO JAN 2 3 2017 COMMUNITY DEVELOPMENT 8-83 Dennis Vavrek @ Dyabode® Sent from my Whone 8-84 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 11 COMMENTER: Dennis Vavrek, Private Citizen DATE: January 23, 2017 Response 11 The commenter expresses support for the project. This comment will be forwarded to the appropriate decision-makers for review and consideration. 8-85 Meeting: Itis From: James Lopes <item: Sent: Monday, January 23, 2017 2:38 PM To: Advisory Bodies Cc: E-mail Council Website Subject: PC communication - San Luis Ranch item Attachments: San Luis Ranch CC 4-1-14 Lopes PPT.pptx Dear Chairperson Stevenson and Commission Members: RE: San Luis Ranch project alternative RECEIVED CITY OF SAN LUIS OBISPO JAN 2 3 2017 COMMUNITY DEVELOPMENT At the last hearing, I promised to send you a project alternative which would save much more prime agricultural soil. Finally I am able to to that; please look over the attached slide show (PDF) and I'll be glad to discuss it with you on Wednesday. I used city planning estimates to show that about 500 residential units would be feasible in attached formats on only 30 percent of the property, saving 70 percent for farmland. As you know, attached residential units are essential to create enough units per acre to result in housing prices which are affordable to low-, moderate- and middle- (workforce) incomes. Just to remind you, at the last hearing I mentioned that the loss of prime agricultural soils is a Class I unmitigable impact, regardless of General Plan policies. Those policies are not "givens." They indicate minimums and discretionary maximums which were acceptable at the time of adoption. As we go forward with fewer and fewer resources, the conservation of prime agricultural soils is like putting cash in the bank. We need to have these assets to grow local foods; saving just half of this farmland is not enough. I ask you to fully review with staff and consultants, the alternatives for reducing the loss of farmland further. As a side note, the applicant may not choose to develop the commercial areas, instead subdividing and selling them to a wealthier developer. They could be developed more fully with mixed-use residential floors which would create the pedestrian -friendly environment for our housing needs. Lastly, the EIR should also include a deep study of the impacts of the commercial development on streets, roads and Highway 101, including especially the Prado Road interchange, comparing strictly commercial to my recommended mixed-use environments. Sincerely, James Lopes James Lopes 1336 Sweet Bay Lane San Luis Obispo, CA 93401 8-86 u C O0 C E- IV V ° 111 > > C T Y 1 '` Ln N v 0 a + c O L .. 4J 0 w ] . mo c a N O 10 ° 6 i W m O Q+ p 0 O Q 1 Q O a ON f 0 I N ti t V1 p T w OL Q G1 a m° Ea c N E N N i t0 E N E d o Qma c" c 0 LL r - I N V- 1 v O L W II N II ( Au 76 4 E o 2 0 T 9 m J S w d ei N ri L ^ U M (, .. IAA a u d N . N . ? 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This comment includes several slides as reference, depicting a reduced development area, in comparison to the project. Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. Response 12.2 The commenter states that the loss of prime agricultural soils should be described as an unmitigable impact, and that the applicable City General Plan policies should be interpreted as “minimums and discretionary maximums which were acceptable at the time of adoption.” The commenter recommends that the Final EIR consider alternatives for further reducing the loss of prime farmland. Refer to Master Response 1 for discussion of the adequacy of project alternatives evaluated in the Draft EIR. The project’s consistency with applicable General Plan policies is described in Section 4.9, Land Use/Policy Consistency, which indicates that the project would be consistent with General Plan policies related to protection of agricultural resources. As discussed therein, the City’s General Plan Land Use Element Policy 8.1.4.f, allows for agricultural preservation requirements for the San Luis Ranch Specific Plan project site to be met off-site at a “substantial multiplier.” Section 6.0, Alternatives, of the Draft EIR evaluates a project alternative (Alternative 4: 50% On-Site Agriculture/Open Space) that would retain 50 percent of the net site acreage as on-site agricultural and open space uses to be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f. As described in Section 6.0, Alternatives, Alternative 4 would retain the portion of land designated for commercial uses (NC) southeast of Froom Ranch Way and southwest of Prado Road in agriculture, which would preserve approximately 3.6 acres of additional on-site agricultural area in comparison to the proposed project. Because Alternative 4 would convert fewer acres of Prime agricultural land to non-agricultural uses, this alternative would have a reduced impact in comparison to the project. Response 12.3 The commenter states that the developer could potentially subdivide and sell the proposed commercial areas to a developer to be developed with more residential and mixed uses to satisfy the housing needs in the City. This comment is speculative, and does not pertain to the results of the environmental analysis in the Draft EIR. CEQA requires that an EIR consider both direct and indirect physical changes to the environment. CEQA §15064(d)(3) states that “an indirect physical change is to be considered only if that change is a reasonably foreseeable impact that may be caused by the project,” and notes that a change that is speculative or unlikely to occur is not reasonably foreseeable. This comment does not address the adequacy of 8-90 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo the Draft EIR. However, the commenter’s statement will be forwarded to the appropriate decision-makers for review and consideration. Response 12.4 The commenter states that the Draft EIR should also include a study of the impacts of the commercial development on local roadways and U.S. 101, including the Prado Road Overpass/Interchange, with a comparison of commercial uses to a more mixed-use focused development. Section 4.12, Transportation, discusses the project’s potential impacts associated with transportation and circulation, which includes impacts along Prado Road under existing and future conditions, and the potential overcrossing of Prado Road at U.S. 101. Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) evaluated all multimodal impacts on the roadways including Prado Road & U.S. 101 interchange, consistent with the requirements of CEQA and the City’s General Plan. The analysis is based on the approved site plan which involves a mix of residential and commercial uses, taking into account the amount of ‘internal,’ ‘pass-by,’ and ‘external’ trips related to the commercial developments fronting Dalidio Drive. Section 6.0, Alternatives, includes a comparison of the project’s identified traffic impacts for each of the evaluated project alternatives. Also, refer to Master Response 1 for discussion of the adequacy of project alternatives evaluated in the Draft EIR. 8-91 Bereman. Katelin From: James Lopes < Sent: Monday, January 23, 2017 2:55 PM To: Advisory Bodies Subject: PC communication Planning Commission RE: First Phase Impact - San Luis Ranch Dear Chairperson Stevenson and Commission: Meeting: t/ 1 - 1 vi - Item: RECEIVED CITY OF SAN LUIS OBISPO JAN 2 3 2017 COMMUNITY DEVELOPMENT The first phase of residential development is the large island of detached housing; the developer proposes access across the farmland to Dalidio Drive. This access road will cut off or make very difficult access between the two remaining farmed areas. It will be raised as a berm due to potential flooding, so tractors and operations will be hard-pressed to navigate crossings. It will create a Class I impact on the smaller agricultural area, perhaps forcing the farmer to abandon farming it. This first phase of residential may be the only one built soon or in the foreseeable future, since developer's fortunes and investments do change. The more feasible access alternative is to develop the bridge to extend Froom Ranch Way to this island. The alternative should be in the EIR. Sincerely, James Lopes James Lopes 1336 Sweet Bay Lane San Luis Obispo, CA 93401 8-92 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 13 COMMENTER: James Lopes, Private Citizen DATE: January 23, 2017 Response The commenter states that the Draft EIR should include an alternative featuring the extension of Froom Ranch Way and construction of the bridge across Froom Creek during the first phase of project development in order to accommodate access for agricultural vehicles to the undeveloped portions of the project site, in addition to the access on Dalidio Drive. Constructing the extension of Froom Ranch Way including the referenced bridge across the Froom Creek as part of Phase 1 is a mitigation measured required in the Draft EIR. Mitigation measures are provided for significant transportation and circulation impacts that are identified as part of the traffic impact analysis and are described in Section 4.12, Transportation. Table 4.12- 1 in Section 4.12, Transportation, lists the required transportation improvements measures required for the project to avoid and/or reduce potential on- and off-site traffic impacts. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. Access for agricultural vehicles will remain via Calle Joaquin and will provide adequate accommodation to the southernmost agricultural areas. Also, refer to Master Response 1 for discussion of the adequacy of project alternatives evaluated in the Draft EIR. 8-93 8-94 8-95 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 14 COMMENTER: Scott Morgan, Director, State Clearinghouse DATE: January 24, 2017 Response The commenter notes that the City of San Luis Obispo is in compliance with the State Clearinghouse review requirements for draft environmental documents, pursuant to CEQA. 8-96 From: Allan Cooper < Sent: Tuesday, January 24, 2017 12:58 PM To: Scott, Shawna; Advisory Bodies Subject: 3777 Orcutt Road and 1035 Madonna Road Attachments: 701 _24_ 17...3777orcutt.pdf Meetina: 'PU Itis Item: „ 3 RECEIVED CITY OF SAN LUIS OBISPO JAN 2 4 2017 Dear Shawna & John — COMMUNITY DEVELOPMENT Would you insure that the letter from David Brodie and attached below is received by the Planning Commission in time for tomorrow's meeting? David does not have access to the internet and is relying on me as his intermediary. Thanks! Allan 8-97 To: SLO Planning Commission Re: Removal of Mature Trees From: David Brodie Date: January 25, 2017 1 would like to protest the removal of groves of trees at 3777 Orcutt Road and 1035 Madonna Road to make way for development. As of two nights ago when I spoke to my relatives who are climate change scientists and BBC film producers stationed in Antarctica, they said summer weather conditions there are the worst that they have encountered. Winds are especially horrendous and dangerous. The weather is completely unpredictable all owing to our rapidly changing climate. Their advice regarding 3777 Orcutt Road and 1035 Madonna Road is that it would be madness" to remove these established trees. A prolonged period of time is required to nurture replacement trees. It is impossible to predict if these replacements will survive climate change. Drought tolerant, pest free trees such as eucalyptus are irreplaceable carbon sequesters and invaluable habitats for butterflies and egrets. In their opinion, all mature trees should be protected and preserved. Thank you! 8-98 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 15 COMMENTER: David Brodie, Private Citizen (comment letter forwarded by Allan Cooper) DATE: January 24, 2017 Response The commenter states that they oppose the removal of trees on the project site, and that drought tolerant, pest-free trees such as the eucalyptus sequester carbon and provide habitats for butterflies and egrets. The commenter states that all mature trees should be protected and preserved. Refer to Response 6.2 for a discussion of the project’s biological impacts related to eucalyptus tree removal. Section 4.6, Greenhouse Gas Emissions, discusses the project’s impacts related to greenhouse gas emissions and climate change. As described in the State CEQA Guidelines, the significance of GHG emissions may be evaluated based on consistency with a regional GHG reduction plan, such as the City’s adopted Climate Action Plan. The Climate Action Plan includes Measure PKS-2, which establishes a goal to develop and acquire parks and open space resources. As discussed in Impact GHG-1, the project would be consistent with applicable measures in the City’s Climate Action Plan. Specifically, the project would be consistent with Measure PKS-2 because it provides public parks and open space, enhancing the Prefumo Creek corridor. Although the project would remove mature trees, which would reduce existing carbon sequestration on the project site, Mitigation Measure BIO-2(b) requires the project to replace impacted riparian trees, and Mitigation Measure BIO-1(f) requires the project to replace eucalyptus trees as they senesce with native species. Compliance with these mitigation measures would further reduce the project’s impact related to GHG emissions and climate change, by offsetting the project’s effect on existing carbon sequestration rates on-site. 8-99 meeting: RECEIVED em: CITY OF SAN LUIS OBISPO Cox, Rebecca From: carolyn smith < Sent: Wednesday, January 25, 2017 10:18 AM COMMUNITY DEVELOPMENT To: Advisory Bodies Subject: Planning Commission - 01/25/17 - San Luis Ranch Draft EIR Input Chair Stevenson and Commissioners, I have lived in the Laguna Lake area for 37 years. I am very concerned about the multiple large projects being proposed in the southern portion of the city which now include: Avila Ranch, San Luis Ranch, and, soon to be before you, John Madonna's Senior Complex plus an additional 275 residential units off of LOVR adjacent to Home Depot. If you look at all three of these projects in a vacuum, you will miss the cumulative effect on traffic, air, and loss of ag land that these large projects will create. While the individual Draft EIR's explain each individual project's significant unavoidable impacts (which are very similar), what they don't do is consider the total effect of the two or even the three projects. I realize the Madonna Senior complex Draft EIR is not before you at this time but since it is going through the city process, I believe it should be considered (if nothing else in the back of your mind) when you are reviewing and discussing the traffic and air quality impacts from San Luis Ranch and Avila Ranch. Since San Luis Ranch proposes to place all of the traffic for the first phase of it's project onto LOVR, the Madonna project should be considered in terms of how it will affect traffic on LOVR. Our city has prided itself in our air quality, even going as far as banning drive-through restaurants and banks due to its negative impacts from idling vehicles. As part of the mitigation methods to the horrendous traffic impacts from these two projects, it is being proposed that longer queue lines be added for turning left and right at numerous negatively affected intersections. This will result in vehicles idling for longer periods of time while they wait through several light cycles to get through the numerous heavily impacted intersections. This flies in the face of our long term city goal of reducing our carbon emissions. We have banned smoking in public areas, plastic bags, Styrofoam containers, and soon plastic bottles at public functions. We are promoting solar panels, water saving plumbing features, insulated glass and other energy saving building materials on new construction, all in an effort toward reducing our energy consumption. Yet, this project, as Avila Ranch, will produce enough traffic to cause violation of the Clean Air Act. How does this fit into our city's goal of reducing our carbon footprint? Allowing these two projects to be built will cause carbon emissions that are harmful to residents' health. Therefore, reviewing the Draft EIR for each of these projects in a vacuum will be a disservice to existing residents, particularly in the southern area of the city, and destroy their quality of life. Further, I am very troubled that our City has over -ruled our County Airport Land Use Plan (ALUP). As noted in the Draft EIR, this project is being proposed to be built pursuant to the California Airport Land Use Planning Handbook (CALUPH) which provides for different safety zone designation and density than the current ALUP. The City (using a paid consultant whose report is disputed by Cal Trans and the Airport Land Use Commission) made up safety zones based on the CALUPH which, according to airport commissioners with whom I have spoken, is primarily used in most cities as a baseline in determining safety zones. The local Airport Commissions (when there is one in place) or area experts when there is no commission, then use the topography, weather, and other conditions to create safety zones based on the unique conditions to the area. As the Draft EIR indicates, there 8-100 have been three accidents in the vicinity of this project, and in 1994, a jet crashed in the area --now vacant ag land --where this project proposes to build housing, killing four people on the plane. My husband, a firefighter at that time, responded to this crash and aircraft debris was strewn for hundreds of yards from the crash site. He believes that if there had been homes in the area, there would have been significant injuries, loss of life, and property damage. While the other aircraft accidents were not directly on this project site, they were under the same flight path and not far from this project. History tells us it's just a matter of time before there will be another aircraft crash -- particularly since the airport is expanding. Three historic accidents on and in proximity of this proposed project should be considered a significant unavoidable impact. It is not designated as such in the Draft EIR since it is not looking at this project site realistically but through the vision of the City's development driven LUCE. The LUCE Committee itself did not over -rule the ALUP, despite being urged to do so. I believe they didn't because they didn't want to be responsible when there is a significant loss of life from a crash at this project site. The City didn't seem to be concerned about it and at one point I heard a city staff member say, "accidents happen." I wonder if that city staff member (or his children) would live in this project and gamble on there not being another crash in the future. I believe the City's frantic desire to build more housing is ignoring significant dangers and this is definitely a significant one. The Draft EIR is utilizing the city's irresponsible gambling of human lives to minimize this danger. I hope you will not allow that and request that the Draft EIR include a scenario of potential loss of lives and property when there is another crash at the site of this project after the proposed build out. Please note that the Airport Land Use Commission has not yet made a conformity determination on this project. Thank you for your consideration. Carolyn Smith SLO City resident 8-101 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 16 COMMENTER: Carolyn Smith, Private Citizen DATE: January 25, 2017 Response 16.1 The commenter states that the Draft EIR does not consider the cumulative effects of the project in combination with other large projects (e.g., Avila Ranch and Madonna Senior Complex) proposed in the City. Specifically, the commenter expresses concern regarding the cumulative impacts to traffic, air quality, and agricultural land as a result of these projects. As described in Section 3.0, Environmental Setting, in order to assess cumulative impacts, the Draft EIR uses the General Plan projection method that considers projects and programs included in the City’s General Plan Land Use and Circulation Elements. This approach is based on City-wide cumulative projections that establish conditions that would exist due to the build-out of the City’s General Plan. Table 3-1 in the Draft EIR shows the buildout potential future development in the Land Use Element Planning Subarea as envisioned by the Land Use Element (including the San Luis Ranch Specific Plan area) and includes the ‘Madonna Site on Los Osos Valley Road’ and ‘Avila Ranch’ as potential development areas in the City. As such, the analysis of cumulative impacts in Section 4.2, Agricultural Resources, Section 4.3, Air Quality, and Section 4.12, Transportation, of the Draft EIR evaluates the existing, near term, and cumulative effects of the project in combination with other large projects in the City, consistent with State CEQA Guidelines. Impacts to traffic and air quality are considered with Avila Ranch constructed in the Near Term conditions in addition to other approved projects, as depicted in Figure 9 of Appendix L, and the John Madonna Senior Complex project is considered under cumulative conditions based on the City’s General Plan buildout as included in the City’s Travel Demand Model. No revisions to the Draft EIR are required in response to this comment. Response 16.2 The commenter states that mitigation requiring longer queue lanes at City intersections conflicts with the City’s effort to reduce carbon emissions, and would result in vehicle emissions that would violate the Clean Air Act. The commenter states that the project’s carbon emissions, in combination with vehicle emissions associated with the Avila Ranch Project, would be harmful to residents’ health and states that each project’s impact should not be considered in a vacuum. The analysis of air quality impacts in Section 4.3, Air Quality, relies on the procedures, guidance, and thresholds provided by the San Luis Obispo County Air Pollution Control District (SLOAPCD), which is the lead air quality regulatory agency for San Luis Obispo County and is responsible for implementing the programs and regulations required by the Federal and State Clean Air Acts through its Clean Air Plan. Impact AQ-1 acknowledges that impacts related to consistency with the SLOAPCD 2001 Clean Air Plan would be significant and unavoidable. This conclusion is based on the fact that the project would result in an increase in vehicle miles traveled (VMT) that would exceed the rate of population growth in the City. As noted in Response 25.1, SLOAPCD has subsequently recommended that the project be considered consistent with the 2001 Clean Air Plan, with incorporation of the mitigation included in the Draft EIR for air quality impacts, which includes provisions to encourage telecommuting, fugitive dust control measures, emissions control measures for construction equipment, operational emission reduction measures from the SLOAPCD CEQA Air Quality Handbook, and 8-102 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo off-site mitigation requirements. Nonetheless, in order to provide a conservative evaluation of the project’s potential regional air quality impact, the Final EIR acknowledges a significant and unavoidable impact related to Clean Air Plan consistency and decision-makers would need to adopt a Statement of Overriding Considerations setting forth why the project’s benefits outweigh this impact, if the project is to be approved. Impact AQ-4 in Section 4.3, Air Quality, addresses the potential health impact related to locating residences in the vicinity of high volume roadways. As described therein, the Draft EIR determined that the project would not expose sensitive receptors to substantial pollutant concentrations and, thus, would not result in health risks associated with such pollutants. With regard to the project’s carbon emissions, as discussed under Impact GHG-1 in Section 4.6, Greenhouse Gas Emissions, the project would be consistent with applicable measures in the City’s Climate Action Plan. As a result, the project’s contribution to cumulative levels of GHGs would not be cumulatively significant. Response 16.3 The commenter notes that the project site is the location of a historic aircraft crash site, and near other crash sites, and that airport operations would pose a safety hazard to future occupants of the site. The commenter requests that the Draft EIR evaluate potential loss of lives and property associated with aircraft accidents on the site upon project buildout. The discussion of Impact HAZ-8 in Section 4.7, Hazards and Hazardous Materials, describes the history of aircraft accidents on the project site, the potential aircraft hazards to development on the project site, and standards included in the proposed San Luis Ranch Specific Plan which would be implemented throughout the Specific Plan Area to avoid or minimize potential airport hazards. Airport- related standards described in the Specific Plan are intended to reduce risk of injury, provide for airspace protection, reduce airport operations interference, prohibit bird attractants, avoid nuisance indoor noise, provide for County avigation easements, provide for disclosure of aircraft operations to prospective buyers and renters, and prohibit use of glare-producing building materials. In addition, the City Council found during its review of airport compatibility for the General Plan Land Use and Circulation Element update that the 2014 Airport Land Use Compatibility Report and revised Land Use and Circulation Elements (LUCE) Update EIR provided substantial evidence in the record that the City’s Land Use Element accurately reflects Airport-related safety hazard zones as set forth in the California Airport Land Use Planning Handbook (CALUPH; 2011) and supporting federal guidance, and that the maps provided in the ALUP did not accurately reflect the actual extent of Airport-related safety zones. As such, the analysis of aircraft accident hazards in the Draft EIR with respect to CALUPH Airport Safety Zones, which the City has found represent the actual extent of Airport- related safety hazard zones, has been determined appropriate. As such, the Draft EIR has adequately evaluated the potential hazards associated with aircraft accidents on the project site, and no revisions to the Draft EIR are required. In addition, in a hearing on April 19, 2017, the San Luis Obispo Airport Land Use Commission determined that the project, with minor modifications, is consistent with the ALUP based on specific findings and subject to conditions set forth in the staff report for the hearing. 8-103 1N3 WdOl3A301.11N(1WWOO Meeting: P Cox, Rebecca 60Z 5 Z NVf 4-- OdS190 SIM N From: Joe E. G, rime Sent: Wednesday, January 25, 2017 2:10 PM To: Advisory Bodies Cc: Joe E. Grimes Subject: Re: Item #3, San Luis Ranch Draft EIR Attachments: PastedGraphic-1.png; Untitled attachment 00008.txt; scan.pdf To the San Luis Obispo Planning Commission January 25, 2017 Re: Item #3, San Luis Ranch Draft EIR The enclosed letter is relevant not only to the San Luis Ranch project, but to all projects in the City's pipeline of proposed developments. This includes Avila Ranch, John Madonna's Senior Complex and residential project, and all the developments along Tank Farm Road and the Orcutt Road area. The cumulative impact of these additional developments, when combined with the existing high pressure conditions on the City's limited circulation system, will cause intolerable traffic congestion on the city's major arteries. The quality of life that once existed in San Luis Obispo is being further threatened with all these projects, and will be lost forever if this excessive growth is not curtailed. If you have a problem reading the content of this email or have a question, please contact me. Sincerely, 1 8-104 Untitled attachment 00028 Joe Grimes Center for Teaching, Learning, and Technology California Polytechnic State University San Luis Obispo, CA 93407 Page 1 8-105 SATURDAY, JULY 8, 2 p o 6 THE TRIBUNE B7 VIEWPOINT County traffic planning means sta0' ying ahead of the curve By CFWll6b FELIX 0Ile of the many things that lake the !ail (alis Obispo area so spec-ial is the lack of traffic cont,estion. This is const evident arid ap- preciated after returning frons a trip to Los Angeles. Still terse car tuly other large nietro. politan area. While; it may ii£itbewssil)]c• to place a do]l,tr value Oil this, we know [lint i.n- Creased traffic- congesticin would severely impact oul• to cal lifestyle. This raises the cl[[estiotl of whether we a^an retain today's eonditious with all Of Pile &T- elopntextt ]le]ng proposed iii the county. As a retired traffic t:Ilgineer. Z tllo[rght rt might be worth- cal g(Werrillients try to sliaml<Zgcwhiletotrlkealookattheroletrafficgrowthisby controuilligttlatdevelopel7s. local govet-tl- the rite of tis vc lopinrtlt. As anmenuandcitizensplayintheciutttile, tilt rate of resicic:ntiaitrafficplatuiingatticdevelop- housinAgrrn•tll in min l lli; meet process. When a major project is pre Posed. the developer mlttit pre vide a traffic itilpad report that includes all analysis cif anyeffectsthelii-Ojcct may haveonlocal and regional Inaffic, if there is a llegalive inifulet, planning officials Bray' require that the developer provide ade. gttate nlitjgaliotis (roadway widening. traffic sagalals, etc.). lire traffic impact retwrt. along with the proposed nuti. gations, are thell subtilittc:d tothelocalgovernment. local agency :staff mem- bers review file proposed project and forward their analysis and reebulniendation to the planning sottlallission or electE' 1 officials iii addition to tl7P sibjm.dve analysis provides] by stuff. lo. - Cal goverluliclits also look at Whether or not particular £le. vc.lopinents:Ire consistel-it with goals Gild policies in the local Genets] Plan. which ]s a cotlrniullity's statement of its Priorities and it l vision for fu- ture growth. ne cif the prinariry wrgs ]o - obi lxi t tevIlOically finlited to 1 perce ni 1wr year. ivlzlil udning limits is diffi- cult, and exceptions' are often griped. pardy because local governments tire continuallypressurccltoaddressthe widening' trap lietweell rite ex stili&; Supply and dhc: tunnel need for housing and servic. its. There also is an incentive: for local governments to ap. Prove dmeloprnews to IInlitl. tain a viable revenue stream d wollkh increased prupertwytalc(:"-, development fees andbusinesstaxis. However. there is a fiscal Catch -?2 that local govern. nlenis face when they imple- lent the trKMIC•related infra - Structure extlmisions needed 14) s[Ipport developulent roads, Traffic signals, sig Inag(". lighting, etc.). l tc'gl pI cijc I s are lytiicallyimplrinetltedeitherbyIdeal government', or, MOM often, by develotiers as Bart of re- quired project iilitigations. An often Overlooked aspect of lhls added infrastructure is that. Lance installed, local jurisdic,- tons are saddled with the 6s. cal rs"'ponsibility for their on. going repair and Ilaaintenance. In 46dit budget tillie% infra erilaintE'IianCe is typi- cally one of ills' first programs rut. reglill]ng is' more rapid dei. teriOration of the infrastrctN I r i rr.° and, when this deferral AlIts in premature fl?lilure, an r,w-c•rl greater fiscal impact bt, cause of replac-eitlent costs zinc] legal ]iabii[ly, SO. while the new infra. structure paid for by develop. erg "lav look like a gift. the tottg-tertn consequences are lx'Orif of that old adage there is no free lunch. Irl niy Upllll£an, the most im- twr ant participant ill this prof c ss is flee cituen. While ocal 1ccidents have the Wti. inate ccalltril over t.11c sclec- linin of their decision-Illakerci, Irony £lo not becolile involvedilltheplanningprocessuntil they, are affected by a particu- lar project. Change, like deadi and tax- es. is inevitable. flow,,,l-, to ensurer that all area retains those olixn[ctcristics that Mike it unique, residents ntlist learn how decisions are lade and how they can influ. Mee the process. Citirens can either br ac- tively involved ill critical deci- sions or leave tlleln to [level. Opeis and local officials. Many jurisdictions have their General Phu' and other planning documents available for review, either by going to Your local government center or by viewilig tiltni online. If You want to protect your wayOflife. you have to stay in. Mr -flied and involved- Charks I efir rsrlrks?d fi)r Pile crify of San Jo.se)&r 30 yeam As a senior t fit' engirrer;r; ire runs drrvulc,I'd tri development and ra- riieiv V &-7 billion airport master plan. Pte and his wVe, 1Varrs y, )nopPd 10 &,v ,rrfs obipeacvuwt nes. I r ! a y tuu years ter. 8-106 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 17 COMMENTER: Joe Grimes, California Polytechnic State University DATE: January 25, 2017 Response The commenter states that the cumulative effect of proposed development projects in the City, including the San Luis Ranch Project, would be intolerable traffic congestion on the City’s major transportation routes and threaten the quality of life in the City. The commenter provides a newspaper article titled County traffic planning means staying ahead of the curve, from The San Luis Obispo Tribune, dated July 8, 2006, which summarizes the role that developers, local governments, and citizens play in the traffic planning and development process. The commenter does not raise any specific concerns with the methods or conclusions of the Draft EIR traffic analysis or required mitigation. However, the commenter’s concern with the operation of the major transportation routes and quality of life in the City will be forwarded to the appropriate decision-makers for review and consideration. 8-107 RECEIVED CITY OF SAN LUIS OBISPO Cox, Rebecca From: Mila Vujovich-LaBarre < COMMUNITY DEVELOPMENT, Sent: Wednesday, January 25, 2017 2:02 PM To: Advisory Bodies; Lichtig, Katie; Harmon, Heidi; Gomez, Aaron; Pease, Andy; Christianson, Carlyn; Rivoire, Dan Subject: DEIR Comments - San Luis Ranch January 25, 2017 Meeting: PC,- 1-71 - 1 1 To: Planning Commission - City of San Luis Obispo Item: Cc: San Luis Obispo City Council Members Katie Lichtig - City Manager Re: Draft Environmental Impact Report (DEIR) San Luis Ranch Development From: Mila Vujovich-La Barre Date: January 25, 2017 Dear Planning Commission Members - Thank you for the opportunity to voice opinions about the Draft Environmental Impact Report (DEIR) for San Luis Ranch. Many of my concerns were expressed during the scoping meeting for this same project on November 17, 2015. Since I was at the last Planning Commission meeting, I wanted to express my ongoing concerns for your consideration and the public record. Although this property is still located in the County of San Luis Obispo, the developer and his team are scheduling multiple City meetings prior to annexation. I feel that once this plan is made truly public that the developer will feel he has done much to comply with the desires of City staff. However, I sense the public will feel like they have not had an opportunity to give appropriate input. A development of this magnitude will cause a significant amount of the public angst. The common person should be given time now to voice their concerns and ideas. The Land Use Circulation Element (LUCE) was funded by a state grant that maximized development in San Luis Obispo. It may have been good in theory for the majority of the LUCE members who had a background in development. However, it did not take into consideration many realities, some of which I have enumerated and discussed below. The LUCE process did not provide for substantial public input. My concerns about the proposal are primarily the following: 1. Water. Where is the water of this development? City and County residents have been asked to conserve for months and I do not see water levels increasing at the sources of our water for a development of this magnitude. 2. Traffic The number of proposed 550 residential units, in addition to the proposed office and commercial space will produce a minimum of 1,000-2,000 vehicles making anywhere from 2-4 trips daily. This upcoming generation may focus on walking, biking and bus travel out of respect for climate change, however most people will still utilize a car. People in the 8-108 surrounding neighborhoods and businesses of Laguna Lake deserve an authentic study of what traffic will look like with this proposed development. They also deserve an authentic appraisal of parking for the proposed development. Traffic flow from the proposed business development should also be part of that same study. Streets appear to be narrow. One -way streets in the development should be considered. There does not appear to be enough parking for the new townhomes. In the preliminary conceptual plan there was a new traffic light in between Dalidio Drive and Oceanaire. It was not clear to me whether there is one or not in this new plan. If there is one, it is going to be problematic. 3. Prado Road. As I wrote previously, the proverbial "elephant in the room" is Prado Road. For years now, people have been asking whether Prado Road is going to be an interchange or an overpass. They have been asking whether or not it a four -lane truck highway as it appears on the LUCE plans. Prado Road was indeed part of the updated Land Use Circulation Element (LUCE) Plan. Also, the LUCE plan is cited in meetings as the rationale for this immense and dense San Luis Ranch development. Prado Road is also part of the traffic circulation plan for Avila Ranch. The public deserves to see the entire plan and the inclusion of the Prado Road overpass or interchange. One cannot "cherry pick" the LUCE plan and provide for just the parts that are easy" and/or profitable. All of the support system should be in place. Since the developer is solely responsible for traffic/road improvements - his "fair share" - this overpass or interchange will substantially impact the cost of the residential units that are being proposed there. For City staff to entertain any development on the San Luis Ranch - formerly known as the Dalidio property - without getting a clear answer on whether or not the overpass or interchange is even viable is unconscionable. A transparent discussion should occur with CALTRANS about the interchange and/or overpass as soon as possible. City elected officials should insist that the traffic infrastructure - out of the pocket of the developer - be completed either at the same time the development is being constructed or prior to it. At last week's meeting the developer surprised me by stating that the plan is now to build homes in the first phase in back of Target and funnel all of the resulting traffic onto Froom Ranch Road and then onto Los Osos Valley Road. Then, the developer's representative quipped, "Who knows when the Prado Road overpass will ever be built." This factor should not be an afterthought. This should be discussed now to avoid extreme congestion on Los Osos Valley Road. Everyone needs to remember that another development the Madonna family's Continued Care Residential (CCR) Facility is also being proposed with traffic to also be funneled on to Los Osos Valley Road. In the current plans, Madonna's CCR also has 280 homes scheduled to be built. The traffic will become unbearable. 8-109 4. Affordable housing. Affordable housing is proposed and the question is, "At what price?" The cost of road improvements needs to be factored into the purchase price so that the developer can make a profit. It would be good business sense to know this obligation beforehand. For the common person to look at the simple equation of 500 homes x $400,000= $200,000,000, it gives a citizen an idea of the profit that Gary Grossman and his team stand to make. Even if the cost of the land at roughly $20,000,000 and the overpass or intersection at an estimated $60,000,000 is factored in that is still a gross profit of $120,000,000. Please look into these numbers and let the public know what the homes would be priced at. Of course, this simple equation does not factor in the cost and profit of the proposed commercial development that is also in the preliminary plan, or the actual cost of the residential construction. 5. Affordable housing vs. Student rentals. Unless there is an opportunity for deed restrictions and/or strict "Conditions, Covenants and Restraints" (CC and R's) on the property who is to say that the units will not be turned into a mass of student rentals. 6. Noise The noise from this development will need to be mitigated. The noise will be from the people, the vehicular traffic and air travel. What is not in the preliminary plans is the anticipated noise from the four- lane truck highway known as Prado Road and the extension of Froom Road that will connect with Los Osos Valley Road. On the preliminary plan, Froom Road appears that it is a line of trees, when in reality it will be a road. It should be made more clear on the plans. Also, the proposed elevation of the units on the plan are two and three stories tall ( 35 feet and 50 feet respectively). The residents will be negatively affected by the fumes and the noise of vehicular traffic. 7. Airport Viability and Safety My other concern is safety from air travel. The proposed development is at the actual site of a plane crash. I was not a proponent of the Airport Land Use Commission (ALUC) override vote that was supported by a majority of the last City Council, due to concerns for the safety of residents on the ground and pilots and passengers in the sky. No one to date has been able to answer the question, "When a crash occurs on the development, who will be held legally responsible?" Is it the City? The developer? The airport? And/or the taxpayers? 8. Trees Having viewed the preliminary plan, my attention is also on the fact that it shows the construction of three-story structures on Madonna Road. The row of eucalyptus trees will need to be eliminated. I question that logic. If people think clear cutting that row of mature trees is a good idea, then I think that it should be in the plans for a row of trees to be planted to the east of the development near the proposed agricultural land so that the view from Highway 101 is one of trees with a foreground of agricultural land and not a cluster of dense homes. From the 8-110 residents' point of view, it seems that they also would appreciate a view of trees rather than one of the highway. 9. Animal protection Parts of the property is home to some environmentally sensitive animals, specifically herons. Please address how those animals will be protected during and after construction. 10. Access to Laguna Lake Access to the adjacent Laguna Lake recreational area has not been given the attention that it deserves. Having looked at the preliminary plan, I would also like to see an above road, pedestrian access to Laguna Lake Park facilitated for future residents, especially due to the fact that the yards on the proposed properties are small and/or non-existent. This would allow people who bike or walk an opportunity to cross Madonna Road without having to halt traffic. 11.Public Input As I mentioned a year ago during the scoping meeting for this project, it seems that the developer is taking inordinate amounts of time meeting with groups of elected officials. It would serve the developer - Gary Grossman and his development team including members of the architectural firm RRM - well to send a notice to the neighborhoods and receive public feedback on the development. After I made these comments last year, I believe only one meeting was held at a local Italian restaurant, but residents and business owners have not had an opportunity to voice their concerns since then. 12. Class 1 Agricultural Land The citizens of the City of San Luis Obispo have the right to determine if they want this Class agricultural land to be annexed into the City and used for residential housing and commercial office space. 13. Other options I have included below the letter that was submitted to both Gary Grossman and Cal Poly President Jeffrey Armstrong. In short, an alternative for this project would be for Gary Grossman to complete and "old-fashioned land swap" with Cal Poly. They have plenty of acreage to build everything that Grossman desires. The agricultural land could be a Cal Poly working farm for decades to come. A ranch style dorm house could be constructed on the Grossman property by Cal Poly for agriculture students who work the land. In turn, Grossman could build an array of housing on Cal Poly land in a public - private partnership that would allow for students and staff to have affordable housing. Grossman's hotel and conference center could give students employment and real life hospitality experience. This proposal would save Grossman the cost of the interchange, it would protect the agricultural land, and decrease the amount of traffic substantially. In closing, thank you for the opportunity to enumerate concerns now so that they can be addressed in the near future. Sincerely, Mila Vujovich-La Barre 8-111 Mila Vujovich-La Barre 650 Skyline Drive San Luis Obispo, CA 93405 January 19, 2015 Dr. Jeff Armstrong — President California Polytechnic University San Luis Obispo, California Mr. Gary Grossman Central Coast Builders Pismo Beach, California Dear Dr. Armstrong and Mr. Grossman, In the spirit of Martin Luther King, I have a dream. This dream can become a reality with a few simple steps and make San Luis Obispo the best it can be. Although you are both hard-working modest men, I also think that people would think you were absolute saviors if you are able to follow through on what I am about to propose. Mr. Grossman, you as the new owner of the 131 -acres of land- previously known as the "Dalidio property" - now called San Luis Ranch. The name change has not changed the sentiments of many locals about that prime agricultural land that is positioned above the City's emergency water supply. Many residents and tourists are also enamored with the view shed that it provides from Highway 101, with the fertile crops and the background of our beautiful mountains. Dr. Armstrong, under your leadership, California Polytechnic University (Cal Poly) has continued to receive awards for its academic rigor and the livability of the campus. My vision, gentlemen, is for a true, old-fashioned land swap. Mr. Grossman, you can deed the 131 -acres of prime agriculture land to Cal Poly. Dr. Armstrong, Cal Poly will give, in turn 131 -acres of buildable land to Mr. Grossman. The land on the Cal Poly land would be the future site of residential housing that could be sold for the competitive market rates to the general public. Currently Mr. Grossman, of your 131 -acres of prime agricultural land, the City of San Luis Obispo will receive roughly 50% of it as open space. The remaining land would have to be the site of the residential and commercial projects that you envision as well as the road infrastructure. A deal with Cal Poly may not place those restrictions on you or your development team. 5 8-112 Mr. Grossman, as with any development project, you would be responsible for the cost of the road infrastructure at the Cal Poly site, however I imagine that it could be off -set by the assistance of students in the various divisions of that support both Engineering and Architecture Departments. Mr. Grossman, you could also build a state -of -the- art hotel there if you and your team desire to be truly extraordinary. The hotel, with conference capabilities, could be a landmark public-private enterprise. Mr. Grossman you could opt to could build a sustainable hotel — similar to the one on Boulder, Colorado that is near zero waste. With the help of the award winning architecture department and the assistance of the professionals at RRM, it could not only have great guest rooms with rural views but a conference center as well. The restaurant at the hotel could be open to the public and could feature a "farm to table" theme with Cal Poly or local meat, fish and of course fruits and vegetables. With its proximity to Cal Poly there would never be a shortage of individuals for near minimum wage employment to serve in various jobs that the hospitality industry affords. With the assistance of Cal Poly's Transportation/ Traffic Engineering department, the new homes and hotel would have access to campus, town and Highway 1 via pedestrian paths, bikes paths, light rail or cars. Mr. Grossman, the genius of this idea if we can get it to work is that you would no longer have to pay for the cost of the contentious Prado Road overpass or interchange that may cost you as much as $70 million by today's estimates. As you know, Caltrans has stated numerous times that a safe interchange at Prado Road and Highway 101 would be very difficult to construct given the proximity of Madonna Road and Los Osos Valley Road. If eliminated, the interchange and/or overpass will not infringe upon the integrity of the new Homeless Service Shelter at 40 Prado Road. You would no longer have to worry about the scrutiny of the Airport Land Use Commission and the factors that may prohibit you from building the size of development that you desire. You would no longer have to be concerned about whether any local landowners would sell you land for the off-site mitigation your design team has discussed. 6 8-113 Dr. Armstrong, Cal Poly would benefit by maintaining the showcase to the agrarian based county in perpetuity. The Cal Poly staff and students will be able to farm 131 - acres of land already adjacent to San Luis Obispo City farm. In my mind, I picture the original farmhouse on the property being refurbished to serve as a visitor center/farmer's market stand where local products from both Cal Poly and native entrepreneurs could be sold — from cheese to wine to fruits and vegetables. Although not mandatory, there could be an eight- person student dorm on site, and housing for a staff member. The site could even have a small venue for entertainment overlooking the fields, and perhaps a venue for intimate ceremonies 50 people or less. Maintaining the land for these uses would allow the row of beloved eucalyptus trees to stay in place. In addition, the Laguna Lake residents will be overjoyed with this proposal. The idea of having homes at up to 500 homes and the commercial space on that location already has voters talking to me about organizing a referendum. Gentlemen, I have been involved in City politics as a concerned citizen for over 16 years. This is simply a fabulous idea and I do hope that you will give it full and immediate consideration. Dr. Armstrong, the residential component on what is now Cal Poly land could house professionals that work in our community or students. The concept would be well- received by many voters who have been so concerned about options for housing. Mr. Grossman, you have told me on more than one occasion that you are prepared to build something tasteful that you could personally be proud of. I seriously think that this is it! Please feel free if you would like to meet with me personally to further discuss this concept that would be a proverbial "win" for both of you and for the entire community as a whole. As a public school teacher, I am generally limited to the hours before 7:30am or after 3:OOpm. Sincerely, Mila Vujovich-La Barre 8-114 650 Skyline Drive San Luis Obispo, CA 93405 8-115 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 18 COMMENTER: Mila Vujovich-LaBarre, Private Citizen DATE: January 25, 2017 Response 18.1 The commenter notes that the City’s Land Use and Circulation Element update was funded by a State grant which maximized development in the City, but states that the Land Use and Circulation Element update did not provide for substantial public input. Accordingly, the commenter states that the public should be given the opportunity to voice their concerns and ideas about the San Luis Ranch Project. As described in Section 1.0, Introduction, Section 15123 of the State CEQA Guidelines states that an EIR shall identify areas of controversy known to the Lead Agency, including issues raised by the agency and the public. In accordance with the State CEQA Guidelines, a Notice of Preparation (NOP) for this EIR was distributed for review by affected agencies and the public on October 19, 2015. Based on comments received from the NOP public hearing and responses received during the NOP comment period, issues known to be of public concern which may be controversial are further evaluated in the Draft EIR. The Draft EIR was circulated for a 52-day public review period that began December 9, 2016 and concluded on January 31, 2017. The original 45-day comment period was scheduled to end on January 23, 2017, but was extended one calendar week. The City held a public Planning Commission hearing on January 11, 2017, which was continued on January 25, 2017, to receive public testimony in the form of verbal comments on the Draft EIR. Therefore, the public has been given opportunities to provide input on the environmental review for project, consistent with the requirements of the State CEQA Guidelines. Response 18.2 The commenter questions where the water for the project will be sourced. As described in Section 4.13, Water Resources, project development would be supplied by City surface water supply which comes from the Salinas Reservoir, Whale Rock Reservoir, and Nacimiento Reservoir. Remaining agricultural uses on the project site would continue to be supplied by groundwater from the San Luis Obispo Groundwater Basin. As discussed under Impact WR-1, the City’s existing water supply would be sufficient to serve the project’s estimated demands. In addition, the project includes water conservation measures intended to manage on-site water consumption associated with the proposed development and would use recycled water for parks, open space, and landscaping, and includes measures to ensure landscaping water efficiency. Response 18.3 The commenter states that the Draft EIR should include an analysis of what traffic will look like with the proposed development, including the proposed commercial development, as well as an evaluation of parking. The commenter states that one-way streets should be included in the project, and that parking for the project is insufficient. The commenter also states that, if included in the project, a parking light between Dalidio Drive and Oceanaire Drive would be problematic. A Multimodal Transportation Impact Study (2016) was prepared by Omni-Means, Ltd. to evaluate projected transportation impact conditions associated with development of the project and is included as Appendix L to the Draft EIR. The Multimodal Transportation Impact 8-116 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Study quantifies the project’s potential impacts to all modes of travel (auto, bike, pedestrian, and transit), and estimates project generation of new person trips using all modes of travel available. The Multimodal Transportation Impact Study analysis estimates that the majority (95.9 percent) of trips generated from the non-recreational uses would be automobile-based trips. The trip generation calculations within the Multimodal Transportation Impact Study include all proposed land uses as presented in the San Luis Ranch Specific Plan. Due to the mix of proposed on-site land uses, the trip generation estimates in the Multimodal Transportation Impact Study also consider internally captured trips between different uses, such as residential to commercial, and commercial to commercial as well as intersection spacing, residential neighborhood traffic calming aspects, and internal site circulation. Mitigation measures are provided for significant transportation and circulation impacts that are identified as part of the traffic impact analysis, which are described in Section 4.12, Transportation. Specifically, Table 4.12-1 in Section 4.12, Transportation, lists the required transportation improvements measures for the project. Consideration of one-way streets within residential areas is applicable to alleyways as presented in the Specific Plan. Parking requirements and roadway cross-sections would be consistent with City zoning regulations, the City’s Municipal Code, and the City’s General Plan. In addition, based on the Specific Plan, on-street parking will be permitted in the single-family unit residential areas. Consistent with the Specific Plan, and as shown in Figure 7 of the Multimodal Transportation Impact Study (Appendix L), the project access on Madonna Road between Dalidio Drive and Oceanaire Drive was assumed to be developed as a side-street stop-controlled intersection with right turn only access (right-in right-out). Furthermore, the project would be required to comply with Policy 4.1.4 New Development of the City’s General Plan Circulation Element which requires that new development provide parking consistent with City plans and development standards. Response 18.4 The commenter states that the public deserves to see the entire plan for the Prado Road & U.S. 101 interchange, and that this improvement should be included in the analysis of the Specific Plan. The commenter states that a discussion should occur with Caltrans about the Prado Road & U.S. 101 interchange. Refer to Master Response 2 for a discussion of the timing of the Prado Road Overpass/Interchange mitigation and opportunities for public review of the Prado Road Overpass/Interchange. Response 18.5 The commenter states that the anticipated market price of the proposed affordable housing should be disclosed. This comment pertains to the profitability of the uses proposed under the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. The suggestions provided by the commenter will be forwarded to the appropriate decision-makers for review and consideration. 8-117 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 18.6 The commenter suggests that without deed restrictions and/or “Conditions, Covenants, and Restraints” the proposed affordable housing could be turned into student rentals. This comment pertains to the management of the proposed uses, which does not reflect on the adequacy or content of the Draft EIR. The suggestions provided by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 18.7 The commenter states that the noise impacts associated with development of the project, including traffic noise along the extended Prado Road and Froom Ranch Way, will need to be mitigated. The commenter also states that preliminary project plans show Froom Ranch Way as a line of trees rather than a roadway and requests that plans be revised to show Froom Ranch Way as a roadway. As described in Section 4.10, Noise, Mitigation Measures N-1(a) through N- 1(d), N-4(a), N-4(b), and N-5(a) through N-5(d), would be required to reduce construction noise, operational noise, and traffic noise to the maximum extent feasible. In addition, Figure 2-6, Project Site Plan, shows the Froom Ranch Way as a paved roadway with a landscaped median and Figure 2-8, Vehicular Circulation Plan, delineates Froom Ranch Way as a vehicular circulation route. Impact N-3 includes a discussion of roadway noise along Froom Ranch Way and along Prado Road under the Existing Plus Project, Year 2035 Prado Road Interchange Plus Project, and Year 2035 Prado Road Over-crossing Plus Project traffic scenarios. As described therein, the project’s roadway noise impacts along Froom Ranch Way and along Prado Road, as well as all other local roadways, would be less than significant with the required mitigation under all traffic scenarios. Response 18.8 The commenter expresses concern for the safety of development on the project site associated with the nearby San Luis Obispo County Regional Airport and notes a prior airplane accident on the site. The commenter asks who would be held legally responsible if another accident were to occur on the project site following project buildout. Refer to Response 16.3 for a discussion of airport accident hazards addressed in the Draft EIR. The commenter’s questions will be forwarded to the appropriate decision-makers for review and consideration. Response 18.9 The commenter suggests that a row of trees be planted on the east side of the proposed development near the agricultural land to shield views of the proposed residential units from U.S. 101. As shown on Figure 2-6, Project Site Plan, the project includes planting of landscape trees along the entire eastern edge of the proposed residential development area. These trees would shield views of the proposed residences from U.S. 101 as well as views of U.S. 101 from the proposed residences. Response 18.10 The commenter states that sensitive animal species, including herons, reside on the project site, and requests an explanation of how those animals will be protected during and after project construction. Section 4.4, Biological Resources, describes the special status animal species found on and in the vicinity of the project site, including great blue heron (Ardea herodias), and the mitigation measures that would be required to reduce impacts to those species. Mitigation Measures BIO-1(a) through BIO-1(h) would reduce impacts to listed, candidate or special-status 8-118 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo wildlife species to a less than significant level and ensure that the project would comply with City Conservation and Open Space Element Policies 7.3.1, Protect Listed Species, and 7.3.2, Species of Local Concern for the protection of special status species. Response 18.11 The commenter requests that access to the Laguna Lake recreational area be considered. The commenter suggests an above-road, pedestrian access to Laguna Lake Park to allow people an opportunity to cross Madonna Road without having to halt traffic. The Draft EIR did not identify project impacts that would be mitigated by the construction of a pedestrian overcrossing on Madonna Road. However, required mitigation measures for project-related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road. Refer to Section 4.12, Transportation, for a discussion of the project’s potential impacts to multimodal circulation and required mitigation. Response 18.12 The commenter states that the project developer should solicit input on the project from the surrounding neighborhood. This comment does not address the adequacy of the content of the Draft EIR. However, the commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. Refer to Response 10.1 for a discussion of the opportunities for the public to provide input on the Draft EIR for the project. Response 18.13 The commenter states that the citizens of San Luis Obispo have the right to determine if they want land with Class I soils to be annexed into the City and used for residential and commercial development. As described in Section 1.0, Introduction, the purpose of the EIR is “to serve as an informational document for the public and City of San Luis Obispo decision-makers. The process will culminate with Planning Commission and City Council hearings to consider certification of a Final EIR as well as the project’s requested approvals.” Section 2.0, Project Description, describes the proposed annexation of the project site into the City of San Luis Obispo. Section 4.2, Agricultural Resources, describes the project’s potential impacts to agricultural resources, and indicates that the project’s potential impacts associated with conversion of prime agricultural soils to urban uses would be significant, but mitigable. Mitigation Measure AG-1 requires the project proponent to provide that for every acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to non-agricultural use as a result of project development, one acre of land of comparable agricultural productivity shall be preserved in perpetuity. No revisions to the Draft EIR are required. Response 18.14 The commenter recommends an alternative to the project entailing a “land swap” between the property owner of the project site and the President of California Polytechnic University (Cal Poly). Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion of the adequacy of project alternatives evaluated in the Draft EIR. 8-119 Meeting: Pc,,' I is t From: Davidson, Doug Sent: Thursday, January 26, 2017 9:14 AM To: Bergman, Katelin Subject: FW: Questions for DEIR on San Luis Ranch Attachments: San Luis Ranch Questions.docx Please include this as correspondence for response — San Luis Ranch. Thanks From: Ron Malak [ Sent: Wednesday, January 25, 2017 3:28 PM To: Davidson, Doug <ddavidson@slocity.org> Subject: Questions for DEIR on San Luis Ranch Hi Doug, Item: 3 RECEIVED CITY OF SAN LUIS OBISPO JAN 2 6 2017 COMMUNITY DEVELOPMENT I apologize for getting these to you so late in the day, that said, attached are questions/ comments for tonight PC meeting. I'm still not sure if these questions are appropriate for tonight's agenda item, but I'm sure you will offer me guidance on this. I am registered for the PC Academy. Thanks for your time and help. Ron Malak 8-120 San Luis Ranch Questions. 1. ES.53 Cumulative Water Resources Impacts — Please explain how water demand would exceed water supply? 2. 2.10 All affordable units are deed restricted. Will there be affordable rental units in this project? 3. 2.14 and 4.2.114.6. Please explain again all options on a minimum of 50 acres to be reserved for farming for this project? Or should this be done at the FEIR or the VTM.. 4. 4.12-35 Please verify that at a minimum, an overpass on Prado rd. will be completed by the end of phase 2. 5. 4.6.10 and 4.6.18 SB 2X requires 33% of electricity from renewable energy by 2020. Avila Ranch conforms to this, 50% of units will have solar on roofs, but San Luis Ranch does not have solar panels or solar canopies. Does staff have any strategies to require SLR meets the same standards as AR? 6. 4.8.29 Is flood insurance required for this development? 7. 4.2.23 Approximately 2. 5 ft of topsoil to be removed as fill. How will it affect the continuing farm operations? The documentation provided by the public is very compelling regarding the negative effects of this process. Please provide alternative to securing fill dirt to raise the height in order to build the project above the flood zone. 8. 4-3-21 The following items are inconsistent, 20,26,27,33,34,35,37. 1 am concerned with the items that do not prepare these units for passive solar, however, the remainder of items are still important. These are addressed on the next page with mitigation measures. The doc states that the 8-121 mitigation measures MAY include but are not limited to ...... how is MAY interpreted in this instance? 9. 4.11-8- 9 Parkland is insufficient for this project. Request alternative with full 5.8 acres. 10. 5-1. 546 units with 34 affordable. This is 6% of the project. Is there a way to increase the percentage of affordable housing? 11. 5-2 Air quality, traffic and land use/policy is impact 1. Request an alternative 5 using the minimum requirements of project as parameters. 12. Would the number of affordable units be reduced in alternative 4. 13. Increase the number and locations of electric vehicle charging stations, eg: condo's and apartments. 8-122 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 19 COMMENTER: Ron Malak, Planning Commissioner DATE: January 26, 2017 Response 19.1 The commenter notes that his letter outlines his questions and comments for the Planning Commission hearing held on January 25, 2017. The commenter’s questions and comments are addressed in Responses 19.2 through 19.14. Response 19.2 The commenter requests an explanation of how cumulative water demand would exceed water supply. As described in the analysis of cumulative impacts in Section 4.13, Water Resources, the total estimated water demand from cumulative projects in the City (including the project) would be 2,359 acre-feet per year (AFY), which represents approximately 91 percent of the current City’s existing water availability of 2,588 AFY. Therefore, the City has sufficient existing and future water supply to provide potable water to the project in combination with planned future development in the City. The summary of Cumulative Water Resources Impacts in Table ES-3 of the Draft EIR has been revised as follows to reflect this conclusion in the Final EIR. Cumulative Water Resources Impacts. The project’s water demand would not exceed supply when combined with all possible future development within the City. In addition, the project would reduce the overall demand on the San Luis Obispo groundwater basin as a result of reduced on-site agricultural uses and, therefore, would not exacerbate potential cumulative impacts on the local groundwater basin associate with future development within the City. Accordingly, the project’s cumulative water supply impact would be less than significant. No mitigation is required. This impact would be less than significant without mitigation. Response 19.3 The commenter notes that affordable units are deed restricted and questions if the project will include rental units. This comment pertains to the economics of the proposed Specific Plan development, which does not reflect on the adequacy or content of the Draft EIR. Response 19.4 The commenter requests an explanation of the options for preserving a minimum of 50 acres for farming. As described in Section 4.2, Agricultural Resources, the project is required by City General Plan Land Use Element Policy 8.1.4.f to dedicate one half of the total land or easements for open space use, and that land dedicated to agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation (including 8-123 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo potential off-site preservation). The project includes a commitment, which will be included in the Development Agreement, to procure an off-site agricultural conservation easement/deed restriction to comply with Land Use Element Policy 8.1.4.f. Section 6.0, Alternatives, includes a discussion of Alternative 4, which has been designed to address this issue by preserving half of the project site acreage in agriculture on-site. In addition, Section 4.2, Agricultural Resources, notes that the project applicant has an existing option-to-purchase agreement on a parcel located within/contiguous to the City’s Greenbelt, and the City has provided the applicant with preliminary approval for this site as an off-site agricultural conservation easement/deed restriction to satisfy Land Use Element Policy 8.1.4.f. However, the specific location of potential off-site agricultural conservation easement land has not been formally identified through a final approval. As described in Impact AG-1, to ensure that the final off-site agricultural conservation easement/deed restriction satisfies the requirements of Land Use Element Policy 8.1.4, the Draft EIR requires the project proponent to comply with Mitigation Measure AG-1, which establishes performance measures for the off-site agricultural conservation easement/deed restriction. Response 19.5 The commenter requests verification that at a minimum, an overpass on Prado Road is being completed by the end of Phase 2. Refer to Master Response 2 and Response 1.1 for a discussion of the project phasing requirements in relation to the required mitigation measures, including details pertaining to the Prado Road Overpass phasing and feasibility. Response 19.6 The commenter notes that Senate Bill 2X requires California to generate 33 percent of its electricity from renewable energy by 2020 and states that the Avila Ranch Project is in compliance with this requirement because 50 percent of the units included in that project would have solar installed. The commenter questions whether City staff have strategies to require the project to meet the same standards as the Avila Ranch Project. It should be noted that Senate Bill 2X does not require individual projects to provide or source electricity from renewable sources. The requirement that the State generate 33 percent of its electricity from renewable energy by 2020 pertains to the State-wide electricity grid. Refer to Response 29.50 for a discussion of the design standards included in the project to accommodate solar panels and solar-heated water. Response 19.7 The commenter questions if flood insurance is required for development associated with the project. For a discussion of potential environmental impacts related to flooding and the project’s consistency with applicable flood zone requirements, refer to Section 4.8, Hydrology and Water Quality. Response 19.8 The commenter asks how the proposed use of topsoil as fill soil would affect continuing farming operations, and states that other public comments received regarding this topic describe the potential negative effects of this process. The commenter requests that the project proponent provide an alternative to securing fill dirt to raise the elevation of the project’s development footprint above the flood zone. Refer to the responses to Letters 3, 8, and 9. 8-124 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 19.9 The commenter states that the project is not consistent with SLOAPCD’s standard operational mitigation measures 20, 26, 27, 33, 34, 35, and 37 described in Table 4.3-10 in Section 4.3, Air Quality. The commenter also expresses concern that the proposed units would not be prepared for solar (measure 20 in Table 4.3-10). The commenter requests clarification concerning the use of “may” in Mitigation Measure AQ-3(a), “Emission reduction measures may include, but would not be limited to...” The measures included in Table 4.3-10 are SLOAPCD’s standard operational mitigation measures from the SLOAPCD CEQA Air Quality Handbook, and the commenter accurately characterizes the conclusions of the Draft EIR’s evaluation of the project’s consistency with these measures. Refer to Response 29.50 for a discussion of the project’s consistency with measure 20 in Table 4.3-10 of the Draft EIR. Therefore, the project would be consistent with measure 20 in Table 4.3-10. Mitigation Measure AQ-3(a) has been revised to change “may” to “shall,” and also to reflect the SLOAPCD’s operational measures in a programmatic manner that offers flexibility with the final project design needed to meet SLOAPCD emissions reduction goals, as follows: AQ-3(a) Standard Operational Mitigation Measures. Prior to issuance of grading permits, the applicant shall define and incorporate into the San Luis Ranch Specific Plan standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook to reduce emissions to below daily threshold levels. Emission reduction measures may shall include, but would not be limited to: […] • Prohibit residential wood burning appliances; • Install a ‘Park and Ride’ lot with bike lockers in a location of need defined by SLOCOG; • Trusses for south-facing portions of roofs shall be designed to handle dead weight loads of standard solar-heated water and photovoltaic panels. Roof design shall include sufficient south facing roof surface, based on structures size and use, to accommodate adequate solar panels. For south facing roof pitches, the closest standard roof pitch to the ideal average solar exposure shall be used; • Increase the building energy rating by 20 percent above 2013 Title 24 requirements (used in the California Emissions Estimator Model) or consistent with 2016 Title 24 requirements, whichever is stricter. Measures used to reach the 20 percent rating cannot be double counted; • Design building to include roof overhangs that are sufficient to block the high summer sun, but not the lower winter sun, from penetrating south facing windows (passive solar design); • Utilize high efficiency gas or solar water heaters; • Install door sweeps and weather stripping (if more efficient doors and windows are not available); • Install energy-reducing programmable thermostats; • Participate in and implement available energy-efficient rebate programs including air conditioning, gas heating, refrigeration, and lighting programs; 8-125 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo • Use roofing material with a solar reflectance values meeting the U.S. EPA/DOE Energy Star® rating to reduce summer cooling needs. • Utilize onsite renewable energy systems (e.g., solar, wind, geothermal, low-impact hydro, biomass and bio-gas); and • Provide and require the use of battery powered or electric landscape maintenance equipment for new development; • Provide a display case or kiosk displaying transportation information in a prominent area accessible to employees or residents; • Provide neighborhood electric vehicles/ car share program; • Provide bicycle-share program;. • Provide bicycle lockers for ‘Park and Ride’ lots; • Provide vanpool, shuttle, mini bus service (alternative fueled preferred); • Provide free-access telework terminals and/or wi-fi access in multi- family projects. Response 19.10 The commenter states that the provided parkland is insufficient for the project, and requests that the Final EIR include an additional alternative analyzing 5.8 acres of parkland within the project site, stating that parkland is insufficient for the project. Parklands and recreational spaces are analyzed in detail in Section 4.11, Recreation. Impact REC-1 recognizes that on-site parks and recreation facilities in the project area would not meet the parkland standards included in Land Use Element Policy 8.1.4 for the San Luis Ranch Specific Plan Area. However, the identified shortfall of parkland would be reduced to a less-than-significant level with incorporation of Mitigation Measure REC-1, which requires the project applicant to pay parkland in-lieu fees to the City of San Luis Obispo. The fees required by this mitigation would be directed to new projects or improvement to existing parks and recreation facilities within the City of San Luis Obispo parks system. Section 6.0, Alternatives, includes an evaluation of alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion the adequacy of project alternatives evaluated in the Draft EIR. Response 19.11 The commenter notes that affordable housing makes up six percent of the residential uses proposed for the project. The commenter questions if there is any way to increase the percentage of affordable housing included in the project. As described in subsection 2.5.2 of Section 2.0, Project Description, the affordable housing component of the project has been developed in accordance with City. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. Response 19.12 The commenter requests a fifth alternative be included in the Draft EIR, using the minimum density requirements for the Specific Plan Area as parameters. According to the City’s General Plan performance standards for the San Luis Ranch Specific Plan Area, the minimum number of residential units anticipated within the Specific Plan Area is 350 units, and the minimum square footage of non-residential development anticipated within the Specific Plan Area is 100,000 square feet (50,000 square feet of commercial and 50,000 square feet of office (refer to Table 2-1 8-126 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo in Appendix B, Draft Specific Plan). The Draft EIR discusses a reasonable range of alternatives to the project in Section 6.0, Alternatives. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for a discussion of the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. Response 19.13 The commenter asks if the number of affordable units would be reduced in Alternative 4. As described in Section 6.0, Alternatives, “Removal of these [31 low-medium density and 7 medium density] residential units would be expected to result in a corresponding reduction in the 80- unit affordable housing density bonus.” Alternative 4 would be reduced from 580 units to 536 units, for a total loss of 44 units. This would include the loss of approximately 6 affordable housing units. Response 19.14 The commenter requests that the project include addition electrical vehicle parking stations and electric vehicle parking station locations. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. 8-127 Los Verdes Park 1 Homeowners' Association, Inc. Los Verdes Park 2 Homeowners' Association, Inc. c/o Sarah Flickinger, Los Verdes Park 1 Homeowners' Association, Inc. 92 Los Verdes Drive San Luis Obispo, CA 93401 January 25, 2017 re: Planning Commission Hearing, San Luis Ranch DEIR To the City of San Luis Obispo Planning Commissioners: Meeting: RECEIVED CITY OF SAN LUIS OBISPO JAN 2 7 2017 COMMUNITY DEVELOPMENT This correspondence is made as a joint statement of the two Homeowners' Associations for the two Los Verdes Park developments located on either side of Los Osos Valley Road within the southern limits of the City of San Luis Obispo. Our neighborhoods are planned urban developments (PUDs)—not unlike the proposed San Luis Ranch Development—of single family homes on individual lots, with several commonly held parcels for communal facilities. Between the two existing residential neighborhoods, we represent more than 175 individual parcels as well as the common interest parcels, and are in direct proximity of the impacts of this development. We are aware that many of our neighbors in the neighborhood off Las Pradreras Drive and other neighboring residential developments echo our concerns. We recognize the additional residential needs outlined in the LUCE and General Plan updates as vital to the long-term sustainability of our community and its shift toward a multimodal future. Our primary concerns are real and immediate impacts to the safety, health and quality of life of our residents, whose homes became a part of this City as early as 1974. CEQA requires that impacts to existing neighborhoods affected by projects be addressed in the DEIR and EIR documents, in an effort to protect existing residents' in the process. The following are specific concerns formally adopted by both HOA boards, with suggestions for amenable mitigations. We have been and continue to be willing to work directly with the developer and the City to work through our issues with the DEIR prior to a subsequent release of the document in an effort to avoid undue delays for the developer. 1). First and foremost, the proposed mitigation measure of an extended turn lane on Los Osos Valley Road near the intersection of South Higuera Street was the subject a settlement agreement between the two HOAs, the City of San Luis Obispo and CALTRANS, when it was proposed as part of the LOVR Interchange Project. Its impacts compromised noise levels, air quality and safety of residential living spaces and safety of vehicle, pedestrian and bicycle travel into, out of and in the vicinity of our neighborhoods beyond acceptable levels. It also caused degradation of access for public safety vehicles and put children loading and unloading at school bus stops at the intersection of Los Verdes Drive and Los Osos Valley Road at risk. The settlement was reached in good faith by all parties, and any proposed 8-128 changes to the agreed upon striping and road alignments requires specific notification prior to consideration (including scoping and DEIR release) under the terms of the settlement agreement. This mitigation measure should be removed from proposal in the DEIR as its inclusion without prior notice violates the terms of the settlement agreement and therefore cannot be legally imposed. As any changes to the striping on Los Osos Valley Road in this vicinity would be infeasible without conflicting with the terms of the settlement agreement, any such mitigation measures must also be removed from proposal in the DEIR. Furthermore, none of these proposed mitigation measures were discussed in the LUCE, making them incompatible with the City's General Plan. A suitable LUCE-evaluated alternative mitigation measure for this area must be considered in lieu so that fair share funding may be assessed. 2). As removal or further reduction of the medians between the Los Verdes parks on LOVR would be necessary in any restriping to additional or extended lanes on eastbound LOVR, it is again infeasible under the terms of the settlement agreement, as it is expressly addressed therein. Any mitigation requiring adjustment to the medians other than the medians' extension should be excluded from consideration as part of this project. 3). The intersection of Los Verdes Drive at Los Osos Valley Road is not evaluated nor discussed in the DEIR. While the document does include impacts at the intersection of LOVR and S. Higuera and LOVR and the NB US 101 intersection, it never specifically addresses or evaluates impacts to the intersection at LOVR and Los Verdes Drive, which serves as the sole vehicular and bicycle entrance and exit points to our residential neighborhoods. There are two school bus stops serving several additional neighborhoods in the greater area at this intersection, which also go unaddressed in the DEIR. This is also the single access point for public safety vehicles traveling to homes within the neighborhoods. That this intersection and impacts to access and public services caused by the addition of project traffic are not discussed at all in this document makes it insufficient as those impacts are real and immediate as early as Phase 1. The addition of project traffic, both near and long term is significant and will have impacts to the safety of Los Verdes Park residents at the intersection of Los Verdes Drive and Los Osos Valley Road for both vehicular and bicycle travel. The impacts further compromise the already failing LOS at the unmentioned and unmitigated intersection and the direct and indirect safety and wellbeing of residents, public servants, service providers (mail, utilities, contractors) and others who travel through this intersection. The addition of project traffic should warrant signalization at Los Verdes Drive prior to completion of Phase 1 to ensure the continued safety of Los Verdes residents and others who travel in and around our neighborhoods. 4. We are concerned about the safety of children traveling between our portion of the City to our neighborhood schools of CL Smith and Laguna Middle School, as well as to/from Pacific Beach High School, particularly for children traveling by bike, as pedestrians or as bus riders. The addition of project traffic on Froom Ranch Way, Oceanaire Drive and Madonna Road is of concern and should be addressed through mitigations, such as (but not limited to): protected, signalized crossing for bikes and pedestrians 8-129 at the east Oceanaire Drive area Bob Jones Trail instersection with Froom Ranch Way; removal of the right turn on red from southbound Madonna onto the west side of Oceanaire Drive; removal of the right turn on red from westbound Oceanaire Drive on the east side of Madonna onto Madonna Road and striping to support safe bicycle coexistence with vehicle stacking and crossing of Madonna at Oceanaire Drive, including vehicle lane striping and buffered bike lanes on both sides of Oceanaire. This is a common crossing for school children, and is already dangerous. The addition of project traffic would exacerbate this condition. 5. As Oceanaire is a safe route for multimodal transport for families traveling to and from schools and neighborhood services in this region, the retention of as many mature trees as possible is of great concern. The large mature trees on the San Luis Ranch site provide positive noise (birds and leaves rustling) and shield airborne particulate matter, including vehicle emissions, agricultural activities, dust and pollen, preserving the air for cyclists and pedestrians. Additionally, the use of monecious and female trees within the proposed development, rather than standard male trees, could help maintain or even reduce airborne pollen counts in this area. 6. We are concerned that the inclusion of the yet unevaluated crossing of 101 at Prado Road (unknown impacts are cited in the DEIR) may cause additional uncalculated impacts to Los Osos Valley Road between our neighborhoods in the near-term scenario, prior to final buildout, particularly if the Prado crossing is denied or restricted in any means by CalTrans. This is something we have already experienced with the addition of shopping centers and housing along LOVR and S. Higuera and in the airport area. Furthermore, the final phase Prado interchange being questionable at this time and the unknown state of extension of Prado beyond S. Higuera, means that LOVR will likely still be the preferred crossing area for this portion of town. As an alternative mitigation until Prado can be built in its entirety, we suggest advancing the LOVR Bypass, approved as part of the LUCE as a solution to regional traffic issues at the intersection of LOVR and S. Higuera. As a mitigation, the San Luis Ranch development could contribute fair share funding to this new roadway. 7. We are concerned as to how bicycles coming off the Bob Jones Trail at Prado Road will be addressed and integrated into the regional traffic flow of the proposed crossing. This is currently our safe alternative toward downtown for those not wanting to ride bikes or walk with traffic along S. Higuera Street. This is also a safe route for students travelling to the High School from our area of town. Could there be bicycle and pedestrian crossing protections put into place at S. Higuera and Elks Lane and Prado and Elks Lane to offer an alternative route for multimodal transportation along Elks Lane, as the corresponding portion of S. Higuera is neither pleasant nor safe for multimodal transportation? Our neighborhoods remain open and available to support the City and developers in achieving the goals of the General Plan through collaborative efforts that serve existing and contemplated developments, as 8-130 well as the greater communities of the City and County of San Luis Obispo. We regret that we were not able to review the DEIR in its entirety prior to release through the CEQA Clearinghouse or we would have provided this feedback and worked with the developer and City to address concerns in advance of publication in an effort to avoid substantive changes that necessitate a new release of the DEIR. Sincerely, Los Verdes Park 1 Homeowners' Association, Inc. Special Board Member Sarah Flickinger Los Verdes Park 1 Homeowners' Association, Inc. President, Board of Directors Los Verdes Park 2 Homeowners' Association, Inc. Special Board Member Darrell Goo Los Verdes Park 2 Homeowners' Association, Inc. President, Board of Directors Bob Barker Cameron Boyne 8-131 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 20 COMMENTER: Sarah Flickinger, Los Verdes Parks 1 and 2 Homeowners Associations DATE: January 27, 2017 Response 20.1 The commenter states that the comment letter is made as a joint statement of the two Homeowners’ Associations (HOA) for the two Los Verdes Park developments located on either side of Los Osos Valley Road, representing more than 175 individual parcels. The commenter states that their concerns are impacts to safety, health, and quality of life. The commenter states that CEQA requires that impacts to existing neighborhoods affected by projects be addressed in the Draft EIR. The commenter states that the comments that follow are specific concerns formally adopted by both HOA boards, with suggestions for amenable mitigations. The commenter states they have been and continue to be willing to work directly with the developer and the City to work through issues with the Draft EIR prior to a subsequent release of the document in an effort to avoid undue delays for the developer. The commenter’s subsequent comments are addressed in Responses 20.2 through 20.8. Response 20.2 The commenter states that the proposed mitigation measure to extend the turn lane on Los Osos Valley Road at S. Higuera Street was the subject of a settlement agreement between the two HOAs, the City, and Caltrans, when it was proposed as part of the Los Osos Valley Road Interchange Project. The commenter states that its impacts compromised noise levels, air quality and safety of residential living spaces, vehicle, pedestrian, and bicycle travel into, out of, and in the vicinity of their neighborhoods beyond acceptable levels. The commenter states that it also caused degradation of access for public safety vehicles including schoolchildren at bus stops at Los Verdes Drive and Los Osos Valley Road. The commenter states that any proposed changes to the agreed-upon striping and road alignments triggers specific notification requirements prior to consideration under the terms of the settlement agreement. The commenter recommends removing any such mitigation measures from the Draft EIR, as their inclusion without prior notice violates the terms of the settlement agreement. The commenter also states that these proposed mitigation measures were not discussed in the LUCE, making them incompatible with the City’s General Plan. City Public Works staff have reviewed the mitigation measures required in the Draft EIR and found that they do not conflict with any conditions of the settlement agreement between the City of San Luis Obispo and Los Verdes I & II HOAs dated April 10, 2012. Response 20.3 The commenter states that removal or further reduction of the medians between Los Verdes parks on Los Osos Valley Road would require restriping for additional or extended turn lanes on Los Osos Valley Road and, therefore, would be infeasible under the terms of the settlement agreement. The commenters states that any mitigation requiring adjustment to the medians other than the medians’ extension should be excluded from consideration as part of this project. The mitigation measures described in Section 4.12, Transportation, can be accommodated without modification of medians along Los Osos Valley Road. Therefore, this mitigation 8-132 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo measure is not in conflict with any conditions of the settlement agreement between the City of San Luis Obispo and Los Verdes I & II HOAs dated April 10, 2012. Response 20.4 The commenter states that the intersection of Los Verdes Drive at Los Osos Valley Road is not evaluated nor discussed in the Draft EIR. The commenter states that there are two school bus stops at this intersection and that is also unaddressed in the Draft EIR. The commenter states that the addition of project traffic, both near- and long-term is significant and would have impacts to the safety of Los Verdes Park residents at this intersection for both vehicular and bicycle travel. The commenter states that the impacts further compromise the already failing Level of Service (LOS) at this intersection. The commenter states that the addition of project traffic should warrant signalization at this intersection prior to completion of Phase 1 to ensure the continued safety of Los Verdes residents and others who travel in and out of these neighborhoods. The Draft EIR analyzed the impacts to the roadway segments which consider partial access and full access driveways as part of the segment analysis. Therefore, the Los Verdes Drive access on Los Osos Valley Road is considered in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) as part of the segment analysis, and the Draft EIR adequately assesses potential multimodal impacts of the project at this location. Installation of a traffic signal would not meet the intersection spacing requirements between signals. Furthermore, the project trip distribution, as depicted in Figures 6A and 6B of Appendix L, does not present a nexus for addition of project trips to side street access at this intersection. Response 20.5 The commenter expresses concern about the safety of schoolchildren traveling by bicycle, as pedestrians, or as bus riders between the Los Verdes Park area to neighborhood schools. The commenter states that the addition of project traffic on Froom Ranch Way, Oceanaire Drive, and Madonna Road is of concern and should be addressed through mitigation. The commenter suggests protected, signalized crossing for bikes and pedestrians at the Bob Jones Trail crossing at Froom Ranch Way; restricting right turn on red at Oceanaire Drive/Madonna Road intersection, westbound on Madonna Road, and northbound Oceanaire Drive; and striping bike lanes on both side of Oceanaire Drive. The commenter states that the addition of project traffic would exacerbate already dangerous conditions for schoolchildren crossing Madonna Road at Oceanaire Drive. The addition of project traffic was not identified as an impact in Section 4.12, Transportation, or the Multimodal Transportation Impact Study (Appendix L) and, therefore, does not present a nexus to require protected crossings at Bob Jones Trail/Froom Ranch Way. Standard striped crossings at the intersections listed will be in compliance with the Manual on Uniform Traffic Control Devices and California Vehicle Code. The addition of project traffic was not identified as an impact in Section 4.12, Transportation, or the Multimodal Transportation Impact Study (Appendix L), and, therefore does not present a nexus to require restricting right turn on red for the currently allowed movements at the intersection of Madonna Road and Oceanaire Drive. The addition of project traffic was not identified as an impact in Section 4.12, Transportation, or the Multimodal Transportation Impact Study (Appendix L) and, therefore, does not present a nexus to require the implementation of striping bike lanes on Oceanaire Drive. 8-133 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 20.6 The commenter states that Oceanaire is a safe route for multimodal transportation for families traveling to and from schools and neighborhoods in this area. The commenter suggests that the retention of large mature trees on the project site is of great concern. Additionally, the commenter states that the use of monecious and female trees within the proposed development, rather than standard male trees, could help maintain or even reduce airborne pollen counts in this area. The Draft EIR did not identify project impacts that would be mitigated by the construction of a pedestrian overcrossing on Madonna Road at Oceanaire Drive. As discussed in Section 4.12, Transportation, mitigation measures for project-related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians, including schoolchildren, and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. Potential biological impacts associated with the removal of trees on the project site are discussed in Section 4.4, Biological Resources. Although the project would remove mature trees mitigation measures contained in the Draft EIR require in-kind replacement of riparian trees four inches or greater measured at diameter-at-breast-height (DBH) at a ratio of 10:1 (replaced: removed), and in- kind replacement of riparian trees 24 inches or greater measured at diameter-at-breast-height (DBH) at a ratio of 10:1. Willows and cottonwoods may be planted from live stakes following guidelines provided in the California Salmonid Stream Habitat Restoration Manual for planting dormant cuttings and container stock (CDFW 2010). The Draft EIR also includes mitigation for sensitive species that use on-site trees for roosting or nesting habitat, including great blue heron, monarch butterfly, bats, and nesting birds. The commenter’s concern regarding airborne pollen does not reflect on the adequacy or content of the Draft EIR. The information and question raised by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 20.7 The commenter expresses concern that the inclusion of the crossing of U.S. 101 at Prado Road (Prado Road Overpass) may cause additional uncalculated impacts to Los Osos Valley Road between the Los Verdes neighborhoods in the near-term scenario, particularly if the Prado crossing is denied or restricted in any means by Caltrans. The commenter states that the final phase Prado Road Overpass/Interchange is questionable at this time and the unknown state of the Prado Road extension east beyond S. Higuera Street results in the preferred crossing being Los Osos Valley Road. The commenter suggests advancing the Los Osos Valley Road Bypass as an alternative mitigation until the Prado Road Overpass can be built. The potential traffic impacts of the Prado Road Overpass are evaluated in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) under the mitigated near-term conditions. The selection of potential design options is currently being processed as part of the PSR for the Prado Road Overpass/Interchange in coordination with the City and Caltrans (Section 501.3 of the Caltrans Highway Design Manual). Although the extension of Prado Road east to Broad Street would provide a significant connection across town, in the near-term scenario, construction of the Prado Road Overpass/Interchange would alleviate traffic congestion and mitigate project impacts at the Madonna Road and Los Osos Valley Road 8-134 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo interchanges, as presented in the Draft EIR. Refer to Master Response 2 for a discussion of the feasibility and adequacy of the Prado Road Overpass mitigation. The Los Osos Valley Road Bypass is outside the scope of the Draft EIR or the Multimodal Transportation Impact Study. Response 20.8 The commenter expresses concern for how bicycles coming off the Bob Jones Trail at Prado Road will be addressed and integrated into the regional traffic flow of the proposed crossing. The commenter requests installation of protections for bicycles and pedestrians crossing Prado Road at Elks Lane and S. Higuera Street at Elks Lane, to provide an alternative route along Elks Lane as the corresponding portion of S. Higuera Street is neither pleasant nor safe for multimodal transportation. The addition of project traffic was not identified as an impact in Section 4.12, Transportation, or the Multimodal Transportation Impact Study (Appendix L) and, therefore, does not present a nexus to require protected crossings at Elks Lane/Prado Road and Elks Lane/S. Higuera Street. Standard striped crossings will be in compliance with the Manual on Uniform Traffic Control Devices and California Vehicle Code. 8-135 GW V4 61 25111 PC Los Verdes Park 1 Homeowners' Association, Inc. Los Verdes Park 2 Homeowners' Association, Inc. c/o Sarah Flickinger, Los Verdes Park 1 Homeowners' Association, Inc. RECEIVED 92 Los Verdes Drive CITY OF SAN LUIS OBISPO San Luis Obispo, CA 93401 Meeting:JAN 2 7 2017 January 25, 2017 Item: 1; LIP- 0EI12__ COMMUNITY DEVELOPMENT re: Planning Commission Hearing, San Luis Ranch DEIR To the City of San Luis Obispo, City Planning Commission and the developers of San Luis Ranch: The Boards of Directors of the Los Verdes Park 1 and Los Verdes Park 2 homeowners' associations are concerned with the CEQA compliance of the San Luis Ranch DEIR documents as prepared and submitted for today's public hearing. The following include some of the inconsistencies with CEQA and General Plan requirements. Due to these issues, we respectfully request that the document be adjusted, properly noticed and recirculated for public review as required under CEQA. Impacted existing residences and other interests were not properly noticed of the DEIR's release as required under CEQA. The DEIR proposes changes and mitigation measures -that are not consistent with the goals and programs in the City of San Luis Obispo's General Plan and suggests that changes to accommodate the inconsistencies be addressed with a General Plan Update, including previously unreviewed and unapproved traffic mitigations, within the DEIR without proper notice and separate public review of the proposed General Plan updates. The DEIR proposes changes and mitigation measures relating to traffic circulation that are not consistent with the City's stated objectives or plans for multi -modal transportation as outlined in the Land Use and Circulation Element of the City's General Plan. CEQA requires consistencies with existing plans. The DEIR is not consistent with CEQA requirements as it includes mitigation measures which cannot be legally imposed due to conflicting legal commitments between our neighborhoods, the City and the State of California Transportation Department. The DEIR does not fully evaluate all significant impacts of the project, including, but not limited to, any evaluation of the intersection of Los Verdes Drive and Los Osos Valley Road and noise impacts, air quality impacts and light pollution impacts at known and additional sensitive receptors in proximity to the project and its traffic impacts, particularly in the area of the Los Verdes Drive intersection with Los Osos Valley Road. The DEIR does not accurately represent the totality of environmental impacts with regard to the Prado Road overpass or future Prado Road Interchange at US 101. As this crucial crossing may still be impossible to build during the near term for any variety of reasons, it should not be assumed as a viable mitigation measure for traffic impacts. The DEIR should address updated traffic counts following completion of the LOVR Interchange Project for accuracy in assessment of existing conditions, the need to assess and project future noise impacts, the need to ensure mitigation measures from other projects that have not been completed are not assumed (i.e. mitigation measures for Chevron development, incomplete mitigations remaining following LOVR Interchange Project, not yet approved mitigation measures for Avila Ranch, etc.), a full detailed analysis of the project in all terms with and without the various options for Prado Road interim and complete connectivity AND with and without the LOVR Bypass as it relates to changes at Prado Road, and significant study of the LOVR Bypass effects in mitigating existing and long term traffic impacts in the region, among others. 8-136 Furthermore, the use of traffic counts taken during March 2015 in the vicinity of Los Osos Valley Road, South Higuera, US 101, Tank Farm Road and Buckley Road is misleading and inaccurate in assessing the current traffic conditions. At the time of these traffic counts, normal traffic patterns were significantly altered as result of it being a late midpoint of construction on the LOVR Interchange Project which included lane and other closures which discouraged use of this area and encouraged uses at other areas such as Madonna Road, 227/Broad Street, etc. Current traffic counts now that the LOVR Interchange Project is completed should be taken in order to accurately describe the current traffic and more accurately assess/project the future traffic volumes in the DEIR. The traffic study began development following or at the near point of completion of the Interchange Project; new traffic counts should have been taken at that time to have any accuracy to the DEIR. The currently included traffic counts are not representative, should be revised and the mitigation measures reassessed based on the current more accurate counts. Such significant changes would trigger rerelease of the DEIR under CEQA. Our neighborhoods and the neighborhoods where our schools are located failed to be noticed at every step of the project as required, including, but not limited to, the scoping hearing, this DEIR hearing, the DEIR release and so forth. We have followed this project, among others, and have continued to be vocal in this failure of notice. However, it remains an ongoing problem, both under CEQA as well as the terms of our settlement agreement. In conclusion, this DEIR needs to be revisited in so many ways to be compliant with CEQA requirements. Continued failure to address these issues up to and including, but not limited to, fundamental changes to the DEIR and full notification and recirculation of the document, may have the effect of putting the future of this project in jeopardy. CEQA and General Plan requirements were enacted to protect citizens, developers, lead agencies and others through the development process, and must be adhered to not only because it is law, but also because it is in the best interest of balancing the sometimes -competing interests of all the parties involved. We remain committed to working with the City, Developer and other interested citizens to ensure the best possible decisions are made. Sincerely, Los Verdes Park 1 Homeowners' Association, Inc. Special Board Member Representing the Joint Partnership of the Los Verdes Parks 1 & 2 HOAs Sarah Flickinger 8-137 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 21 COMMENTER: Sarah Flickinger, Los Verdes Parks 1 and 2 Homeowners Associations DATE: January 27, 2017 Response 21.1 The commenter states that the Board of Directors of the Los Verdes Park 1 and Los Verdes Park 2 HOAs are concerned with the CEQA compliance of the Draft EIR and that their comments list inconsistencies with CEQA and General Plan requirements. The commenter requests that the document be adjusted, properly noticed and recirculated for public review as required under CEQA. The commenter’s subsequent comments are addressed in Responses 21.2 through 21.11. Response 21.2 The commenter states that existing residences and other interested parties were not properly noticed of the release of the Draft EIR as required by CEQA. The environmental review process and noticing requirements, as described in Section 1.0, Introduction, and pursuant to the State CEQA Guidelines, have been carried out by the City for the project. In accordance with these requirements, a Notice of Preparation (NOP) for this EIR was distributed for review by affected agencies and the public on October 19, 2015. The Draft EIR was circulated for a 52-day public review period that began December 9, 2016 and concluded on January 31, 2017. The original 45- day comment period was scheduled to end on January 23, 2017, but was extended one calendar week. The City held a public Planning Commission hearing on January 11, 2017, which was continued on January 25, 2017, to receive public testimony in the form of verbal comments on the Draft EIR. Therefore, the project has been adequately noticed in the community and the public has been given opportunities to provide input on the environmental review for project, consistent with the requirements of the State CEQA Guidelines. Response 21.3 The commenter states that the mitigation measures included in the Draft EIR are not consistent with the goals and programs in the City’s General Plan. The commenter notes that these measures would require an update to the General Plan, which would occur without proper notice or public review. As described in Section 1.0, Introduction, for each significant impact identified in the Draft EIR, the City must find, based on substantial evidence, that either: (a) the project has been changed to avoid or substantially reduce the magnitude of the impact; (b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or (c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (State CEQA Guidelines Section 15091). Accordingly, the findings for the project would tie consistency of the mitigation measures included in the Draft EIR with the General Plan and other relevant City policies. If City decision-makers approve the project with unavoidably significant environmental effects, the City must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic or other reasons supporting the City’s decision. Response 21.4 The commenter states that the Draft EIR proposes changes and mitigation measures relating to traffic circulation that are not consistent with the City’s stated objectives or plans for multi- 8-138 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo modal transportation as outlined in the Land Use and Circulation Element of the City’s General Plan. The Draft EIR requires mitigation measures consistent with the policies set forth in Chapter 6 of the City’s General Plan Circulation Element for multimodal mitigation measures. The Draft EIR and Multimodal Transportation Impact Study are consistent with the multimodal level of service objectives, standards, and significance criteria as presented in Policies 6.1.1-6.1.6 of the Circulation Element. The City’s Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals and the project and mitigation measures required in the Draft EIR would aid in implementing these goals with General Plan policy concurrence and implementation of transportation demand management (TDM) strategies. Therefore, the traffic analysis included in the Draft EIR is consistent with the State CEQA Guidelines. Response 21.5 The commenter states that the Draft EIR is not consistent with CEQA requirements, as it includes mitigation measures which cannot be legally imposed due to conflicting legal commitments between the Los Verdes neighborhoods, the City, and Caltrans. The traffic impact analysis was completed within the context of existing settlement agreements, and mitigation measures required in the Draft EIR are not in conflict with any of the specific conditions of existing settlement agreements. Refer to Response 20.2. Response 21.6 The commenter states that the Draft EIR does not fully evaluate all significant impacts of the project, including, but not limited to, any evaluation of the intersection of Los Verdes Drive and Los Osos Valley Road and noise impacts, air quality impacts, and light pollution impacts at known and additional sensitive receptors in the proximity of the project and its traffic impacts, particularly in the area of the Los Verdes Drive intersection. The Draft EIR analyzed impacts to roadway segments which consider partial access and full access driveways as part of the segment analysis. Therefore, the Los Verdes Drive access on Los Osos Valley Road is considered in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) as part of the segment analysis and adequately assesses multimodal impacts from the proposed project for this location. Section 4.3, Air Quality, Section 4.10, Noise, and Section 4.1, Aesthetics, address potential concerns regarding impacts to air quality, noise, and lighting. Response 21.7 The commenter states that the Draft EIR does not accurately represent the totality of environmental impacts with regard to the Prado Road Overpass/Interchange. The commenter states that this crossing may be impossible to build during near-term for any variety of reasons, and it should not be assumed as a viable mitigation measure for traffic impacts. Refer to Master Response 2 for a discussion of the feasibility of the Prado Road Overpass mitigation. Response 21.8 The commenter states that the Draft EIR should address: • Updated traffic counts following completion of the Los Osos Valley Road Interchange Project for accuracy in assessment of existing conditions; • The need to assess and project future project noise impacts; 8-139 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo • The need to ensure mitigation measures from other projects that have not been completed or approved are not assumed (i.e. Chevron, Avila Ranch, and remaining mitigations following the Los Osos Valley Road interchange Project); • Analysis of the project in all terms with and without various options for Prado Road interim and complete connectivity; and • Analysis with and without the Los Osos Valley Road Bypass as it relates to changes at Prado Road and effects in mitigating existing and long term traffic impacts in the region. The City of San Luis Obispo maintains traffic counts for selected intersections and roadway segments, updated every two years. As stated in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L), the existing traffic counts were collected during February and March of 2014. The traffic counts were collected prior to commencement of construction of the Los Osos Valley Road Interchange Project, which began in November 2014, and prior to any temporary management or control that would affect traffic such as lane closures. When the Multimodal Transportation Impact Study commenced, the most recent traffic counts from the City were utilized in the analyses, per CEQA requirements. Conditions representing the completed Los Osos Valley Road interchange are represented in the Multimodal Transportation Impact Study under near-term conditions. The near-term and cumulative baseline (no project) analyses assume planned improvements consistent with the General Plan. Refer to Master Response 2 for a discussion of the feasibility of the Prado Road Overpass mitigation. The selection of potential design options is currently being processed as part of the PSR for the Prado Road Overpass/Interchange in coordination with the City and Caltrans (Section 501.3 of the Caltrans Highway Design Manual). Refer to Response 20.7 for a discussion of the Los Osos Valley Road Bypass relative to the scope of the Draft EIR analysis. Response 21.9 The commenter states that the use of traffic counts taken during March 2015 in the vicinity of Los Osos Valley Road, S. Higuera Street, U.S. 101, Tank Farm Road and Buckley Road is misleading and inaccurate in assessing the current traffic conditions. The commenter states that at the time of these traffic counts, normal traffic patterns were significantly altered as a result of it being a late midpoint of construction of the Los Osos Valley Road Interchange Project which included lane closures, etc. The commenter suggests that current traffic counts now that the Los Osos Valley Road interchange Project is completed should be taken in order to accurately describe the current traffic and more accurately assess/project the traffic volumes. The commenter states that the Multimodal Transportation Impact Study began following or at the near point completion of the Interchange Project; and suggests that new traffic counts should have been taken at that time. The commenter states that the currently included traffic counts are not representative, should be revised and the mitigation measures reassessed based on current more accurate counts, and that such significant changes would trigger re-release of the Draft EIR under CEQA. This comment is not consistent with the technical analysis in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L). Refer to Response 21.8 for a discussion of the timing of the existing traffic counts. 8-140 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 21.10 The commenter states that neighborhoods and neighborhoods where schools are located in the vicinity of the project site were not properly noticed of the project scoping hearing, Draft EIR hearing, and Draft EIR release. Refer to Response 21.2 for a discussion of noticing requirements and actions carried out for the project. Response 21.11 The commenter summarizes their concerns with the Draft EIR’s compliance with CEQA requirements. The commenter requests that the Draft EIR be revised, noticed, and recirculated. Refer to Responses 21.2 through 21.10. 8-141 C01 T SA N:LiIIS OBISPCI COUNTY OF SAN LUIS OBISPO DEPARTMENT OF AGRICULTURE / WEIGHTS & MEASURES Marty 5ettevendemie Ag Commissioner/ County Sealer DATE: January 26, 2017 TO: Doug Davidson, Deputy Director FROM: Lynda L. Auchinachie, Agriculture Department SUBJECT: San Luis Ranch Specific Plan Draft Environmental Impact Report (1921) The Draft Environmental Impact Report for San Luis Ranch Specific Plan identifies the p6tential for land use incompatibilities between the proposed residential and agricultural uses. The San Luis Obispo County's Agriculture Element has an agricultural buffer policy that may be of assistance when determining an adequate buffer size to reduce incompatibilities. In general, a buffer for irrigated vegetables would range from 200-600 feet. I have attached a copy of the buffer policy for your reference. Comments and recommendations are based on policies in the San Luis Obispo County Agriculture Element, Conservation and Open Space Element, the Land Use Ordinance, the California Environmental Quality Act (CEQA), and on current departmental policy to conserve agricultural resources and to provide for public health, safety and welfare while mitigating to the extent feasible the negative impacts of development to agriculture. If you have questions, please call 781-5914 Department of Agriculture / Weights & Measures 2156 Sierra Way I San Luis Obispo, CA 93401 I (P)80S-781-5910 I (F) 805-781-1035 agcommslo@co.slo.ca.us I slocounty.ca,gov/agcomm 8-142 APPENDIX C: AGRICULTURAL BUFFER POLICIES vie foilmmg ag Duffer policies have been adopted by the Board of Supervisnrs;revised .November 2(1 5). llolicv Statement It is the policy of the lgricultural C011urissioner and Phiniung Director through the countv's land use Agriculture Element to: Promote and protect alriculrure Protect the public's health and safen 3. Provide the Board of Supe.msors, LAK0, School Districts, and Ci.n, Councils with technical information, assistance and buffer re.comi-ienclarions to address Lind use comparlblllry and is ries affecting agriculture. Objectives Ihe AgrlctilRlral (,011iliilsslollerwiLl e"alLlate referrals to deternlllle if pote.11u.al 'tilgillflc:lllt land u e c(infllct" between agricultural lands and non-agricultural lands will occur with the proposed project. 'I lie basis for (lie determination and recommended nlirigation measures will be provided in a written report. Determination and recommendations are advisors- and made on a site-specific basis wirhiri the established buffer policies and procedures. Buffers !reduce Land Use Contlict from: Pesticide I'se A. Provides for a margin of safety for the public and sensitive non -Larger areas. B. Reduces die need for sprain buffers or other governmental restrictions which negatively imlaact agriculture. C. Helps maintain the feasibility of pesticide use as in alternative for sustainable agriculture. D. Reduces local neighbor conflict and compliants ro agriculturalist and goverrimenr agencies. 2. Noise and Night time lighting A, Reduces the potential for nuisance from a v,.mety of agricnlrural sources such as bird frightening devices, pumps, heavy equipment, wind machines, etc. B, Reduces local neighbor conflict and complaints to governluulral agencies. C. Reduces the disturbance frorn noise and light associated with light han-estirlg. AGRICUI.TURP Ei. FMFNT C-1 AGRICULTURAL BUFFER 1101 ICIFS RF\%isED MAY 2010 APPE'NDIX C 8-143 3. Dust A. Creates distance or screeiliilg for dust to settle out before offecring hones or people. 4. l'respass/%andalism/'l belt%T.irter/T,iabilin A. 1-'Ie1pj reduce the pOrelltlal ne„aUICe I111pact rhal people and pets Ciro have on agniculuural pr.Opel'tl'. B. Helps reduce the impact tlrar 611 a.- livestocic can have cm neighbor p1•operrt•. 5. Rodent Control 1. Helps maintain the use of agricultur l rodent control materials which mai be otherwise prohibited in close prosiminv to hollies, schools, and other urban areas. B. Reduces the likelihood of accidental poisoning of pets. 6. _Agricultural Burris A . Helps maintain agriculrural burning as a cuIrtu•stl management tool. Otherwise, burns Inas• be ptollibited nr further re;gulared if dwelliile=s ;Ire built toy, close to agriculrund properly. 13. Prowms the publics licalth and safcry. 7. BQukeepers jA1 Helps preserve the use of bees for honcy production and pollinarion. Othm isc, beekeepers mag be forced to move hive ser,,., out or -agricultural areas due to close proximity- to urban areas. B. P[otCCCS the public's 11Ca1d1 and , ens frons bees searching Cor food incl water. 8. Erosion and Development A. Reduces the sources ofsoil erosionIll agriculturaIIrea fro I'll develnpIll ell tactivitie.s oil adjacent lands. B. Reduces impacts on agriculture from flooding and siltation. 9. Ila.r.borage and inrroduction of agricultural disease and pests A. Protects agriculture by reducing ill iile.ident of insect and diseases morins from backvard situation; to adjacent agriculture. 10. Orher sources of land use conflict unique to certain situations. AGRICULTURAL, BI, FFER POLIC'IF_S AGRICULI C'U'. ELEMENT APPENDIX C REVISED MAY 201 0 8-144 Referral Process L The Agricultural Conuniss6ner's office responds w referrals sent by the Plamull,, Department, Public Forks, LAFCQ, School Districts, or CITY gcwernment. issues usualle relave to proposed development. land dir•isiocls, lot Gne ad;usrnaents, zoning or general pian changes adjacent to or in the ricini[ of existing ayricttlntral land use. Responses are in writing and advisory only, 3. an on -sire evaluation is conducted usually With the applicant and/or agent. Nearby agricultural operators are contacted whenever possible. 3. l,:eisting agricultural use, withira an appropriate range, is evaluated for potential significant land use conflict with the proposal. Realistic ttiiu.ace <lgricultLtral use, inn agricultural zoned parcels may alc) be considered. 4. Buffer derernunations and other nutigiuion are made on a vise ba case basis consiclerI g established bullet clistanEe ranges :and :all relevant Facrnrs. (.;e;tlnrt tit ide sranel:ucl or miltilnurn serback distances are used onh when specified in the LL O, i-Io evm this procedural guideline is followed to provide for tnaMinum consisrenc\•. 5. Reconunended mitigation ±neasures are sublecr. to review ;and modlflcatlon by the deparunent as long as the margin of safery is n.iaintained, potentisil nuisance issues are adecluarely addressed and potenrial land use conflict is munt:uned ar a level below significance. 6. agricultural Commissioner land use reports wi11 also identih potential land use contlicrs ;tnd negative impacts ro agriculture in situations ,vh1ch mat- be parrinilc or nor at all mirigared. Jfven with buffer sctbacks, etc., agriculturalists mar be turther wstricred in their producriou practices or experience losses due to adjacent clescloprnc•nt. Agricultural Commissioner's staff is available for testimony at public hearings upon the reclucsr of the Board of Supervisors, Planning CotnlnissK;n, Subdivision Revicm- Board, Planning and Building Department, LAFC O, or cin, government. Procedural Guideluies In/ro la•tior Type and extent of agricultural use, zoning, site specific non -crap factors, and the nature of rhe land use proposal are the mast sigcificant factor; ui a derermiriatIon of significant land use conflict and .subsetluenr nungation measures. Agricultural Use A. 1 -vent: An evaluation is made. if existing agricultural use is of a "production agriculture" scope. This differentlares "hobby farms", " anchenes", or other smaller non-commercial LTpe agricetltural uses. AGRICULTURE. Et F,c IENT C'- i AGRICI;f "f l 1i:11. Bl_`rFFR POLICIES REVISED MAY 2010 APPLNDI\ C 8-145 B. Type: Farming practices van considerably by type of agricultural use. Subsequendi, land use conflict determinations and .recommended mitigstion measures are often directly related to the n.pe of agricultural use poteimAlly impacted by the referred land use proposal. C. Historical/Current/Future: An evaluation malt- be made concerning the >uitabilitS- of a particular parcel or area for certain type; of agricultural uses, zoning zoning on A>ricutlntral use parcels adjacent/near the re" rred land use proposal are evaluated. J he zoning of the referred parcels and the overall zoning of the area mar• also be evaluated. A. Parcels adjacenr to [lie refer'r'al 1)1`01 ct, zoned ftgrict;lture, 1,6111 x111 csistiu r, or restli,ric future Agriculau•al use. norrnall} pix-widc a bA,i, for ;t land use corrtiicr determinarion and :subsequent nutigation measure,. B. Parcels adjacent to the referral projec r not zoned agriculture tnay provide a basis for a basis for a land use contlicr determination only if a "production agriculture" use exists at The time of evaluation. Sire Specific tiara -Crop Factors Various site specitic tactors are evaluared and por.crttially, urilizcd in bind use conflict dercrmrnacions and mitigation tncasures. Thcsc include. but arc norlimittd to: topography. pre.a'ling w-nd direction, natural screening (e.g.; vc gctarion. so -c"111 -channel:`, soil n•pe, location of existing roads, and the c%tcnr c ->i csisring devclopmcnr. Narurc of the Proposal Specific factors related to the referred land use proposal that maybe significant include, but are not limited to: parcel size, configuration, density of development, and intended rape of land use. Developments, which include dwellings or schools, may need larger buffets than businesses where the presence of people mqy be limiter{. Nfitiryarion Measure, Ob51,!, lire Building setbacks (buffer;; and/or,creening techniques (xval_ls, landscaping, etc." are t.rsefui to increase rhe likelihood of compatibilitl• between development (homes, schools, etc." and agriculrui:M properry. Puffers are the most e.ffecrire mitigation measure. AGRICULTURAL. BLTFFER POLICIES C-4 AGRICULTURE ELE)11aT APPENDIX C RFViSFD MAY 2010 8-146 ti,•np The buffer is placed on the developer's property and «i11 he recorded as a distance from the property line to the proposed occupied structure. However, the total buffer distance calculation and recomnlenchmon i measured from proposed occupied structure ro the edge of dee agricultural operation. The Duffer will allow for such land uses as landscaping, barns, storage buildings, orchards, pastures, etc., while prorecting the au,ricultural use and the public'S health and satery. The Counn; does not have the authority to restrict the agricultural land use in order to accomplish the recon1111ended butler. However, the _LgfiCultL'ral Coinnilssioner does have the authority, and has at rimes, imposed spray buffers and other restrictions to pest management. practices due to development or other potential hazards near agricultural Operations. A26cukural Buffer Disrance 1; ererminaritins General Guidelines A. Deternunatioils are made based on all relevanr site and project criteria, practical lulowledge of agricultural practices, technical literature, contact with other professionals within the Util ersitr, indusu7v. government agencies and training. B. "Margin of safen_" and "probability" concepts are used in determining setback distances. C. The department's land use reports will identify- recommended mitigation measures and will not provide alrerrlarives. D. existing dwellings adjacent to agricultural use may already ne;gauvelt• impact agriculture. Buffer mitigations address reducing future or addirional impacts and wren t necessarily affected be_- existing dWelli.ngs unless the extent of eNistiug developmenr is such that the proposal does not sigtu6eantly worsen the lard use conflict already present. Butter Distance Ranges by Crop A riculttural practices associated yvith the production of crops are the most important contributing factor to land use conflict when development occurs in close pro unity to agriculturtl areaS. Since production pracuces vary considerably In type of crop Duffel' distances may Nrary accordingly Ranges in distance are necessan due to the 1.1ltluencr their site or project specific factors may leave, AGRICULTURE ELFit4F-.\T REVISED MAY 2010 C -J AGR1C`U1JtJRA1. BUFFFR P01 IC.'IFS APPENDIX C 8-147 uEfer Distance lame by (:rr i Table 1 Me of g—ricultrtral Use F3uPier Distance Range Intensive Agricultural Uses Vine }and 00 - (still nett Irrigated orchard: if )I t - (,i tt] feer Irri,gated 1-egetables and berries 2116 . (stun feet Irrigated Forage and i-icld C:rOps Irl[[ - 400 tt:et VhOle;ale nu.r5erte, - 011tC100ts Itjlj - att[I feeer Greenhouses 11th - 300 feet 2. Non -Intensive Agricultural Uses Dn- farm held crops, orchards and vineyard; 1_00-700 feet Rangeland/pasture 50-200 Feet Sire specific non -crop cacrors (such as ropogr-,iphp, prevmling ttiind direction, and elegy anion di'ferences'r and proposal specifications often 'affect the i-Matl buffer distance recr:rlr.mendarion within ranges listed in NUMber 1 and ?. Significant overriding Factors or land unsuitable For aQriculrurll use could justity recr,rded buCer, les, [11111 the• indicated rartge. 3. Buffers and Do'elopment PoLemial Porential development on the referred land use proposal will always be considered. However, with certain types o f production agricultural crop uses its de fined in Table ? below on '.agriculrural zoned laud, theanalysis mat lead to a recomitiendarion to alter the project. F. Zoning and Buffer, 1. _Affect of _ mculnu-al I.. e Zoning (.in Project Mirra;aric,rt. Tile zoning on agricultural Use parcelq m-111acenr to rhe proprised land use refen,al ITIAC affect buffer duern-uriat1ons, The following table: applies to the zoning of parcels potentially affectc•.d by proposed projects. These parcels usuallt- adjoin the propwwd project, but man also encompass orher parcels in the nearby arca r,rcglonal considerations). AGRICULTURAL. BUFFER POLICIES C-6 AGRICC LT[RL. ELEMENT APPF.Nr)fx C R17VISF_i) []VIA Y ?010 8-148 Zoning and 13Liffel hero=1u leslciatil,+i: 1•able. Adjacent Parcel Project Parcel Mitigation Zoning Ag Use Buffers May Be Proposed Recommended Development Possible Affected fig. Zone. Production :1g. Use YCS Yes Ag. Zone Prime Soils lies ye." 1g. 'Lone Realistic Future Ag. ]Use Yes No Non -Ag. Zone Production ,'\g. Use Yes Ves Notl-A-r. Zone. Noll-pEOduction Ag. Use No o Foil -Ag. Zoite Reapstic Future Production No No Ag. Use Production agricultural use parcels in non-agricultural zone; which have 111toric agricultural value, prime. soils, or other unique agricultural characreri:tic, \will receive Elle a111e le -%-el of recorrimencled mitigation protection as dogricultural zoned parcel:. B. Use of Project dirigation on Agriculturally Zoned Parcels Typically, buffers are not neccssai7- are on parcels zoned agriculture. However. buffers xvill be reconinae tided on parcels zoned agriculture M-hich are under 20 acres III size (substandard sized IOCS comniunly known is aiidquated subdivisions). N-4aXimurn appropriate buffer distance -within approved ranges will be reconunended, but distances nlav need to be reduced to allow Cor reasonable llon)e sites on existing parcels S*eCIfIC S"iLuntlon'll Issues kXlien bUfters are reconunended fc,r proposed LIM] Use project; ;1Cl;;lce1.t to 1lro ILIC60n agricul[ure on non-agriculruraUy zoned property, the report will normally sr,,ice: "•The but ter hail become null and void if furlre cle elopnlenr on adj:ue!1r parcel(,'.precludes production a flculttlre." Such,i d .rernlination shall be inade III cOlhLtl[atlon With the Department of Agriculture. The Agricultural Cionlrtlissioner will not recon -1t1 -lend Elle specific n'pe 1;f phinu lil.tterMl or construction nlarerial for a wall or Fence for screening purposes, bur may stare and evtluate the applicants written proposal. Organic farllling practices will nor [Fplcally 111t7L1cncC 1711I1gaC1Ci !1 nleHslifca. AGRicUi,TURE El.FMENT C-7 AGR1C1;1_Tl'RAI, B(`1TF;R floi IC1Fy RFvISED MAY 2010 ,APPENDIX C 8-149 4. Proposed industrial land uses ncljacenr to agricultural areas may also present significant land use conflict. Specific types of industrial use will be evaluated oti a case-by-case basis through the normal .referral process. T_and use conflict may be significantly reduced if the agricultural Use and the proposed use is opt red%operated by the same party (eg: \t inetw or a roadside stand added to an existing agricultural operation..' G. Occupied sn-ucture(s) that already exist within a "buffer zone" are not a ffected by the buffer restrictions. Buffers w ll only affect location of proposed occupied structures. Mobile homes are considered home sites and subsequently can be replaced by permanent home construction within the buffer >.one. Permanent home replacement (e.g., fire destruction) u.-ould also be unaffected btu the buffer. Disclosure The agricultural buffer document will he duly recorded in the chsun of title of the subject property. AGRICULTURAL BUFFER POLICIES C-8 AGRICULTURE ELEN NT APPENDIX C REVISED MAY 2010 8-150 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 22 COMMENTER: Lynda Auchinachie, County of San Luis Obispo Department of Agriculture/Weights & Measures DATE: January 26, 2017 Response The commenter states that the Agricultural Buffer Policies included in the County of San Luis Obispo’s Agriculture Element may be of assistance when determining an adequate buffer size to reduce incompatibilities, and states that a buffer for irrigated vegetables would typically range from 200 to 600 feet. The commenter attaches a copy of the County’s Agricultural Buffer Policies for reference. As described in Section 2.5.1 in Section 2.0, Project Description, the project site is within the City of San Luis Obispo’s Sphere of Influence and Urban Reserve Line, and the project is designed to be consistent with both City and Local Agency Formation Commission (LAFCo) policies. Since the project would be within City jurisdiction and is not located adjacent to any land within the County, County agricultural buffer policies would not apply to the project. Neither the City nor the State has adopted standards related to the size of agricultural buffers. However, Conservation and Open Space Element Policy 8.3.2, Open Space Buffers, in the City’s General Plan requires that buffers be placed between urban development and agricultural operations. The project would include a 72-foot buffer between agricultural operations and urban development to reduce and/ or avoid noise, dust, light impacts, odors, chemical use, access by people and pets, crop pilferage, and pesticide drift to new residential and commercial land uses on the project site. The 72-foot buffer allows for 60 feet of multimodal right-of-way beyond a 12-foot landscaped buffer north of the roadway, which would include landscape trees and vegetation. Ongoing agricultural activities on the project site would be required to implement standard dust control measures required by the San Luis Obispo Air Pollution Control District (SLOAPCD). In addition, as described in Master Response 3, the Draft EIR has been revised to describe the applicant’s commitment to transition on-site agricultural operations to utilize organic farming practices. 8-151 From: Brett Cross [mailto:brettcross@yahoo.com]   Sent: Sunday, January 29, 2017 3:23 PM  To: Leveille, Brian <bleveille@slocity.org>  Subject: Project # SPEC/ER 1502‐2015 State Clearinghouse #2015101083  The Environmental Impact Report is deficient in the following areas. 1. The EIR does not address the increase in negative health consequences from located high density residential next to a major arterial road. 2. The EIR mitigation measures for the loss of roosting areas is not consistent with CEQA guidelines. 3. The EIR doesn't properly address cut-through traffic along Oceanaire Dr. 4. Mitigation measures required to bring LOS appear to speculative. Sincerely, Brett Cross 1217 Mariners Cove San Luis Obispo, CA 93405 8-152 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 23 COMMENTER: Brett Cross, Private Citizen DATE: January 29, 2017 Response 23.1 The commenter states that the Draft EIR does not address the increase in health risk from locating high density residential uses next to a major arterial road. Impact AQ-4 in Section 4.3, Air Quality, addresses the potential impact related to locating residences in the vicinity of high volume roadways. The Draft EIR determined that the project would not expose sensitive receptors to substantial pollutant concentrations from U.S. 101, the nearest high volume roadway to the project site, because the proposed residences would be more than 500 feet from U.S. 101, and because annual average daily traffic on the nearest segment of U.S. 101 is approximately 65,000 vehicles per day, which is less than the 100,000 vehicles per day threshold recommended by the California Air Resources Board (ARB) for urban roadways. Response 23.2 The commenter states that the Draft EIR mitigation measures for the loss of roosting areas are not consistent with CEQA requirements. Section 4.4, Biological Resources, discusses the project’s potential impacts to herons, as well as other species of bats and birds that may occur and roost in the project vicinity, including removal of roosting habitat and harassment or injury if these species are present in the vicinity of areas of disturbance at the time of construction. Mitigation Measures BIO-1(f), BIO-1(g), and BIO-1(h) require the implementation of a habitat enhancement plan within the project site, creation of offsite nesting habitat, pre-construction surveys, environmental monitoring, construction window limitations, passive relocation, and bat box installation. Implementation of the mitigation identified in Section 4.4, Biological Resources, would reduce potential impacts to these species to a less-than-significant level. No further revisions to the Draft EIR are required in response to this comment. Response 23.3 The commenter states that the Draft EIR doesn’t properly address cut-through traffic along Oceanaire Drive. Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) consider a percentage of the project vehicle traffic to be distributed to Oceanaire Drive (refer to Figures 6A and 6B of Appendix L for the project trip distribution). The project trip distribution does not project an impact on cut-through traffic on Oceanaire Drive. Any existing neighborhood cut-through traffic is not related to this project. However, existing cut- through traffic is reflected in the existing and no project traffic volumes in Appendix L. Response 23.4 The commenter states that mitigation measures required to achieve acceptable LOS appear to be speculative. The measures of effectiveness (i.e., speed, delay, MMLOS, volume/capacity, queues, etc.) are based on validated theoretical calculations and methodologies presented in the Highway Capacity Manual (HCM), 5th Edition. These are accepted methods for conducting traffic impact analysis. Please refer to Federal Highway Administration (FHWA) Traffic Analysis Toolbox Volume VI: Definition, Interpretation, and Calculation of Traffic Analysis Tools Measures of Effectiveness. The analysis and mitigation measures are consistent with the City’s Multimodal Transportation Impact Study Guidelines. 8-153 From: Brett Cross [mailto:brettcross@yahoo.com]   Sent: Monday, January 30, 2017 3:47 PM  To: Leveille, Brian <bleveille@slocity.org>  Subject: Project # SPEC/ER 1502‐2015 State Clearinghouse #2015101083  Additional Comments 1. The EIR doesn't adequately evaluate potential health threats from heavy metals and other pollutants that will be present in storm water and settle in the multi use detention basins. 2. The EIR assumes that the multi modal split objectives will be met thus mitigating Level of Service impacts to less than significant in all but two of the intersections studied. There is no objective basis for assuming modal split objectives can be met. Sincerely, Brett Cross 1217 Mariners Cove San Luis Obispo, CA 93405 8-154 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 24 COMMENTER: Brett Cross, Private Citizen DATE: January 30, 2017 Response 24.1 The commenter states that the Draft EIR does not adequately evaluate potential health impacts associated with heavy metals and pollutants that will be present in stormwater and would settle in the proposed detention basins. Section 4.8, Hydrology and Water Quality, describes potential water quality impacts and stormwater conveyance issues within the San Luis Ranch Specific Plan Area. Specifically, Section 4.8.1(d) describes heavy metals and other pollutants that could affect water quality and could be present in stormwater. This section explains that the Central Coast Regional Water Quality Control Board (CCRWQCB) is responsible for establishing requirements that prescribe the discharge limits and establish water quality objectives for the Central Coast Basin. The project would be subject to CCRWQCB’s Resolution R3-2013-0032, which outlines runoff reduction and treatment requirements. This includes water quality treatment requirements as well as runoff retention requirements to minimize pollution in runoff water. Furthermore, as described under Impact HWQ-1, Section 7.3 of the San Luis Ranch Specific Plan (refer to Appendix B) requires development in the Specific Plan Area to be designed to conform to stormwater management requirements of the City of San Luis Obispo, including standards for Low Impact Development (LID), and construction of retention and detention systems that would be adequate to meet the needs of future development and consistent with State and local requirements. Project compliance with the requirements described in the Draft EIR would reduce potential impacts associated with detention of stormwater on the project site, including potential public health impacts, to a less than significant level. No further revisions to the Draft EIR are required in response to this comment. Response 24.2 The commenter states that the Draft EIR assumes that the multimodal split objectives will be met, mitigating LOS impacts to less than significant in all but two of the intersections studied. However, the commenter states that there is no objective basis for assuming modal split objectives can be met. This statement is incorrect. The City’s mode split objective is not an assumption of the Draft EIR. The City’s travel demand model, which is the basis for the Multimodal Transportation Impact Study (Appendix L) and the Draft EIR analysis, includes a mode choice model that predicts mode split under certain conditions. This mode choice model is validated to actual observed mode splits. The Draft EIR states that under existing and near- term plus project conditions, seven of nine study area intersections would operate at unacceptable LOS, with mitigation provided unless identified as a Class I impact. The Draft EIR concluded that impacts would be reduced to the extent feasible with the implementation of City policies and additional mitigation measures. Mitigation measures are identified in Table 4.12-1. The City’s Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. 8-155 Air Pollution Control District San Luis Obispo County January 30,2017 Brian Leveille City of San Luis Obispo 919 Palm Street San Luis Obispo CA 93401 SUBJECT:APCD Comments Regarding the San Luis Ranch Project formerly Dalidio Ranch Project Dear Mr. Leveille: Thank you for including the San Luis Obispo County Air Pollution Control District (APCD) in the environmental review process. We have completed our review of the proposed project located at Madonna Rd. in San Luis Obispo. The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment/Pre- Zoning and Development Plan/Tentative Tract Map for a 131- acre project site, including annexation of the site into the city of San Luis Obispo. The project includes construction of up to 580 residential units, 150,000 square feet of commercial development, 100,000 square feet of office development and a 200-room hotel with a portion of the site preserved for agriculture and open space use. The project is planned to be constructed in six phases, beginning in 2017. The following ore APCD comments that are pertinent to this project. GENERAL COMMENTS As a commenting agency in the California Environmental Quality Act (CEQA) review process for a project, the APCD assesses air pollution impacts from both the construction and operational phases of a project, with separate significant thresholds for each. Please address the action items contained in this letter that are highliehted bv bold and underlined text. Consistency with the Clean Air Plan Page 4.3-9 Regarding consistency with the Clean Air Plan, since the population projections (and associated VMT) in the Clean Air Plan end in 2015, APCD feels it is more appropriate to focus on the consistency with the Transportation and Land Use strategies in the Clean Air Plan. This project is located within the urban reserve line; incorporates land use and transportation control measures and strategies (even though TCM T-8 was not included as 100% Posl Consumer Recycled Poper r 805.781 .5912 r 805.78 1 .1002 w slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401 I I 8-156 Environmentql lmpoct Report t'or Son Luis Ranch Project formerly Dalidio Ronch Project lanuory 30, 2017 Page 2 of 6 noted on page 4.3-12) outlined in the Clean Air Plan; and incorporates a list of applicable mitigation measures for operational phase emissions. Therefore, with regards to the consistency analysis, the APCD would consider the project impacts significant but mitigable with the mitigation measures proposed in the DEIR. Page 4.3-3 It should be noted the California Air Resources Board maintains two of the ten stations (not 10 as stated in the DEIR) in San Luis Obispo County and the APCD maintains the rest. Construction Page 4.3-14 Under the Fugitive Dust Control Measures (AQ-2(a)) bullet #2, APCD recommends adding the following language to the mitigation measure. Since water use is a concern due to drought conditions. the contractor or builder shall consider the use of an APCD-approved dust suppressant. where feasible. to reduce the amount of water used for dust control. Page 4.3-16 MM AQ-2d addresses architectural coating activities. APCD recommends. in addition to usinglow VOC paints. that the proiect proponent consider extending coating applications by limiting the daily coating activities to reduce daily and quarterly emissions. Page 4.3-17 Due to the size of the grading project and the close proximity to numerous sensitive receptors, including Pacific Beach High School 750 feet west of the project, C.L. Smith Elementary School located approximately 1,500 feet north of the project site, and residents 75 feet to the west. APCD recommends a Construction Activity Management Plan (CAMP) be prepared to ensure the project specific equipment used for the construction achieves the emission reduction estimates that were presented in the DEIR. The CAMP shoutd be submitted to the APCD for review and approval at least 3 months before the start of construction. As indicated in the CEQA Handbook, off site mitigation measures may be required for a project that exceeds the Tier 1 threshold. Construction Phase ldling Limitations As indicated above, this project is in close proximity to nearby sensitive receptors. projects that will have diesel powered construction activity in close proximity to any sensitive receptor shall implement the following mitigation measures to ensure that pubtic heatth benefits are realized by reducing toxic risk from diesel emissions. APCD recommends these measures be added as mitigation for the construction phase of the project. 1. a. 0■‐roα J diese′ve力 ′cres sha∥comply with section 2485 ofttitle 1 3 ofthe⊂alifornia Code of Regulations. This regulation lirnits id∥ng frorn diesel―fueled cornrnercial rnotor 8-157 frlyirOrmcη ォα′加 ραcξ R"Orξ ヵ r5α ρ ιυなRα rc力 Pro」iccξ 力rmcrry pα ″鰤ο Rα ncわ Prげ CCt ノαηtrα 月/3o2θ フア Page 3 o/6 vehicles with gross vehicular weight ratings of rnore than 1 0,000 pounds and licensed for operation on highways. lt app∥es to⊂a∥fornia and non―⊂a∥fornia based vehicles. ln general′the regulation specifies that drivers of sald vehicles: 1. Sha∥notidle the vehicle′s primary diesel engine for greaterthan 5-rnlnutes at any location′except as noted in Subsection(d)Ofthe regulationi and′ 2. Sha∥not operate a dlesel―fueled aux∥iary power system (APS)to pOWer a heater,air conditioner,orany anc∥lary equipment on that vehicle durlng sleeping or resting in a sleeper berth for greaterthan 5.O rninutes at any location when wlthin l,000 feet of a restricted area′except as noted in Subsection(d)ofthe regulatlon. b.orr‐roα J dieser e9uripment Shall comply wtth the 5-minute idling restttction idenJled in Section 2449(dx2)ofthe⊂alifornla Air Resources Board's ln―use()ff―Road Diesel regulation. c.Signs must be posted in the designated queuing areas and job sites to remind drivers and operators ofthe state′s5-rnlnute id∥ng∥rnit. d. The specific requirements and exceptlons in the regulations can be reviewed at the following web sites:w1/vw.arb.cコ 翼亘msprΩ ytruck_idllロ ゴfactsheetpdf and ―w.arb.ca.g型 生巽ュ=2⊇型D」L塾 =/fr00al卓 df. AND 2. ln addition to the state required dieselld∥ng requirements′the project app∥cant sha∥ comply with these rnore restrictive requirements to rninirnize impacts tO nearby sensitive receptors: a. Staging and queuing areas sha∥not be located within l,000 feet of sensitive receptorsi b. Dieselid∥ng within l,000 feet of sensitlve receptOrs sha∥not be perrnlttedi c. Use of alternative fueled equipmentis recornrnendedi and d. Signs that specify the nO id∥ng areas rnust be pOsted and enforced atthe site. Proposed truck routes should be evaluated and selected to ensure routing patterns have the least irnpact to residential dwe∥ings and Other sensitive receptors,such as schools,parks,day care centers′nursing homes,and hospitals.lfthe prqect has signincant truck trips where hauling/truck trips are routine activity and operate in close proxirnity to sensitlve receptors′tOxic risk needs to be evaluated. in additiOn to the mitigatiOn measures outlined on pages 4.3¨14 to 4.3‐16.APCD recommends the fol:owing measure be included as m■igation for this proiect l.Naturallv Occurring Asbestos Page 4.3-29 ofthe DEIR addresses natura∥y occurring asbestOs(NOA).lt shOuld be noted 8-158 fr7γ ′rOη mcη 的′柿ραcr Rcpο rι /or5α η ιυおRα ηc力 Prげ cct力 鯛 Crly θα′′ "ο Rα nc力 Prげ ccι ノαηυαr/3o2077 Pagc 4 o/6 2. notification and reDOrting to the APCD be included as a condition of approvalfor the … Demolition/Asbestos Demo∥tion activities can have potentlal negative air quanty lrnpacts′includlng issues surrounding proper hand∥ng′abatement′and dlspOsal of asbestos containing rnaterial (ACM). Asbestos containing rllaterlals could be encountered durlng the demo∥tion or remode∥ng of existing structures or the disturbance′demo∥tion,or relocation of above or below ground uti∥ty pipes/pipe∥nes(e.g.′transite pipes orlnsulation on pipes). :f this iurisdictions,including the reouiremenis stipu:ated in the Nationa:Emission Standard for Шazttrdous Air Po∥utants(40CFR61.SttLDart M‐asLestos NESHAP〕. These requirements include′but are not∥ rnited to:1)written notification′vvithin at least 1 0 buslness days of activities corlarnencing′to the AP⊂D′2)asbeStOS Survey conducted by a Certified Asbestos Consultant′and,3)app∥Cable removal and disposal requirements of identified A⊂M. Please contactthe APCD Engineering&⊂omp∥ ance Division at(805)781- 591 2 or gO to slocleanalr.o曜 山型les―r緊 襲止ョt10ns/asbestostthp for further information.丁o obtain a Notification of Demo∥tlon and Renovation forrn go to the″Other Forms″section of slocleanalr.o鱈 Jttra卑 /download―formstthp. EffecJve Februav 25,2000, . lf you have any questlons regarding these requirements,contaCtthe APCD Englneering&Comp∥ance Divlsion at(805)781-5912. Based on the information provlded′we are unsure ofthe types of equipmentthat may be present durlng the proieCt'S construction phase.Portable equipment′50 horsepower(hp)Or greater′used during construction activities rnay require Ca∥fornia statewide portable equipment registration(issued by the⊂a∥fornia Alr Resources Board)oran AP⊂D perrnit. 丁he fo∥owing llstis provlded as a guide to equipment and operatlons that may have perrnitting requirements′but should not be viewed as exclusiveo For a rnore deta∥ed listing′ refer to the ttechnical Appendices,page 4-4′in the AP⊂Dis 2012 CEQA Handbook. ・ Power screens,conveyors′dlesel engines,and/or crushersi ・ Portable generators and equipment vvith englnes that are 50 hp Or greater; ・ Electrical generation plants or the use of standby generatorsi ・ internal combustion enginesi ・ Rock and pavement crushlngi ・ Unconfined abrasive blasting operationsi ・ Tub grindersi ・ 丁rornrlnel screensi and′ ・ Portable plants(e.g.aggregate plant,asphalt batch plant,concrete batch plantr etc). 3. 4. 8-159 印И″Oρ ″c′ `α ′ノ〃ρσcr R"οriル r5α η ιυなRα ηψ PrOに cr/●″ηer/y οα山 "O Rα η6カ Prげθcr ノαηυαγ 30 2θ フア Page 5 o/6 ● 5. DemontiOn of structures coated with lead―based palntis a concern forthe AP⊂D. lmproper demo∥tion can resultin the release oflead―containing partlcles fron∩the site. Sandblasting or removal of paint by heatlng with a heat gun can resultln significant ernissions oflead. 丁herefore,proper abatement oflead before demontion Ofthese structures rnust be performed to preventthe release oflead from the site. DependiEЦ ≧on removalrnethod_ can also be found on∥ne at wwwoepattvノ lead. operational Phase Ernissions Page 4.3-19 Based on APCD calculatlons using calEEMod 201 6.3.1′at bundout the estimated annual unrnitigated operational phase ernissions vvould be over 25 tons/yearfor ROG+NOx not19,9 tons/year as indicated in ttable 4.3-9, However′APCD staff agree with the approach to provide onsite rnitigation and offsite rnitigation if needed to bring the overa∥operational phase ernissions below 25 tons/year. Page 4.3-21 1t should be noted thatthe AP⊂D has a rule vvhich addresses requirements for wood burnlng deuces. ect. Residential Wood Combustion Under APCD Rule 504′ 。 These devices include: ・ AII EPA―Certlfied Phase ll wood burning devices; ・ Catalytic wood burning devices which ernitless than or equalto 4.l grams per hour of partlculate rnatter which are not EPA― Certlfled but have been verified by a nationa∥y― recognlzed testing lab; ・ Non― catalytic wood burning devices which ernltless than or equalto 7.5 grams per hour of particulate rnatter which are not EPA¨⊂ertified but have been verlfled by a nationa∥y― recognized testing labl ・ Pe∥et―fueled woodheaters,and ・ Dedicated gas―fired fireplaces. 1‐5912. Page 4.3-25 1n addltlon to the onsite mitigation rneasures proposed on page 4.3-25′APCD recommendsthe ist. 8-160 Environmentol lmpoct Report for Son Luis Ronch Project formerly Dolidio Ronch Project Jdnuory 30,2017 Page 6 of 6 . For the hotel portion of the project, APCD recommends the San Luis Obispo Car Free Program. Vehicle emissions are often the largest source of emissions from the operational phase of development. This project has the potential to increase the amount of vehicle trips to the county and appropriate mitigation measures must be considered. San Luis Obispo (SLO) Car Free is a program to encourage car-free transportation to and around San Luis Obispo County. SLO Car Free provides tools to travelers on the pleasures and availability of traveling to the area without their cars, or by parking their cars once they arrive. By pledging to travel to, or around SLO County without a car, visitors receive special incentives from participating hotels, restaurants, transportation services, and attractions. ln addition, businesses receive free advertisement on SLO Car Free's website which highlights their efforts of encouraging "green" tourism to San Luis Obispo Counry. Businesses are also promoted through other social media networks and at the numerous events that SLO Car Free panicipates in each year. The SLO Car Free website (SlOCarFree.org) is a hub for information and web-links on transportation, lodging, attractions, and other visitor needs. Visitors can use the website to find out what they can do in SLO County and how they can do it without a car. To mitigate the potentialvehicle trips to the proposed (business/facility. etc.) the business must sign up to participate in the SLO Car Free Program. provide incentives to car-free travelers. and promote the program in their communication tools. To get signed up for SLO Car Free. please contact Meghan Field in the APCD Planning. Monitoring & Outreach Division at (8051 781-5912. Greenhouse Gases Pursuant to the CEQA Handbook, an environmental document that relies on a greenhouse gas reduction plan for an impact analysis, identify those requirements specified in the plan that apply to the project. lf those requirements are not otherwise binding and enforceable, they should be incorporated as mitigation measures applicable to the project. lt was not clear in the DEIR which measures would be binding and enforceable; therefore, APCD recommends measures that are not binding be called out specifically as mitigation measures. Again, thank you for the opportunity to comment on this proposal. lf you have any questions or comments, feel free to contact me at (805) 781 -4667. Sincerely, ｀1止 のニ MelLsaGuise Air Quality Specialist MAG/lhs CC: 」Ohn Rickenbach′City of San Luis Obispo hAplanヽ ceqaヽprolectreviewヽ 2000ヽ 2000フ 0369ヽ 2036‐9 docx 8-161 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 25 COMMENTER: Melissa Guise, Air Quality Specialist, San Luis Obispo County Air Pollution Control District DATE: January 30, 2017 Response 25.1 The commenter introduces SLOAPCD and their role as a commenting agency, and states that the Draft EIR’s determination of consistency with the SLOAPCD 2001 Clean Air Plan should focus on the project’s consistency with the Transportation and Land Use strategies in the Clean Air Plan. The commenter states that SLOAPCD considers the project consistent with the Clean Air Plan, and recommends that the project’s impacts be described as significant but mitigable with the mitigation measures included in the Draft EIR. As described in Section 4.3, Air Quality, implementation of Mitigation Measures AQ-3(a) through AQ-3(b) would ensure that the project would be consistent with the Clean Air Plan transportation control measures (TCMs) and land use strategies. However, consistent with the findings and methodology for air quality analysis of the LUCE Update EIR, the Draft EIR determined that mitigation is not available to reduce projected VMT such that the project’s vehicle trip rate increase would not exceed population growth in the region, and that the project would be potentially inconsistent with the existing 2001 Clean Air Plan 1. As required under CEQA, the Draft EIR is based on a reasonable worst case analysis for this issue. Therefore, the conclusion in the Final EIR remains that this impact would remain significant and unavoidable with mitigation. However, City decision-makers may consider the SLOAPCD’s opinion that impacts related to the Clean Air Plan are significant but mitigable in the context of Findings that would be required to be made for the project’s approval. Response 25.2 The commenter states that the Air Resources Board (ARB) maintains two of the ten stations in San Luis Obispo County and SLOAPCD maintain the rest. The first paragraph on Page 4.3-13 has been corrected as follows: Table 4.3-3 summarizes the annual air quality data for the local airshed. The ARB maintains over 60 air quality monitoring stations throughout California, including ten two stations in San Luis Obispo County. The remaining stations in San Luis Obispo County are maintained by SLOAPCD. […] Response 25.3 The commenter recommends adding language describing SLOAPCD-approved dust suppressants to Mitigation Measure AQ-2(a). Mitigation Measure AQ-2(a) has been revised as follows: 1 As part of the September 16, 2014 San Luis Obispo City County Special and Regular Meeting, the City Council voted to adopt and certified the Final LUCE Update EIR and adopted a Statement of Overriding Consideration related to the LUCE’s significant and unavoidable impacts related to its potential inconsistency with the 2001 Clean Air Plan (Resolution No. 10569). 8-162 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo AQ-2(a) Fugitive Dust Control Measures. Construction projects shall implement the following dust control measures so as to reduce PM10 emissions in accordance with SLOAPCD requirements. • Reduce the amount of the disturbed area where possible; • Water trucks or sprinkler systems shall be used during construction in sufficient quantities to prevent airborne dust from leaving the site. Increased watering frequency shall be required whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water or a SLOAPCD-approved dust suppressant shall be used whenever possible;, to reduce the amount of potable water used for dust control; […] Response 25.4 The commenter recommends that, in addition to using low VOC paints as required by Mitigation Measure AQ-2(d), the applicant should consider extending the architectural coating phase to reduce daily and quarterly emissions. As demonstrated in Table 4.3-7 of Section 4.3, Air Quality, with implementation of low VOC-emission paint as required by Mitigation Measure AQ-2(d), as well as Tier 3 off-road engine compliance and level 2 diesel particulate filters required by Mitigation Measure AQ-2(c) construction emissions would not exceed either of the SLOAPCD Quarterly Tier 2 thresholds of significance and impacts would be less than significant with mitigation. Because the commenter’s recommendation is not required to reduce this impact below the SLOAPCD’s adopted significance thresholds for construction, no changes to Mitigation Measure AQ-2(d) are warranted. Nonetheless, the commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. Response 25.5 The commenter states that due to the size of proposed grading and the site’s proximity to sensitive receptors, SLOAPCD recommends that a Construction Activity Management Plan (CAMP) be prepared to ensure the project specific equipment used for the construction achieves the emission reduction estimates presented in the Draft EIR. The commenter states that the CAMP should be submitted to SLOAPCD for review and approval at least 3 months before the start of construction. The commenter also states that SLOAPCD’s CEQA Air Quality Handbook states that off-site mitigation measures may be required for a project that exceeds the Tier 1 threshold. Including off-site mitigation in the CAMP would facilitate compliance with Mitigation Measures AQ-2(a) through AQ-2(d). Therefore, mitigation for Impact AQ-2 has been revised to include this recommendation, consistent with SLOAPCD requirements: AQ-2(e) Construction Activity Management Plan. Emissions reduction measures and construction practices required to comply with Mitigation Measures AQ-2(a) through AQ-2(d) shall be documented in a Construction Activity Management Plan (CAMP) and submitted to SLOAPCD for review and approval at least three months before the start of construction. The CAMP shall include a Dust Control Management Plan, tabulation of on and off-road construction equipment (age, horse-power and miles and/or hours of operation), construction truck trip schedule, construction work-day period, and 8-163 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo construction phasing. If implementation of the Standard Mitigation and Best Available Control Technology measures cannot bring the project below the Tier 1 threshold (2.5 tons of NOX+ROG per quarter), off-site mitigation shall be implemented in coordination with SLOAPCD to reduce NOX and ROG emissions to below the Tier 1 threshold. Response 25.6 The commenter recommends additional emissions control measures to reduce diesel-idling construction-related emissions for inclusion in Mitigation Measures AQ-2. Generally, SLOAPCD’s diesel-idling recommendations are required by existing State law or included in Mitigation Measures AQ-2(b). Mitigation Measure AQ-2(b) has been revised as follows: AQ-2(b) Standard Control Measures for Construction Equipment. The following standard air quality mitigation measures shall be implemented during construction activities at the project site: • Maintain all construction equipment in proper tune according to manufacturer’s specifications; • Fuel all off-road and portable diesel powered equipment with ARB certified motor vehicle diesel fuel (non-taxed version suitable for sue off-road); • Use diesel construction equipment meeting ARB’s Tier 2 certified engines or cleaner off-road heavy-duty diesel engines, and comply with the State Off-Road Regulation; • Use on-road heavy-duty trucks that meet the ARB’s 2007 or cleaner certification standard for on-road heavy-duty diesel engines, and comply with the State On-Road Regulation; • Construction or trucking companies with fleets that do not have engines in their fleet that meet the engine standards identified in the above two measures (e.g. captive or NOX exempt area fleets) may be eligible by proving alternative compliance; • On-road diesel vehicles shall comply with Section 2485 of Title 13 of the California Code of Regulations. This regulation limits idling from diesel-fueled commercial motor vehicles with gross vehicular weight ratings of more than 10,000 pounds and licensed for operation on highways. It applies to California and non-California based vehicles. In general, the regulation specifies that drivers of said vehicles: 1. Shall not idle the vehicle's primary diesel engine for greater than 5-minutes at any location, except as noted in Subsection (d) of the regulation; and, 2. Shall not operate a diesel-fueled auxiliary power system (APS) to power a heater, air conditioner, or any ancillary equipment on that vehicle during sleeping or resting in a sleeper berth for greater than 5.0 minutes at any location 8-164 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo when within 1,000 feet of a restricted area, except as noted in Subsection (d) of the regulation. • Off-road diesel equipment shall comply with the 5-minute idling restriction identified in Section 2449(d)(2) of the California Air Resources Board's In-Use Off-Road Diesel regulation. • All on and off-road diesel equipment shall not idle for more than 5 minutes. Signs shall be posted in the designated queuing areas and or job sites to remind drivers and operators of the 5 minute idling limit; • In addition to the state required diesel idling requirements, the project applicant shall comply with these more restrictive requirements to minimize impacts to nearby sensitive receptors: 1. Signs that specify the no idling areas shall be posted and enforced at the site. 2. Diesel idling within 1,000 feet of sensitive receptors is not permitted; 3. Staging and queuing areas shall not be located within 1,000 feet of sensitive receptors; and 4. Use of alternative fueled equipment is recommended; • Electrify equipment when feasible; • Substitute gasoline-powered in place of diesel-powered equipment, where feasible; and • Use alternatively fueled construction equipment on-site where feasible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel. Response 25.7 The commenter states that truck routes should be evaluated and selected to ensure routing patterns have the least impact to residential dwellings and other sensitive receptors, such as schools, parks, day care centers, nursing homes, and hospitals. The commenter states that toxic risk should be evaluated if significant truck trips would routinely operate in close proximity to sensitive receptors. Construction truck trips would be expected to follow the most direct route to U.S. 101, which primarily passes existing commercial areas, rather than residences. As described in Section 4.12, Transportation, the planned Prado Road overpass and southbound ramps would provide additional direct access to U.S. 101 that would not pass residential uses. As described in Section 2.0, Project Description, construction of the project would occur in six phases between 2017 and 2023 and hauling activities would occur primarily during grading and site preparation activities at the beginning of each construction phase. Based on the default construction phasing estimates used by CalEEMod, site preparation and grading activities would occur for approximately 40 to 50 days per construction phase. Potential health risk impacts are typically anticipated for projects that would expose sensitive receptors (such as residential uses) to toxic air contaminants (including diesel exhaust) for an extended period of time, generally 30 or more years. Because construction truck trips would primarily pass through commercial, not residential areas, and due to the relatively short duration of this activity in 8-165 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo comparison to the typical analysis period for health risk impacts, health risks associated with construction trips would not result in a significant impact. In addition, Mitigation Measure N-1(a) in Section 4.10, Noise, requires that construction vehicles and haul trucks utilize roadways that avoid residential neighborhoods and sensitive receptors. The measure also requires the applicant to submit a proposed construction vehicle and hauling route for City review and approval prior to grading/building permit issuance. Implementation of Mitigation Measure N-1(a) would restrict haul trucks route and reduce impacts related to toxic air contaminants from hauling and construction vehicles to a less than significant level. No additional mitigation is required. Response 25.8 The commenter states that the Draft EIR should note that prior to any construction activities at the site, the project proponent must submit to the SLOAPCD all required documentation, reports, and exemption requests related to naturally occurring asbestos (NOA). The commenter recommends that the requirement to complete NOA notification and reporting to the SLOAPCD be included as a condition of approval for the project. As noted in Section 4.3, Air Quality, the project would be required by ARB’s Air Toxics Control Measure (NOA ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations to submit a geologic evaluation and exemption request to SLOAPCD for approval prior to any grading activities. Furthermore, as described in Section 4.7, Hazards and Hazardous Materials, Mitigation Measure HAZ-6 requires sampling for NOA on site and development of a site-specific health and safety plan prior to grading activities, if NOA is detected in soil or bedrock beneath the project site. Response 25.9 The commenter states that asbestos containing materials (ACM) could be encountered during the demolition or remodeling of existing structures or the disturbance, demolition, or relocation of above or below ground utility pipes/pipelines (e.g., asbestos-cement pipes or insulation on pipes). The commenter notes that if the project would include any of these activities, then it may be subject to regulatory requirements, including the requirements stipulated in the National Emission Standard for Hazardous Air Pollutants (40CFR61, Subpart M - asbestos NESHAP). Section 4.7, Hazards and Hazardous Materials, includes a summary of NESHAP requirements. Impact HAZ-7 notes that Dalidio Farm Complex includes buildings that, due to their age, may contain asbestos and/or lead-based paint, but concludes that compliance with existing rules and regulations (SLOAPCD Rule 412, Airborne Toxic Control Measures; Section 93106 of the California Code of Regulations, Asbestos Airborne Toxic Control Measure for Surfacing Applications; CalOSHA; and California Code of Regulations §1532.1) would reduce impacts related to ACM and lead-based paint during building demolition to a less than significant level. Response 25.10 The commenter states that SLOAPCD prohibits developmental burning of vegetative material within San Luis Obispo County. The project does not propose developmental burning of vegetative material. Therefore, no revisions to the Draft EIR are required in response to this comment. 8-166 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 25.11 The commenter recommends that, in order to minimize delays, the project proponent contact SLOAPCD prior to start of the project regarding permitting requirements for construction equipment because portable equipment, 50 horsepower (hp) or greater, used during construction activities may require California statewide portable equipment registration (issued by the California Air Resources Board) or a SLOAPCD permit. The project would be required to acquire permits for portable equipment as required by ARB’s portable equipment registration program or SLOAPCD’s permit program. Response 25.12 The commenter states that proper abatement of lead before demolition of structures must be performed to prevent the release of lead from the site and notes that, depending on removal method, a SLOAPCD permit may be required. Please refer to Response 25.9 for a response to this comment. Response 25.13 The commenter states that SLOAPCD calculations using CalEEMod 2016.3.1 resulted in estimated annual unmitigated operational phase emissions at buildout that would exceed 25 tons/year for ROG+NOX, not 19.9 tons/year as indicated in Table 4.3-9. However, the commenter concludes that SLOAPCD staff agree with the approach to provide onsite mitigation and offsite mitigation, if required, to bring the overall operational phase emissions below 25 tons/year. The commenter does not provide their modeling results or recommendations for changes to model assumptions that could be replicated to determine the source of the discrepancy between their annual operational results and those estimated in the Draft EIR. Nonetheless, as noted by the commenter, Mitigation Measures AQ-3(a) and AQ-3(b) would be required to reduce daily operational phase emissions and would simultaneously reduce annual operational emissions below threshold levels. Response 25.14 The commenter states that SLOAPCD has a rule which addresses requirements for wood burning devices (Rule 504). SLOAPCD recommends this condition be added to the list of applicable mitigation measures for the operational phase of the project. Rule 504 states that no wood burning device for which a building permit application is submitted on or after February 1, 1994, may be installed in any new or existing dwelling unit unless it is a District-approved device. Mitigation Measure AQ-3(a), Standard Operational Mitigation Measures, includes the option of prohibiting all residential wood burning appliances in order to reduce daily operational emissions. As discussed in Response 29.48, the applicant is proposing to include provisions restricting installation of wood burning devices in project residential units. Therefore, no additional conditions requiring compliance with SLOAPCD Rule 504 are required. Response 25.15 The commenter recommends that Mitigation Measure AQ-3(a), Standard Operational Mitigation Measures, require the hotel component of the project to participate in the SLO Car Free Program, provide incentives to car-free travelers, and promote the program in their communication tools. Mitigation Measure AQ-3(a) has been revised as follows: 8-167 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo AQ-3(a) Standard Operational Mitigation Measures. Prior to issuance of grading permits, the applicant shall define and incorporate into the San Luis Ranch Specific Plan standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook to reduce emissions to below daily threshold levels. Emission reduction measures may shall include, but would not be limited to: […] In addition, the proposed hotel component of the Specific Plan shall participate in the SLO Car Free Program, provide incentives to car-free travelers, and promote the program in their communication tools. Plan Requirements and Timing. Future development shall incorporate the listed provisions into development plans and submit proof that emissions have been reduced to below daily threshold levels through a combination of these measures and off-site mitigation (described in Mitigation Measure AQ- 3[b]) prior to issuance of grading permits. Monitoring. The Commercial Development Department shall verify compliance prior to issuance of grading permits. The Commercial Development Department shall site inspect to ensure development is in accordance with approved plans prior to occupancy clearance. Commercial Development staff shall verify installation in accordance with approved building plans. Response 25.16 The commenter states that an environmental document that relies on a greenhouse gas reduction plan for an impact analysis must identify those requirements specified in the plan that apply to the project. The commenter recommends that requirements that are not otherwise binding and enforceable should be incorporated as mitigation measures applicable to the project. Table 4.6-3 in Section 4.6, Greenhouse Gas Emissions, identifies requirements specified in the City of San Luis Obispo Climate Action Plan that apply to the project. The consistency analysis in Table 4.6-3 is based on design features of the project detailed in Section 2.0, Project Description. If approved, the design features described in the project description would become conditions of approval for the project. No additional mitigation measures are required to ensure that the project would comply with requirements specified in the Climate Action Plan. 8-168 Maptinrt• From: Davidson, Doug Sent: Monday, January 30, 2017 7:34 AM To: Bergman, Katelin Cc: John Rickenbach Subject: FW: San Luis Ranch DEIR comments Attachments: San Luis Ranch DEIR comments.pdf Follow Up Flag: Follow up Flag Status: Flagged Item: %M Lv S 2 nv i 1D 1 RECEIVED 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 8-169 1 of 7 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 8-170 2of7 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 orparks... 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 8-171 3of7 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. 8-172 4 of 7 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 doated- 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 8-173 5 of 7 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 8-174 6of7 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 8-175 7 of 7 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 8-176 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 26 COMMENTER: Anne Wyatt, Private Citizen DATE: January 30, 2017 Response 26.1 The commenter states that they generally concur with the Draft EIR’s consideration of project impacts and mitigation measures. The commenter also states that they believe that a few impact areas merit further discussion, analysis, and in some cases, assigning a higher level of impact. The commenter also states that the Draft EIR should provide more analysis of Alternative 3. The following comments in the commenter’s letter provide further specificity to the commenter’s concern with the discussion, analysis, and impact conclusions in the Draft EIR. The commenter’s specific concerns and recommendations are addressed in Responses 26.2 through 26.17. Response 26.2 The commenter expresses concern for funding of required improvements including the Prado Road Overpass, stating that the Final EIR should address and analyze the possibility there will not be sufficient funding for the overpass, and should identify impacts that would be mitigated by the Prado Road Overpass as significant and unavoidable. Refer to Master Response 2 for a discussion of the funding and feasibility of the Prado Road Overpass mitigation. Response 26.3 The commenter notes the City’s Land Use and Circulation Element multimodal objectives, and suggests that dual left turn lanes as a mitigation measure would conflict with the Land Use and Circulation Element goals and the City’s Bicycle Transportation Plan, and will prevent the City from reaching these goals. The Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. Based on the General Plan multimodal priority ranking as shown in Table 4.12-3, vehicular impacts take priority over bicycles at this location. Based on California Vehicle Code, vehicles shall yield to bicycles on the roadway. Bicycles can use the outside of the left turn lane(s) to turn at signals in a safe and convenient manner while signaling. Bicycles would also be accommodated on parallel Class I facilities or frontage roads along Madonna Road, Los Osos Valley Road, and Higuera Street. Bicycles may use sidewalks and crosswalks if needed. Based on the Bicycle Transportation Plan, the City may install bike boxes at intersections to facilitate bicyclist left turn positioning and provide adequate bicycle visibility and safety. Response 26.4 The commenter states that the project is inconsistent with General Plan Housing Element Policy 11.2, which states that the City should “Prevent new housing on sites that should be preserved as dedicated open space or parks…” The commenter states that denser housing on the project site would preserve more prime agricultural soils, and states that more detail about Alternative 3 would provide more information about whether this alternative would minimize agricultural land disturbance while retaining historical structures in place. The commenter states that a project that provides housing while consuming less of the prime agricultural land on the project 8-177 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo site should be analyzed in the Draft EIR. Refer to Section 4.9, Land Use/Policy Consistency, for a discussion of the project’s consistency with Housing Element Policy 11.2. It should be noted that this policy does not identify prime agricultural soils as “open space or parks.” The project’s consistency with City General Plan policies related to the preservation of agricultural resources is discussed in Section 4.2, Agricultural Resources, and Section 4.9, Land Use/Policy Consistency. Section 6.0, Alternatives, evaluates Alternative 3, which would preserve the existing historic structures on the project site, and Alternative 4, which would preserve a larger area of the prime agricultural soils on the project site. Refer to Master Response 1 for a discussion of the adequacy of the range of alternatives evaluated in the Draft EIR. Response 26.5 The commenter states that the loss of Class I and Class II prime agricultural soils should be considered a significant and unavoidable impact. The commenter also expresses the opinion that the Draft EIR statement that “Land Use Element Policy 1.9.2 allows development on prime agricultural land if the development contributes to the protection of agricultural land,” is incorrect and represents circular thinking. Land Use Element Policy 1.9.2 states that “The City may allow development on prime agricultural land if the development contributes to the protection of agricultural land in the urban reserve or greenbelt by […] securing for the City or for a suitable land conservation organization open space or agricultural easements or fee ownership with deed restrictions.” Impact AG-1 describes the Draft EIR findings that the direct conversion of FMMP-mapped Prime Farmland to non-agricultural uses would be a significant but mitigable impact. Mitigation Measure AG-1 requires conservation in perpetuity of comparable agricultural land, which is consistent with the intent of Land Use Element Policies 1.9.2 and 1.13.8. Land Use Element Policy 1.13.8 specifically envisions development on up to 50 percent of the net site acreage within the San Luis Ranch Specific Plan area, and also allows for off-site preservation of comparable agricultural land to satisfy this requirement. Additionally, as described in Section 4.2, Agricultural Resources, City General Plan Land Use Element Policy 8.1.4.f requires that one half of the total land or easements be dedicated for open space use, and that land dedicated to agriculture shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation (including potential off-site preservation). The project includes a commitment, which will be included in the Development Agreement, to procure an off-site agricultural conservation easement/deed restriction to comply with Land Use Element Policy 8.1.4.f. Response 26.6 The commenter states that not only should the impact to prime agricultural soils be identified as significant and unavoidable, but that the Draft EIR should recalculate the actual agricultural remainder land. The commenter states that the acreage reflected in the Draft EIR includes the proposed the Agricultural Heritage Facilities & Learning Center, which should be considered developed. The commenter suggests that there is sufficient area on the site to place commercial operations within commercial development zones, and that encroaching on active agriculture in order to protect it is flawed. The potential agricultural impacts of the project are discussed in Section 4.2, Agricultural Resources, and Section 4.9, Land Use/Policy Consistency, discusses applicable General Plan and Specific Plan policies related to the preservation of agricultural heritage at the project site. The development of the Agricultural Heritage and Learning Center is potentially consistent with policies related 8-178 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo to cultural heritage, conservation and open space, and land use. The Draft EIR identifies this loss of Prime Farmland as a significant impact, and requires Mitigation Measure AG-1, which requires that impacts to Prime Farmland be mitigated at a 1:1 ratio (acres of Prime Farmland converted to acres of Prime Farmland preserved in perpetuity). It should be noted that the acreage calculations presented in the EIR are based on the Draft Specific Plan included in Appendix B, and the acreage required mitigation would be calculated based on the final map , as well as subject to the review and approval by the City’s Natural Resource Manager, consistent with revisions made to Mitigation Measure AG-1 in Responses 29.4 and 29.41. Mitigation Measure AG-1 allows for the required mitigation to be achieved through dedication of an on- and/or off-site easement(s) or deed restriction(s) located within or contiguous to the City’s Urban Reserve Line or Greenbelt. In addition, Mitigation Measure CR-1(c) requires that the Agriculture Heritage Facilities & Learning Center include interpretive signage detailing the history of the San Luis Ranch Complex and the project site, its significance, and its important details and features, including images and details from the HABS documentation described in Mitigation Measure CR-1(b) and any collected research pertaining to the historic property. Response 26.7 The commenter states that the Residual Impacts discussion under Impact AG-1 is unclear. As shown in Table 4.2-3, 112 acres of the project site are Cropley clay with 0 to 2 percent slopes, and Salinas silty clay loam with 0 to 2 percent slopes, which may be categorized as Prime Farmland by the FMMP. Pursuant to the Land Use Element Policy 1.13.8, 50 percent or 56 acres, of the project site’s acreage must be retained in agricultural and/or open space uses. Based on this requirement and as discussed in Response 29.42, this section of Impact AG-1 has been revised for clarity as follows: 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 56 acres of land of comparable agricultural productivity to be preserved in perpetuity on- or off-site to satisfy the requirement of Mitigation Measure AG-1 that impacts to Prime Farmland be mitigated at a 1:1 ratio acres of Prime Farmland converted to acres of Prime Farmland preserved in perpetuity). 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 56 acres of Prime Farmland offsite as required by Mitigation Measure AG-1 would result in a minimum of 3 acres of Prime Farmland required to be preserved off-site (56 total acres required to be preserved minus 53 acres proposed to be preserved on-site) mitigation ratio of approximately 10:1 (acres preserved off-site to acres required on-site), which would appear to satisfy the intent of the “substantial multiplier” clause. However the final determination of the project’s consistency with City policy rests with City Council. Therefore, for the purposes of CEQA, implementation of Mitigation Measure AG-1 would ensure that the project would be potentially consistent with the intent of Land Use Element Policy 8.1.4.f and 1.13.8, as well as Conservation and Open Space Element Policy 8.6.3 (refer to Section 4.9, Land Use/Policy Consistency, for a detailed discussion of the project’s consistency with applicable City policies). However, the final determination of the project’s consistency 8-179 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo with City policy, including the degree to which the project satisfies the “substantial multiplier” clause, rests with City Council. Therefore, with implementation of Mitigation Measure AG-1, this impact would be reduced to a less than significant level. Response 26.8 The commenter notes that affordable housing makes up six percent of the residential uses proposed for the project relative to the 14 Class I impacts identified for the project. The commenter also states that the project should be designated as “Potentially Inconsistent” with Housing Element Policy 2.4 due to the amount and distribution of affordable housing included in the project. As described in Subsection 2.5.2 of Section 2.0, Project Description, the affordable housing component of the project has been developed in accordance with City requirements and specification. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. The information and question raised by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 26.9 The commenter states that the growth-inducing impacts of the project should be analyzed in the Draft EIR, including housing impacts and parking scenarios. The commenter suggests that an alternative housing mix and phasing could better meet the project objectives and reduce Class I impacts. Refer to Section 4.14, Population and Housing, for a discussion and analysis of project impacts to population and housing and Section 5.0, Other CEQA-Required Discussions, for a discussion of the growth-inducing effects of the project and potential impacts associated with these effects. Refer to Section 6.0, Alternatives, as well as Master Response 1 for a discussion of the adequacy of project alternatives evaluated in the Draft EIR in complying with CEQA while meeting the basic objectives of the project. Response 26.10 The commenter suggests that Phases 1, 2, and 3 of the project be reversed in order for smaller, more affordable housing to be constructed prior to other housing types. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. The commenter’s suggestion will be forwarded to the appropriate decision-makers for review and consideration. Response 26.11 The commenter states that rental housing should be required as a percentage of the proposed housing within the Specific Plan Area. This comment pertains to the Specific Plan, which does not reflect on the adequacy or content of the Draft EIR. This comment will be forwarded to the appropriate decision-makers for review and consideration. Response 26.12 The commenter states that the Draft EIR should include analysis of the parking associated with residential development included in the project in order to assess the impacts of parking areas to transportation and circulation. As discussed in Response 18.3, the trip generation estimates in the Multimodal Transportation Impact Study (Appendix L) consider intersection spacing, residential neighborhood traffic calming aspects, and internal site circulation. Mitigation measures are provided for significant transportation and circulation impacts that are identified as part of the traffic impact analysis, which are described in Section 4.12, Transportation. In 8-180 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo addition, on September 27, 2013, Governor Brown signed SB 743 into law, which makes several changes to the State CEQA Guidelines for residential, mixed-use, and employment center projects located in infill areas. SB 743 provides that parking impacts for infill projects are not considered significant impacts on the environment under CEQA. As such, circulation impacts caused by the design of the project, including the location of residential driveway sand parking areas, are addressed in the Draft EIR. Response 26.13 The commenter states that the project should be designated as “Potentially Inconsistent” with Housing Element Policy 8.1 in the Draft EIR because parking-related and mobility impacts are unaddressed. Refer to Response 26.12 for a discussion of the analysis included in the Draft EIR relative to the project site’s internal circulation and mobility. Response 26.14 The commenter states that the City should require mandated median-income and workforce- income affordable deed restrictions to mitigate impacts and target housing to City needs. This comment pertains to the management of the proposed uses, which does not reflect on the adequacy or content of the Draft EIR. Refer to Response 26.8 for a discussion of the affordable housing distribution included in the project. The suggestions provided by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 26.15 The commenter states that it is unlikely that employees of the proposed commercial uses would live in the proposed on-site residential units or that residents of the proposed residential uses would work in the proposed on-site commercial space. This comment does not reflect on the adequacy or content of the Draft EIR. This comment will be forwarded to the appropriate decision-makers for review and consideration. Response 26.16 The commenter states that an alternative evaluating a project with a wider variety of housing in a denser mixed should be including in the Draft EIR. Section 6.0, Alternatives, includes descriptions and analyses of four alternatives determined to constitute a “reasonable range” of project alternatives, consistent with CEQA requirements. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for discussion of the adequacy of project alternatives evaluated in the Draft EIR. Response 26.17 The commenter recommends that Appendices should be titled, rather than only numbered, when posted on the City’s website for public review. No revisions to the Draft EIR are required in response to this comment. However, the commenter’s recommendation will be forwarded to the appropriate decision-makers for review and consideration. 8-181 January 30, 2017 City of San Luis Obispo Community Development Department Attn: Brian Leveille, Senior Planner 919 Palm Street San Luis Obispo, CA 93401 Re: San Luis Ranch Environmental Impact Report Dear Mr. Leveille, I am a young professional living in San Luis Obispo for almost 10 years since graduating from Cal Poly. I was lucky enough to find a job locally and was thrilled to be able to stay in the area after college. Since then, my fiancé and I have rented a tiny apartment downtown, less than 450 square feet. We have scraped and saved over the years and have dreamed of owning a home in San Luis Obispo. I strongly support the San Luis Ranch Project and really appreciate the diversity of housing it offers. I love that there is something for everyone with this project– 580 units that vary from single family units to studio apartments. This covers a large variety of buyers and will fit so many needs! I feel that the City needs more range in the housing it offers – we mostly see single family units in town which price most first time homebuyers out of the market but are also completely oversized for many families looking to live more “minimally.” I think the EIR went into an incredible level of detail and I support this project and all of the mitigation measures and elements as proposed. I think the design of the project was very well thought out and appreciate elements such as green building and energy efficiency, parks and open spaces, and a connection to local agriculture. This is a great infill project that will not contribute to urban sprawl and allow us to reduce GHG emissions by providing housing closer to where people work (less commuters). I appreciate the time and effort staff has taken in reviewing this project and am very much looking forward to the certification and approval of the EIR. Thank you for time your time. Sincerely, Dianna Beck San Luis Obispo Resident 8-182 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 27 COMMENTER: Dianna Beck, Private Citizen DATE: January 30, 2017 Response The commenter states support for the project and the detail included in the Draft EIR. The commenter’s support and comments will be forwarded to the appropriate decision-makers for review and consideration. 8-183 From: Streder, Melissa@DOT [mailto:melissa.streder@dot.ca.gov]   Sent: Monday, January 30, 2017 3:55 PM  To: Leveille, Brian <bleveille@slocity.org>  Cc: Newland, Larry C@DOT <larry.newland@dot.ca.gov>; Mcclintic, Paul@DOT  <paul.mcclintic@dot.ca.gov>; Valadao, Paul@DOT <paul.valadao@dot.ca.gov>; Boyle, Frank@DOT  <frank.boyle@dot.ca.gov>; Hendrix, Peter A@DOT <peter.hendrix@dot.ca.gov>; Utter, Cindy A@DOT  <cindy.utter@dot.ca.gov>; Inkrott, Kristen K@DOT <kristen.inkrott@dot.ca.gov>; Fukushima, Adam  <AFukushima@slocity.org>; Hudson, Jake <jhudson@slocity.org>  Subject: Caltrans Comments on San Luis Ranch DEIR    Good Afternoon Brian,    Please find attached Caltrans comments on the San Luis Ranch Specific Plan DEIR. We appreciate having  the opportunity to meet with Jake and Adam earlier this month regarding the project. The comments  provided in the attached letter are complimentary to and expand on those discussed in the meeting  upon a more detailed review of the DEIR. Contact me if you have any questions regarding our  comments. We would be happy to meet with city staff in person as well if that would be helpful. Thank  you again for the opportunity to comment on this project. I appreciate a reply that you have received  this email for our records.    Best Regards,     Melissa Streder  Associate Transportation Planner  California Department of Transportation  (805) 549‐3800  (Mon‐Thurs)      8-184 8-185 8-186 8-187 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 28 COMMENTER: Melissa Streder, California Department of Transportation DATE: January 30, 2017 Response 28.1 The commenter states that the California Department of Transportation (Caltrans) has reviewed and attached their comments on the Draft EIR. The commenter notes that their comments in this letter are complimentary to and expand on those discussed in an earlier meeting with City representatives. Subsequent comments from this letter are addressed in Responses 16.2 through 16.8. Response 28.2 The commenter expresses gratitude for the opportunity to comment on the Draft EIR. The commenter expresses support for the project goals of providing work-force housing while offering multimodal transportation alternatives and notes that the project objectives are consistent with the Caltrans Strategic Management Plan 2015-2020 and State planning priorities. The commenter’s support of these objectives will be forwarded to City decision-makers for their consideration. Response 28.3 The commenter notes that a meeting with City Public Works staff occurred on January 3, 2017, and references the Caltrans U.S. 101 Transportation Concept Report (TCR), which identifies severe congestion and longer periods of forced-flow traffic conditions on U.S. 101 as becoming more frequent by 2040 through the City of San Luis Obispo. The commenter states that the mitigation proposed at U.S. 101 and Prado Road for the project would create challenges in approving a full interchange at U.S. 101 and Prado Road due to Caltrans’ interchange spacing requirements. Refer to Master Response 2 for a discussion of the feasibility of the Prado Road Overpass mitigation. Response 28.4 The commenter requests that the Final EIR include additional ramp merge and diverge analysis as well as a weaving analysis, and requests sufficient time to review and comment on the additional analysis. The commenter states that their analysis of existing conditions indicate that there is substantial queueing at the U.S. 101/Los Osos Valley Road southbound off-ramp onto the U.S. 101 mainline. The commenter also requests that the Final EIR include a weaving analysis prepared using the Leisch method for the short weave intersections between the northbound U.S. 101/Prado Road on-ramp to the northbound U.S. 101/Madonna Road off- ramp and the segment between the southbound U.S. 101/Marsh Street on-ramp to the southbound U.S. 101/Madonna Road off-ramp. The commenter notes that a Project Initiation Document (PID) is currently being prepared to evaluate options for the Prado Road Overpass. The commenter states given the status of the PID and need for additional analysis, it would be premature to condition any phase of the development with the requirement of a full interchange at Prado Road. 8-188 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo The most current information and analysis available at the time of the Draft EIR in regards to queuing at the U.S. 101/ Los Osos Valley Road southbound off-ramp onto the U.S. 101 mainline is provided in the Multimodal Transportation Impact Study (Appendix L) and is the basis of the Draft EIR transportation analysis. Ramp merge and diverge analysis as well as weaving distance is not provided in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) because it is not identified as a measure of effectiveness with impact thresholds or as required content of traffic impact study reports per the Caltrans Guidelines for the Preparation of Traffic Impact Studies. This analysis is being provided separately in support of the PSR for the Prado Road Overpass/Interchange. Refer to Master Response 2 for a discussion of the feasibility of the Prado Road Overpass mitigation. Response 28.5 The commenter requests that any run-off from the project site not be conveyed into Caltrans' right-of-way. The commenter also states that post-development run-off should not be added to Perfumo Creek. The commenter notes that they do not support storm run-off impacts from the project to U.S. 101. Refer to Response 24.1 for a discussion of stormwater conveyance issues and detention and treatment requirements for the project. Response 28.6 The commenter recommends that the proposed commercial development at the northwest corner of the project site be set back sufficiently from U.S. 101 to allow for maintenance activities. The commenter notes that future maintenance of the development within the State’s right-of-way would require a third party maintenance agreement. A requirement for building and public improvement plans within or adjacent to State right-of-way would be required by Caltrans to ensure adequate access is provided for maintenance. Response 28.7 The commenter expresses support for sustainable development that would facilitate the reduction of vehicle miles traveled (VMT). The commenter recommends the implementation of innovative design and TDM measures. Based on the San Luis Ranch Specific Plan, the proposed mixed used development presents a twenty percent internal capture rate in the PM peak hour, with incentives to take alternate modes of transportation. This assumption is incorporated into the Multimodal Transportation Impact Study (Appendix L) analysis. These multimodal incentives include a transit ‘hub’ that will directly serve the development, Class I bike trails located internally to the project site with access to adjacent proposed land uses and existing communities, additional parks and recreational uses for the new residents and guests, and bicycle and pedestrian accommodations. Response 28.8 The commenter states their interest in working with local partners to support sustainable development. The commenter expresses their appreciation of the City and developer’s efforts to address the workforce housing and transportation needs of the community while implementing development that supports multimodal choices and improved quality of life. The commenter’s statements will be forward to City decision-makers for their consideration. 8-189 January 30, 2017 Mr. Doug Davidson Community Development Department 919 Palm Street San Luis Obispo, Ca 93401 RE: San Luis Ranch SPEC/ANNW/ER 1502-2015 Draft EIR Comments SCH# 2015101083 Dear Mr. Davidson: Thank you for the opportunity to provide comments on the San Luis Ranch Draft Environmental Impact Report. We look forward to working with you and the rest of the city staff to provide as much information as possible on this project for the community and the decision makers to consider during the public review process. ES -1 and 2-1 Use address P.O. Box 13 Pismo Beach, Ca 93449 Pg. ES-9 MM T-1(h) Please add in MM the words “if feasible” based on the final design of the overpass or interchange. Pg. ES-9-15 Traffic MM The timing of the Prado Road overpass is listed as construction prior to Phase 2. Please clarify that this MM means funding of the fair share of the Prado overpass/ interchange prior to completion of Phase 2. Pg. ES-17 MM A-1 Please correct the acreage figures to 56 acres not 59.3 as noted in the Agricultural section of this letter. Pg. ES-21 MM AQ-3(a) Please delete the last two bullets or note that these are regional programs that this project could be part of in the future but not project specific. Pg. ES-21 MM AQ-3 (b) This MM is not specific to this project and does not provide the detail needed to determine if this is a feasible and financial viable MM. We are requesting that this MM be deleted. Pg. ES-27 MM BIO 1(e) Based on the volume of earth moved for this project, we request that the BIO 1 (e) bullet 6 item (3) remove the reference to 2 cubic yards of dirt being stockpiled will be covered with a tarp. Once the earthmoving and rough grading starts for the project there should be very little stockpiling involved. However if there is stockpiled material for any length of time with will be handled by other means of erosion control versus tarping the pile. Please amend this MM. Pg. ES-29 MM BIO-1(f) Bullet 3 (b) please revise this MM as the requirement of moving the existing trees with nest in them may be challenging. Pg. ES-31 MM BIO-2(b) Please add an option that tree replacements may also happen off-site in coordination with the city. This will assure that the site is not overly planted with replacement trees. Pg. ES-34 MM HAZ-5(b) See attached RWQCB Letter that concurs that the groundwater tests are below national standards. This MM is not needed anymore. Pg. ES-39 MM N-4 (b) The first section of this mitigation outlining 100 to 250 foot setbacks would result in no or very little commercial development for this site and does not reflect the 8-190 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 2 site plan within the Specific Plan on page 3-38. Please delete the first two sentences of this MM. We agree with the provisions detailing the sound wall between the commercial and residential uses Pg. ES-40 MM N-5(a) Please note in this MM that the residential units abutting the commercial center will need these additional MM but the rest of the residential units do not need this added noise mitigation. Introduction Pg. 1.1 p. 2 The map application is for a “Vesting” Tentative Tract Map. Please correct this title throughout the document. Add the word “…significant portion of the site” Pg. 1-4 p. 4 This paragraph should be revised to reflect the outcome of the traffic study for a n overpass and/or full access interchange, phased over time. Project Description Pg. 2-1 p. 4 We suggest changing the “sensitive” to prominent. Pg. 2-3 Fig. 2.2 Please add more detail to this map including street names, Laguna Lake Regional Park, Target, etc. This will provide the reader a better orientation in the site vicinity. Pg. 2-6 p. 3 Please add Laguna Lake Regional Park to the west. Pg. 2-8 Fig. 2.5 The Multifamily portion of the site should have both sections colored orange. The legend should note that this orange color is “High-Density Residential”. Pg. 2-9 Fig. 2.6 Note the same color correction needs to be done on this map for the High Density Residential. Also we request that you rotate this map to be consistent with all of the other maps in this section. Pg. 2-10 Tble 2-1 Please footnote this table and in other related sections that the Froom Ranch Way bridge crossing over Perfumo Creek and the road connection to the existing Froom Ranch Road are immediately off site of this 131. 0 acre property but part of this project review. Pg. 2-11 p. 1 Please change the building height of the multifamily portion of the project from 35 feet to 40 feet. This change should be noted throughout the document. Pg. 2-12 p. 1 The historical structure should be as high as they are in there current configuration. What if a water tower is proposed for the historic center? Would it need to be less than 45 feet or could it be higher? Pg. 2-12 p.2,3 Over the last year, work has been done to determine the type of trail to be located along the creek and based on the natural setting the city has determined that this should be a 6-foot wide nature trail. The Bike Routes will be designed on Froom Ranch Way and Dalidio Road. Please amend these two paragraphs to reflect this change to the project as it relates to the Bob Jones Trail. See attached plan that was presented to the bike committee. Pg. 2-13 Fig. 2-7 Please rotate this map to be consistent with all of the other Figures. Please update this map to reflect this plans presented to the bike committee. (See attached). There is no bike lane improvements proposed for Oceanaire. Pg. 2-15 Fig. 2-8 Please rotate this map to be consistent with all of the other Figures. It may help to add some road names to this map. Fig 2-9 Fig 2-10 Fig 2.11 Attached are updated utility plans based on the work we have been doing with the City over the last year. There are no changes to project impacts with these new maps but they reflect the project review over the last year with city staff. Please use these updated plans in the Final EIR. Pg. 2-21 Fig. 2-12 This map is consistent with the other maps in this section except that the legend is 8-191 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 3 rotated. Also it should be clear that the center park also includes underground storage (green) just like the commercial storage (blue). Please add more detail in the legend to make this clear. Pg. 2-22 p. 1 Please take the sentence about topsoil and add it Figure 2 -13. This will correct the record about saving the fertile Class I and Class II topsoil for the agricult ural operation when the project is completed. Pg. 2-23 Fig. 2-13 Please note what the gray shading is on this map. The 100 year flood plain? Pg. 2-25 Fig. 2-14 Please rotate this Figure like the others. 4.1 Aesthetics Pg. 4.1-4 p. 2 The last sentence does not reflect what was stated in the Project Description pg. 1-5 and 1-6. This site does include a transit center along with bus stops, bike trials, and walking paths. Please correct this paragraph as this site is consistent with SB 743. Pg. 4.1-14 p. 2 In the last sentence, the height for all buildings including multifamily will be 50 feet. In the Project Description we asked for a 40 foot height for the multifamily Please make this correct in this paragraph. 4.2 Agricultural Resources General comment * The entire Ag Resources section should be checked for erroneous math in Table 4.2-3, since we found numerous instances where the 3.3 acres of Salinas soils located within the creek bed and bank of Perfumo Creek are counted as prime agricultural land (bringing the converted acreage to 59.3 acres, instead of the correct 56). This error does not seem to be repeated in the Land Use section 4.9. Pg. 4.2-2 p. 1 Add paragraph describing existing entitlements (Measure J) to clarify setting. Pg. 4.2-3 p. 2 “Soils and Crop Production: Three types of soils are found…” Pg. 4.2-6 p. 3 References Table 4.2-1. Should be Table 4.2-3. Pg. 4.2-8 Fig. 4.2-2 Prime Ag acreage is incorrect – per Table 4.2-3 and Soils Report, area of Prime Farmland to be converted is 56 acres, not 59. This figure should also note the related impact to agriculture if Measure J the existing entitlements were to be built. Pg. 4.2-9 p. 4 Should reference LAFCO Policy 12. Pg. 4.2-15: Tble 4.2-3 Per Table 4.2-3, as well as Soils Report, project site contains 109 acres of Prime Farmland. (3 acres of Salinas soils are the creek and bank of Perfumo Creek). Pg. 4.2-16 p. 1 “Approximately 56 acres of on-site Prime Farmland would be converted to non- agricultural use.” (59.3 again erroneously include Perfumo Creek Salinas soil acreage.) Pg. 4.2-18 MM AG-1 All three sections of MM AG-1 should be corrected to reflect conservation of 56 acres of Prime Farmland. (59.3 again erroneously include Perfumo Creek Salinas soil acreage.) MM AG-1, Section 1 should be corrected to read “The land covered by said on- and/or off-site easements…” Pg. 4.2-19 p. 1 Residual Impacts discussion assumes 59.3 acres of off-site preservation in addition to the 50% requirement? This is inconsistent with all applicable LAFCO and City LUCE policies, and creates an internal inconsistency in the DEIR document, since Mitigation Measure AG-1 is correctly described in Table 4.9-2. This paragraph should be corrected to note 1:1 mitigation ratio not 10:1 ratio. Pg. 4.2-21 p. 2, 3 Discussions in these two paragraphs should note prevailing winds usually from the 8-192 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 4 northwest which would blow dust to the freeway away from the residential area. Pg. 4.2-21 P. 3 The 72-foot agricultural buffer mirrors the buffer that has existed on this agricultural property since the development of the Oceanaire Neighborhood . This urban agricultural field will be transiting into an organic farming operation thereby reducing further the potential conflicts between urban and agricultural uses. Please expand this discussion in this paragraph. Pg. 4.2-24: p. 5 “by converting approximately 56 acres of Prime Farmland ....” (59.3 again erroneously includes Perfumo Creek Salinas soil acreage.) 4.3 Air Quality General Comment Please confirm that the VMT analysis appropriately captures commute trips avoided/discontinued by the build out of this project. It seems that there is a misrepresentation of the VMT vs. population growth calculation. It is not clear that this project was given credit for the density of the project, affordability, multimodal project design as means to reduce traffic and relate air quality impacts. Please confirm that these project features were considered in the traffic and air quality models. Pg. 4.3-18-19 Pg. 4.3-26-27 MM AQ-3(b) This section acknowledges that this project will have significant air quality impacts during long term daily operation (Table 4.3-8) even though it also states that it is below the thresholds on an annual basis (Table 4.3-9). We question the need to do off-site Air Quality MM’s listed in AQ-3(b). Most of the listed items are regional programs. These MM measure should not be tied to the first two Phases of the project as they would be below the Operational Daily Air Pollution Emissions based on all of the on-site MM AQ-3(a) required for the project. For the rest of the Phases we question if these regional off-site mitigation measures listed in AQ-3(b) are reasonable or financially viable. This MM is open ended with no clear relationship to this project. If SLOAPCD is looking for a funding source for these regional improvements they should establish a fee program that would serve as mitigation for the impacts to air quality. We request that this MM not be tied to the grading permits of this project but some later timing based on some later timing such as Phase 4, 5, or 6, Pg. 4.3-21 Tbl. 4.3-10: #13 –Provisions restricting installation of wood burning devices will be incorporated into the SP. Please change this Table to Consistent in this line item. #18 and #47– The project site is located just over ½ mile from the proposed large Park & Ride lot on Calle Joaquin. Also, this project includes a Transit Center in the commercial area that will include parking and bike storage. Please note that this project is Consistent with the MM. #20 – Standards for roof trusses to accommodate solar panels and solar-heated water will be incorporated into the SP. Please note that project is Consistent with this MM. Pg. 4.3-22 #21 – Standards requiring building development to exceed Title 24 requirements will be incorporated into the SP. Please note that project is Consistent with this MM. 8-193 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 5 #26 – To the extent feasible on this small and micro-lot development, standards requiring passive solar design will be incorporated into the SP. Please note that project is Consistent with this MM. #27 – Standards requiring installation of high efficiency gas or solar water heaters will be incorporated into the SP. Please note that project is Consistent with this MM. Pg. 4.3-23 #33 – Standards requiring installation of door sweeps or weather stripping will be incorporated into the SP. Please note that project is Consistent with this MM. #34 – Standards requiring installation of energy-reducing programmable thermostats will be incorporated into the SP. Please note that project is Consistent with this MM. #35 – Standards requiring participation in energy-efficient rebate programs will be incorporated into the SP. Please note that project is Consistent with this MM. #36 – To the extent consistent with Airport Area land use guidelines, standards requiring the use of roofing materials with solar reflectance to reduce summer cooling SP. Please note that project is Consistent with this MM. #37- The SP does not include on site renewable energy systems. Please note that project is Consistent with this MM. #39 – Standards requiring use of battery powered or electric landscape maintenance equipment will be incorporated into the SP. Please note that project is Consistent with this MM. Pg. 4.3-24 #42 – Standards for transportation information in a display case located at the on- site bus stops and transit center public transportation center will be incorporated into the SP. Please note that project is Consistent with this MM. #50 – Standards for free-access telework terminals or wi-fi access in the multi- family component of the project will be incorporated into SP. Please note that project is Consistent with this MM. #’s 44, 45, 48 – These items involve regional share programs that maybe coordinated by the City of San Luis Obispo and SLOCOG when they are developed but should not be tied directly to this project at this time . 4.4 Biological Resources Pg. 4.4-3 Fig. 4.4-1 What is the source of the potential state/federal waters for this Figure? This is different than what A&M submitted to USACE for 404 permit. We would like to review these map for consistence. The red willow thicket habitat in SW section of project includes anthropogenic vegetation on west edge and is predominantly arroyo willow- more accurate to call willow riparian. City has requested removal of 6 canary palms downstream of Froom Ranch Way bridge as part of site mitigation near Outfall #4. Project boundary should reflect 8-194 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 6 extended boundary down riparian corridor. Figure should be updated with comments below addressed Pg. 4.4-60 BIO-1(f) Mitigation Measure Great Blue Heron and Monarch Butterfly Impact Avoidance and Minimization; specifically the part dealing with the herons. Bullet 3 (b) please revise this item. Several of the nests are in full grown older eucalyptus trees. These 60 foot high trees may not be successfully boxed and moved to another site while trying to protect the nests in the trees. Does the city want these trees at Laguna Lake? Instead revise MM to state Alternative relocations plans could be development by qualified biologist and approved by the City’s Natural Resources Manager. Pg. 4.4-56 MM Bio-1(d) Bullet 3. – Please revise “areas of project site that lie within 50 feet upland from riparian and jurisdictional areas shall be surrounded by a solid temporary exclusion fence that shall extend at least 18 inches above the ground….” Pg. 4.4-61 MM BIO-1(g) Please revise this mitigation measure to be consistent with that of Avila Ranch EIR. General timing of nesting season, required survey buffers, and required construction activity setbacks. Each of these categories appear be to more stringent for this project in comparison to Avila Ranch. 4.5 Cultural Resources Pg. 4.5-2 p. 3 “Horse Racing” p: Original track was one mile, later shortened by ½ mile. Pg. 4.5-23 p. 2 “Plan Requirements and Timing”: “shall prepare relocation and/or reconstruction plan…. prior to issuance of grading permits for the Phase 3”. In the third sentence it should say “relocated or reconstructed”, not “removed”. Pg. 4.5-26 p. 5 Please take out the word “removal” and use the word “relocate or reconstructed” as permitted in the MM’s and city policies 4.6 Greenhouse Gas Emissions Pg. 4.6-16 Tble. 4.6-1 We understand from SLOAPCD that the amortization for residential structures should be 50 years not 25 years as noted in this table. Please amend this table according. Pg. 4.6-17 Pg. 4.6-21 Tble. 4.6-2 Tble. 4.6-4 Table 4.6-2 and Table 4.6-4 provides information for the year this project is completely built out in 2020 and beyond without mitigation. It does not reflect the 2030 or 2050 state wide reductions in GHG emissions. We ask that both these tables reflect full build out date for 2020 of the project and also include two more columns that calculate the 40% reduction in 2030 and the 80% reductions 2050 required by AB 32, SB 32, AB 357, etc. With these calculations the 40% reduction would be 3.48MT per cap. And then at 2050 the 80% reduction would be at level of 1.16 per cap which is consistent with the City of San Luis Policies. Could you please add this is important information to include in this EIR. 4.7 Hazards and Hazardous Materials Pg. 4.7-4 Fig. 4.7-1 The acreage of the property shown as within adopted ALUP Safety Zone S -1b may be incorrect, since the GIS transfer from the ALUP analog map has been rectified by a correctly rotated and scaled by Cannon civil engineers. This orthographically corrected map has been accepted by the Airport Land Use Commission as the corrected representation of the adopted ALUP analog map. The new ALUC map should be used for Figure 4.7-1. 4.7-29 p.1 References to Figure 4.7-1, within ALUP S-1b safety zone, may need to be corrected based on the new map being used by ALUC. (Please see discussion above of Figure 4.7-1.) 4.8 Hydrology and Water Quality 8-195 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 7 Pg. 4.8-1- 4 p. 6 This paragraph confuses floodplains and floodways. The FEMA definitions for a floodway is: “A "Regulatory Floodway" means the channel of a river or other watercourse and the adjacent land areas that must be reserved in order to discharge the base flood without cumulatively increasing the water surface elevation more than a designated height. Communities must regulate development in these floodways to ensure that there are no increase s in upstream flood elevations”. Regulatory floodways are shown on FEMA flood maps, and there are no regulatory floodways on the project site. Also, it is the northwestern (not the northeastern) portion of the site that is outside the FEMA Special Flood Hazard Area (SFHA) . FEMA uses the term Special Flood Hazard Area (SFHA) to encompass flood insurance zones based on the 100-year flood. Two relevant FEMA definitions are: The FEMA definition of for Base Flood is: “The flood having a one percent chance of being equaled or exceeded in any given year. This is the regulatory standard also referred to as the "100-year flood." The base flood is the national standard used by the National Flood Insurance Program (NFIP) and all Federal agencies for the purposes of requiring the purchase of flood insurance and regulating new development. Base Flood Elevations (BFEs) are typically shown on Flood Insurance Rate Maps (FIRMs).” The FEMA definition of Special Flood Hazard Area (SFHA) is: “The land area covered by the floodwaters of the base flood is the Special Flood Hazard Area (SFHA) on NFIP maps. The SFHA is the area where the National Flood Insurance Program's (NFIP's) floodplain management regulations must be enforced and the area where the mandatory purchase of flood insurance applies. The SFHA includes Zones A, AO, AH, A1-30, AE, A99, AR, AR/A1-30, AR/AE, AR/AO, AR/AH, AR/A, VO, V1-30, VE, and V.” Pg. 4.8-17 Top of page The top two bulleted requirements should not app ly to areas that are no longer in a FEMA floodplain resulting from the required LOMR process (see prior bullet on page 4.8-16). Pg. 4.8-26 Impact HWQ-3 We question the wording of this item which states that the pr oposed “agricultural” uses would increase the quantities of pollutants. The word agricultural should be deleted from this impact. There will not be an increase in impacts from the remaining ag uses. Pg. 4.8-27 p. 2 This paragraph relates to stormwater treatment but indicates that the detention structures would be designed to limit the release of “first flush” water, which generally contains the highest concentration of pollutants from buildup during the dry season. This statement is incorrect. All treatment (through biofiltration and retention facilities) for this project is handled separately from the detention system which does nothing to treat flows passing through it. Pg. 4.8-27 p. 2 Also please note the discrepancy in the last half of this paragraph. No stormwater treatment is required for agricultural uses; however, the project represents a net reduction in agricultural acreage..... as a result ..... the project would be expected to reduce the long-term agricultural pollutant load There is a discrepancy between this statement and Impact HWQ-3 should be clarified. Page 4.8-28 HWQ- 3(a) This section indicates that the Master Drainage Plan shall contain ..... Hydrodynamic separation products. Currently the system is designed using LID 8-196 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 8 and Biofiltration Treatment Systems as described in Resolution R3-2013-0032, and has not planned on utilizing No-Retention Based Systems such as hydrodynamic separators. Performance Requirement No. 2: “Water Quality Treatment” lists Non Retention Based Systems as their least preferred option. Please resolve this conflict between these systems in this section. Pg.4.8-32 P. 1 In the first sentence, replace “and that the FIRM revised by FEMA to be consistent with the post-development 100-year floodplain as mapped based on the City of San Luis Obispo Waterway Management Plan hydrologic and hydrau lic models” with “consistent with the proposed site development, creek improvements and bridge, Prado Road overpass, and site and floodplain grading, and proposed detention facilities.” This comment is requested because FEMA requires the use of FEMA hydraulic models in the CLOMR/LOMR applications. The FEMA models produce results compatible with the City models for Prefumo and San Luis Obispo Creek. 4.9 Land Use Pg. 4.9-4 p. 1 The acreage of the property located within adopted ALUP Safety Zone S-1b may be incorrect, since the GIS transfer from the ALUP analog map has been rectified by a correctly rotated and scaled by Cannon civil engineers. This orthographically corrected map has been accepted by the Airport Land Use Commission as the corrected representation of the adopted ALUP analog map. Please confirm the acreage Pg. 4.9-10 Tble. The LUCE requires 5.8 acres of parkland. The project intends to provide approximately 3 acres the required parkland onsite and pay park in-lieu fees for the remainder. This approach is consistent with City Policies. 4-10 Noise Pg. 4.10-20 MM-N3 Impact specifically omits Madonna Road, but does not clarify that the existing + project noise levels are lower than existing on this segment. Please clarify the impact statement Pg. 4-10.32 Typo, last sentence. Should be Table 4.10-16. Pg. 4-10.34 MM-N5(a) Please include passive ventilation as an option on residential units. Language to demonstrate compliance should be the same as Avila Ranch, which does not specify additional reports or studies are required. Please amend this MM. Pg. 4-10.34 MM-N5(b) MM-N5(d) The outdoor hotel pool area with an 8 foot high masonry wall seems excessive. There are many other options for sound mitigation for this outdoor area associated with the pool. Please provide for other alternatives such as landscaping, berms, glass, screening features etc. that would reduce the noise from the freeway. Please provide alternative in these MM’s or delete MM-N5(d) completely. Pg. 4-10.35 MM-N5(c) As an alternative to the 6 foot high wall along Froom Ranch Way, please include an option for 6 foot high landscape berm or other options. 4.11 Recreational No Comments 4.12 Transportation See attached comment letter from ATE. 4.13 Water Resources Pg. 4.13-4 p. 1 For purposes of clarification only, the FEIR should specify that 3,380 AFY of the total Nacimiento dependable supply is considered primary, while the remaining 8-197 Mr. Davidson San Luis Ranch Draft EIR Comments 1/30/2017 Page 9 2,102 AFY, acquired in March 2016, is for secondary purposes. A footnote or reference should explain the definition of primary and secondary, as defined in the 2016 Urban Water Management Plan (UWMP), since these terms are also used in Table 4.13-2. Pg. 4.13-4 Tble 4.13-2 This table should include a footnote referenc e to the 2016 UWMP defining the difference between primary and secondary sources. In addition, it might be helpful if another column were added to this table to show how many AFY of each category is considered potable versus non-potable. Pg. 6-23 p. 3 We do not agree that Alternative 3 is the Preferred Alternative because it does not meet the Project Objective #6. By leaving the existing buildings as is, the proposed “Agricultural Heritage Facilities and Learning Center” as proposed in the Specific Plan would not be developed. Ironically by leaving the buildings in their current location they would be severed from the active agricultural operation by residential development. Also reducing the buildable area for residential use would result in less diversity of housing types because all of the units would have to be multifamily high density two and three story units. The San Luis Ranch Project as proposed with the mitigation measures from this EIR is the environmentally superior project that fully meets the goals of the City of San Luis Obispo and the Objectives of the Specific Plan. We look forward to working with you and Rincon on addressing these items. Please contact us if you have any questions on these comments. Sincerely, Laurie Tamura, ACIP Principal Planer Attachments: RWQCB letter September 17, 2015 ATE letter January 30, 2017 Updated Wastewater System Updated Domestic Water System Updated Recycled Water System Updated Pipeline System Updated Bicycle Plan 8-198 8-199 8-200 8-201 8-202 8-203 8-204 8-205 8-206 8-207 8-208 8-209 8-210 8-211 8-212 8-213 8-214 8-215 8-216 8-217 8-218 8-219 8-220 8-221 8-222 8-223 8-224 8-225 8-226 8-227 8-228 8-229 8-230 8-231 8-232 8-233 8-234 8-235 8-236 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 29 COMMENTER: Laurie Tamura, AICP, Principal Planner, Urban Planning Concepts, Inc. DATE: January 30, 2017 Response 29.1 The commenter requests a change of address for the Project Proponent in sections 0.0, Executive Summary, and 2.0, Project Description. Revisions to the Draft EIR have been made in both places to reflect the following: Coastal Community Builders c/o Marshall Ochylski (Project Representative) 979 Osos, Suite F7 San Luis Obispo, CA 93401 P.O. Box 13 Pismo Beach, CA 93449 Response 29.2 The commenter requests that the words “if feasible” be added to the text of Mitigation Measure T-1(h). As described in Master Response 2 and Response 1.1, the project applicant would be required to pay their fair share of improvement cost allocation toward the Prado Road Overpass and U.S. 101 northbound ramps prior to Phase 2 of the project, and the Prado Road Overpass and U.S. 101 southbound ramps post project completion. Therefore, if the overpass required by the mitigation measures in the Draft EIR were determined to be infeasible, the project would not be able to be implemented as planned. If the Project Study Report (PSR) or Plan, Specification, and Estimate (PS&E) identify an alternative means of mitigation for the projects transportation impacts, such a change would be accommodated through an amendment to the Specific Plan and Final EIR. Refer to Master Response 2 for a discussion of the feasibility, adequacy, timing, and funding of the Prado Road Overpass mitigation. Responses 29.3 The commenter notes that the timing of mitigation requiring the Prado Road Overpass and ramps indicates that these improvements would need to be constructed prior to Phase 2. The commenter requests that the description of phasing be modified to state that the funding of the fair share of the Prado Road Overpass/Interchange would be required prior to completion of Phase 2. Refer to Master Response 2 and Response 1.1 for a discussion of the project phasing requirements in relation to the required mitigation measures. Responses 29.4 The commenter requests that Mitigation Measure AG-1 in the Executive Summary be revised to change the acreage from 59.3 acres to 56 acres. As described in Response 29.40, approximately 56 acres of on-site Prime Farmland would be converted to non-agricultural use. Therefore, this section has been revised as follows, consistent with the revisions shown in Response 29.33, and Responses 29.40 through 29.42. Impact AG-1. The project would result in AG-1. Agricultural Conservation. Prior to issuance of any grading permits the project proponent shall provide that for With implementation of Mitigation Measure AG-1, 8-237 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo the direct conversion of 59.3 56 acres of Prime Farmland, as mapped by the FMMP, to non- agricultural uses. Therefore, impacts would be Class II, significant but mitigable. every one (1) acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to non-agricultural use as a result of project development, one (1) acre of land of comparable agricultural productivity shall be preserved in perpetuity. The land dedicated to agriculture pursuant to this measure shall be of size, location and configuration appropriate to maintain a viable, working agricultural operation. The acreage required to meet the 1:1 ratio may be met by the off-site agricultural conservation easement/deed restriction proposed by the project applicant, as long as this land meets the conditions outlined in this measure. Said mitigation shall be satisfied by the applicant through: 1) Granting a perpetual conservation easement(s), deed restriction(s), or other farmland conservation mechanism(s) to the City or qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, for the purpose of permanently preserving agricultural land. The required easement(s) area or deed restriction(s) shall therefore total a minimum of 59.3 56 acres of Prime Farmland. The land covered by said on- and/or off-site easement(s) or deed restriction(s) shall be located within or contiguous to the City’s Urban Reserve Line or Greenbelt subject to review and approval of the City’s Natural Resources Manager; or 2) Making an in-lieu payment to a qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, to be applied toward the future purchase of a minimum of 59.3 56 acres of Prime Farmland in San Luis Obispo County, together with an endowment amount as may be required. The payment amount shall be determined by the qualifying entity or a licensed appraiser; or 3) Making an in-lieu payment to a qualifying entity which has been approved by the City and that is organized for conservation purposes, to be applied toward a future perpetual conservation easement, deed restriction, or other farmland conservation mechanism to preserve a minimum of 59.3 56 acres of Prime Farmland in San Luis Obispo County. The amount of the payment shall be determined by the qualifying entity or a licensed appraiser; or 4) Any combination of the above. this impact would be reduced to a less than significant level. Response 29.5 The commenter states that the last two bullets in Mitigation Measure AQ-3(a) should be deleted or a note should be added that these are regional programs that this project could be part of in the future but are not project specific. The project’s compliance with applicable regional programs that may affect air quality is discussed in several other comments raised by the commenter, and revisions have been made to Mitigation Measure AQ-3(a) in response to these specific comments. The last two bullets of Mitigation Measure AQ-3(a) relate to providing vanpool or shuttles and providing free access telework terminals and/or wi-fi access in multifamily projects. Please refer to Responses 19.9, 29.47, 29.61, and 29.62 for responses to the specific issues raised by this comment. 8-238 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.6 The commenter requests that Mitigation Measure AQ-3(b) be deleted because it is not specific to the project and does not provide the detail needed to determine whether it is feasible and financially viable. Mitigation Measure AQ-3(b), Off-Site Mitigation, is specific to the project because the project’s operational emissions contribute to regional concentrations of criteria pollutants within the air basin and off-site mitigation would directly reduce regional pollutant concentrations. It should also be noted that Mitigation Measure AQ-3(b) is only required if implementation of standard emission reduction measures from the SLOAPCD CEQA Air Quality Handbook described in Mitigation Measure AQ-3(a) are found to be infeasible or insufficient to reduce project emissions to below SLOAPCD’s adopted daily threshold levels for land use development projects. Mitigation Measure AQ-3(b) also includes a mechanism for determining feasibility and financial viability; in accordance with SLOAPCD methodology, Mitigation Measure AQ-3(a) requires excess emissions to be multiplied by the cost effectiveness of mitigation as defined in the State’s current Carl Moyer Incentive Program Guidelines to determine the annual off-site mitigation amount and extra; this amount would then be extrapolated over the life of the project to determine total off-site mitigation. SLOAPCD has indicated in their comments on the Draft EIR (refer to Letter 25) that they agree with this approach to provide onsite mitigation as a first priority, and to allow offsite mitigation, if needed to reduce project emissions to below their adopted emissions thresholds. Please refer to Response 29.47 for additional discussion of the applicability of Mitigation Measures AQ-3(a) and AQ-3(b). Response 29.7 The commenter states that based on the volume of earth moved for this project Mitigation Measure BIO-1(e) should be revised to remove the requirement that two cubic yards of dirt being stockpiled be covered with a tarp. The commenter states that if there is stockpiled material for any length of time, it will be handled by other means of erosion control. The construction general permit requires covering all loose stockpiled construction materials that are not actively being used (i.e. soil, spoils, aggregate, fly-ash, stucco, hydrated lime, etc.). Therefore, Mitigation Measure BIO-1(e) has been revised to allow for other City-approved means of erosion control: 3. Erosion shall be controlled by covering stockpiled construction materials (i.e. soil, spoils, aggregate, fly-ash, stucco, hydrated lime, etc.) All earth stockpiles over 2.0 cubic yards that are not actively being used, shall be covered with a tarp consistent with the applicable construction general permit, or through other means of erosion control approved by the City (e.g., and ringed surrounding with straw bales or silt fencing). The site shall be maintained to minimize sediment-laden runoff to any storm drainage system including existing drainage swales and/or sand watercourses. Response 29.8 The commenter requests a revision to Mitigation Measure BIO-1(f), as the requirement of moving the existing trees with nests in them may be challenging. Refer to Response 29.64 for a discussion of revisions to this measure. 8-239 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.9 The commenter requests that the Draft EIR include an option that tree replacements required by Mitigation Measure BIO-2(b) may also happen off-site in coordination with the City. The commenter states that this revision would assure that the site is not overly planted with replacement trees. Tree replacement locations will be determined in the Habitat Mitigation and Monitoring Plan (HMMP). The applicant shall submit the HMMP to the City for approval prior to recordation of the Vesting Tentative Map. Additionally, the City Arborist and Tree Committee have expressed a preference for on-site replacement, where possible. Mitigation Measure BIO-2(b) has been revised as follows to clarify standard City practices: BIO-2(b) Tree Replacement. Riparian trees four inches or greater measured at diameter-at-breast-height (DBH) shall be replaced in-kind at a minimum ratio of 3:1 (replaced: removed). Trees 24 inches or greater inches DBH shall be replaced in-kind at a minimum ratio of 10:1. Willows and cottonwoods may be planted from live stakes following guidelines provided in the California Salmonid Stream Habitat Restoration Manual for planting dormant cuttings and container stock (CDFW 2010). • Tree replacement shall be conducted in accordance with a Natural Habitat Restoration and Enhancement Plan to be approved by the City’s Natural Resource Manager. • The Natural Habitat Restoration and Enhancement Plan shall prioritize the planting of replacement trees on-site where feasible, but shall allow that replacement trees may be planted off-site with approval of the City’s Natural Resource Manager. • Replacement trees may be planted in the fall or winter of the year in which trees were removed. All replacement trees will be planted no more than one year following the date upon which the native trees were removed. Response 29.10 The commenter refers to an attached letter, included as Comment 29.92, which summarizes the Central Coast Regional Water Quality Control Board (Water Board) review of the Shallow Soil Vapor Assessment Report prepared for the project by Enviro Assets, Inc. and Geosolutions, Inc. on July 20, 2015. The commenter states that Mitigation Measure HAZ-5(b) is no longer required based on the information included in the Water Board’s letter. Based on this comment and the conclusions of the Water Board letter, Section 4.7, Hazards and Hazardous Materials, has been revised to reflect the guidance of the Water Board on this issue, as follows: Adjacent Hazardous Materials Sites. In November 2014, Cleath-Harris Geologists, Inc. (Cleath-Harris) prepared a Hydrogeologic Description and PCE Characterization for Dalidio Laguna Ranch, San Luis Obispo County, California report (Hydrogeology Report; refer to Appendix H), which identified tetrachloroethylene (also called perchloroethylene, or PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. The project site is located adjacent to commercial uses to the northeast and residential uses to the southwest. Dry cleaning facilities have been recorded present to the north of the site as early as the 1930s. According to the 8-240 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Hydrogeology Report, the identified PCE groundwater contamination is attributed to spills at these hydrologically upgradient dry cleaning facilities. Shallow groundwater at the site generally flows towards the south-southwest, and wells on the project site have exhibited PCE groundwater contamination above the United States Environmental Protection Agency (U.S. EPA)/Central Coast Regional Water Quality Control Board (RWQCB) Maximum Contaminant Level (MCL) for drinking water of 5 micro grams per liter (µg/L). Cleath-Harris Analyzed PCE concentrations in four on-site wells and two off-site City wells to the south and the east of the site. The highest concentrations of PCE were detected at wells near U.S. 101 along the eastern side of the project site. PCE contamination is within the shallow aquifer groundwater (refer to Appendix H for detailed PCE characterization results). Groundwater within the deep aquifer could not be isolated in existing wells on the project site. Therefore, the PCE concentration in the deep aquifer is unknown. The domestic water well has a PCE concentration of 1.0 µg/L, which is within the U.S. EPA/RWQCB MCL for drinking water of 5.0 µg/L. The irrigation groundwater well has a PCE concentration of 9.5 µg/L, which exceeds the U.S. EPA MCL. […] The Initial Study determined that that the site is not near a private airstrip (Threshold 6), that the site does not expose people to significant risk of wildland fire (Threshold 7), and that the project would not interfere with an adopted emergency response or evacuation plan (Threshold 8). Therefore, Thresholds 6, 7, and 8 are not discussed further in this section. See Section 4.14, Issues Addressed in the Initial Study, for a discussion of these issues as well as discussions of potential hazards related to exposure to radiation and electromagnetic fields and identified tetrachloroethylene (also called perchloroethylene, or PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. Additionally, impacts associated with exposure to hazardous materials (Threshold 1) due to proposed agriculture uses adjacent to residential and commercial land uses are addressed in Section 4.2, Agricultural Resources. Impact HAZ-5 and Mitigation Measures HAZ- 5(a) and HAZ-5(b) have been deleted from Section 4.7, Hazards and Hazardous Materials, and Table ES-2, Class II, Significant but Mitigable Environmental Impacts, in the Executive Summary has been revised accordingly. Section 4.14, Issues Addressed in the Initial Study, has been revised as follows to reflect the Water Board’s conclusion that the project site does not pose a major threat to human health from vapor intrusion to any of the proposed development included in the project: The project Initial Study concluded that the project would result in a less than significant impact associated with hazards to the public or the environment due to listed hazardous materials sites. This issue has been further analyzed in Section 4.7, Hazards and Hazardous Materials, based on an updated search of applicable databases and reports for records relating to any known hazardous materials contamination within the San Luis Ranch Specific Plan Area. Based on the updated search results, the project was found to result in a potentially significant impact associated with hazardous materials sites, and would require mitigation to reduce potential impacts to a less than significant level. Refer to Section 4.7, Hazards and Hazardous Materials, for analysis detailed discussion of this issue. 8-241 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo In November 2014, Cleath-Harris Geologists, Inc. (Cleath-Harris) prepared a Hydrogeologic Description and PCE Characterization for Dalidio Laguna Ranch, San Luis Obispo County, California report (Hydrogeology Report; refer to Appendix H), which identified tetrachloroethylene (also called perchloroethylene, or PCE) contamination in groundwater in the vicinity of the San Luis Ranch Specific Plan Area. The project site is located adjacent to commercial uses to the northeast and residential uses to the southwest. Dry cleaning facilities have been recorded present to the north of the site as early as the 1930s. According to the Hydrogeology Report, the identified PCE groundwater contamination is attributed to spills at these hydrologically upgradient dry cleaning facilities. Shallow groundwater at the site generally flows towards the south- southwest, and wells on the project site have exhibited PCE groundwater contamination above the United States Environmental Protection Agency (U.S. EPA)/Central Coast Regional Water Quality Control Board (RWQCB) Maximum Contaminant Level (MCL) for drinking water of 5 micro grams per liter (µg/L). Cleath-Harris Analyzed PCE concentrations in four on-site wells and two off-site City wells to the south and the east of the site. The highest concentrations of PCE were detected at wells near U.S. 101 along the eastern side of the project site. PCE contamination is within the shallow aquifer groundwater (refer to Appendix H for detailed PCE characterization results). Groundwater within the deep aquifer could not be isolated in existing wells on the project site. Therefore, the PCE concentration in the deep aquifer is unknown. The domestic water well has a PCE concentration of 1.0 µg/L, which is within the U.S. EPA/RWQCB MCL for drinking water of 5.0 µg/L. The irrigation groundwater well has a PCE concentration of 9.5 µg/L, which exceeds the U.S. EPA MCL. In July 2015, EnviroAssets, Inc. and GeoSolutions, Inc. prepared a Shallow Soil Vapor Assessment Report (Appendix H), to summarize active soil gas sampling conducted at the project site in November 2014, and February and March 2015. Concentrations of volatile organic compounds identified in soil vapor samples collected during the vapor assessment were compared with Environmental Screening Levels (ESLs) provided by the RWQCB. The RWQCB provides ESLs for residential and commercial property use scenarios because land use is a consideration in the types of exposure that are possible when environmental risks are evaluated. No chemicals were detected in soil vapor samples above ESLs applicable to the proposed use of the sampled areas. PCE was detected in 36 of 47 analyzed samples (77 percent). All detections for PCE except from location SV-46, located at the southern tip of the project site in the proposed Agricultural area, were below residential ESLs. The maximum concentration of PCE detected in the sample collected at location SV-46 of 382.71 micrograms per cubic meter (µg/m3) is below the commercial ESL. Additionally, sampling results were not indicative of an on- site source for PCE and were consistent with passive migration of a dilute groundwater plume beneath the project site from off-site sources. In September 2015, the RWQCB reviewed the Shallow Soil Vapor Assessment Report. Based on the review of the Shallow Soil Vapor Assessment Report and the data therein, the RWQCB concludes that the project site does not pose a major threat to human health from vapor intrusion to any of the proposed development included in the project and no further action is necessary regarding solvents detected on the project site. Therefore, 8-242 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo impacts associated with hazardous materials sites located in the vicinity of the project site are less than significant. […] Response 29.11 The commenter states that the setback requirements in Mitigation Measure N-4(b) would result in no or very little commercial development for the project site and does not reflect the site plan within the Specific Plan on page 3-38. The commenter requests that the first two sentences be deleted from the measure. Mitigation Measure N-4(b) has been revised to eliminate the conditional requirement that parking areas and loading docks be located away from noise- sensitive land uses, and retain the requirement that a noise barrier for parking areas or loading docks would be located within 250 feet of the residential properties to the west of the commercial component, as follows: N-4(b) Parking Lot/Loading Dock Orientation and Noise Barrier. Parking areas and loading docks within the proposed retail areas shall be located a minimum of 100 feet from the property lines of the nearest residential properties. For parking areas and loading docks located a minimum of 250 feet from the property line of residential properties to the west, or for parking areas and loading docks located a minimum of 150 feet from the property line of residential properties to the west with a building intervening line-of-sight between the parking area/loading dock and the residential property, no further mitigation would be required. If parking areas or loading docks would be located closer to the within 250 feet of the residential properties to the west than described above, a masonry noise barrier shall be installed along the eastern boundary of the proposed residences adjacent to the commercial land use area on the eastern portion of the project site. The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. Response 29.12 The commenter requests that Mitigation Measure N-5(a) be revised to state that the measure only applies to residential units abutting the commercial center and would not be required for the rest of the residential units. Mitigation Measure N-5(a) is not related to noise from commercial development. Instead the measure is required for all proposed residences, hotel, and offices that may be exposed to excessive roadway noise along Froom Ranch Way and Madonna Road. Therefore, Mitigation Measure N-5(a) has been revised as follows: N-5(a) Interior Noise Reduction. The project applicant shall implement the following measures, or similar combination of measures, which demonstrate that interior noise levels in proposed residences adjacent to Froom Ranch Way and Madonna Road, hotel, and offices would be reduced below the City’s 45 dBA CNEL interior noise standard. The required interior noise reduction shall be achieved through a combination 8-243 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo of standard interior noise reduction techniques, which may include (but are not limited to): Response 29.13 The commenter states that the map application for the project is for a Vesting Tentative Tract Map, not a Tentative Tract Map. In addition, in Section 1.0, Introduction, the commenter requests adding the word “significant” before the phrase “portion of the site” in the sentence that reads, “The project includes a mixture of residential, commercial, office, and hotel uses, with a portion of the site preserved for agriculture and open space uses.” The following revisions have been made throughout the document: Page ES-1 of Section 0.0, Executive Summary: The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment/Pre-Zoning, and Development Plan/Vesting Tentative Tract Map for a 131-acre project site, including annexation of the site into the City of San Luis Obispo. Page 1-1 of Section 1.0 Introduction: The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment and pre-zone, Development Agreement/Memorandum of Understanding, and Development Plan/Vesting Tentative Tract Map for the 131-acre project site, including annexation of the site into the City of San Luis Obispo. Page 2-1 of Section 2.0, Project Description: The San Luis Ranch Project consists of a Specific Plan, General Plan Amendment/Pre-Zoning, and Development Plan/Vesting Tentative Tract Map for a 131-acre project site, including annexation of the site into the City of San Luis Obispo. Page 2-6 of Section 2.0, Project Description: Adoption of the San Luis Ranch Specific Plan and approval of related entitlements would require several actions from the City and other public agencies as described in Section 2.8, including a Specific Plan, General Plan Amendment/Pre-Zoning, Development Plan/Vesting Tentative Tract Map, annexation of the site into the City of San Luis Obispo, and architectural review. Page 2-26 of Section 2.0, Project Description: • Specific Plan • General Plan Amendment/Pre-Zoning • Development Plan/Vesting Tentative Tract Map(s) 8-244 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo • Development Agreement Page 3-3 of Section 3.0, Environmental Setting: The cumulative impacts discussion considers the contribution to environmental effects of the proposed Specific Plan, General Plan Amendment/Pre-Zoning, Development Plan/Vesting Tentative Tract Map, Development Agreement/Memorandum of Understanding, and architectural review for the 131-acre project site, including annexation of the site into the City of San Luis Obispo. Page 5-1 of Section 5.0, Other CEQA Required Discussions: The impacts identified below are based on buildout of the project which includes a Specific Plan, General Plan Amendment/Pre-Zoning, Vesting Tentative Tract Map, and development plan for the 131-acre project site, including annexation of the site into the City of San Luis Obispo. Page 5-2 of Section 5.0, Other CEQA Required Discussions The project, as proposed, would require discretionary approvals from the City including the San Luis Ranch Specific Plan, General Plan Amendment/Pre-Zoning, Vesting Tentative Tract Map, and development plan for the 131-acre site, including annexation of the site into the City of San Luis Obispo, and Architectural Review. Regarding the requested revision in Section 1.0, Introduction, the referenced language has been revised as follows to accurately describe the conditions and the project description: The project includes a mixture of residential, commercial, office, and hotel uses, with a portion approximately 53 acres of the site preserved for agriculture and approximately 7.4 acres preserved for open space uses. Response 29.14 The commenter requests that the discussion included in Section 1.1.3, Relationship of the Project to the Land Use and Circulation Elements, include the conclusion that the Prado Road Overpass/Interchange would be required to avoid and/or reduce project traffic impacts. The following revisions have been made to Section 1.1.3 in response to this comment. […] The traffic study conducted for this EIR is, in part, intended to identify if and when implementation of the Prado Road overpass or interchange is necessary to achieve acceptable levels of service on City roadways and intersections, in consideration of vehicle trips generated by the proposed San Luis Ranch Project, in combination with existing and anticipated development in the City. Based on the review and analysis of potential traffic impacts identified for the project in Section 4.12, Transportation, the project would be required to pay an equitable share toward the Prado Road Overpass and U.S. 101 northbound ramps prior to Phase 2 of the project; and the Prado Road Overpass and U.S. 101 southbound ramps post project completion. 8-245 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.15 The commenter recommends changing the word “sensitive” with “prominent” in the sentence in Section 2.0, Project Description. The following revision has been made: Its visually sensitive prominent location at a southern gateway to the City has led to a policy to preserve approximately half of the agriculture and open space on-site, both to preserve views and to maintain the City’s agricultural heritage. Response 29.16 The commenter requests that more labels be added to Figure 2-2. The figure currently shows existing places in the project vicinity. Land uses and current setting descriptions are described in the text of Section 2.0, Project Description. No revisions to the Draft EIR are required in response to this comment. Response 29.17 The commenter requests that Section 2.0, Project Description, be revised to include Laguna Lake Park among the existing uses around the site under the “West” direction. While portions of Laguna Lake are located northwest of the site, Laguna Lake Park is located north of the project site, and is listed under the “North” existing uses. Response 29.18 The commenter requests that Figure 2-5 on page 2-8 of Section 2.0, Project Description reflect that the multi-family portion of the site has the same orange color coding. The commenter requests that the legend be adjusted so the orange color is High Density Residential. The recommended revisions to Figure 2-5 have been made in response to this comment. Response 29.19 The commenter requests that Figure 2-6 on page 2-9 of Section 2.0, Project Description reflect that the multi-family portion of the site has the same orange color coding. The commenter requests that the legend be adjusted so the orange color is High Density Residential and that the figure orientation is changed to portrait style. The recommended revisions to Figure 2-6 have been made in response to this comment. Response 29.20 The commenter requests that a footnote be added to Table 2-1 and ”other related sections” of the Draft EIR stating that the Froom Ranch Way bridge crossing over Prefumo Creek and the road connection to the existing Froom Ranch Way are located off of the project site, but are part of project review. To clarify this issue, Section 2.0, Project Description, has been revised as follows: The project proposes to provide or pay fair share fees for such public improvements as a widening of Madonna Road along project frontage, additions to Dalidio Drive/Prado Road, an extension of Froom Ranch Way across Prefumo Creek in the southwest corner of the site, and to contribute in fair share towards an overpass or interchange connection for Prado Road. Some of these proposed improvements, including the Froom Ranch 8-246 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Way extension across Prefumo Creek, would be located off of the project site, but are part of project review. In addition, the proposed Froom Ranch Way bridge crossing is included in the discussion and analysis of potential environmental impacts throughout Section 4.0. No revisions to the draft EIR are required in response to this comment. Response 29.21 The commenter requests that the description of height limits for the multi-family residential uses be revised to reflect a maximum residential height limit of 40 feet. Section 2.0, Project Description, has been revised to reflect this updated information as follows: Residential The project includes a mix of 580 low-medium, medium, and high density residences that would be located primarily on the northwestern and central portion of the project site. Housing would range from detached single-family units to attached multi-family dwellings, and are described in detail Chapter 3 of the Specific Plan (Appendix B to this EIR). The low-medium density residential zone (NG-10) would allow for residential units at a density of up to 10 units per acre with a height limit of 35 feet. Residential products envisioned for this zone include single-family and small-lot residential. The medium-density residential zone (NG-23) would allow for residential units at a density of up to 23 units per acre with a height limit of 35 40 feet. Residential products envisioned for this zone include detached townhomes, attached townhomes, and multi- family structures such as apartments or condos. The high-density multi-family residential zone (NG-30) would allow for residential units at a density of up to 30 units per acre with a height limit of 3540 feet. Residential products envisioned for this zone include detached townhomes, attached townhomes, and multi-family structures such as apartments or condos. The neighborhoods would be connected with a local street, bicycle circulation, and trail system, and would contain recreational areas. Internal circulation would include night lighting designed to meet ‘dark sky’ standards. The discussion of Impact AES-1 in Section 4.1, Aesthetics, has also been revised to reflect this information as follows: Due to the proposed building setbacks from U.S. 101, background views of Cerro San Luis, Bishop Peak, and the Irish Hills from U.S. 101 would continue to be visible to the same extent as they are currently, as these features are visible above the existing eucalyptus tree line west of the project site and existing commercial structures north of the project site, and the heights of the proposed structures would not project above the existing tree line to the west or the existing development to the north. Residential development would range from detached single-family units to attached multi-family dwellings, with a maximum height limit for all single-family residential land use types of 35 feet and multi-family residential land use types of 40 feet. Proposed architectural styles, massing, and building heights are described in the Specific Plan. Commercial structures would be constructed at a maximum height of 50 feet. Mature eucalyptus trees at the site range from 80 to 100 feet in height. 8-247 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Also, refer to the revisions in Response 29.32 which reflect this information. Response 29.22 The commenter states that the historical structures should be as high as they are in the current configuration. The comment questions whether a water tower, if proposed as part of the historic center, would have to be less than 45 feet in height or if it could be higher. As discussed in Section 2.0, Project Description, structures in the Agricultural Heritage Facilities & Learning Center would have a maximum height limit of 35 feet. However, historical structures would be permitted to exceed this limit up to a 45-foot maximum. Response 29.23 The commenter states that the proposed extension to the Bob Jones Trail Regional Trail should be described as a six-foot wide nature trail and notes that bike routes will be located on Froom Ranch Way and Dalidio Drive. Section 2.0, Project Description, has been revised to reflect this information as follows: The project would establish links in the City’s Bicycle Transportation Plan. As discussed above, the project would construct a six-foot wide nature trail with bike routes on Froom Ranch Way and Dalidio Drive connecting a segment of the Bob Jones Bike Trail, providing and provide a connection from Laguna Lake Park and nearby neighborhoods and businesses along Madonna Road to the existing segment of the Bob Jones Trail near the Target shopping center at the southern portion of the City limit at Froom Ranch Way. The project would create interior bicycle trails and lanes, including a Class I Bike Trail and Class II Bike lanes. These facilities are consistent with the goals established by San Luis Obispo’s 2013 Bicycle Transportation Plan. Figure 2-7 shows the project’s proposed bicycle circulation plan. The commenter also includes a copy of the San Luis Ranch Bicycle Lanes and Paths Site Circulation Plan which was presented to the City’s bike committee. As stated in the discussion of bicycle and pedestrian circulation in the description of the project land use concept in Section 2.0, Project Description, the project would create interior bicycle trails and lanes, including a Class I Bike Trail and Class II Bike lanes, consistent with the goals established by San Luis Obispo’s 2013 Bicycle Transportation Plan. Figure 2-7 shows bicycle circulation routes along the proposed extension of Froom Ranch Way and Dalidio Drive, as the commenter has noted. Response 29.24 The commenter requests that the map on Figure 2-7 be rotated to be consistent with the presentation of other figures. The commenter requests that the map be updated with the attached San Luis Ranch Bicycle Lanes and Paths Site Circulation Plan. The commenter notes that there are no bike lane improvements proposed for Oceanaire Drive. Figure 2-7 is oriented to match the other figures in the Draft EIR project description, and reflects future bicycle circulation in the project site vicinity, including both existing bicycle lanes/pathways (e.g., on Oceanaire Drive) and on- and off-site improvements included in the project and described in the text of Section 2.0, Project Description. The figure provided by the comment includes several components which are not legible, including the legend and multiple labels. 8-248 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.25 The commenter requests that Figure 2-8 be rotated to match the other graphics. The commenter also requests that road names be added to the figure. Road names are visible on the figure, and visible on other figures throughout the Draft EIR. The figure is legible and accurate, and oriented to match other figures in the document. Response 29.26 The commenter provides utility plans from a more recent draft of the proposed Specific Plan and requests that these plans be used in replacement of existing figures in Section 2.0, Project Description (Figures 2-9, 2-10, and 2-11). The revised utility plans provided by the commenter do not indicate a difference in the substance of the proposed utility infrastructure as compared to the project. The figures currently used in the Draft EIR are representative of the Draft Specific Plan included in Appendix B. Therefore, the utility plans provided by the commenter have not been used in replacement of existing Figures 2-9, 2-10, and 2-11 in Section 2.0, Project Description. Response 29.27 The commenter acknowledges that Figure 2-12 is consistent with the other maps included in the Draft EIR, but requests that the legend be rotated, and the center park shown in the figure be revised to include underground storage. Figure 2-12 accurately depicts the stormwater detention plan for the project and is oriented to match other figures in the document. The legend in Figure 2-12 has been revised to describe the center park area as “Proposed Retention (including underground storage).” Response 29.28 The commenter requests that the description of topsoil in the discussion of proposed project grading in Section 2.0, Project Description, be added to Figure 2-13. Figure 2-13 is intended to provide an illustration of the grading plans for the project while the text of the project description describes the grading and other project information in detail. As such, the written description of topsoil is appropriately placed in Section 2.0, Project Description. Response 29.29 The commenter requests that the gray shading on Figure 2-13 be identified. The grey shading on Figure 2-13 shown in the Draft EIR represents the existing 100-year flood zone as reflected on the grading plan provided by Canon, the applicant’s engineer. Figure 2-13 has been revised for the Final EIR to exclude this shading for clarity. Response 29.30 The commenter requests that Figure 2-14 be rotated. Figure 2-14 is legible, accurate, and oriented to match the other figures in the Draft EIR. No revisions to the Draft EIR are required in response to this comment. Response 29.31 The commenter states that the description of the project relative to the discussion of Senate Bill (SB) 743 in Section 4.1, Aesthetics, should be revised to reflect that the project would include a transit center along with bus stops, bike trials, and walking paths, and that the project would be consistent with SB 743. As described in Section 4.1.1(c), under SB 743, a project’s aesthetic impacts are not considered significant impacts on the environment if: 1) the project is a 8-249 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo residential, mixed-use residential, or employment center project, and 2) the project is located on an infill site within a transit priority area. A transit priority area is an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in an adopted Transportation Improvement Program. A “major transit stop” is defined in Section 21064.3 of the California Public Resource Code as a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. The transit stop included in the project is not a considered a “major transit stop” in the Draft EIR since the number of routes serviced by the stop and frequency of service intervals are unknown at this time. Therefore, the project does not meet both SB 743 criteria to preliminarily determine that aesthetic impacts of the project would not be significant. Accordingly, the analysis of aesthetic impacts in the Draft EIR is warranted pursuant to SB 743. Nevertheless, the following revisions have been made to the description of project in the discussion of SB 743 in Section 4.1.1(c) of the Draft EIR. Senate Bill (SB) 743. Governor Brown signed SB 743 in September 2013, which made several changes applicable to CEQA for projects located in areas served by transit (Public Resources Code Section 21099). Under SB 743, a project’s aesthetic impacts are not considered significant impacts on the environment if: 1) the project is a residential, mixed-use residential, or employment center project, and 2) the project is located on an infill site within a transit priority area. A transit priority area is an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in an adopted Transportation Improvement Program. A major transit stop is defined in Section 21064.3 of the California Public Resource Code as a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. This provision for aesthetic impacts does not include impacts to historic or cultural resources. The project is an open space, residential, and commercial use development project, which is located on land currently identified as a Specific Plan Area by the City and would include a transit center, bike trials, and walking paths., but However, the project site is not considered to be a transit priority area, and the proposed transit center is not designated as a “major transit stop” since the number of routes serviced by the stop and frequency of service intervals are unknown at this time. and t Therefore, the project is not exempt from consideration for aesthetic impacts under the CEQA process. Response 29.32 The commenter requests that the description of height limits for the multi-family residential uses in the discussion of Impact AES-2 be revised to reflect a maximum residential height limit of 40 feet. As such, the following revisions have been made to the discussion of aesthetic impacts under Impact AES-2 in the Draft EIR. Proposed commercial and residential development in the northern portion of the site would be visually consistent with adjacent land uses to the north and west, and would provide a visual transition from suburban residential uses west of the project site to 8-250 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo commercial uses east of the project site. The eastern 52.7 acres of the project site along U.S. 101 would be maintained in agricultural use. The San Luis Ranch Specific Plan development standards include building height maximums for each of the development types proposed on the project site. In general, low-medium density residential (NG-10) would have a maximum height of 35 feet. Medium- and high-density residential (NG-23 and NG-30) would have a maximum height of 40 feet., and c Commercial, office, and hotel uses, would have a maximum height of 50 feet. Response 29.33 The commenter states that Section 4.2, Agricultural Resources, should be reviewed to ensure that the acreage of prime agricultural land described in the Draft EIR is correct. The commenter states that 3.3 acres of Salinas soils located within the Prefumo Creek bed and bank should not be counted as prime agricultural land. The commenter also states that Section 4.8, Land Use, reflects a different total area of prime agricultural land (56 acres) than Section 4.2, Agricultural Resources. As the commenter notes, the Prime Farmland on the project site shown in the Draft EIR included approximately three acres of Salinas silty clay loam, which is located within Prefumo Creek and the bank area. Section 4.2.1(c) has been revised to correct this acreage, as follows: The Cropley clay soil is constrained by seasonal wetness due to the slow surface runoff, which reduces the ability to farm when the ground is wet. The Salinas silty clay loam soil has no constraints related to crop production. The remaining three acres of Salinas silty clay loam are within the creek and bank area of Prefumo Creek and have limited agricultural production value. The 19 acres of Cropley clay that are presently used for the packing facility, storage areas, eucalyptus groves, and drainage areas, have little or no agricultural production value. Characteristics of the soil types found on the project site are described in Table 4.2-3. As shown in Table 4.2-3, 112 acres of the project site are Cropley clay with 0 to 2 percent slopes, and Salinas silty clay loam with 0 to 2 percent slopes, which may be categorized as Prime Farmland by the FMMP. As described above and shown in Table 4.2-3, the area described as Salinas silty clay loam with 0 to 2 percent slopes includes three acres within the creek and bank area of Prefumo Creek that have limited agricultural production value and are categorized as Other Lands. Therefore, approximately 109 acres of the project site meet the FMMP criteria for Prime Farmland (refer to in Section 4.2.1[e] for a detailed discussion of the FMMP and associated category criteria). Additional revisions have been made in Section 4.2, Agricultural Resources, to correct other instances of this error. These revisions are reflected in Responses 29.37, 29.40, 29.41, 29.42, and 29.45. Response 29.34 The applicant states that the setting information in Section 4.2, Agricultural Resources, should be revised to describe the existing Measure J entitlement. This entitlement is described in Section 1.1.1, Summary of the Proposed Project. In addition, the Measure J entitlements and the potential environmental impacts of these entitlements as they pertain to the proposed project are described in Section 6.0, Alternatives. 8-251 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.35 The commenter indicates that the statement in the Draft EIR that two types of soils are found on the project site should be revised to state that three types of soils are found on the project site. As stated in Section 4.2.1(c), the two types of soils found on the project site are Cropley clay and Salinas silty clay loam. The commenter may be referring to Table 4.2-3, which shows three rows describing on-site soils, but it should be noted that two of these rows describe the Cropley clay soil type at two different slope ranges – 0 to 2 percent and 2 to 9 percent. Therefore, no changes to the Draft EIR are required in response to this comment. Response 29.36 The commenter notes that the reference to Table 4.2-1 in Section 4.2.1(d) should refer instead to Table 4.2-3. This reference has been updated as follows: The project site soils and their associated acreages and capability classifications are shown in Table 4.2-13 (only the irrigated capability class is shown because irrigation water is available and in active use at the site). Response 29.37 The commenter states that the acreage of Prime Farmland within the proposed development area on Figure 4.2-2 should be revised from 59 to 56 acres, and that the figure should also note the impact to agriculture of the Measure J entitlements were to be built. As discussed in Response 29.33, the Prime Farmland on the project site shown in the Draft EIR included approximately three acres of Salinas silty clay loam, which is located within Prefumo Creek and the bank area. Figure 4.2-2 of the Draft EIR shows Prime Farmland on the project site, as designated by the California Department of Conservation (DOC) Farmland Mapping and Monitoring Program (FMMP). The acreage reflected on this figure has been revised to reflect that the acreage of FMMP Prime Farmland within the proposed development area is 56 acres. In response to the comment regarding the Measure J entitlements, Section 6.0, Alternatives, includes a discussion of the potential environmental impacts of the Measure J entitlements as they pertain to the proposed project. Response 29.38 The commenter states that Section 4.2.1(g) should include a reference to LAFCo Agricultural Policy 12. This section of the Draft EIR has been revised to include a reference to this policy, as follows: Local Agency Formation Commission. Local Agency Formation Commissions (LAFCos) are state agencies that were created in 1963 to help organize, manage, and regulate the provision of public services to development at the local level. San Luis Obispo LAFCo must approve any annexation or Sphere of Influence adjustment request made by the City, based on policies that discourage sprawl, preserve prime agriculture, and ensure the provision of public services. LAFCo must consider the effect that any annexation proposal may produce on existing agricultural lands. By guiding development toward vacant urban land and away from agricultural land, LAFCo assists with the preservation of valuable agricultural resources. The Cortese‐Knox‐Hertzberg (CKH) Act of 2000, which provides LAFCo with its 8-252 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo authority, strongly discourages the use of prime agriculture land for development. In 2008 San Luis Obispo LAFCo adopted Agricultural Goals‐Policies‐Guidelines developed to help preserve agricultural resources. LAFCo Agricultural Policy 12 applies to projects that propose annexation of land containing prime agricultural soils. This policy requires that such projects include mitigation requiring a substitution ratio of at least 1:1 for the prime land to be converted from agricultural use. Response 29.39 The commenter states that, per Table 4.2-3, as well as the Soils Report, the project site contains 109 acres of Prime Farmland. Refer to Response 29.33 for revisions made to the Draft EIR related to this comment. Response 29.40 The commenter states that the sentence “Approximately 59.3 acres of on-site Prime Farmland would be converted to non-agricultural use” in Impact AG-1 should be revised to state that 56 acres of Prime Farmland would be converted to non-agricultural use. As discussed in Response 29.33, the Prime Farmland on the project site shown in the Draft EIR included approximately three acres of Salinas silty clay loam, which is located within Prefumo Creek and the bank area. Impact AG-1 has been revised to correct this acreage (and associated calculations), as follows (it should be noted that these corrections also reflect corrected estimates of the net site acreage of the project site, which are reflected in Section 2.0, Project Description): Impact AG-1 The project would result in the direct conversion of 59.3 56 acres of Prime Farmland, as mapped by the FMMP, to non-agricultural uses. Therefore, impacts would be Class II, significant but mitigable. Approximately 109 acres of the 131-acre project site are currently used for the production of irrigated row crops including celery, broccoli, lettuce, Asian vegetables, and peas. As shown in Figure 4.2-2 and Table 4.2-3, the project site contains 112 109 acres of Prime Farmland, as designated by the FMMP, with 109 acres in agricultural production. This Prime Farmland comprises approximately 83 percent of the site, with non-Prime Farmland located along the western and northwestern fringes of the site. The project would preserve approximately 52.7 53 acres in agriculture adjacent the San Luis Obispo City Farm and along the project site frontage with U.S. 101, all of which is designated Prime Farmland. The remaining agricultural area represents (approximately 40.7 43 percent) of the net site acreage and 40 percent of the gross site acreage (when major roadways and right of way for the Prado Road interchange are discounted) in agriculture, primarily adjacent the San Luis Obispo City Farm and along the project site frontage with U.S. 101, all of which is designated Prime Farmland. Approximately 59.3 56 acres of on-site Prime Farmland would be converted to non-agricultural use. It should be noted that no revisions to the LESA model, or the associated values shown in Table 4.2-4, were required as a result of these corrections, as the existing worksheets (refer to Appendix C) used the correct acreage for the project site, soil types, and areas currently in irrigated agricultural production. 8-253 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.41 The commenter states that Mitigation Measure AG-1 should be revised to describe conservation of 56 acres of Prime Farmland rather than 59.3 acres. The commenter also states that Mitigation Measure AG-1 should be revised to describe on- and/or off-site easement(s). As discussed in Response 29.33, the Prime Farmland on the project site shown in the Draft EIR included approximately three acres of Salinas silty clay loam, which is located within Prefumo Creek and the bank area. The applicable portion of Mitigation Measure AG-1 has been revised as shown: […] Said mitigation shall be satisfied by the applicant through: 1) Granting a perpetual conservation easement(s), deed restriction(s), or other farmland conservation mechanism(s) to the City or qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, for the purpose of permanently preserving agricultural land. The required easement(s) area or deed restriction(s) shall therefore total a minimum of 59.3 56 acres of Prime Farmland. The land covered by said on- and/or off-site easement(s) or deed restriction(s) shall be located within or contiguous to the City’s Urban Reserve Line or Greenbelt subject to review and approval of the City’s Natural Resources Manager; or 2) Making an in-lieu payment to a qualifying entity which has been approved by the City, such as the Land Conservancy of San Luis Obispo, to be applied toward the future purchase of a minimum of 59.3 56 acres of Prime Farmland in San Luis Obispo County, together with an endowment amount as may be required. The payment amount shall be determined by the qualifying entity or a licensed appraiser; or 3) Making an in-lieu payment to a qualifying entity which has been approved by the City and that is organized for conservation purposes, to be applied toward a future perpetual conservation easement, deed restriction, or other farmland conservation mechanism to preserve a minimum of 59.3 56 acres of Prime Farmland in San Luis Obispo County. The amount of the payment shall be determined by the qualifying entity or a licensed appraiser; or 4) Any combination of the above. Response 29.42 The commenter states that the Residual Impacts discussion following Mitigation Measure AG-1 appears to assume that the measure requires 59.3 acres of off-site agricultural preservation, which would be inconsistent with applicable LAFCo and City General Plan policies, and would create an inconsistency within the Draft EIR. The Residual Impacts discussion following Mitigation Measure AG-1 has been revised as shown: 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 56 acres of land of comparable agricultural productivity to be preserved in perpetuity on- or off-site to satisfy the requirement of Mitigation Measure AG-1 that 8-254 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo impacts to Prime Farmland be mitigated at a 1:1 ratio (acres of Prime Farmland converted to acres of Prime Farmland preserved in perpetuity). 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 56 acres of Prime Farmland offsite as required by Mitigation Measure AG-1 would result in a minimum of 3 acres of Prime Farmland required to be preserved off-site (56 total acres required to be preserved minus 53 acres proposed to be preserved on-site) mitigation ratio of approximately 10:1 (acres preserved off-site to acres required on-site), which would appear to satisfy the intent of the “substantial multiplier” clause. However the final determination of the project’s consistency with City policy rests with City Council. Therefore, for the purposes of CEQA, implementation of Mitigation Measure AG-1 would ensure that the project would be potentially consistent with the intent of Land Use Element Policy 8.1.4.f and 1.13.8, as well as Conservation and Open Space Element Policy 8.6.3 (refer to Section 4.9, Land Use/Policy Consistency, for a detailed discussion of the project’s consistency with applicable City policies). However, the final determination of the project’s consistency with City policy rests with City Council. Therefore, with implementation of Mitigation Measure AG-1, this impact would be reduced to a less than significant level. Response 29.43 The commenter states that language in Impact AG-3 should be clarified to indicate that prevailing winds from the northwest would blow dust toward the freeway, away from residential areas. Impact AG-3 has been revised to clarify this information as follows: […] In compliance with the City’s Open Space Buffers policy, the project would include a 72-foot buffer between agricultural operations and urban development to reduce and/ or avoid noise, dust, light impacts, odors, chemical use, access by people and pets, pilferage, and pesticide drift to new residential and commercial land uses on the project site. The 72-foot buffers allow for 60 feet of multimodal right-of-way beyond 12-foot residential rear yard space. The prevailing winds in the region are generally from the northwest, directing agricultural dust away from adjacent residential areas when wind blows from that direction. Compliance with Conservation and Open Space Element Policy 8.3.2 would ensure that land use conflicts between agriculture and adjacent residential and commercial land would be minimized. Response 29.44 The commenter states that the proposed 72-foot agricultural buffer mirrors the existing buffer on the property, which has been in place since the development of the Oceanaire neighborhood. The commenter notes that the remaining active on-site agricultural uses would transition to organic farming practices as part of the project, reducing potential conflicts between urban and agricultural uses. As described in Response 29.22, the Draft EIR has been revised to include a commitment from the applicant to transition on-site agricultural operations to utilize organic farming practices. Consistent with this revision, Impact AG-3 has been revised to clarify this information as follows: 8-255 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo […] As described above, the Specific Plan includes a 72-foot buffer between agricultural operations and urban development to reduce and/ or avoid noise, dust, light impacts, odors, chemical use, access by people and pets, pilferage, and pesticide drift to new residential and commercial land uses on the project site. The proposed agricultural buffer includes berm and bioswale configurations limits on production hours and machinery use for adjacent agricultural operations. In addition, the Specific Plan proposes that on-site agricultural operations would include transition to organic farming, which would not involve pesticide or chemical fertilizer use on the site. However, the increase in the number of residents in the area and new accessible pathways, bike paths, and roadways would increase the potential for conflicts at on-site agricultural lands and the adjacent SLO City Farm which can result in direct economic impacts to agricultural operations, potentially impacting the overall economic viability of continued agricultural operations. Therefore, impacts associated with conversion of Farmland to non-agricultural use would be potentially significant. Response 29.45 The commenter notes that Section 4.2.3(c), Cumulative Impacts, states that the project would convert 59.3 acres of Prime Farmland to non-agricultural use. As discussed in Response 29.33, the Prime Farmland on the project site shown in the Draft EIR included approximately three acres of Salinas silty clay loam, which is located within Prefumo Creek and the bank area. Section 4.2.3(c), Cumulative Impacts, has been revised to correct this acreage, as follows: […] Implementation of the project would contribute incrementally to the loss of agricultural land within the City and in San Luis Obispo County by converting approximately 59.3 56 acres of Prime Farmland to non-agricultural use. Although agricultural resources in the project vicinity are mainly in areas outside of City limits, agriculture is a major industry in San Luis Obispo County. Development of Prime Farmland and Farmland of Local or Statewide Importance would contribute to cumulative impacts to regional agricultural resources. Such impacts would result in incompatibilities with agricultural uses and a decrease in Prime Farmland, Unique Farmland, and/or Farmland of Statewide Importance. San Luis Obispo County has experienced the trend of conversion of agricultural resources to developed uses; between 2010 and 2012, the FMMP recorded a net loss of 3,601 acres of Important Farmland, and between 2008 and 2010, the FMMP recorded a net loss of 810 acres (Department of Conservation 2012; Department of Conservation 2010). Response 29.46 The commenter requests confirmation that the VMT analysis appropriately captures commute trips avoided/discontinued by the project due to its density, affordability, and multimodal design. The commenter states that there is a misrepresentation of the VMT versus population growth calculation. As described in Section 4.3, Air Quality, estimates of vehicle trips and associated air pollutant emissions were based on peak hour trip generation rates from the project Multimodal Transportation Impact Study (refer to Section 4.12, Transportation, and Appendix L). The trip generation rates in the Multimodal Transportation Impact Study are based on the Institute of Transportation Engineers 9th Edition Trip Generation Manual, and also account for reductions 8-256 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo expected from the mixed use and pedestrian-oriented characteristics of the project (see Appendix L), including internal capture and pass-by trips. The VMT was appropriately estimated for the proposed project. Therefore, the VMT and population growth analysis included in Section 4.3, Air Quality, accurately reflect reasonably-anticipated VMT associated with the project. Response 29.47 The commenter questions the need to provide off-site mitigation per Mitigation Measure AQ- 3(b) because most of the emissions reduction programs in the mitigation measure are regional programs. The commenter also states that the mitigation measure should not be tied to the first two phases of the project as daily operational emissions during these phases would be below daily thresholds with implementation of Mitigation Measure AQ-3(a). The commenter also questions whether the offsite measures described by Mitigation Measure AQ-3(b) are reasonable or financially viable, and suggests that there is no relationship between the project and the offsite regional programs. The commenter suggests that SLOAPCD should instead establish a fee program that would serve as mitigation for impacts to regional air quality. Lastly, the commenter requests that compliance with Mitigation Measure AQ-3(b) not be tied to the grading permits of this project but to later timing based on Phase 4, 5, or 6. Please refer to Response 29.6, which includes a discussion of the feasibility and applicability of offsite mitigation. While the operational emissions of the first two phases of the project would be below daily thresholds, the Draft EIR evaluates the project’s total operational emissions at buildout. Therefore, both Mitigation Measures AQ-3(a) and AQ-3(b) are described in the Draft EIR as applying to the project as a whole. Compliance with Mitigation Measures AQ-3(a) and AQ-3(b) are tied to grading permits to ensure that operational emissions are in place to ensure, prior to occupancy of the project, that the project’s criteria pollutant emissions would not exceed daily threshold levels. Mitigation Measure AQ-3(b) is required only if the on-site emissions reduction measures described in Mitigation Measure AQ-3(a) would not be sufficient to reduce operational emissions to below daily threshold levels. Therefore, compliance with the off-site mitigation requirements of Mitigation Measure AQ-3(b) would only be triggered for later phases of development that would continue to exceed SLOAPCD’s daily thresholds after compliance with the on-site mitigation requirements of Mitigation Measure AQ-3(a). Response 29.48 The commenter requests that the project be considered consistent with measure 13 of Table 4.3- 10 on the basis that the Specific Plan will include provisions restricting wood burning devices. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 13 in Table 4.3-10. Response 29.49 The commenter states that the project site is located just over 0.5 mile from the proposed Park & Ride lot on Calle Joaquin and the project would include a Transit Center in the commercial area that would include parking and bike storage, and therefore, that the consistency determinations for measures 18 and 47 in Table 4.3-10 in Section 4.3, Air Quality, are incorrect. The commenter requests that the project be considered consistent with measures 18 and 47 of Table 4.3-10. The proposed Park & Ride lot on Calle Joaquin is not part of the project, nor is it approved and 8-257 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo anticipated to be constructed prior to development of the Specific Plan Area. Therefore, the Draft EIR does not assume that the project would be located within one-half mile of an existing or pending Park and Ride lot. The project would include a Transit Center with bike lockers and commuter parking; Consequently, Table 4.3-10 in Section 4.3, Air Quality, has been revised as follows: 18 Site design; transportation Project is located within one-half mile of a ‘Park and Ride’ lot or project installs a ‘Park and Ride’ lot with bike lockers in a location of need defined by SLOCOG. Ozone, Particulate, Greenhouse Gases Inconsistent Consistent The project is not within one-half mile of a Park and Ride lot, but the project would include a Transit Center with parking for commuters and bike lockers, nor would it include development of a Park and Ride lot with bike lockers. […] 47 Transportation Provide bicycle lockers for existing ‘Park and Ride’ lots where absent or insufficient. Ozone, Particulate, Greenhouse Gases Inconsistent Consistent See consistency discussion for Measure #18. Response 29.50 The commenter requests that the project be considered consistent with measure 20 of Table 4.3- 10 because the Specific Plan will include standards for roof trusses to accommodate solar panels and solar-heated water. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 20 in Table 4.3-10. Also, refer to Response 29.47 for a discussion of the implementation requirements and timing for Mitigation Measures AQ-3(a) and AQ-3(b). Response 29.51 The commenter requests that the project be considered consistent with measure 21 of Table 4.3- 10 because the Specific Plan will include standards requiring building development to exceed Title 24 requirements. As discussed in Section 4.3, Air Quality, the Specific Plan currently includes the goal of “Meeting or Exceeding Title 24 Standards.” However, the Specific Plan does not include a requirement that development exceed Title 24 by 20 percent, as specified in measure 21 of Table 4.3-10. Therefore, Table 4.3-10 in Section 4.3, Air Quality, has been revised for clarification as follows: 21 Energy efficiency Increase the building energy rating by 20% above Title 24 requirements. Measures used to reach the 20% rating cannot be double counted. Ozone, Greenhouse Gases Inconsistent Although the Specific Plan includes the goal of “Meeting or Exceeding Title 24 Standards,” the Specific Plan does not include standards requiring building development to exceed Title 24 requirements by 20%. Response 29.52 The commenter requests that the project be considered consistent with measure 26 of Table 4.3- 10 because the Specific Plan will include standards requiring passive solar design to the extent feasible. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards 8-258 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 26 in Table 4.3-10. Response 29.53 The commenter requests that the project be considered consistent with measure 27 of Table 4.3- 10 because the Specific Plan will include standards requiring installation of high efficiency gas or solar water heaters. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 27 in Table 4.3-10. Response 29.54 The commenter requests that the project be considered consistent with measure 33 of Table 4.3- 10 because the Specific Plan will include installation of door sweeps or weather stripping. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 33 in Table 4.3-10. Response 29.55 The commenter requests that the project be considered consistent with measure 34 of Table 4.3- 10 because the Specific Plan will include standards requiring installation of energy-reducing programmable thermostats. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 34 in Table 4.3-10. Response 29.56 The commenter requests that the project be considered consistent with measure 35 of Table 4.3- 10 because the Specific Plan will include standards requiring participation in energy-efficient rebate programs. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 35 in Table 4.3-10. Response 29.57 The commenter requests that the project be considered consistent with measure 36 of Table 4.3- 10 because the Specific Plan will include standards requiring the use of roofing materials with solar reflectance to reduce summer cooling, to the extent feasible while remaining consistent with Airport Area land use guidelines. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 36 in Table 4.3-10. 8-259 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.58 The commenter states that the Specific Plan does not include onsite renewable energy, but requests that the project be considered consistent with measure 37 of Table 4.3-10. As the Specific Plan would not include onsite renewable energy, it cannot be considered consistent with measure 37, which requires utilization of onsite renewable energy (e.g., solar, wind, geothermal, low-impact hydro, biomass and bio-gas). Therefore, no revisions to the Draft EIR are required in response to this comment. Response 29.59 The commenter requests that the project be considered consistent with measure 39 of Table 4.3- 10 because the Specific Plan will include standards requiring use of battery powered or electric landscape maintenance equipment. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 39 in Table 4.3-10. Response 29.60 The commenter requests that the project be considered consistent with measure 42 of Table 4.3- 10 because the Specific Plan will include standards for transportation information in a display case located at the onsite bus stops and transit center. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 42 in Table 4.3-10. Response 29.61 The commenter requests that the project be considered consistent with measure 50 of Table 4.3- 10 because the Specific Plan will include standards for free-access telework terminals or wi-fi access in the multifamily component of the project. No revisions to the Draft EIR are warranted at this time because the Specific Plan analyzed in the Draft EIR (refer to Appendix B) does not currently include the design standards described by the commenter. If the applicant includes this standard in an updated draft of the Specific Plan, then the project would be consistent with measure 50 in Table 4.3-10. Response 29.62 The commenter states that measures 44, 45 and 48 in Table 4.3-10 involve regional share programs that may be coordinated by the City of San Luis Obispo and SLOCOG when they are developed but should not be tied directly to this project. Measures 44, 45, and 48 involve the provisioning of a neighborhood electric vehicles/car share program, a bicycle-share program, and a vanpool or shuttle service. These measures are described in the SLOAPCD CEQA Air Quality Handbook as applicable to residential, commercial, and industrial land use projects. However, the feasibility of these measures is more consistent with a regional approach to air quality management, and these measures are consistent with existing regional programs and policies in the City’s adopted 2012 Climate Action Plan, which the project was found to be consistent with (refer to Section 4.6, Greenhouse Gas Emissions). Therefore, Table 4.3-10 has been revised as follows: 8-260 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo 44 Transportation Provide neighborhood electric vehicles / car share program for the development. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include a neighborhood electric vehicle/car share program. 45 Transportation Provide bicycle-share program for development. Ozone, Particulate, Greenhouse Gases Inconsistent The Specific Plan does not include a bicycle share program. 46 Transportation Provide preferential parking / no parking fee for alternative fueled vehicles or vanpools. Ozone, Particulate, Greenhouse Gases Consistent See consistency discussion for Measure #43. 47 Transportation Provide bicycle lockers for existing ‘Park and Ride’ lots where absent or insufficient. Ozone, Particulate, Greenhouse Gases Inconsistent See consistency discussion for Measure #18. 48 Transportation Provide vanpool, shuttle, mini bus service (alternative fueled preferred). Ozone, Particulate, Diesel Particulate Matter, Greenhouse Gases Inconsistent The Specific Plan does not provide for vanpool, shuttle, or minibus service. Response 29.63 The commenter questions the source for the potential state/federal waters for Figure 4.4-1. The commenter states that Figure 4.4-1 is different than what Althouse & Meade submitted to the U.S. Army Corps of Engineers (USACE) for the 404 permit and that they would like to review these maps for consistency. The commenter also states that the red willow thicket habitat in the southwest section of project site includes anthropogenic vegetation on west edge, is predominantly arroyo willow, and should be characterized as willow riparian. The commenter states that the City has requested removal of six canary palms downstream of Froom Ranch Way bridge as part of site mitigation near Outfall #4. The commenter requests that Figure 4.4-1 be updated accordingly. As part of the Draft EIR analysis, Rincon Consultants conducted a biological resource evaluation of the project site to supplement the applicant-provided findings with an independent evaluation of biological resources. As part of the evaluation, Rincon inspected all potentially jurisdictional features within the project site to record existing conditions and determine limits of USACE, Regional Water Quality Control Board (RWQCB), and California Department of Fish & Wildlife (CDFW) jurisdictions. Figure 4.4-1 is different than what Althouse & Meade submitted to USACE for the 404 permit because the Althouse & Meade mapping effort took place in March and April of 2015 and Rincon’s evaluation took place a year later in April 2016, and the extent of regulatory jurisdiction changed between the time of Althouse & Meade’s evaluation and Rincon’s evaluation. The small amount of vegetation in the western edge of the study area evaluated in the Draft EIR is surrounded by arroyo willows and does not contain adequate square footage to be categorized as ruderal/developed (anthropogenic). The red willow thicket vegetation community includes intermittent Canary Island date palms (Phoenix canariensis) downstream of the proposed Froom Ranch Way bridge. If the City requires removal of these additional trees within the riparian corridor, this work would be completed under the supervision of the City’s Natural Resources Manager, and would be subject to any applicable CDFW, USACE, and RWQCB permitting requirements and conditions. Therefore, no revisions to the Draft EIR are required in response to this comment. Response 29.64 The commenter requests a revision to the third bullet of Mitigation Measure BIO-1(f) on the basis that several of the heron nests are in full-grown eucalyptus trees. The commenter states 8-261 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo that the 60-foot high trees may not be successfully boxed and moved to another site, and asks if the City wants these trees at Laguna Lake. The commenter requests a revision to Mitigation Measure BIO-1(f)to state that alternative relocations plans could be development by qualified biologist and approved by the City’s Natural Resources Manager. Mitigation Measure BIO-1(f) refers to the methods described in Crouch et al. (2002), and referenced in the Biological Constraints Report prepared by Althouse & Meade on behalf of the project applicant (refer to Appendix F). Refer to Response 6.2 for discussion of the applicability and feasibility of this mitigation. For clarification purposes, the following revision has been made to Mitigation Measure BIO-1(f): • Following the completion of the nesting season in late summer, a certified arborist specializing in the translocation of trees will examine the mature trees onsite and work with the City’s Natural Resources Manager to determine whether or not it is feasible to relocate the mature trees containing nests the mature trees containing nests shall be boxed and moved across Madonna Road to a suitable location at Laguna Lake Open Space. Response 29.65 The commenter requests that Mitigation Measure BIO-1(d) be revised to reduce the distance from riparian resources and height of exclusion fencing for California red-legged frog (CRLF), western spadefoot, and coast range newt. Implementing a solid temporary exclusion fence around areas of the project site that lie within 100 feet upland from riparian and jurisdictional areas is necessary and sufficient to avoid and minimize potential impacts to these species. Industry standard silt/exclusionary-fencing is 36-inches in height. If 6-inches of the silt fence are buried beneath the soil as indicated in the report, then 30-inches would remain above ground. Therefore, the current language in Mitigation Measure BIO-1(d) accurately reflects best biological management practices, and no revisions to the Draft EIR are required in response to this comment. Response 29.66 The commenter requests that Mitigation Measure BIO -1(g) be revised to be consistent with the requirements in the Avila Ranch EIR. The commenter goes on to say that the general timing of nesting season, required survey buffers, and required construction activity setbacks appear be to more stringent for this project in comparison to Avila Ranch. The nesting bird season typically lasts from February 1 to September 15. Great blue heron nests within the project site are known to be active from February 1 to August 31. The breeding bird season identified in the Draft EIR accurately reflects information that is specific to this project site, and no revisions to the Draft EIR are required in response to this comment. Response 29.67 The commenter states, with regards to the discussion of horse racing in San Luis Obispo in the setting of Section 4.5, Cultural Resources, that the original horse race track was one mile and later shortened by a half mile. In response to this comment, the following revisions have been made to the discussion of Horse Racing in San Luis Obispo in Section 4.5, Cultural Resources: 8-262 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Horse Racing in San Luis Obispo. Horse racing was documented to be a popular sport in the region since the time of the Mexican ranchos in the first half of the 19th century (Angel 1883). Historical newspaper articles discuss the establishment of horse racing tracks in the San Luis Obispo area from 1874 through 1887. During this period a half one-mile race track was located in the vicinity of Madonna Plaza, which would be slightly to the northeast of the project site (Bertrando 1999a). After 1901, ownership of the portion of the project site with the spectators’ barn/viewing stand changed hands, and the spectators’ barn/viewing stand was reportedly moved to its current location on the northwest portion of the project site, near Madonna Road. It was reported that when the spectators’ barn/viewing stand was moved into the project site, the track was shortened by a half mile (Froom in Bertrando, 1998). Response 29.68 The commenter requests a revision to the Plan Requirements and Timing in Mitigation Measure CR-1(c) to replace the word “removal” with “relocated or reconstructed.” Mitigation Measure CR-1(c) has been revised as follows: Plan Requirements and Timing. The project applicant shall prepare the relocation and reconstruction plan for the main residence and the spectators’ barn/viewing stand to the satisfaction of the Community Development Director prior to the issuance of project grading permits. Project grading plans shall detail phasing and include sufficient detail to demonstrate the sequencing and completion of the relocation and reconstruction plan. The applicant shall complete archival documentation of the San Luis Ranch Complex prior to the removal, relocation, reconstruction, and/or demolition of the structures on the project site to the satisfaction of the Community Development Director. The applicant shall develop and install an informational display of the site’s identified historical resources prior to opening of the Agricultural Heritage Facilities and Learning Center to the public. Response 29.69 The commenter requests a revision in Section 4.5.3(c), Cumulative Impacts, to replace the word “removal” with “relocate or reconstructed.” This section has been revised as follows: As discussed in Section 4.5.2, the San Luis Ranch Specific Plan, as well as other approved and proposed plans in the City, is required to comply with existing General Plan Conservation and Open Space Element Policies 3.3.1, 3.3.2, 3.3.3, 3.5.1, 3.5.2, 3.5.3, 3.5.4, 3.5.5, 3.5.6, 3.5.7, and 3.6.3, which address the protection of historical and archaeological resources within the City. As described in Impact CR-2, the project would not result in the loss of any significant archaeological resources and, therefore, would not contribute substantially to the cumulative loss of archaeological resources in the City. However, the project would result in a significant and unavoidable impact associated with the removal, relocation, or reconstruction of individually historic structures that are part of the historically significant San Luis Ranch Complex. As such, the project would contribute to the cumulative loss of historic resources in the City. Therefore, the project would 8-263 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo also result in a Class I, significant and unavoidable, cumulative impact to historical resources. Response 29.70 The commenter states that SLOAPCD recommends amortizing residential structures by 50 years not 25 years, as noted in Table 4.6-1 and requests that the calculation be changed. As noted in Section 4.3, Air Quality, SLOAPCD recommends amortizing construction-related emissions over the life of the project; SLOAPCD suggests the life of a project is typically 50 years for residential projects and 25 years for commercial projects. The project includes both commercial and residential uses; therefore, to provide a conservative estimate of construction emissions, emissions were amortized over the shorter lifetime duration of 25 years. Response 29.71 The commenter states that Table 4.6-2 and Table 4.6-4 provide information for the year this project is completely built out in 2020 and beyond without mitigation, but do not reflect 2030 or 2050 statewide reductions in GHG emissions. The commenter requests that these tables be revised to include two more columns that calculate the 40 percent reduction in 2030 and the 80 percent reductions 2050 required by AB 32, SB 32, and AB 357. The commenter asserts that with these calculations the 40 percent reduction would be 3.48 metric tons (MT) per capita and in 2050 the 80 percent reduction would be 1.16 per capita, which is consistent with the City of San Luis Obispo policies. As stated in Section 4.6, Greenhouse Gas Emissions, SB 32 extends the statewide AB 32 reduction goal, requiring the State to further reduce GHGs to 40 percent below 1990 levels by 2030, and Executive Order S-03-05 has set forth a long-term reduction target to reduce GHG emissions in California by 80 percent below 1990 level by the year 2050. While the State has adopted the AB 32 Scoping Plan and multiple regulations to achieve the AB 32 year 2020 target, there is no currently adopted State plan to meet post-2020 GHG reduction goals. ARB is currently working to update the Scoping Plan to provide a framework for achieving the 2030 target set forth by SB 32 (ARB 2015). As a result, State reduction strategies cannot be applied to the project to achieve long-term reductions, because they cannot be assumed to occur in the absence of a Scoping Plan and associated State-level GHG-reduction programs and policies. Based on guidance from the Association of Environmental Professionals’ (AEP) Climate Change Committee (AEP, Beyond 2020: The Challenges of Greenhouse Gas Reduction Planning by Local Governments in California, 2015), the analysis in the Draft EIR relies on current adopted thresholds for the immediate future. As such, the analysis in the Draft EIR evaluates future conditions in the year 2020 based on the City’s adopted Climate Action Plan and does not evaluate post-2020 horizons. Response 29.72 The commenter states that the acreage of the project site in Airport Land Use Plan (ALUP) Safety Zone S-1b, shown on Figure 4.7-1, may be incorrect as a result of recent corrections made to the ALUP map. The commenter suggests that a corrected ALUP map be used for Figure 4.7-1. Figure 4.7-1 is based on the most current and officially adopted ALUP Aviation Safety Area map. Therefore, the airport safety areas shown on Figure 4.7-1 and described in the Draft EIR are accurately represented for the purposes of the EIR and no changes to the Draft EIR are required in response to this comment. 8-264 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.73 The commenter suggests that references to Figure 4.7-1 be revised based on corrections made to the figure in relation to Comment 29.72. Refer to Response 29.72. No changes to the Draft EIR are required in response to this comment. Response 29.74 The commenter states the description of Project Site Flooding in Section 4.8, Hydrology and Water Quality, confuses floodplains and floodways. The commenter provides the Federal Emergency Management Agency (FEMA) definitions for ‘floodway,’ ‘special flood hazard areas (SFHA),’ and ‘base flood’ with reference to how such terms are typically used by FEMA. The commenter goes on to state that there are no regulatory floodways on the project site and specifies that the northwestern portion of the site is outside the FEMA SFHA. The following revisions have been made to the discussion of Project Site Flooding in Section 4.8, Hydrology and Water Quality: c. Project Site Flooding. Approximately 75 percent of the Specific Plan Area is designated as Special Flood Hazard Area because it is situated in a designated 100-year floodplain as identified by the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM). A base flood, also referred to as a 100-year flood, is defined as a flood event with a one percent probability of being equaled or exceeded during any given year. Regulatory Ffloodways are defined as stream channels plus adjacent floodplains land areas that must be kept free of encroachment as much as possible so that in order to discharge the base 100-year floods can occur without substantial increases to flood elevations. The north-northeastern portion of the site is not within the 100-year floodplain, and therefore, is not within a FEMA-designated floodway. The remainder majority of the project site, with the exception of the north-northwestern portion of the site and a small portion of the site along the eastern boundary, is located within the FEMA-designated 100-year floodplain. , and therefore, No portion of the site is within the a FEMA-designated regulatory floodway. The extent of the 100-year floodplain is shown on Figure 4.8-2. Response 29.75 The commenter states that 4th and 5th bulleted items in the list of applicable Municipal Code 17.84 – Floodplain Management Regulations in Section 4.8, Hydrology and Water Quality, would not apply to project development as a result of the Letter of Map Revision (LOMR) requirement in the listed regulations. The project would introduce residential and commercials structures into what is currently a FEMA-designated 100-year floodplain. Accordingly, the Draft EIR discusses all floodplain regulations for which the City would be responsible for ensuring project applicability and compliance with upon submittal of final development plans. Therefore, the Municipal Code 17.84 – Floodplain Management Regulations are appropriately included in the Draft EIR. Response 29.76 The commenter questions the use of the word “agricultural” in the impact statement for Impact HWQ-3 in Section 4.8, Hydrology and Water Quality, and requests that “agricultural” be deleted from the impact statement. The commenter states that there will not be an increase in impacts from agricultural uses remaining on the site with the project. The following revisions have been made to Impact HWQ-3: 8-265 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Impact HWQ-3 During operation, the proposed residential, and commercial, and agricultural uses would increase the quantities of pollutants associated with runoff and sedimentation. The project’s impact on water quality would be Class II, significant but mitigable impact. These changes have also been carried through to the summary of Impact HWQ-3 in Table ES-2. Response 29.77 The commenter states that the description of stormwater treatment facilities in the discussion of Impact HWQ-3 in Section 4.8, Hydrology and Water Quality, incorrectly characterizes the function of proposed detention basins and stormwater treatment facilities included in the project. The following revisions have been made to the discussion of Impact HWQ-3 in response to this comment and based on the Preliminary Drainage Report prepared for the project by Cannon on October 14, 2016: […] As described in Impact HWQ-2, the project design includes the construction of a diversion structure on the upstream side of the property at the Cerro San Luis Chanel which would divert flows into an underground storage chambers detention system within the commercial portion of the project site (refer to Figure 2-12 in Section 2.0, Project Description). The underground detention structures would be designed to limit the release of “first flush” water, which generally contains the highest concentration of pollutants from buildup during the dry season. […] Response 29.78 The commenter states that there is a discrepancy between impact statement Impact HWQ-3 and the conclusions in the discussion of Impact HWQ-3 relative to agricultural uses potential impacts to water quality. Refer to Response 29.76 for revisions made to the Draft EIR which resolve this discrepancy. Response 29.79 The commenter states that the requirement in Mitigation Measure HWQ-3(a) to include hydrodynamic separation products – non-retention based systems – in the Master Drainage Plan conflicts with the CCRWQB’s Resolution R3-2013-0032 Post-Construction Requirements for Water Quality Treatment. The following revisions have been made to Mitigation Measure HWQ-3(a) in response to this comment: HWQ-3(a) Stormwater Quality Treatment Controls. BMP devices shall be incorporated into the stormwater quality system depicted in the Master Drainage Plan (refer to Mitigation Measure HWQ-1[c]). The final design of the stormwater quality system shall be reviewed and approved by the City. The Master Drainage Plan shall contain the following relevant BMPs: • Vegetated bioswales to reduce sediment and particulate forms of metals and other pollutants along corridors of planted grasses. 8-266 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo • Vegetated buffer strips to reduce sediment and particulate forms of metals and nutrients. • Hydrodynamic separation products to reduce suspended solids greater than 240 microns, trash, and hydrocarbons. These hydrodynamic separators shall be sized to handle peak flows from the project site consistent with applicable regulatory standards. Response 29.80 The commenter requests a revision in the discussion of Impact HWQ-4 to replace the statement “and that the FIRM revised by FEMA to be consistent with the post-development 100-year floodplain as mapped based on City of San Luis Obispo Waterway Management Plan hydrologic and hydraulic models” with “consistent with the proposed site development, creek improvements and bridge, Prado Road Overpass, site and floodplain grading, and proposed detention facilities.” This section has been revised as follows: Mitigative Components of the Specific Plan and Impact Conclusion. As described above, the Specific Plan includes a preliminary grading plan that would raise the elevation of the central portion of the project site above the post-development 100-year floodplain as shown in Figure 4.8-3. The project includes a conditional letter of map revision (CLOMR) application requesting that the FEMA 100-year floodplain boundary be redefined, and that the FIRM revised by FEMA to be consistent with the post- development 100-year floodplain as mapped based on the City of San Luis Obispo Waterway Management Plan hydrologic and hydraulic models consistent with the proposed site development, creek improvements and bridge, Prado Road Overpass, site and floodplain grading, and proposed detention facilities. Compliance with required City Flood Damage Prevention Regulations Code 17.84.050 and flood management measures including Special Floodplain Management Zone Regulation and the City Waterways Management Plan would reduce the risk of significant loss or injury as a result of flooding. […] Response 29.81 The commenter states that the acreage of the project site located within adopted ALUP Safety Zone S-1b may be incorrect due to changes to the ALUP maps. Refer to Response 29.72 for a discussion of the airport safety areas depicted on the figures and described in the text of the Draft EIR. Response 29.82 The commenter states that the project’s combined provision of approximately three acres of parkland and payment of in-lieu fees would be consistent with the performance standards described in Land Use Element Policy 8.1.4 which require 5.8 acres of parkland in the Specific Plan Area. In the consistency analysis discussion for Policy 8.1.4 in Table 4.9-1, the project has been determined to be potentially consistent with the City’s General Plan parkland performance standard for the Specific Plan Area on the basis of the proposed parkland and payment of in- lieu fees. No changes to the Draft EIR are required in response to this comment. 8-267 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.83 The commenter states that Impact N-3 omits Madonna Road, but does not clarify that the existing + project noise levels are lower than existing noise levels on this segment. Analysis under Impact N-3 includes the clarification the commenter requests by stating that “Noise levels would decrease on the project site along Madonna Road under the Existing Plus Project and Cumulative Plus Project scenarios” (Page 4.10-24). The summary in the impact statement for Impact N-3 is accurate. Response 29.84 The commenter points out a typo in the last sentence of Page 4.10-32. The last sentence on Page 4.10-32 has been revised as follows: Table 4.10-1816 shows the estimated interior noise levels with windows closed (CNEL). Response 29.85 The commenter requests that Mitigation Measure N-5(a) include passive ventilation as an option on residential units. The commenter also states that the mitigation measure should be consistent with the Avila Ranch EIR, which did not require addition reports to demonstrate compliance. Mitigation Measure N-5(a) includes a list of standard interior noise reduction techniques to achieve the City’s interior standard of 45 dBA CNEL. Passive ventilation is not a standard interior noise reduction technique; therefore, it would not be appropriate to include it as an option in Mitigation Measure N-5(a). The project could include passive ventilation, as long as other noise reduction techniques are implemented to achieve the City’s interior noise standard. As Mitigation Measure N-5(a) does not require specific interior noise reduction techniques, a report prepared by a qualified acoustical consultant is required to confirm compliance with this measure and that the City’s interior standard is achieved. N-5(a) Interior Noise Reduction. The project applicant shall implement the following measures, or similar combination of measures, which demonstrate that interior noise levels in proposed residences, hotel, and offices would be reduced below the City’s 45 dBA CNEL interior noise standard. The required interior noise reduction shall be achieved through a combination of standard interior noise reduction techniques, which may include (but are not limited to): • In order for windows and doors to remain closed, mechanical ventilation such as air conditioning shall be provided for all units (Passive ventilation may be provided, if mechanical ventilation is not necessary to achieve interior noise standards, as demonstrated by a qualified acoustical consultant). Response 29.86 The commenter states that the outdoor hotel pool area with an 8 foot high masonry wall seems excessive. The commenter states that there are other options for sound mitigation for this outdoor area, and requests that the Draft EIR be revised to provide for other alternatives such as landscaping, berms, glass, screening features etc. that would reduce the noise from the freeway. Mitigation Measure N-5(d) has been revised to accommodate alternative methods for exterior noise reduction. A requirement to submit a report prepared by a qualified acoustical consultant 8-268 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo to confirm that the City’s exterior standard is achieved has also been added to the measure, in order to sufficiently evaluate alternative noise reduction measures. N-5(d) U.S. Highway 101 Noise Barrier at Hotel. If the hotel includes an outdoor activity area (such as a patio or pool) a masonry noise barrier or alternative barrier, such as berms, landscaping, or glass, must be installed along the eastern property line of the hotel where it abuts the U.S. 101 right of way to protect these outdoor activity areas from sound intrusion from traffic along U.S. 101. If a masonry noise barrier is implemented, The the noise barrier shall provide, at minimum, an 8 foot high barrier between U.S. 101 and the hotel from the final grade of whichever use (i.e., U.S. 101 or hotel) has a higher final elevation. Such a The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. If an alternative material is used, the developer shall submit a report to the Community Development Department by a qualified acoustical consultant demonstrating that the specific exterior noise reduction techniques included in the hotel component of the project would achieve exterior noise levels that would not exceed 60 dBA CNEL. Response 29.87 The commenter requests that Mitigation Measure N-5(c) be revised to include a 6 foot high landscape berm or other options, as an alternative to the 6 foot high wall along Froom Ranch Way. Mitigation Measure N-5(c) has been revised to accommodate alternative methods for exterior noise reduction. A requirement to submit a report prepared by a qualified acoustical consultant to confirm that the City’s exterior standard is achieved has also been added to the measure, in order to sufficiently evaluate alternative noise reduction measures. N-5(c) Froom Ranch Way Noise Barrier. A masonry noise barrier or alternative barrier, such as a landscaped berm, shall be installed along the southern property line of residential lots that abut Froom Ranch Way to protect outdoor activity areas (patios and pools) at these residences from sound intrusion from traffic along Froom Ranch Way. The noise barrier or berm shall provide, at minimum, a 6 foot high barrier between Froom Ranch Way and the neighboring residences from the final grade of whichever use (i.e., Froom Ranch Way or residences) has a higher final elevation. If a masonry noise barrier is implemented, the The noise barrier shall be constructed of any masonry material with a surface density of at least three pounds per square foot, and shall have no openings or gaps. If an alternative material is used, the developer shall submit a report to the Community Development Department by a qualified acoustical consultant certifying that the specific exterior noise reduction techniques included would achieve exterior noise levels that would not exceed 60 dBA CNEL. 8-269 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.88 The commenter references an attached comment letter from Associated Transportation Engineers (ATE) for comments on Section 4.12, Transportation. Responses to the comments in the attached ATE letter are included in Responses 29.93 through 29.132. Response 29.89 The commenter requests that the description of Water Resource Availability in Section 4.13, Water Resources, specify that 3,380 acre-feet per year (AFY) of the total Nacimiento Reservoir dependable supply is primary supply, while the remaining 2,102 AFY is for secondary purposes. The commenter also requests that the definition of primary and secondary water supply from the 2016 Urban Water Management Plan (UWMP) be included in the section. The 2016 UWMP has yet to be formally adopted as the most up-to-date UWMP for the City. However, the information requested for inclusion by the commenter is included in the City’s 2015 UWMP which is referenced in the Draft EIR. The following revisions have been made in Section 4.13, Water Resources, in response to these comments using the City’s 2015 UWMP. a. Water Supply. […] The Water and Wastewater Element of the City’s General Plan, updated in 2016, specifies that the City shall utilize multiple water resources to meet its water supply needs. Having several sources of water avoids dependence on any one source that may not be available during a drought or other water supply reduction or emergency. According to the Water and Wastewater Element, the City accounts for water supplies necessary to meet three specific community needs: 1) Primary water supply, 2) Reliability reserve, and 3) Secondary water supply. The primary water supply is the amount of water needed to serve the build-out population of the City as identified in the Land Use Element of the General Plan. The reliability reserve provides a buffer for future unforeseen or unpredictable long-term impacts to the City’s available water supply. The secondary water supply is the amount of water remaining from the City’s available water resources above those needed to meet the primary water supply and reliability reserve. The City’s 2015 Urban Water Management Plan (UWMP) provides detailed information on water sources for the City. […] Water Resource Availability. […] The Nacimiento Reservoir is operated as a water supply project for Monterey County and thus, safe annual yield is not used for the City’s contractual water supply from this source. As described above, for the Nacimiento Reservoir, “dependable yield” is the City’s contractual water right from this resource. The original amount contracted from the Nacimiento Reservoir for primary supply was 3,380 AFY until March 2016 when City Council approved the addition of 2,102 AFY from Nacimiento Reservoir to the City’s secondary water supply. Recycled water is counted as part of the City’s available water resources based on the annual usage. As the City has discontinued groundwater use, this supply is not included in the estimate of available water resources to meet community needs. Table 4.13-1 provides a summary of the City’s available water resources. 8-270 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.90 The commenter states that Table 4.13-2 should include a footnote with reference to the 2016 UWMP with the definitions of primary and secondary sources. The commenter also requests that an additional column be added to the table specifying how many AFY of each source is potable and how many AFY of each source is non-potable. As stated in Response 29.89, the 2016 UWMP has yet to be formally adopted as the most up-to-date UWMP for the City. However, the following changes have been made in Section 4.13, Water Resources, in response to these comments, based on the City’s 2015 UWMP: Water Demand. […] In 2015, the City’s potable water use was 4,908 AF. The 2016 annual potable water availability includes the City’s primary water supply, reliability reserve, and secondary water supply, totaling 12,109 AFY. Table 4.13-2 shows the City’s current water demand and water availability. Table 4.13-2 Current Water Demand and Water Availability in the City of San Luis Obispo Water Yield and Demand AFY Primary Water Supply1 7,496 Reliability Reserve2 1,201 Secondary Water Supply3 3,412 2015 Actual Water Demand 4,908 Source: City of San Luis Obispo 2016a; 2016b. 1. Primary water supply is the amount of water needed to serve the build-out population of the City as identified in the Land Use Element of the General Plan. 2. Reliability reserve provides a buffer for future unforeseen or unpredictable long-term impacts to the City’s available water supply. 3. Secondary water supply is the amount of water remaining from the City’s available water resources above those needed to meet the primary water supply and reliability reserve. Response 29.91 The commenter states that Alternative 3 should not be considered the environmentally superior alternative on the basis that it does not meet the project objectives described in Section 2.0, Project Description. The commenter also states that this alternative would result in less diversity of housing types because all remaining units on the project site under this alternative would need to be multifamily high-density two- and three-story units to fit on the remaining project site development footprint. As described in Section 6.0, Alternatives, Alternative 3 was identified as the environmentally superior alternative over other alternatives due to the preservation of the San Luis Ranch Complex and reduced environmental impacts resulting from the reduced development footprint. Retaining the existing structures on the project site in their current condition would avoid the significant and unavoidable historical impact associated with the removal of the San Luis Ranch Complex. As described in Section 6.0, Alternatives, this alternative envisions fewer single-family homes in comparison to the project. No revisions to the Draft EIR are required in response to this comment. However, the commenters concern will be forwarded to the appropriate decision- makers for review and consideration. 8-271 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.92 This comment is an attachment from the Central Coast Regional Water Quality Control Board (Water Board), which notes that the Water Board a has reviewed the Shallow Soil Vapor Assessment prepared for the project by Enviro Assets, Inc. and Geosolutions, Inc. on July 20, 2015. This comment also states that the Water Board concurs with the findings of the assessment relative to the migration of solvents in the groundwater plume underlying the project site. In addition, this comment states that the soil vapor concentrations are below Environmental Screening Levels and, as such, the site does not pose a threat to human health from vapor intrusion to occupied buildings and no further action is required regarding solvents detected on the site. Refer to Response 29.11 for a discussion of this letter. This information will be forwarded to the appropriate decision-makers for review and consideration. Response 29.93 The commenter states that the Associated Transportation Engineers (ATE) has conducted a peer review of the Multimodal Transportation Impact Study (Appendix L), which was used to prepare Section 4.12, Transportation, of the Draft EIR. The commenter notes that their comments in this letter include evaluation of the impact thresholds, existing and baseline traffic volumes, project trip generation assumptions, project trip distribution assumptions, project-specific impacts, cumulative traffic impacts, level of service calculations, vehicle queue forecasts, mitigation measures, and mitigation phasing. Response 29.94 The commenter states that the Multimodal Transportation Impact Study (Appendix L) states that LOS D is acceptable for State Highway Facilities; however, the analysis applies LOS C as minimum standard to State facilities. The commenter also reiterates statements in the Multimodal Transportation Impact Study regarding thresholds and the City Synchro network. Per the December 2002 Caltrans Traffic Impact Study Guidelines, the State’s minimum threshold is LOS C/D cusp (the point of transition between LOS C and LOS D). Response 29.95 The commenter states that existing Levels of Service for Intersections #3 (Madonna Road/Dalidio Drive), #5 (Madonna Road/U.S. 101 Southbound Ramps/Madonna Inn), and #8 (Higuera Street/South Street) do not appear to be reasonable compared to ATE’s calculations prepared in 2015. ATE’s 2015 analysis is not appropriate for comparison at these intersections for the following reasons: 1. ATE’s analysis used out-of-date 2012 volumes & peak hour factors, whereas the Multimodal Transportation Impact Study (Appendix L) used the most current volumes available at the time of preparation; 2. ATE’s analysis did not use actual signal timing parameters, whereas the Multimodal Transportation Impact Study used signal timing parameters exported directly from signal controllers that were checked and validated; 3. ATE’s analysis used an out-of-date 2000 HCM methodology, whereas the Multimodal Transportation Impact Study used the most current 2010 HCM methodology; and 4. ATE’s analysis is not consistent with the project description evaluated by the Multimodal Transportation Impact Study and the Draft EIR. 8-272 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.96 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter states that these forecasts should be compared to existing traffic conditions in the field in order to verify and calibrate the model’s accuracy. All forecasts (i.e., volumes, delay, MMLOS, queues, etc.) are based on validated theoretical calculations. These are accepted methods for conducting traffic impact analysis. Please refer to FHWA Traffic Analysis Toolbox Volume VI: Definition, Interpretation, and Calculation of Traffic Analysis Tools Measures of Effectiveness. Response 29.97 The commenter states that the impacts and mitigations for Madonna Road/Los Osos Valley Rod (Intersection #1) and Madonna Road/Oceanaire Drive (Intersection #2) are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter states that these forecasts should be compared to existing traffic conditions in the field in order to verify and calibrate the model’s accuracy. The commenter also questions the need to mitigate impacts on right-turn pockets when queues exceed the storage provided, because right-turning vehicles at signalized intersections do not cause spillback that can block the adjacent through lane movements. The commenter recommends that the Multimodal Transportation Impact Study (Appendix L) consider more appropriate strategies to mitigate these impacts. The commenter also states that the project- added peak hour trips to the westbound right-turn movement at Madonna Road/Oceanaire Drive does not provide an adequate nexus to require constructing the Prado Road Overcrossing, and recommends that the analysis consider an optimized signal timing strategy to mitigate this impact. Per FHWA Signalized Intersections: An Informational Guide (July 2013), turn storage lengths should be sufficient to prevent vehicles from spilling back into the adjacent thru lane. Providing adequate storage length improves both operations and safety. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.98 The commenter questions signal timing assumptions at Intersection #3 (Madonna Road &Dalidio Drive) and requests that they are checked for Existing & Existing Plus Project conditions at various intersections. As part of the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Response 29.99 The commenter notes that the Multimodal Transportation Impact Study (Appendix L) identifies a significant impact at Madonna Road/U.S. 101 Southbound Ramps/Madonna Inn (Intersection #5). The commenter states that LOS D is acceptable for State Highway Facilities, but the 8-273 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Multimodal Transportation Impact Study applies LOS C as minimum Standard to State facilities. Refer to Response 29.94 for a discussion of the appropriate LOS threshold for State Highway Facilities. Response 29.100 The commenter questions signal timing assumptions at Intersection #5 (Madonna Road/U.S. 101 Southbound Ramps/Madonna Inn) and requests that they are checked for Existing & Existing Plus Project conditions at various intersections. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Response 29.101 The commenter states that identified impacts at Madonna Road/U.S. 101 Northbound Ramps (Intersection #6) and Madonna road/South Higuera Street (Intersection #7) would be mitigated with adjustments to the traffic signal timing at these intersections, and questions the need to mitigate these impacts with the Prado Road Overpass when less significant mitigation measures are available. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.102 The commenter questions signal timing assumptions at Intersection #8 (Higuera Street/South Street) and requests that they are checked for Existing & Existing Plus Project conditions at various intersections. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Response 29.103 The commenter states that the study identifies a project specific impact at Los Osos Valley Road/Froom Ranch Way (Intersection #9). The commenter states that there is no queuing impact at Los Osos Valley Road/Froom Ranch Way given the current lane configuration and that given the volumes and acceptable level of service extension of the right-turn lane is not warranted. This comment is inconsistent with the technical analysis. Although there are impacts identified at Froom/Los Osos Valley Road, they are not identified as project specific, and fair share impact percentages are provided in Table 123 of the Multimodal Transportation Impact Study (Appendix L). The statement that the intersection is forecast to operate acceptably and there is no queuing impact at this intersection is inconsistent with the technical assessment of forecasted multimodal LOS, queue lengths, and available storage capacity. Per FHWA Signalized Intersections: An Informational Guide (July 2013), turn storage lengths should be sufficient to prevent vehicles from spilling back into the adjacent thru lane. Providing adequate storage length improves both operations and safety. Response 29.104 The commenter states that delay calculations for Auto Park Way/Los Osos Valley Road (Intersection #10) should account for two-stage left turn maneuvers. The analysis accounts for two-stage gap acceptance using a two-way left-turn median and HCM 2010 methodologies. 8-274 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.105 The commenter requests that impacts which have been mitigated by the recently completed Los Osos Valley Road interchange project be deleted from the Multimodal Transportation Impact Study (Appendix L). The Los Osos Valley Road interchange project was not completed at the time the traffic analysis was initiated. However, the analysis acknowledges that no mitigation is required with the completion of the Los Osos Valley Road interchange and conditions representing the completed Los Osos Valley Road interchange are represented in the Multimodal Transportation Impact Study under near-term conditions. This impact is not carried forward into the Draft EIR based on the Multimodal Transportation Impact Study’s acknowledgement of the Los Osos Valley Road interchange project and near-term analysis. Response 29.106 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions the need to mitigate right turn lane storage impacts, when right turning vehicles can store in the thru lane then diverge into the right turn lane when the approach turn green. The commenter questions the need to mitigate various impacts with the Prado Road Overpass when less significant mitigation measures are available. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Per FHWA Signalized Intersections: An Informational Guide (July 2013), right turn storage lengths should be sufficient to prevent vehicles from spilling back into the adjacent thru lane. Providing adequate storage length improves both operations and safety. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.107 The commenter requests that impacts which have been mitigated by the recently completed Los Osos Valley Road interchange project be deleted from the Multimodal Transportation Impact Study. The commenter questions the need to mitigate right turn lane storage impacts, when right turning vehicles can store in the thru lane then diverge into the right turn lane when the approach turn green. The commenter questions the need to mitigate various impacts with the Prado Road Overpass when less significant mitigation measures are available. Refer to Response 29.105 for a discussion of impacts which have been mitigated by the Los Osos Valley Road interchange project. Refer to Response 29.106 for a discussion of the applicable FHWA recommendations for right turn storage lengths. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.108 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter states that theoretical queue forecasts at Los Osos Valley Road/South Higuera Street (Intersection #14) may be overstated. The commenter questions the need to mitigate right turn lane storage impacts, when right turning vehicles can store in the thru lane then diverge into the right turn lane when the approach turn green. The commenter questions signal timing assumptions at Intersection #14 (Los Osos Valley Road/Higuera Street), Intersection #16 (Higuera Street/Tank Farm Road), & Intersection #18 (Prado Road/Higuera Street) and 8-275 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo requests that they are checked for Existing & Existing Plus Project conditions. The commenter states that the requirement to widen Prado Road to provide a second left-turn lane appears to be a typographical error, since the northbound left-turn lane is on S. Higuera Street. The commenter states that the addition of a second left-turn lane to resolve the forecast queue storage issue is not warranted. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Refer to Response 29.106 for a discussion of the applicable FHWA recommendations for right turn storage lengths. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. The requirement to widen Prado Road to provide a second left-turn lane has been reviewed and determined not to be a typographical error. Justification for the addition of a second left-turn lane to mitigate project impacts is provided on pages 55 and 79 of the Multimodal Transportation Impact Study (Appendix L). Response 29.109 The commenter states that the Multimodal Transportation Impact Study (Appendix L) identified roundabout control as the mitigation for Dalidio Drive/SC Project Driveway (Intersection #25). The commenter suggests less significant alternative mitigation measures such as turn lanes and signalization. The Draft EIR identifies alternative mitigation to roundabout control as restricted access. The commenter’s suggested alterative mitigations (signalization and turn lanes) were initially considered but rejected due to inconsistency with General Plan Policy. Response 29.110 The commenter questions the validity of the level of service analyses for Madonna Road Eastbound between Oceanaire Drive and Los Osos Valley road (Segment #1), Madonna Road Eastbound between Oceanaire Drive and Dalidio Drive (Segment #2), Madonna road Westbound between El Mercado and Dalidio Drive (Segment #3), Madonna Road Eastbound between U.S. 101 Northbound Ramps and S. Higuera Street (Segment #6), and Los Osos Valley road Northbound between Froom Ranch Way and Madonna Road (Segment #13). The commenter recommends that the segment analysis be reviewed assuming the intersection mitigation measures. The commenter reiterates Multimodal Transportation Impact Study findings that the intersections along Los Osos Valley Road between Froom Ranch Way and Madonna Road are forecast to operate at LOS D or better during the PM peak hour under existing plus project conditions. Street segment level of service analysis was done in compliance with the adopted Transportation Research Board’s 2010 HCM. The HCM is the industry standard for level of service analysis. Response 29.111 The commenter states that traffic signal timing optimization should be considered for impacts at Madonna/Los Osos Valley Road (Intersection #1), and should be considered first for impacts at all impacts at signalized intersections. Traffic signal timing optimization was used as the first consideration for improving impacts in the Multimodal Transportation Impact Study (Appendix L). As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. 8-276 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.112 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions the need to mitigate various impacts with the Prado Road Overpass when less significant mitigation measures are available. The commenter states that traffic additions at Madonna Road/Los Osos Valley Road (Intersection #1) and Madonna Road/Oceanaire Drive (Intersection #2) do not provide an adequate impact nexus to require constructing the Prado Road Overpass. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.113 The commenter suggests that near-term forecasts and analysis should first be completed assuming the Prado Road Overpass is not constructed. The commenter suggests that because the Los Osos Valley Road/Froom Ranch Road intersection operates acceptably under near-term plus project without the Prado Road Overpass, project traffic volumes without the Prado Road Overpass would be accommodated within acceptable LOS. As suggested, near-term forecasts and analysis were initially conducted assuming no Prado Road Overpass. This scenario was rejected due to impacts requiring the Prado Road Overpass as mitigation at Phase 2 of the project. Response 29.114 The commenter questions signal timing assumptions at Intersection #3 (Madonna Road & Dalidio Drive)and requests that they are checked for near term & near term plus project conditions at various intersections. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Response 29.115 The commenter states that the calculations for Madonna Road/El Mercado (Intersection #4) assume one existing westbound left turn lane when there are actually two. The Multimodal Transportation Impact Study (Appendix L) shows that only one westbound turn lane was utilized for near term conditions in the PM peak hour. However, the queue spillback from Madonna Road/Dalidio Drive (Intersection #3) causes the identified impact, and the recommended mitigation for this adjacent intersection would still be required. The Synchro/Simtraffic worksheets for Intersection #4 have been updated to reflect two westbound left-turn lanes. The increased capacity for the westbound left turn lane at El Mercado is not projected to mitigate impacts from the queue spillback from Madonna Road/Dalidio Drive. Response 29.116 The commenter states that the Multimodal Transportation Impact Study (Appendix L) states that LOS D is acceptable for State Highway Facilities. However, analysis applies LOS C as minimum standard to State facilities. The commenter suggests alternative mitigation with adjustment of 8-277 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo signal timing at Madonna Road & U.S. 101 Ramps, and provides a Synchro Report to support this comment. Refer to Response 29.94 for a discussion of the appropriate LOS threshold for State Highway Facilities. Review of the provided timings in Synchro show a max split of 10 seconds for the eastbound lane, and 20 seconds for the westbound lane. The Change Period and Max Green Setting as shown in the Synchro worksheet should be considered for timings instead of the Phase Duration. Refer to HCM 2010 Chapter 18 for how the Phase Duration is calculated. Response 29.117 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions signal timing assumptions at various intersections and requests that they are checked for Existing & Existing Plus Project conditions at various intersections. The commenter states that this issue could be mitigated with adjustments to the traffic signal timing, and does not warrant the construction of the Prado Overpass. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.118 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter states that the project is forecast to add 19 left turns increasing the queue length from 151 to 258 feet at Madonna Road/U.S. 101 Northbound Ramps (Intersection #6) under near term conditions. The commenter states that this increase does not appear reasonable give the minor project traffic additions and the small change in intersection delay. The commenter states that this issue could be mitigated with adjustments to the traffic signal timing, and does not warrant the construction of the Prado Overpass. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. The project adds traffic to certain movements which in turn affect conditions at other traffic movements. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.119 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions the need to mitigate right turn lane storage impacts, when right turning vehicles can store in the thru lane. The commenter recommends that the analysis include an optimized signal timing strategy for mitigating impacts at Madonna Road/South Higuera Street (Intersection #7). 8-278 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Refer to Response 29.106 for a discussion of the applicable FHWA recommendations for right turn storage lengths. As described in Response 29.111, traffic signal timing optimization was used as the first consideration for improving impacts in the Multimodal Transportation Impact Study (Appendix L). As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Response 29.120 The commenter questions signal timing assumptions at Intersection #8 (Higuera Street/South Street) and requests that they are checked for Existing & Existing Plus Project conditions at various intersections. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Response 29.121 The commenter suggests that near-term forecasts and analysis should be completed assuming the Prado Road Overpass is not constructed. The commenter suggests that because Los Osos Valley Road/Froom Ranch Way (Intersection #9) operates acceptably under near-term plus project without the Prado Road Overpass, and project traffic volumes without the Prado Road Overpass would be accommodated with acceptable levels of service. Near-term forecasts and analysis were initially conducted assuming no Prado Road Overpass. This scenario was rejected due to impacts requiring the overpass as mitigation at Phase 2 of the project. Response 29.122 The commenter states that the study identifies a project specific impact at Los Osos Valley Road/Froom Ranch Way (Intersection #9). The commenter also states that there is no queuing impact at Los Osos Valley Road/Froom Ranch Way, given the current lane configuration and that given the volumes and acceptable level of service extension of the right-turn lane is not warranted. The statement that there is no queuing impact at this intersection is inconsistent with the technical assessment of forecasted queue length and available storage capacity. Construction of the Prado Road Overpass results in a significant volume increase on the westbound approach, which results in the need for the right-turn lane identified in the Multimodal Transportation Impact Study (Appendix L). Response 29.123 The commenter states that delay calculations for Los Osos Valley Road/Auto Park Way (Intersection #10) should account for two-stage left turn maneuvers. The analysis accounts for two-stage gap acceptance using a two-way left-turn median in the analysis and HCM 2010 methodologies. Response 29.124 The commenter states that the Multimodal Transportation Impact Study summary table identifies a significant impact at Los Osos Valley Road/Calle Joaquin (Intersection #11), but that queue data in Table 56 of the Multimodal Transportation Impact Study (Appendix L) do not indicate a 8-279 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo queuing impact. Refer to Table 64 & 65 of the Multimodal Transportation Impact Study. Table 64 correctly presents the Near Term Project Conditions 95th Percentile Queuing Analysis. Table 56 is a document production error, and has been removed from Appendix L. Response 29.125 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions the need to mitigate left turn lane storage impacts, when left turning vehicles can store in the thru lane then diverge into the left turn lane when the approach turns green. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Refer to Response 29.103 for a discussion of the applicable FHWA recommendations for turn storage lengths. Response 29.126 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions the need to mitigate right turn lane storage impacts, when right turning vehicles can store in the thru lane then diverge into the right turn lane when the approach turns green. The commenter states that project-added traffic at Los Osos Valley Road/U.S. 101 Northbound Ramps (Intersection #13) does not provide an adequate impact nexus to require the mitigation of constructing the Prado Road Overpass. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Refer to Response 29.106 for a discussion of the applicable FHWA recommendations for right turn storage lengths. The analysis included optimizing signal timings as the first stage for mitigations. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. Response 29.127 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter states that the Multimodal Transportation Impact Study (Appendix L) summary table does not identify an impact for the westbound right turn lane at South Higuera Street/Suburban Drive (Intersection #15), instead showing a potential impact for the southbound right turn queue. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. As described in Response 29.124, Table 56 is a document production error, and has been removed from Appendix L. Response 29.128 The commenter questions the need to mitigate the impact at South Higuera Street/Tank Farm Road (Intersection #16) with the Prado Road Overpass when other mitigation measures are available. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. 8-280 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 29.129 The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter states that the impact locations and recommended pocket lengths in Table 65 of the Multimodal Transportation Impact Study (Appendix L) are not consistent with the findings of the queuing analysis presented in Table 56. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. As described in Response 29.124, Table 56 is a document production error, and has been removed from Appendix L. Response 29.130 The commenter states that roundabout control at Dalidio Drive/Prado Road/Froom Ranch Way (Intersection #21) may be problematic due to grades and intersection spacing in the long- term scenario with the Prado Road Overpass and ramps. The commenter recommends that the Multimodal Transportation Impact Study (Appendix L) explore signalization of this intersection. The statement that roundabout control would be problematic due to grade and spacing is speculative and inconsistent with the preliminary design work for the project site currently under review by the City of San Luis Obispo Public Works Department. Response 29.131 The commenter states that the Multimodal Transportation Impact Study (Appendix L) identified roundabout control as mitigation for impacts at Dalidio Drive/SC Project Driveway (Intersection# 25). The commenter recommends that the analysis consider alternative mitigation measures such as turn lanes and signalization. The Draft EIR identifies restricted access as an alternative to roundabout control as mitigation. The commenter’s suggested alterative mitigations (signalization and turn lanes) were initially considered but rejected due their inconsistency with General Plan Policy. Response 29.132 The commenter notes that the Multimodal Transportation Impact Study (Appendix L) includes a phasing analysis to determine during which project phase the major improvements would be required to reduce identified project impacts. The commenter states that queue forecasts are derived from the Synchro/Simtraffic model, and are therefore theoretical forecasts based on input parameters used in intersection modeling. The commenter questions signal timing assumptions at various intersections and requests that they be checked for existing & existing plus project conditions at various intersections. The commenter suggests that the phasing assessment found no deterioration of level of service under the near term Scenario as a result of the interchange not being in place and suggests that the Prado Road Overpass is not warranted. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Northbound right turn overlap phase for Madonna Road/U.S. 101 Southbound Ramps/Madonna Inn (Intersection #5) was utilized in the analysis. No changes were identified. As discussed in Response 29.116, the Change Period and Max Green Setting as shown in the Synchro HCM 2010 worksheet should be considered for timings instead of the Phase Duration. Refer to HCM 2010 Chapter 18 for how the Phase Duration is calculated. 8-281 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Consistent with City policy and guidelines, the analysis identifies an impact based on the increase in v/c ratio of 0.01 or more when the LOS threshold is already exceeded. In the AM peak hour under near term conditions, Madonna Road/U.S. 101 Southbound Ramps/Madonna Inn operates at unacceptable LOS D and the project increases the v/c ratio by more than 0.01, resulting in a project impact at this interchange. Traffic signal timing optimization was used as the first consideration for improving impacts in the analysis. Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. 8-282 Meeting: From: Andrew Smith <Item: Ups h i1 RECEIVED Sent: Monday, January 30, 2017 1:41 PM CITY OF SAN LUIS OBISPO To: Advisory Bodies Subject: San Luis Ranch Draft EIR Comments JAN 3 0 2017 COMMUNITY DEVELOPMENT Dear Planning Commission Members, My name is Andrew Smith and I have been a resident of San Luis Obispo since 2002. I graduated from Cal Poly and have been fortunate enough to find work here, buy a house here and have a child here. We currently live at the corner of Oceanaire Drive and Seaward Street. I work across town, off of Industrial Way. I commute by bike as often as possible by choice and commuted for years by bike to a previous job in Los Osos. I feel that my chosen transportation method allows me a slightly different view of our roads as opposed to the average automotive commuter. Traffic is already an issue on all roads that are to be impacted by this project. Southbound 101 often is a parking lot from the Madonna over pass through Pismo Beach. Los Osos Valley Road recently underwent a major upgrade to increase the overpass over 101 from one lane to two in each direction. Madonna Road is often a parking lot from Los Osos Valley Road back to Highway 101. All of these areas are identified in the Draft EIRs for BOTH the San Luis Ranch and Avila Ranch developments. Adding all these homes will impact traffic. As a resident I am worried by the Draft EIR. On page 1 of Section 4.12, concerning transportation, Madonna Road is not even mentioned. In addition, the Traffic Impact Study cited is listed as Appendix K, which is incorrect. It is Appendix L. As a practicing mechanical engineer, small errors like these greatly concern me as they point towards larger issues or even negligence. Madonna Road is one of two roads that directly border the proposed development. Currently the intersection of Madonna Road and Oceanaire Drive is severely impacted with afternoon traffic regularly backed up to Dalidio Drive, the other road that borders this development. In the Traffic Impact Study used as source material, this intersection (Madonna and Oceanaire) is said to have a 14.2 second delay during PM peak hours. This compares to 56.2 seconds at Madonna and Dalidio and 45 seconds at Madonna and Los Osos Valley roads. These numbers are all existing conditions during peak PM hours. As a daily commuter this does not reconcile with my experience; the intersection of Madonna and Oceanaire is a significantly longer delay than the intersection of Madonna and Dalidio. To directly quote from page 35 of the Transportation Impact Study: "...most of the segments are currently operating at deficient LOS for pedestrian and transit modes, as well as several segments for automobile mode... a reduction in traffic volume is often the only way to theoretically achieve exceptional LOS scores for these modes." As stated in the Draft EIR, the mitigation for traffic at this intersection would be to construct the Prado Road overpass. This would not impact vehicle traffic heading to or from CL Smith Elementary or Laguna Middle schools. This would not reduce vehicle traffic to or from Los Osos Valley road if the individuals are heading northbound. The Traffic Impact Study uses a traffic analysis program to study traffic. I am trained and regularly use analysis programs as part of my job and realize they cannot necessarily be taken as absolutely correct. Rather they are much like the weather forecast, which is also the result of an analysis program. Slightly incorrect inputs or parameters can have massive effects on the outcome. We cannot know with any certainty where the hundreds of families that would move into this development would drive and when. I would like to propose having the EIR study the effects of eliminating the access from the Madonna frontage road to the Madonna and Oceanaire interchange. Currently the intersection is a 6 way intersection that defaults to a timed mode (as opposed to a `smart' mode) during peak traffic hours. This means that even though there may be no traffic waiting to merge from one direction, the light will still turn green for that direction for a period of time. If the intersection was to be changed to a 4 way light (traffic on Oceanaire and Madonna only) it could potentially reduce the cycle time. The traffic currently accessing through the frontage roads would be forced to go through the adjoining neighborhoods to reach Oceanaire, but these are only a few homes and it is only an additional block. The change 8-283 would be easy to accomplish with a vehicle block at the current ingress/egress locations. Other more creative mitigation efforts could (and should) include a pedestrian overcrossing of Madonna Road in order for Elementary and Middle school children to safely walk/cycle to school and for residents to access Laguna Lake park. This overcrossing could also allow bikes access from the Bob Jones trail off Los Osos Valley Road to the Madonna Inn bike path if done correctly. In closing I would like to say that I understand the want to build more housing and I feel that this is a good location to do it. I do however feel that the traffic impacts seem to be brushed aside, especially when taking the long view and realizing other developments are necessarily coming (some simultaneously, as Avila Ranch). The traffic can and will only become worse, so please plan ahead and not just `plug the dam with our finger'. There is tremendous profit to be had in these types of developments, let's make sure as a community we also profit from the development, and not just monetarily. Let's make sure the developer is not allowed to put us at a disadvantage in the long term for a short term gain. Thank you for your time, Andrew Smith 1102 Seaward St San Luis Obispo, CA 93405 8-284 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 30 COMMENTER: Andrew Smith, Private Citizen DATE: January 30, 2017 Response 30.1 The commenter states that he is a resident off of Oceanaire Drive and commutes across town via bicycle. The commenter states that traffic is already an issue on all roads that would be impacted by this project and expresses concern from the Draft EIR. The commenter’s subsequent comments are addressed in Responses 30.2 through 30.5. Response 30.2 The commenter states that on page 1 of Section 4.12, Transportation, Madonna Road is not mentioned, and that this section incorrectly labels the Multimodal Transportation Impact Study as Appendix K, when it is actually Appendix L. The commenter states that the intersection of Madonna Road and Oceanaire Drive is severely impacted, and notes that the Multimodal Transportation Impact Study describes a 14.2 second delay during the PM peak hour under existing conditions, which does not correspond to the much higher delay at the adjacent intersections. The commenter disagrees with the results of the Multimodal Transportation Impact Study at this intersection, stating that from personal experience the intersection operates with much longer delay than the adjacent intersections. The labeling of the Draft EIR appendices will be updated to reflect that the Multimodal Transportation Impact Study is Appendix L. Page 1 of Section 4.12, Transportation, mentions Madonna Road as having regional access to U.S. 101 and local access to the project, and a description of this roadway as part of the local roadway network is on page 4.12-8. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Due to the limitations of the HCM methodologies for intersections with more than four legs, the delay and service levels were calculated using HCM 2000 methodologies for the Oceanaire Drive intersection for the automobile mode. For comparison, the traffic that is delayed from turning from/to the side street of Oceanaire Drive is approximately 13 percent of the total traffic being served by the intersection during the PM peak hour. At Madonna Road/Dalidio Drive, approximately 27 percent of the PM peak hour traffic is turning with 12 percent more vehicles being served through the intersection. At Madonna Road/ Los Osos Valley Road, there is a higher volume of turning vehicles, and approximately 48 percent more vehicles going through the intersection compared to Madonna Road/Oceanaire Drive. As described in Response 23.4, the measures of effectiveness (i.e., speed, delay, MMLOS, volume/capacity, queues, etc.) are based on validated theoretical calculations and methodologies presented in the HCM. These are accepted methods for conducting traffic impact analysis. Please refer to FHWA Traffic Analysis Toolbox Volume VI: Definition, Interpretation, and Calculation of Traffic Analysis Tools Measures of Effectiveness. 8-285 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 30.3 The commenter states that the mitigation to construct the Prado Road Overpass will not reduce vehicle traffic on Los Osos Valley Road northbound/westbound, including traffic heading to or from CL Smith Elementary or Laguna Middle School. The commenter expresses doubt regarding the conclusions of the traffic modeling completed in the Multimodal Transportation Impact Study (Appendix L). Refer to Master Response 2 for a discussion of the necessity and adequacy of the Prado Road Overpass mitigation. The traffic forecasts and project trip distribution was determined using the City’s Travel Demand Model. As presented in the Draft EIR, construction of the Prado Road Overpass would result in a shift in traffic between Madonna Road and Los Osos Valley Road. Since Los Osos Valley Road northwest of Madonna Road provides regional access to communities west of San Luis Obispo, the Travel Demand Model and forecasts do not project a decrease in regional traffic. However, based on the City’s Travel Demand Model, the construction of the Prado Overpass or Interchange will reduce traffic along Los Osos Valley Road, specifically at the Los Osos Valley Road interchange with U.S. 101. Response 30.4 The commenter suggests having the Draft EIR study the effects of eliminating the access from the Madonna Road frontage roads to the 6-way Oceanaire Drive intersection to reduce the cycle time. The commenter states that the intersection does not operate as an actuated signal during the peak periods with approaches turning green when there is no traffic that actuates the light. The commenter states that mitigation should include a pedestrian overcrossing at this intersection to accommodate elementary and middle school children to safely cross Madonna Road and connect to the Bob Jones Trail. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. Although the signal is fully actuated, it is in coordination with the Los Osos Valley Road/Madonna Road intersection, which may give the appearance of a fixed time operation. The Draft EIR did not identify project impacts that would be mitigated by the construction of a pedestrian overcrossing at this location. Mitigation measures for project-related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road. Response 30.5 The commenter states that the project site is a good location to build additional housing, but states a concern with the project’s potential traffic impacts, including cumulative traffic impacts. The commenter states that the project developer should not be allowed to put the community at a disadvantage for a short-term-gain. The commenter does not raise specific concerns about the conclusions of the Draft EIR in this comment. Refer to Responses 30.1 through 30.4 for a discussion of the commenter’s specific concerns regarding the project’s potential traffic impacts. No further revisions to the Draft EIR are required in response to this comment. However, the commenter’s concerns will be forwarded to the appropriate decision-makers for review and consideration. 8-286 Meeting: Item: S L/y K Vi,%A De- l - 11Wr ti s Com— _ r wrA 11 E2 r % J r. A s ,, It . c .r Gl .i.. it le -1 y>I!!l—+1 RECEIVED CITY OF SAN LUIS OBISPO JAN 3 0 2017 I COMMUNITY DEVELOPMENT ilk j6>r4 Vv k-r K L-cTrL4p— 4=R- No L f 0 L, Cu i Ttvi T= i tom[ 1cJ Vl,( — CA T ' P 1 F 58-287 V,6-"7rR-- t aim / Imn IM -Aral "A t Iry t. 11 O-eg J 3 a r1 T FS —43 go c7r v A -a' t 'L -1 F 'C x gLI(Z tZ W L L4— 4 w W i'iia-t. C r-t)*N Tit+ I -v L*e, yr`' y L. -Z- L' - W l Rg i° .. s.m Tr i tr1 el Cz- A. l.Z> l -j Ul c Tl t- l i •f r_ -+ y6t bbly — n g2 r— A C' I .1912¢ ` ' A, - 1 e.p ,*ppi °Ci ®i.. .yy.+` . r c-i. e -._"G'.'".f' kl'# r 4 e . tom.,.+-1±1 m-'.' -.,I ..1't cy"'sa_I.,. 8-288 46 -t=i r- L+cL rjv-- Li_ e--4 ,:rmr W-[ .fir. x t+ :re-,, .'. .1J_t•__t' N i i AP -ELI t> t 1 .114. 10 Ln, wo 41 G -r A-tzrratz - I. 'i;tr lr" r to t t r tom - - E;-1-t)- Tp-i- ' -'Llys . L-.uiz a-ot? l+.rr; . -T r N bF 'moo t l ice- rJ 6+F tw,L'"' T "Gt+c. D-i..l i Vz& 'C' ev%1 Z 5 T T444 3 3i P4f,= s P3 C.'r- 8-289 B tip N* - us -r-, N aye-rl Prc f2 -TL fJ4- EW- us epz LIo aCi-Mmm t - tj 1 N-FeKe- w t -r -- -- tz-WA-M f-> n- m 8-290 M Flpre 2.5 Draft Site Plan y tir , s VjMrsion4 ww ru LEGEND 4 h PUBLIC PARKING ALLEY (LANE) TVP ='ti N. Is CG-MMERCIAL ACRICULT1UR.AL INTERItiA OPEN;PACE PARRS, CREEK, 3A6I1'6. INTERNAL =1PEN SPACE RE JDEMTIAL 40 'WIDE LOT; R.ES DENTIAL 0/IDE LOS; RESIDENTIAL 3 -;TORY .AT -AC iED .AND DETA,=HED Qy 1 '`i ;LL iS I SPECIFIC PLAN I City of San Luis Obispo, CA I August 28, 2015 Preliminary Draft 8-291 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 31 COMMENTER: Gary Smith, Private Citizen DATE: January 30, 2017 Response 31.1 The commenter states that the project would result in long-term impacts and costs to taxpayers, and identifies agriculture and open space preservation and traffic and circulation as key issues. The commenter’s statements related to traffic and circulation are addressed in Responses 31.2 through 31.5. Regarding agriculture and open space preservation, the commenter states that the City’s goal to preserve a minimum of 50 percent of the site in agricultural use is inappropriate. The commenter states that the outreach surveys conducted for the City’s Land Use and Circulation Element Update process indicate public support for preservation of agriculture and open space preservation, and reduction in traffic congestion. The comment states that the 50 percent agricultural land preservation requirement should not be based on the net site acreage, and that taxpayers will be required to pay for roadway, infrastructure, and public service improvements, flood protection, and annexation. The commenter requests that the EIR, along with the Planning Commission’s recommendations, be vetted, and that initial and future projected costs be disclosed to the public before actions are taken by the City Council. The project’s consistency with applicable City General Plan policies, including Land Use Element Policy 8.1.4, which requires the City to preserve half of the agriculture and open space land in the San Luis Ranch Specific Plan Area, is discussed in Section 4.9, Land Use/Policy Consistency. Section 6.0, Alternatives, includes an evaluation of the potential impacts of the existing Measure J entitlements (Alternative 2) in comparison to the project. Regarding the commenter’s recommendation that the 50 percent on-site agricultural land preservation requirement not be based on the net site acreage, it should be noted that the specific requirements needed to be met by the applicant to ensure consistency with this City policy, including the precise acreage to be preserved on- and off-site, and the “substantial multiplier” required by the City for off-site agricultural preservation, would be determined by the City at the time that final approval for off-site property exchanged to meet the on-site requirement is considered. However, to provide clarity and transparency for consideration of this issue, the Residual Impacts discussion under Impact AG-1 has been revised as follows: Approximately 109 acres of the 131-acre project site are currently used for the production of irrigated row crops including celery, broccoli, lettuce, Asian vegetables, and peas. As shown in Figure 4.2-2 and Table 4.2-3, the project site contains 112 109 acres of Prime Farmland, as designated by the FMMP, with 109 acres in agricultural production. This Prime Farmland comprises approximately 83 percent of the site, with non-Prime Farmland located along the western and northwestern fringes of the site. The project would preserve approximately 52.7 53 acres in agriculture adjacent the San Luis Obispo City Farm and along the project site frontage with U.S. 101, all of which is designated Prime Farmland. The remaining agricultural area represents (approximately 40.7 43 percent) of the net site acreage and 40 percent of the gross site acreage (when 8-292 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo major roadways and right of way for the Prado Road interchange are discounted) in agriculture, primarily adjacent the San Luis Obispo City Farm and along the project site frontage with U.S. 101, all of which is designated Prime Farmland. Approximately 59.3 56 acres of on-site Prime Farmland would be converted to non-agricultural use. The commenter’s concerns regarding the burden of the project on taxpayers, and requests that recommendation that the EIR and the Planning Commission’s recommendations be vetted, and that project costs be disclosed to the public before the City Council acts will be forwarded to the appropriate decision-makers for review and consideration. Response 31.2 The commenter states that all of the residential visitors, service and delivery vehicles, commercial, and hotel patrons have to be accounted for in the Draft EIR analysis. The commenter states that the 2014 Land Use and Circulation Element Update Project review indicated a significant and unavoidable impact to traffic (CIR-3, ES-14). The commenter states that the project will feed onto Los Osos Valley Road and Madonna Road, with the redesigned Dalidio Drive providing a connection to the Prado Road Overpass, which the commenter states could generate 26,000 vehicles per day. The commenter states that the conclusion that the extension of Froom Ranch Way to Dalidio Drive would reduce traffic on the Los Osos Valley Road corridor is speculative and unsubstantiated. Refer to Responses 30.2 and 30.3, which address the validity of the City’s Travel Demand Model as used in the Multimodal Transportation Impact Study (Appendix L) and the Draft EIR, and anticipated reduction in vehicle trips along Los Osos Valley Road with the required project mitigation. Response 31.3 The commenter states the opinion that a reduced project containing 375 residential units and reduced commercial-retail space would be cost effective to the taxpayers, but does not provide supporting evidence. The provision of 375 residential units would be close to the minimum allowable density at the project site, which was not analyzed as a part of the Draft EIR. However, Section 6.4.4, Alternative 4: 50% On-Site Agriculture/Open Space, provides a scenario in which a total of 44 residential units would be reduced, resulting in an overall residential buildout reduction from 580 units to 536 units. Based on the analysis of Alternative 4, the incremental reduction in residential units was determined to have similar environmental impacts significant and unavoidable impacts across six environmental issues (cultural resources, land use, noise, biological resources, hazards and hazardous materials, and recreation), and therefore comparable to the project. The incremental reduction in residential units provided in Alternative 4 would result in incrementally reduced VMT, as stated in Section 6.4.4. However, vehicle trips generated in Alternative 4 would still be expected to exceed the capacity and LOS thresholds for the intersections and roadways in the project and specific plan area. Though impacts to transportation and circulation under Alternative 4 would be slightly reduced in comparison to the project, the incremental reduction of residential units would not avoid the significant and unavoidable transportation impacts. A development alternative with fewer residential units and reduced commercial area would generally have a similar footprint as the project, due to the designated land uses and zones 8-293 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo comparable to Figure 2-4, Proposed Project Pre-Zoning. The reduction of residential units from 580 proposed in the project to 536 in Alternative 4, or 375 residential units as proposed by the commenter, would ultimately not reduce any of the project’s significant and unavoidable impacts to a level below significance thresholds. Therefore, Alternative 4 was determined infeasible and a lower density development alternative proposed by the commenter would result in similar conclusions. The commenter’s perspective that the project should be reduced in size and scale with “interim open space for possible future development,” would not reduce the significant and unavoidable impacts discussed throughout the Draft EIR and specified in Section 5.0, Other CEQA-Required Discussions. Potential future development of any undeveloped space would have to comply with the provisions of the San Luis Ranch Specific Plan and the City of San Luis Obispo General Plan. As such, development would have to be consistent with the land use designations of the San Luis Ranch Specific Plan area, and resulting impacts would be similar to those identified for the project in the Draft EIR. The commenter also states that there is no data supporting the interest or long-term revenue for the Agricultural Heritage and Learning Center. Sections 4.2, Agricultural Resources, and 4.5, Cultural Resources, analyze and discuss the significance of the San Luis Ranch Complex, and the development of an Agricultural Heritage and Learning Center as part of the project. Section 4.9, Land Use/Policy Consistency, provides a thorough analysis of relevant General Plan and Specific Plan policies pertaining to the preservation of agricultural heritage at the project site. The development of the Agricultural Heritage and Learning Center is directly aligned with policies pertaining to cultural heritage, conservation and open space, and land use. Response 31.4 The commenter states that the Prado Road Overpass/Interchange reduces agricultural land use at the project site, and a reduction in residential and commercial land uses would provide additional land for agricultural uses. As described in Section 4.12, Transportation, the Prado Road overpass at U.S. 101 and associated ramps are necessary to mitigate the potential circulation impacts of the project, and mitigation measures in Impacts T-1, T-2, T-3, T-8, T-9, and T-10 require the project developer to pay fair share fees for such public improvements. The potential residual impacts that may result from project mitigation requiring construction of the Prado Road & U.S. 101 overpass, including impacts to agricultural resources, are discussed in Section 4.12.5(d). This discussion concludes that the foreseeable long-term impacts of the Prado Road/U.S. 101 overpass/interchange would include potential obstruction of scenic views, loss of prime agricultural land west of U.S. 101, and land use impacts associated with acquisition of additional right-of-way. In addition, Section 6.0, Alternatives, includes analysis of impacts associated with Alternative 4 which is intended to retain 50 percent of the net site acreage as on- site agricultural and open space uses to be consistent on-site with the City’s General Plan Land Use Element Policy 8.1.4.f. The commenter’s recommendation that reducing residential and commercial land uses would provide additional land for agricultural uses is discussed in Response 31.3. Response 31.5 The commenter states that impacts associated with the pre-application plan for review of the Madonna on Los Osos Valley Road Specific Plan – 3 should be considered. The commenter 8-294 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo states that the Madonna on Los Osos Valley Road Specific Plan project could impose a significant impact on the traffic and circulation long the Los Osos Valley Road and Madonna corridors. This comment does not pertain to the San Luis Ranch Project and does not reflect on the adequacy or content of the Draft EIR. This comment will be forwarded to the appropriate decision-makers for review and consideration. 8-295 Meeting: Item:- nay , LJ k V4 alp. M YL RECEIVED CITY OF SAN LUIS OBISPO JAN 3 0 2017 COMMUNITY DEVELOPMENT I - - - - " s, 1 M, r- t & t64 Z l Ii.P l ; '+f es c , F, ' OF— Y Land Use Proposed Project Land Use Element Recommended Reduced Project Alternative Commercial 150,000 s.f. 50-200,000 s.f. 50,000 s.f. Office 100,000 s.f. 50- 150,000 s.f. 50,000 s.f. Residential 580 units 350-500 units 350 units Hotel 200 rooms 200 rooms 200 rooms F, ' OF— Y 8-296 Quantity Proposed Project Residential 580 units Commercial 150,000 s.f. O fice 100,000 SJ' Hotel 200 rooms Land ;ries above account for97% of project daily trips. Reduced project consistent with Land Use Element Daily Derived Rate Trips 8.11 0.06 0.01 8.17 Total Residentiai 350 units 8.11 Cornrnercia1 50,000 s.f. 0.06 0-; ice SCD,L$ro s.=. 0.01 Hotel 200 rooms 8.17 Total As % of Proposed Project r- P 4,706 8,839 1,313 1, 634 16,492 2,340 2,946 657 1, 634 8,077 490 PM Derived Rate Trips 0.28 0.01 0.00 0.60 162 786 190 120 1,258 0.28 98 0.01 262 0.00 95 0.60 120 575 46% F tz.-. ---- .-G•IZtd C i L._ v.SL.. W 1 1 1.1"'i" .— belt f'rt'Ku 4!'t mow -J o t?-'t' '--. "' ?P.S'V t Pr,- TEkc--- T fir LO TV, ttJu-h v t rt©u I C'i Ur.1 T, ,- L C."-`L.. + ,W Vr=dt=J%1iZ_ yVt 1-1l F V1 1 c4—i ir lii.. y+l,,i,_+ ,fie 2 - ' 5'P -t 6 -f'Lwr P a' -Z.vr'_ `-'J ---___ 8-297 114l,ru?V Lr,r V i j k r--1 cnopov f'-t ' ,-tom,. _-1 r1 r_ '' Ilk x -1R.iit r i s r:,-:1"ai -., I .N sib , f i rri• . .a rti x. • s i r P 6Y , r i 1' i:r r T ' UMAM-1 - Wit —11 A -T`.. .- of . 42. 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AGRICULTURAL INTERVJ OPEN SPACE I # PARKS, CREEK, BASINS, INTERNAL OPEN SPACE RESIDENTIAL 40' NIDE LOTS RESSIDENTIAL 30' WIDE LOTS RESIDENTIAL S -STORY ATTACHED AND DETACHED F 7 "Fr— 1,57 IS` _ `i SPECIFIC PLAN I City of San Luis Obispo, CA I August 28, 2015 Preliminary Draft 8-300 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 32 COMMENTER: Gary Smith DATE: January 30, 2017 Response The commenter recommends an alternative that fulfills the minimum requirements of the project parameters based on the City of San Luis Obispo General Plan. According to the City’s General Plan performance standards for the San Luis Ranch Specific Plan Area, the minimum number of residential units anticipated within the Specific Plan Area is 350 units, and the minimum square footage of non-residential development anticipated within the Specific Plan Area is 100,000 square feet (50,000 square feet of commercial and 50,000 square feet of office (refer to Table 2-1 in Appendix B, Draft Specific Plan). The Draft EIR discusses a reasonable range of alternatives to the project in Section 6.0, Alternatives. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for a discussion of the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. 8-301 RECEIVED CITY OF SAN LUIS OBISPO JAN 3 0 2017 COMMUNITY DEVELOPMENT Meeting: item: .Sky,Lvi5 bE19-- To whom that may care about our SLO city as I do. 1/29/ 17 Myself, my wife, and our two young children live on Oceanaire Drive on the east side of Madonna Rd. We bought our home ten years ago after graduating from Cal Poly. We liked the convenience of this part of town and its close proximity to schools and parks and hiking trails. I have decided to devote some of my time and efforts toward aiding in the impacts that will result from a proposed San Luis Ranch development. Someone recently told me that through positively engaging with local government, one could actually have an impact; I hope to do that here. Although I would love to have the old Dalidio Ranch remain unchanged completely, 1 understand the situation both with the developer and the city, and want my efforts and opinions to be realistic and based on good judgment and data. I have a few points of concern pertaining to the San Luis Ranch EIR that I wanted to get to you in writing. They are as follows: 1. The EIR does not provide substantial evidence that the Prado Road overpass is required in Phase 2 of the development. In simple talk, the traffic report provides that the proposed development, once complete, would plague some of the city's main traffic arteries with unavoidable negative impacts on traffic; mainly LOVR and Madonna. At certain times, both these roads currently get backed up with traffic at levels that are irritating to the SLO human. The traffic report states a worsening of traffic on LOVR and Madonna even with the Prado overpass. Without the overpass, or in its absence for the years following the San Luis Ranch project but before it gets built, the traffic would be considered unacceptable, by citizens and city planners alike. The main point is to ensure that the Prado overpass is a "condition" of allowing this project to even begin. Letting development commence without clear Caltrans approval, realistic design, bidding, and funding, is irresponsible and leaves a door open for finger pointing, unaccountability, and possible litigation down the road. We as a city should not waste our taxpayer dollars on overlooked assumptions. 2. The EIR alternatives analysis does not describe a range of reasonable alternatives. It incorrectly discards a "reduced project, vehicle trip reducing alternative" on the grounds that it would be inconsistent with the City's Land Use Circulation Element. In fact, a reduced project alternative is consistent with the LUCE, and could cut the project traffic in half potentially eliminating traffic impacts, and certainly reducing the severity of impacts. A new and realistic alternative, studying a reduced build out, should be conducted and added to the current EIR. The build out size of this alternative should be close to the low end parameters designated for this parcel in the 2014 LUCE. Findings should be re -presented to the community and City Planning. 8-302 3. Within the traffic study done for the EIR, the mitigations pertaining to Madonna Rd. did not include or suggest the construction of a pedestrian/bicycle overpass. Our neighborhood has a number of children who cross the Madonna/Oceanaire crosswalk twice a day, to and from CL Smith Elementary, and the Laguna Middle School. There are also park goers, hikers, bikers and folks bring their dogs to the Laguna Lake Dog Park who all cross the Modonna/Oceanaire intersection. Unfortunately the kids returning from school and afterschool programs have to cross during current peak traffic hours. The impact the pedestrian crossing at Madonna and Oceanaire has on the traffic slows the whole artery of Madonna Rd. down considerably. Every driver can relate to the "white walking man image" still illuminated on the sign, even though the biker or jogger who pressed the button has long since crossed. Many agree that this intersection is currently one of the city's traffic bottlenecks. Now jump ten years into the future. Imagine the added vehicles on Madonna resulting from the San Luis Ranch, plus the added pedestrians and bikers originating from the said development, also needing to cross this intersection. This creates a scenario too unsafe and time consuming to accept. This is SLO town. That does not mean we like driving slow! It means we appreciate a SLO lifestyle, one that affords us the pleasure of not having to sit in traffic as other cities to the north and south do. A legitimate mitigation to this is a pedestrian/bike overpass (or tunnel). All the crosswalk hassle and danger that current and future, Madonna Rd. drivers, and crossers, would have to deal with, should the proposed development occur, could be eliminated by an overpass (or a tunnel). This should be looked at in the traffic section of the EIR, and if it is deemed a possible aid to this part of town, then the money to build it should be considered necessary and well spent. After all, safety, efficiency, and mental well being for our citizens are factors we all can agree to care about. Thank you for your consideration of these matters. Ma un Wells I . 0 1654 Oceanaire Dr San Luis Obispo, CA 93405 8-303 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 33 COMMENTER: Maysun Wells DATE: January 30, 2017 Response 33.1 The commenter states that they live on Oceanaire Drive east of Madonna Road, and that they would prefer the project site to remain unchanged, but that they understand the situation for the developer and the City. The commenter states that their letter notes their concern pertaining to the Draft EIR. The commenter’s subsequent comments are addressed in Responses 33.2 through 33.4. Response 33.2 The commenter states that the Draft EIR does not provide substantial evidence that the Prado Road Overpass would be required by Phase 2 of the project development. The commenter states that the traffic analysis indicates that project traffic would result in negative unavoidable impacts on regional traffic, specifically along Los Osos Valley Road and Madonna Road. The commenter states that currently both these roads get backed up with traffic. The commenter suggests the Prado overpass be a “condition” of allowing this project to begin. The commenter expresses concern that starting development without Caltrans approval, realistic design, bidding, and funding, would be irresponsible. Refer to Section 4.12, Transportation, for a discussion of the project’s impacts to the regional transportation system. Refer to Master Response 2 for a discussion of the feasibility and adequacy of the Prado Road Overpass mitigation. Response 33.3 The commenter states that a realistic alternative “should be close to the low end parameters designated for this parcel in the 2014 LUCE.” According to the City’s General Plan performance standards for the San Luis Ranch Specific Plan Area, the minimum number of residential units anticipated within the Specific Plan Area is 350 units, and the minimum square footage of non- residential development anticipated within the Specific Plan Area is 100,000 square feet (50,000 square feet of commercial and 50,000 square feet of office (refer to Table 2-1 in Appendix B, Draft Specific Plan). The Draft EIR discusses a reasonable range of alternatives to the project in Section 6.0, Alternatives. Other alternatives can be considered, but are not required to satisfy the requirements of CEQA. Refer to Master Response 1 for a discussion of the potential environmental effects of the lower buildout level discussed for the San Luis Ranch Specific Plan Area in the Land Use Element. Response 33.4 The commenter states that the Multimodal Transportation Impact Study did not include or suggest construction of a pedestrian/bicycle overcrossing on Madonna Road, and expresses concern for schoolchildren crossing at Oceanaire Drive. The Draft EIR did not identify project impacts that would be mitigated by the construction of a pedestrian overcrossing at this location. Mitigation measures for project-related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road. 8-304 Meeting: From: Raquel Smith < Sent: Monday, January 30, 2017 2:01 PM To: Advisory Bodies Subject: San Luis Ranch Draft EIR Comments Dear Planning Commission members, Item: ,M 1,\;s 04wi" YJL=I RECEIVED CITY OF SAN LUIS OBISPO JAN 3 0 2017 COMMUNITY DEVELOPMENT Thank you for taking the time to consider the San Luis Ranch development project. As residents of San Luis Obispo, we are all aware of the need for workforce housing here in town. My husband and I were fortunate enough to be able to buy a house a couple years ago here in SLO; however, many of our friends have been forced to live in surrounding cities and commute into work each day because they cannot afford to live in town. As much as I understand the need for increased workforce housing, I have a number of concerns regarding the San Luis Ranch project. I do think that the Dalidio property is a great location for more housing; however, the traffic impacts that will surely be generated by a development of this size have not been properly considered. During commute times, the section of Madonna Road between Dalidio Dr and Los Osos Valley Road is a nightmare. It is not uncommon to see cars lined up from light to light, unable to cross the intersection at a green light because the light ahead has yet to change. My husband commutes by bike to work every day and knowing that he is contending with all of these cars morning and night is frightening. However, he continues to commute by bike so that he can do his part both for the environment and for the local traffic congestion. The light at Madonna Road and Oceanaire Drive is particularly heinous. This 6 -way intersection does not operate with "smart" behavior during peak traffic. Instead, it operates with timed behavior, which means that even if there are only cars on the main roads, the frontage roads each still get a green light, which slows the timing considerably. A minor change - continuing the "smart" behavior of this intersection during peak traffic times - would likely decrease traffic considerably. A major change - removing the frontage road intersection access and rerouting the traffic around the block - would not result in major traffic increases in the neighborhoods and would reduce much of the problem that this intersection causes. Additionally, crossing Madonna Road at Oceanaire drive, which many people do in their walks to and from CL Smith Elementary, Laguna Middle School, Laguna Lake, and the nearby bus stops, is a frightening event as it is. Adding the volume of traffic that is expected to result from this development would certainly cause issues for resident safety. The mitigations discussed in the Draft EIR are not sufficient to solve these traffic issues on Madonna Road. As a resident who uses these streets daily, I am concerned that our safety will be at risk if the development were to go through as proposed. The Prado overpass should take priority over any housing builds. Building patches to deal with overburdened systems is always more costly, time -intensive, and difficult in the long run. Taking care of future inevitable problems before they arise is an under appreciated yet absolutely necessary step in creating healthy communities. Please consider the impacts that this development will have on the existing local residents before approving this Draft EIR. Thank you, Raquel Smith 8-305 1102 Seaward St San Luis Obispo, CA 93405 8-306 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 34 COMMENTER: Raquel Smith DATE: January 30, 2017 Response 34.1 The commenter expresses gratitude to decision-makers for considering the San Luis Ranch development and the need for workforce housing within the City. The commenter expresses concern regarding the project and states that the Dalidio property is a great location, but that the traffic impacts have not been properly considered. The commenter’s detailed comments are addressed in Response 34.2. Response 34.2 The commenter states that during commute times, Madonna Road between Dalidio Drive and Los Osos Valley Road is backed up with vehicles not being able to progress through the traffic signals. The commenter expresses concern for bicycle safety due to the vehicular volume and traffic. The commenter states that the Madonna Road/Oceanaire Drive intersection traffic signal does not operate as an actuated, “smart” signal, but rather with a fixed timed operation, meaning the frontage roads will be called during the cycle when there are no cars present. The commenter suggests changing the signal timing at Oceanaire Drive to be actuated on all legs of the intersection during peak traffic times. The commenter also suggests removing access to the Madonna frontage roads at Oceanaire Drive and rerouting traffic around the block. The commenter expresses concern for schoolchildren crossing at this location, and states that the project-added traffic volume would exacerbate issues for resident safety. The commenter states that the mitigations discussed within the Draft EIR are not sufficient to solve the traffic issues on Madonna Road, and recommends that the Prado Road Overpass should take priority over any housing. As described in Response 29.98, during the Final EIR review, signal timing assumptions were checked and validated by Omni Means, and no changes were identified. As described in Response 30.4, although the signal is fully actuated, it is in coordination with the Los Osos Valley Road/Madonna Road intersection, which may give the appearance of a fixed time operation. Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L) utilized actuated signal timings for analysis at Madonna Road/Oceanaire Drive. Based on the pedestrian and bicycle analysis as detailed in the Multimodal Transportation Impact Study, the project does not present any impacts to these modes at this location. The multimodal analysis is consistent with City General Plan policy, CEQA, and HCM methodologies. The HCM methodologies take into consideration the affects to vehicular volume on pedestrian and bicycle modes. Refer to Response 29.96 for a discussion of the traffic modeling methodologies. Also refer to Response 30.2, which address the validity of the City’s Travel Demand Model as used in the Multimodal Transportation Impact Study (Appendix L) and the Draft EIR. Section 4.12, Transportation, and the Multimodal Transportation Impact Study present required mitigation for project-related multimodal impacts, and is consistent with CEQA Guidelines. 8-307 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Refer to Master Response 2 for a discussion of the feasibility and adequacy of the Prado Road Overpass mitigation. 8-308 Meeting: From: Davidson, Doug Sent: Monday, January 30, 2017 7:35 AM To: Bergman, Katelin Subject: FW: Letter to Planning Commission Attachments: Final Neighborhood Letter With Endorsements.pdf Follow Up Flag: Follow up Flag Status: Flagged More SLR comments.... From: Zoya Dixon [ Sent: Sunday, January 29, 2017 12:33 PM To: Davidson, Doug <ddavidson@slocity.org>; Fowler, Xzandrea <XFowler@slocity.org> Subject: Letter to Planning Commission Item: SOffiv 5 LV t - RECEIVED CITY OF SAN LUIS OBISPO JAN 3 0 2017 COMMUNITY DEVELOPMENT Good afternoon Doug and Xzandrea, I spoke on Wednesday night's Planning meeting and emailed our community letter to the advisorybodies email (though not in adequate time, unfortunately, for it to be on the record.) I have attached our letter to you as well, as I understand comment is open until the Both; is there anyone else I should email this to? Many thanks for your help, Zoya Zoya Dixon DowntownABQ MainStreet Initiative 8-309 Dear Planning Commission: We are concerned residents of the Laguna Lake neighborhood, which abuts the San Luis Ranch development. Some of us have lived in the area for 43 years; others, just a few months. Though our backgrounds and professions may differ, we all value our close-knit community, our access to open space, and our ability to live a lifestyle that San Luis Obispo in particular cherishes and promotes. We have severe concerns about the quality of life in the neighborhood and the impact the San Luis Ranch development will have on our community. . We concur that housing is desperately needed in San Luis, and that tens of thousands of vehicle trips into the city each day from neighboring communities is unacceptable and unsustainable. The planned implementation of parks and open space in the plan is commendable, as is the trail connection to Bob Jones. That said, a few issues continued to arise during our neighborhood meeting that was held on January 15: Madonna & LOVR Already Overburdened with Traffic; Prado Overpass is Insufficient and Does Not Allow Access to Highway 101 According to the EIR, the San Luis Ranch development would generate 16,000 new trips in the area (Section 4.2). Madonna and LOVR are already overburdened and not properly planned for pedestrians, and the proposed mitigation efforts for an overpass at Prado does not suffice to route traffic so that it is best absorbed into the existing infrastructure. In fact, according to the EIR (Environmental Impact Report) T-1 (page 8), 9 intersections would operate at unacceptable automobile, bicycle, or pedestrian LOS" (loads of service), with two of those impacts at the Madonna Road & Dalidio Drive and Los Osos Valley Road & Froom Ranch Way intersections designated as Class I, significant and unavoidable. Indeed, Impact T-2 on page 9 lists no fewer than 19 intersections that would operate at untenable levels, and again subsequent mitigation efforts would still leave intersections at LOVR and Froom Ranch Way as significantly impacted without avoidance. These impacts are reiterated several times throughout the document. This is unacceptable. Suggested mitigation efforts to optimize signal timing and construct an overpass at Prado at Phase 2 are insufficient as confirmed by the EIR Exec. Summary page 9, which states that these impacts "may not be feasibly mitigated to a less than significant level." Can we not alleviate traffic and construct the Prado overpass in an earlier phase? As members of this community with families and with pets, who pride ourselves on our neighborhood and enjoy relative ease of access to Laguna Lake, we cannot let such severe impacts go unnoticed, especially when it comes to our safety as pedestrians and as citizens. EIR Has Ignored Impact on Local Schools The EIR does not address the impact of the new housing on local schools. This is important at least because streets and sidewalks should be planned to provide safe ways to and from schools, especially where there are major streets involved, and especially given that the project is promoting itself as affordable family housing where, presumably, children will be able to walk to and from neighboring schools. In addition, the burden of these extra children on the local schools has not been addressed. When can we expect to hear about the impacts that this development will have on our school system? Removing Wildlife from the Area Decreases Area Diversity and Abundance The preservation of habitat for wildlife, especially that habitat that abuts the creek, and the proposed mitigation efforts include the recruiting of nesting adult herons to new habitat "via decoys and playback of vocalizations." (Page 29, Executive Summary, EIR.) 8-310 There is abundant language on the preservation of agricultural views from Highway 101; can we not also think creatively to preserve agricultural and riparian views from Oceanaire and from Madonna, rather than relocate nesting birds with props and bird calls? As members of this community, we enjoy these views and want our children to be able to enjoy these views, and their subsequent wildlife, as well. In addition to our desire to preserve our local views and wildlife, the preservation of the wildlife itself is an important issue. Information abounds that relocation of wildlife is most often disastrous for the wildlife and fails to achieve the human goal. As the earth's dominating species, we have an obligation to those that do not go about life with heavy machinery to protect their habitat and ways of life. In summary, we understand the need for housing in the city of San Luis Obispo. As residents, we see the impacts of city streets that are filled with mostly college students and rundown, overpriced homes. At the same time, it is in the city's best interest to preserve what is truly fantastic about this area of town. We urge the commission members to consider: Would you feel safe having your children or grandchildren walk to school where an additional 16,000 trips will be taking place daily on roads that are already overburdened? Have you ever complained about the lack of school infrastructure and sufficient numbers of teachers and classrooms to support your children and grandchildren as they learn? How would you feel about telling your children about the heron nests, but regretfully saying that they can no longer see them due to human disturbance that was caused by careless action? We choose to live in the Laguna Lake area because of the unique beauty and community that it affords. Much discussion has been made of increasing affordable housing in the city, and yet with this plan we are not honoring the folks who live in one of the most affordable places in the city. We appreciate your thoughtful consideration to these matters, in particular the questions above. Signed, The Laguna Lake Community, including: 1. Zoya Dixon, Oceanaire Court 2. Raquel Smith, Seaward and Oceanaire 3. Andrew Dixon, Oceanaire Court 4. AJ Smith, Seaward and Oceanaire 5. Scott Head, Oceanaire Dr 6. Carly Head, Oceanaire Dr 7. Theodora Jones, Oceanaire Dr 8. Deidre Crabtree, Oceanaire Dr 9. William C. Pierotti, Coral Street 10. Polly Gammons, Avalon St. 11. Philip Gammons, Avalon St. 12. Diane Anthony, Oceanaire Dr 13. Daniel Cramer, Huasna Dr 14. Vanessa Cramer, Huasna Dr 15. Maysun Wells, Oceanaire Dr 16. Kila Wells, Oceanaire Dr 17. Gary Smith, Oceanaire Dr 18. Dottie Andoli, Pinecove Dr 19. JoAnn Ruthenbeck, Oceanaire Court 20. Fred P Andoli, Pinecove Dr 21. Greg Crabtree, Oceanaire Dr 8-311 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 35 COMMENTER: Zoya Dixon, Private Citizen; Laguna Lake Community DATE: January 30, 2017 Response 35.1 The commenter states they spoke at the Planning Commission hearing and emailed their letter to advisory bodies, and have attached a letter with comments on behalf of the Laguna Lake Community. In the letter on behalf of the Laguna Lake Community, the commenter provides general information about the community, and states that the community has concerns with the project. The commenter concurs that housing is needed in San Luis Obispo and that the issue of commute vehicle trips in and out of the City is unacceptable and unsustainable. The commenter states that the project’s planned implementation of parks and open space, as well as the trail connection to Bob Jones, is commendable. The issues raised in this introductory comment are further addressed in Responses 35.2 through 35.5. Response 35.2 The commenter states that Madonna Road and Los Osos Valley Road are already overburdened with traffic, and the Prado Road Overpass is insufficient and does not allow access to U.S. 101. The commenter states that Madonna Road is not properly planned for pedestrians, and the proposed mitigation for an overpass at Prado Road would not suffice to route traffic so that it is best absorbed into the existing infrastructure. The commenter notes that the Draft EIR concludes that multimodal operations at several area intersections would operate at an unacceptable LOS with project-added traffic, and that two of these intersections – Madonna Road/ Dalidio Drive and Los Osos Valley Road /Froom Ranch Way – would continue to operate at an unacceptable LOS with mitigation, resulting in significant and unavoidable transportation impacts at these intersections. The commenter states that the Draft EIR mitigation measures to optimize signal timings and provide the Prado Road Overpass at Phase 2 of project construction are insufficient. The commenter questions why construction of the Prado Road Overpass is not required before any development to alleviate traffic. As stated in the Table 4.12-1, the Prado Road Overpass with Northbound U.S. 101 Ramps is required to mitigate impacts that would occur during Phase 2. This improvement would allow additional access across U.S. 101 and would result in a shift of traffic between Madonna Road and Los Osos Valley Road, providing mitigation to several project impacts in the near-term and cumulative scenarios. Refer to Master Response 2 for a discussion of the feasibility and adequacy of the Prado Road Overpass mitigation. Mitigation measures for project-related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road during Phase 1 of project construction. Potential right-of-way constraints at Madonna Road/Dalidio Drive and at Los Osos Valley Road/Froom Ranch Way may result in feasibility limitations for identified multimodal mitigation at these intersections. However, as shown in Table 4.12-1, widening of both intersections to include additional turn lanes would provide sufficient capacity and is included 8-312 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo as required mitigation. If these improvements are identified as infeasible due to right-of-way constraints, these impacts would be unavoidable, as identified in the Draft EIR. Response 35.3 The commenter states that the Draft EIR does not address the impact of the project on local schools, and states that streets and sidewalks should be planned to provide safe ways to and from schools. As discussed in Section 4.12, Transportation, mitigation measures for project- related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians, including schoolchildren, and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. Section 4.14.12, Public Services, discusses the project’s potential impacts on schools, as well as impacts from new students on local schools. As discussed in that section, the project would add an estimated 179 students to public schools in the City of San Luis Obispo. However, the students generated by the project would not result in exceedance of District school capacities. In addition, Senate Bill 50 implemented school impact fees that any new development project is required to pay. Payment and collection of the fees under SB 50 is considered full and complete mitigation for impact to public schools. The project applicant would be required by State law to pay the fair share of impact mitigation fees, and impacts to public schools. Response 35.4 The commenter states that the removal of habitat for wildlife, especially the habitat that abuts Prefumo Creek, decreases area diversity and abundance, and requests that the project preserve agricultural and riparian views from Oceanaire Drive and from Madonna Road, rather than relocate nesting birds. The commenter states the preservation of the wildlife itself is an important issue, and states that relocation of wildlife is often ineffective. Potential aesthetic and visual impacts are discussed in Section 4.1, Aesthetics. However, it should be noted that CEQA requires that an EIR evaluate impacts to public viewsheds, as opposed to private views. In addition, as described in Section 2.0, Project Description, the project would retain approximately 53 acres of the southern portion of the project site adjacent to the San Luis Obispo City Farm in agricultural use, and approximately 7 acres of the site, including the Prefumo Creek riparian corridor, in open space. Mitigation Measure BIO-1(f), which is designed to avoid and minimize potential impacts to the monarch overwintering grove or active great blue heron nests, is discussed in Response 6.2. Section 4.4, Biological Resources, discusses the project’s potential impacts to the riparian habitat that abuts Prefumo Creek including the removal of riparian vegetation as a result of the proposed Froom Ranch Way bridge crossing and bench widening. Mitigation Measures BIO- 2(a), BIO-2(b), and BIO-2(c) require a Habitat Mitigation and Monitoring Plan which will provide a minimum 2:1 ratio (replaced: removed) for temporary and permanent impacts to riparian habitat, replacement of riparian trees four inches or greater at a minimum ratio of 3:1, replacement of trees 24 inches or greater in-kind at a minimum ratio of 10:1, and Froom Ranch Way Bridge design modifications to avoid riparian areas. Implementation of the mitigation identified in Section 4.4, Biological Resources, would reduce potential impacts to riparian habitat 8-313 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo to a less-than-significant level. No further revisions to the Draft EIR are required in response to this comment. Response 35.5 The commenter states their understanding of the housing needs in San Luis Obispo. The commenter reiterates the questions addressed in Responses 35.2 through 35.4, and also states a general concern about the introduction of new traffic. Project-generated traffic and potential impacts on local circulation is discussed in Section 4.12, Transportation. No revisions to the Draft EIR are required. However, the commenter’s statements and questions will be forwarded to the appropriate decision-makers for review and consideration. 8-314 Meeting: From: Audrey Bigelow <Item: S L4-- DG1 i t2-- Sent: ZSent: Monday, January 30, 2017 4:18 PM To: Advisory Bodies Subject: Attn: PC, Re: 1035 Madonna Road Dear Planning Commission: Hemalata Dandekar, Daniel Knight, John Larsen, Ronald Malak and Charles Stevenson - I've reviewed the San Luis Ranch EIR and I would like to offer my support of this project. The City desperately needs new housing and we need housing of all types. There is a huge gap here in the cost of living vs. wages paid that is affecting the workforce of San Luis Obispo dramatically because they can't afford to buy a home here. I like that this project offers a variety of housing types and even though the single-family lots are smaller, it will still fill a huge need for first time home buyers. The total number of units is reasonable but will still barely make a dent in increasing the housing stock up to what this city needs. We have to start somewhere, though. The EIR also discusses the actual construction of the houses using energy efficient features, which I think is huge. It's important for people to realize that newer homes are more energy and water efficient than current homes in the city and not only are we trying to get homes built here, we want to support environmentally friendly building whenever possible. In general, I believe the EIR is a good public document and I commend the staff for their efforts on it. I am supportive of the analysis and mitigation measures contained within. Sincerely, Audrey Bigelow 13+ Year Resident of San Luis Obispo Audrey Bigelow RECEIVED CITY OF SAN LUIS ODISPO JAN 3 1 2017 COMMUNITY DEVELOPMENT 8-315 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 36 COMMENTER: Audrey Bigelow, Private Citizen DATE: January 31, 2017 Response The commenter states her support for the project, citing the need for new housing, and noting that project provides a variety housing types. The commenter notes that the Draft EIR includes a discussion of the energy efficient features in the proposed residences, and states that they support the conclusions of the Draft EIR, and the required mitigation measures. The commenter’s support will be forwarded to the appropriate decision-makers for review and consideration. 8-316 Meeting.- From: eeting: From: Sent: To: Subject: Attachments: Please refer to attached. CD Carl Dudley < Monday, January 30, 2017 4:20 PM Advisory Bodies San Luis Ranch EIR support.pdf San Luis Ranch EIR support.pdf Grammar by CD, hardware by a PDA provider, transmission by a cellular service/wifi provider. Item: S L, 12 -til r - RECEIVED CITY OF SAN LUIS OBISPO JAN 3 1 2017 COMMUNITY DEVELOPMENT 8-317 January 30, 2017 Carl Dudley 866 Escuela Court San Luis Obispo, CA 93405 Planning Commission C/o Michael Condron Director, Community Development Department 919 Palm Street San Luis Obispo, CA 93401 Re: San Luis Ranch EIR 1035 Madonna Road Dear Planning Commission Members: This letter is to express my support of the San Luis Ranch proiect EIR. As some of you know I'm very concerned about housing for our workforce in San Luis Obispo. We have many young talented people that struggle to find affordable housing and are moving from our City. This drain of human resources impacts us every day. Our issue is compounded by they travel times of others which creates gridlock during peak travel times. This situation has a very negative impact on our environment and personal health causing a decay of our healthy lifestyle. I'm a resident of the City living off of Los Osos Valley Road, so have concern for convenient travel to the downtown area. That being said, with the additional overpass and additional bus stops I believe my inconvenience won't be much worse than it is now. I hope you have the same concerns of lack of housing and the overall health of our environment. Please show your sincerity by supporting this long overdue EIR and project. Thank you Carl D dley 8-318 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 37 COMMENTER: Carl Dudley DATE: January 30, 2017 Response The commenter states his support for the project, citing the need for new housing. The commenter acknowledges that travel times create traffic congestion and states that this situation has an adverse impact on the environment and human health. The commenter states their support for the conclusions of the Draft EIR. The commenter’s support will be forwarded to the appropriate decision-makers for review and consideration. 8-319 8-320 January 30, 2017 City of San Luis Obispo Community Development Department Attn: Doug Davidson, Deputy Director 919 Palm Street San Luis Obispo, CA 93401-3218 Subject: San Luis Ranch Project – Draft Environmental Impact Report (DEIR) Project # SPEC/ANNX/ER 1502-2015 State Clearinghouse #2015101083 Dear Mr. Davidson: The San Luis Obispo Council of Governments (SLOCOG) submits the following comments on the Draft Environmental Impact Report (DEIR) of the San Luis Ranch Project (hereby referenced as “Project”). This letter is organized with comments on the following sections: Air Quality and Greenhouse Gas Emissions Land Use and Planning Transportation andTraffic Air Quality and Greenhouse Gas Emissions Consistency with Sustainable Communities Strategy (SCS) As the Metropolitan Planning Organization (MPO) for the San Luis Obispo region, SLOCOG is required to prepare a Regional Transportation Plan (RTP), which is updated every four years, and includes a Sustainable Communities Strategy (SCS). The SCS (pursuant to SB 375, 2008) must identify a forecasted development pattern and transportation network that will meet greenhouse gas emission reduction targets specified by the California Air Resources Board [ARB] through their RTP planning process (2010 RTP Guidelines, California Transportation Commission). As such, several policies of SLOCOG’s 2014 RTP/SCS reference coordination in land use and transportation planning in the region, and reducing greenhouse gas (GHG) emissions from passenger vehicle travel in order to meet regional GHG targets specified by ARB. Policy OTS 8 (Land Use and Transportation Coordination) states “Facilitate the development and economic vitality of communities in ways that reduce trips and travel distances. Maintain and improve the regional transportation system in a manner which assists development and implementation of local jurisdictions’ general plans that support livable community concepts and efforts.” 8-321 Policy OTS 13 (Climate Change) states “Develop and implement programs and advocate land uses that will reduce overall vehicle miles traveled, delay, and support alternative vehicle and other programs to attain state-designated greenhouse gas reduction targets for the region.” Policy SCS 4 states “Reduce vehicle miles of travel related emissions by encouraging the use of public transit and other alternative forms of transportation and by supporting and encouraging the adoption of general plans and zoning that promote more compact communities.” In order to implement SB 375, SLOCOG – like other MPOs in California – use scenario planning tools to test policy options for different development patterns to determine which future land use scenarios will allow the region to meet the regional GHG reduction targets set by ARB. SLOCOG developed four future year scenarios (one for future year 2020 and three for future year 2035, with a focus on two variables: a) share of new housing that is multi-family, and (b) share of new employment located in urbanized areas. Table 1 shows how the four future year scenarios varied. Table 1. Policy differences of 2020 scenario and three 2035 scenarios in 2014 RTP/SCS Scenario Scenario Name Share of new housing that is multi-family (MF) Share of new employment located in urbanized areas Projected GHG emissions per capita 2020 Scenario 1 Near Future Scenario 22% 82% -8.40% 2035 Scenario 1 Business As Usual Scenario 25% 85% -7.90% 2035 Scenario 2 Preferred Growth Scenario 35% 90% -9.43% 2035 Scenario 3 Aggressive Scenario 45% 95% -10.91% In order to develop future year land use scenarios, proposed land use projects with pending entitlements were considered. At the time, the City of San Luis Obispo’s Land Use and Circulation Element (LUCE) considered Special Focus Area 2, with a range of 350 to 500 new housing units. SLOCOG’s 2035 Preferred Growth Scenario assumes 500 housing units (at San Luis Ranch); each of the three 2035 future land use scenarios assumed full build-out of San Luis Ranch, consistent with what was assumed in the City of San Luis Obispo’s Land Use and Circulation Element. None of the future land use scenarios tested more than 500 units at San Luis Ranch. The three 2035 land use scenarios varied on employment allocated to San Luis Ranch area; additionally, only commercial retail and tourist-serving hotel) employment was assumed for the San Luis Ranch area (no office employment was allocated). Table 2 shows how the three scenarios varied in the level of new growth assigned to San Luis Ranch area. Table 2. New Housing Allocated to San Luis Ranch (Special Focus Area 2) Scenario Scenario Name New housing units New jobs 2035 Scenario 1 Business As Usual Scenario 500 du 340 jobs 2035 Scenario 2 Preferred Growth Scenario 500 du 290 jobs 2035 Scenario 3 Aggressive Scenario 500 du 240 jobs 8-322 Land Use and Planning Housing choices The Project provides a mix of housing product with a residential density range of 12.5 units per acre to 19.2 units per acre, representing small- and medium-lot single-family detached housing, and single- family attached/condo housing. It is assumed that the affordable housing density bonus units would be constructed as multi-family housing, but this is not clear based on a review of theDraft EIR. This represents a range of housing proposed for this project, and is consistent with SLOCOG’s policy language regarding mix of housing. Policy SCS 7 of the SLOCOG 2014 RTP/SCS states “Support equitable, affordable housing. Expand location- and energy-efficient housing choices for people of all ages, incomes, races and ethnicities to increase mobility and lower the combined cost of housing and transportation.” Over the past nine years, SLOCOG staff has collected building permit data from the eight local jurisdictions in the region, for the time period of 2000 to 2014. The three building permit surveys were conducted in 2007, then in 2011, and most recently in 2015. A key finding was that during the time period, San Luis Obispo has permitted a greater mix of housing than other communities and the region as a whole. Figure 1 shows the share of new housing units permitted by type ofunit from 2000 to 2014, including single-family detached (small-, medium-, and large-lot), single-family attached/condo, and multi-family duplex and apartment units), among other housing units. San Luis Obispo permitted a greater share of MF Apartment units, SF Attached/Condo, and 2nd Units than the region as a whole, and a similar share of SF Detached (Small-Lot) units as the region. The Project proposes a strong mix of housing product, when compared to what has been permitted from 2000 to 2014, as well as compared to the region as a whole. Table 3 shows the distribution of housing types across the four proposed residential land uses (NG-10, NG-23, NG-30, and the affordable housing density bonus units, assumed to be NG-30), and how that compares to housing product types as considered in the San Luis Obispo Regional Building Permit Survey Data Summary Report (2000-2014) SLOCOG [2016], currently unpublished). 8-323 Figure 1. Share of New Housing Units by Type, Incorporated Cities (2000 to 2014) Table 3. Distribution of Proposed Housing Types compared to SLOCOG Building Permit Survey Lot size ranges are not stated in the DEIR; the lot sizes above are estimated based on gross density. Note: It is assumed that the housing product for affordable housing density bonus units is MF Apartment . As shown in Table 3, the project will provide a greater share of SF Detached (Small-Lot) than what was permitted between 2000 and 2014 (51.7% versus 12.0%). The project also proposes a greater share of SF Attached/Condo than what was permitted between 2000 and 2014 (34.5% versus 20.0%). Although it is not stated in the Draft EIR, it is assumed that the affordable housing density bonus units would be built as MF Apartment. If so, the project proposes a smaller share of MF Apartment than what was permitted between 2000 and 2014 (13.8% versus 28.0%). Proposed Residential Land Uses Number of units Share of units Estimated lot size Housing Product Type as compared to SLOCOG Building Permit Survey) NG-10 200 34.5% 4,000 sq. ft.SF Detached (Small-Lot) NG-23 100 17.2% 3,000 sq. ft.SF Detached (Small-Lot) NG-30 200 34.5% 2,250 sq. ft.SF Attached/Condo NG-30 80 13.8%not stated*MF Apartment 580 100.0% 8-324 Clarification of affordable housing density bonus In section 2.5.2 (Land Use Concept), it is not clear from Table 2-1 (Planned San Luis Ranch Specific Plan Area Development) of the location of the 80 affordable housing density bonus units would be located in the San Luis Ranch Project. Additionally, Figure 2-14 (Project Phasing Plan) does not clearly indicate the proposed location of the 80 affordable housing density bonus units. Please update chapter 2.0 Project Description to provide clarity on this matter. Clarification of Surrounding Land Uses (section 2.4.1) In section 2.4.1 (Surrounding Land Uses), in describing the land uses to the north, “Central Coast Plaza Shopping Center” is presumably meant to be “SLO Promenade” (which contains businesses such as Bed Bath and Beyond, Cost Plus, the empty building formerly occupied by Forever 21 until January 2016, and is adjacent to Embassy Suites). The signage at the entrance to this shopping center clearly indicates its name as SLO Promenade. When describing the land uses to the east of US 101, this section does not mention the planned location for the RTA Transit Maintenance Facility, planned adjacent to the Homeless Services Center on Prado Road. Market Absorption for Regional Retail In a review of section 2.5.2 Land Use Concept and Table 2-1 (Planned San Luis Ranch Specific Plan Area Development), the proposed mix of uses includes up to 150,000 square feet of retail commercial, and up to 100,000 square feet of office. Two regional shopping centers are located immediately adjacent and north of the Project site. Two other regional shopping centers are located just west of the Project site, along Los Osos Valley Road. These include the following: SLO Promenade: This center includes an estimated 256,000 square feet of regional and local retail, with several main anchor businesses and a number of pad buildings. Half of this center’s retail square footage remains vacant. The anchor building, formerly occupied by Forever 21 – and previously Gottschalks – is approximately 120,000 square feet in size, and half of a pad building (formerly occupied by Hometown Buffet – approximately 7,000 square feet) remains empty)1,2. Madonna Plaza: This center includes an estimated 330,000 square feet of regional and local retail, with several main anchor businesses and a number of pad buildings. This center has experienced a several significant turnovers in retail square footage in the previous decade; most recently, Sports Authority closed in March 2016, leaving a 23,826 square foot retail space vacant3. 1 Lambert, Cynthia & Wilson, Nick (16 November 2015). “Forever 21 in San Luis Obispo to close after holidays”, San Luis Obispo Tribune. Retrieved from: http://www.sanluisobispo.com/news/business/article45154953.html accessed January 30, 2017). 2 Wilson, Nick (5 February 2016). “Hometown Buffet in SLO closes, employees left scrambling”, San Luis Obispo Tribune. Retrieved from: http://www.sanluisobispo.com/news/business/article58794753.html (accessed January 30, 2017). 3 Ames, Danielle (3 March 2016). “Sports Authority in SLO among 140 to be closed nationwide”, San Luis Obispo Tribune. Retrieved from: http://www.sanluisobispo.com/news/business/article63846367.html (accessed January 30, 2017). 8-325 Prefumo Creek Commons: This center, which was constructed in 2011 and 2012, includes an estimated 188,658 square feet of regional and local retail, with several main anchor businesses and two pad buildings. MacSuperstore announced its closure at the end of 2016, leaving its 5,000 square feet of retail vacant4. Irish Hills West: This center, which was developed over the past 10 to 15 years, includes an estimated 430,000 square feet of local and regional retail, with several anchor buildings, several medium-sized anchor buildings, and several pad buildings. The significant transition at this shopping center in recent years was the closure of Circuit City in early 20095. This location was later occupied by New Frontiers (November 2010), which has since transitioned to a Whole Foods Market. Across the above four regional retail properties within close proximity to the San Luis Ranch Project, there is an estimated 1.2 million square feet of local and regional space. As noted above, an estimated 155,826 square feet of retail remains vacant, representing 13 percent of the total regional retail square footage of these four regional retail properties along Madonna Road and Los Osos Valley Road. Meanwhile, there is a nationwide trend towards a preference for online shopping (e-commerce) over shopping in brick-and-mortar stores. The National Retail Federation estimated that 108.5 million Americans shopped online over the Thanksgiving weekend in 2016, well above the 99.1 million who shopped in stores6. Late in the 2016 holiday shopping season, the federation estimated that holiday sales will hit nearly $656 billion, which encompasses $117 billion in e-commerce activity, nearly 18 percent of holiday season sales7. After a disappointing holiday shopping season, several well-established national brands announced store closures across the country. In January 2017, Macy’s announced closures of 68 of its stores nationwide, and plans to close about 100 stores (15% of its store base)8. Sears Holding Corporation is also struggling financially nationwide. Also in early January 2017, Sears announced plans to close 150 stores (108 Kmart stores and 42 Sears stores – 10% of the Sears store base) by April 2017; although no Sears stores are scheduled for closure in California at this time9. 4 Ames, Danielle. (28 November 2016). “MacSuperstore in SLO is closing at end of the week”, San Luis Obispo Tribune. Retrieved from: http://www.sanluisobispo.com/news/business/article117505293.html (access January 30, 2017). 5 No author. Retrieved from: http://www.slideshare.net/finance22/circuit-city-stores-store-closing-list-11609- updated-information-2909-1045am-et (January 30, 2017). 6 Wahba, Phil. (27 November 2016). “About 10 Million More Americans Shopped Online Than In Stores Over Black Friday Weekend” Fortune. Retrieved from: http://fortune.com/2016/11/27/black-friday-nrf-shopping/ (accessed January 30, 2017). 7 Soergel, Andrew. (20 December 2016). “As Online Sales Boom, Is Brick -And-Mortar on the Way Out?” U.S. News and World Report. Retrieved from: http://www.usnews.com/news/articles/2016-12-20/with-online-sales- booming-is-brick-and-mortar-on-the-way-out (accessed January 30, 2017). 8 Peterson, Hayley. (4 January 2017). “Macy’s is closing 68 stores – here’s where they will shut down”, Business Insider. Retrieved from: http://www.businessinsider.com/list-of-macys-stores-closing-2017-1 (accessed January 30, 2017. 9 Peterson, Hayley. (4 January 2017). “Sears is closing 150 stores – here’s the full list”, Business Insider. Retrieved from: http://www.businessinsider.com/list-of-sears-and-kmart-stores-closing-2017-1 (accessed January 30, 2017). 8-326 However, adding an additional 150,000 square feet of regional retail in a struggling retail landscape may lead to retail cannibalization of existing – and adjacent – regional retail properties. SLOCOG’s 2014 RTP/SCS includes a number of policies and strategies related to economic vitality and economic competitiveness, especially as it relates to reducing trips, trip distances, and travel distances. Policy SCS 2 of the SLOCOG 2014 RTP/SCS states “Facilitate the development and economic viability of communities in ways that reduce trips and travel distances.” SLOCOG suggests the City or project applicant conduct a comprehensive regional retail market analysis to determine the need for additional regional-serving retail space in the San Luis Obispo market, given the current nationwide conditions and trends in the retail shopping landscape. SLOCOG recommends this study be completed before moving forward with approval of the San Luis Ranch Project in its current design. Transportation/Traffic Prado Road Extension, Overcrossing, and Interchange As noted in our EIR scoping letter of November 17, 2015, the 2014 RTP/SCS recommends construction of an overcrossing and interchange at Prado Rd. (see “References” section at the end of this letter). The inclusion of the Prado Road overpass and northbound ramp reconstruction in Phase 2 fulfills this 2014 RTP/SCS recommendation. Also as noted in the scoping letter, anticipated funding constraints may limit SLOCOG’s ability to contribute to highway improvement projects in the near/mid-term. During its most recent programming cycle, SLOCOG received no new Statewide Transportation Improvement Program (STIP) funding from the state to allocate toward regionally-significant or land-use necessitated highway capacity and access improvements. Due to the uncertainty of the fate of pending legislation in the California legislature, it is uncertain how much near-term state and federalfunding SLOCOG will receive, and for what purposes (e.g. maintenance or capacity-increasing). SLOCOG will continue to work with its member jurisdictions to program projects according to their funding priorities, SLOCOG policies, and the limits of funding. SLOCOG is hopeful that, with more robust infrastructure funding at the federal and state levels for future programming cycles, that a regional share of the Prado Rd. project could be defined and compete for SLOCOG discretionary funding. As is noted in the DEIR, the ultimate design of the Prado Rd. overcrossing and-or interchange is being reviewed as part of the PSR/PDS process involving the City, Caltrans, and SLOCOG. Appendix L indicates that Dalidio/Prado and the overcrossing would include two vehicular travel lanes in each direction. The Draft San Luis Ranch Specific Plan (Fig. 6.13) also indicates the Prado Road West Class I (and-or Class II) bike facilities on the overcrossing that are recommended in the City Bicycle Transportation Plan. Fig. 6.4 indicates that pedestrian accommodations would also be provided on the overcrossing. The SLOCOG 2014 RTP/SCS includes an overcrossing with only two auto lanes (one in each direction). The 2014 RTP/SCS (Chapter 4) provides the following policy: 8-327 HSR 7. Coordinate with Caltrans and local jurisdictions to include intermodal strategies with improvements to state highways and regionally significant routes including bike lanes, pedestrian access, public transit, shuttle stops, and park-and-ride lots. US 101 Auxiliary Lanes The DEIR notes some significant and unavoidable impacts to the US 101 mainline under cumulative-plus- project conditions (e.g. Impact T-10, p. 4.12-102). The 2014 RTP/SCS (see the appendix of this letter) recommends the construction of auxiliary lanes. We do not see any discussion of auxiliary lanes in the DEIR. Please note if they were considered as a part of the Draft EIR. Modal split The City has ambitious goals in its Circulation Element (Table 1) to achieve 20 percent bike, 12 percent transit, and 18 percent walking/carpool/other forms mode splits. The Draft San Luis Ranch Specific Plan DEIR Appendix B) states: San Luis Ranch will feature enhanced transit facilities and a new transit center that will increase the accessibility of transit to the area. A key purpose of transit amenities is to de-emphasize the use of private automobiles as a primary mode of transportation for the neighborhood. (Sec. 6.3 intro) Pedestrian and bicycle amenities will be included throughout the Specific Plan Area so as to promote walking and bicycling to nearby daily-need amenities. (Sec. 6.4 – intro) San Luis Ranch will contribute to the City’s existing bicycle network with several notable improvements…Both safety and circulation aspects for cyclists will be greatly enhanced throughout the Plan Area. (Sec. 6.4.2) The proposed project accords with these multimodal priorities with a substantial level of investment in multimodal connections. Furthermore, there is the potential to implement transportation demand management (TDM) strategies, as discussed further. Given the above project characteristics and potential features, it is surprising that almost all external person trips (95-97%) are assumed to be auto trips (App. L, pp. 42-43). Even when one accounts for internal capture, it is evident that the external mode split for alternative modes could also be robust. For example, Fig. 6.8 of the Specific Plan shows how many external destinations are within a 10-minute walk. The planned Class I connections to Madonna Rd. and across Prado Rd. provide low-stress bike connectivity to other parts of the city. Travel demand management (TDM) strategies Pursuant to our Regional Transportation Plan policies, our Transportation Demand Management (TDM) Program shall “support projects and programs that integrate transportation choices intheir development and/or operations” (Maximizing Systems Efficiency, Policy 10, 2014 RTP/SCS). 8-328 Additionally, 2014 RTP/SCS MSE Policy 3 states “Assist local jurisdictions in developing communities in ways that reduce the demand on the roadway system by coordinating residential, commercial and industrial development in ways that reduce the need to drive”. Our scoping letter suggested that the EIR should consider transportation demand management (TDM), including encouragement and education about non-single-occupancy-vehicle travel modes, as a potential mitigation measure. We have not discovered any TDM programs or projects proposed for the San Luis Ranch development. Transportation demand management is a set of strategies, programs, services, and physical elements that influence travel behavior by mode, frequency, time, route, or trip length in order to help achieve highly-efficient and sustainable use of transportation facilities. To affect meaningful travel behavior change and encourage the widespread utilization of alternatives to single-occupant vehicles (SOV), residents and other travelers must first understand the options available in the multimodal transportation system – how they work, how to use them, and the benefits they offer. This requires a level of information and support that demystifies travel options and makes them rational and desirable alternatives to the car. Measures of Effectiveness for TDM programs should be two-fold: a reduction in peak-period vehicle trips and a reduction in overall weekly vehicle trips. In order to achieve this, SLOCOG/SLO Regional Rideshare asks that this development be required to develop a TDM Plan to reduce trips generated by on-site residential uses and on-site office uses, and construction activities. The trip reduction plan shall have a measured baseline of vehicle trips from which reductions shall be determined at the time of the future trip generation analyses. Also required, as part of an ongoing TDM program is: Identification of a Site Transportation Coordinator(s), for both the residential and commercial components of the project who maintains and updates an on-site trip reduction bulletin board(s) in any common areas posting information such as carpool, vanpool, and car share opportunities, transit schedules, bus routes, and the availability of on-site long term bike parking. The City shall be notified of Site Transportation Coordinator’s name and contact information. An annual survey of both residential and commercial occupants in order to receive feedback on travel and commute patterns, their likelihood of using alternative transportation modes, and the effectiveness of the program meeting its goals. Distribution of materials approved by the City should be done in the following manner: Owner-occupied units. Upon a residential dwelling being sold or offered for sale, the Applicant must notify and offer to the buyer or prospective buyer, as soon as it may be done, materials describing public transit, ridesharing, and non-motorized commuting opportunities available in the vicinity of the project, including a map showing location of on-site bicycle parking, transit stops, bicycle routes, and a list of retail and service destinations within walking distance. Such information must be transmitted no later than close of escrow; 8-329 Rental units. Upon a residential dwelling being rented or offered for rent, the Applicant must notify and offer to the tenant or prospective tenant, materials describing public transit, ridesharing, and non-motorized commuting opportunities in the vicinity of the development including a map showing location on-site bicycle parking, transit stops, bicycle routes, and a list of retail and service destinations within walking distance. The materials must be provided no later than the time the rental agreement is executed. As the region’s primary manager of TDM, SLO Regional Rideshare is available to coordinate and work free of charge with occupants and/or the developer on implementation on all TDM programs and plans. Thank you for the opportunity to provide input. Sincerely, Jeff Brubaker Geoffrey Chiapella Transportation Planner Transportation Planner 8-330 Appendix – References SLOCOG 2014 Regional Transportation Plan and Sustainable Communities Strategy (2014 RTP/SCS) http://www.slocogconnectingcommunities.com/ 2014 RTP/SCS project references Prado Rd., Froom Ranch Way, Bob Jones Trail: Prefumo Creek Connection 1. “Reconstruct key interchanges including the Prado Road interchange…” (US 101 Improvement Strategy #11, p. 4-12) 2. “Few parallel routes and frontage roads exist along the west side of US 101 through San Luis Obispo. Interchange/over-crossing concerns occur at Los Osos Valley Rd, Prado Road, and Santa Rosa St.-SR 1.” (p. 4-21, emphasis added) 3. “Prado Rd. interchange/over-crossing: A new interchange or overcrossing at Prado Rd. has been proposed for construction to serve expanded commercial and residential development. It is anticipated that this new facility will relieve congestion at the Madonna and Los Osos Valley Rd. interchanges and route traffic to and from the Airport Area via the Prado Rd. extension. This project is also identified in the US 101 Corridor Mobility Master Plan.” (p. 4-22) 4. US 101 / Prado Rd. I/C and NB auxiliary lane as a constrained, land-use-necessitated, long- term project (Fig. 4-41) 5. CEN-MHWY-1003: Prado Rd. overcrossing at US 101; US 101 NB/SB auxiliary lanes: Broad St. to Marsh St. [with bike-ped connection] as an unconstrained project 6. CEN-MHWY-1402: US 101 / Prado Rd. I/C and NB auxiliary lane as a constrained project in Central County (App. A, Table 4-3, p. A-6) 7. CEN-RORS-1002: Prado Rd. bridge widening [over San Luis Obispo Creek] as a non-highway, regional Tier 1 route of regional significance in Central County (App. A, Table 4-14, p. A-20) 8. CEN-RORS-1003: Prado Rd. extension: South Higuera St. to Broad St. [with bike lanes] as a non-highway, regional Tier 1 route of regional significance in Central County (App. A, Table 4-14, p. A-20) 9. The US 101 CMMP recommends the completion of the Prado Rd. interchange as a medium- to long-term improvement (executive summary, pp. 7 and 9) 10. CEN-RORS-1013: Froom Ranch Way extension: end of Froom Ranch Way to Dalidio Dr. 11. CEN-AT1-1014: Bob Jones Trail: Prefumo Creek bike path connector [Madonna Rd. to US 101] US 101 CMMP: US 101 Corridor Mobility Master Plan Executive summary available in Appendix G at above link 8-331 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 38 COMMENTER: Jeff Brubaker and Geoffrey Chiapella, San Luis Obispo Council of Governments DATE: January 30, 2017 Response 38.1 The commenter states that SLOCOG has comments on the project, and that the letter is organized with three sections: Air Quality and Greenhouse Gas Emissions, Land Use and Planning, Transportation and Traffic. Response 38.2 The commenter states that SLOCOG’s Sustainable Communities Strategy (SCS) must identify a forecasted development pattern and transportation network that will meet State GHG emission reduction targets and summarizes several policies (Policies OTS 8, OTS 13, and SCS 4) included in the 2014 Regional Transportation Plan (RTP)/SCS intended to reduce GHG emissions in the region. The commenter also states that the project includes more residential units than evaluated in the RTP/SCS, and that project development would generate more new jobs than evaluated in the RTP/SCS. Nevertheless, the project would be consistent with Policy OTS 8 (Land Use and Transportation Coordination), Policy OTS 13 (Climate Change), and Policy SCS 4, intended to reduce trips and travel distances, support alternative transportation, create livable and compact communities, and support programs to attain GHG reduction targets for the region. As discussed in Section 4.6, Greenhouse Gas Emissions, the project includes mixed use development within a compact community that emphasizes bikeways, pedestrian, and transit connections, which contribute to reducing trips and travel distances in the region. Furthermore, the project includes workforce housing, including 34 affordable units, to increase local housing options for workers in the community and reduce the need for commuting. Section 4.6, Greenhouse Gas Emissions, concludes that the project would be consistent with the City’s Climate Action Plan. Similarly, the project would also be consistent with the applicable policies of the RTP/SCS. Response 38.3 The commenter notes the types and densities of housing proposed for the project although it is not clear what type of housing the proposed affordable housing would be. However, the commenter states that the project’s proposal to include a range of housing types and densities is consistent with Policy SCS of the SLOCOG 2014 RPT/SCS to support equitable, affordable housing. The commenter notes that based on regional building permit data and building permit surveys, the City of San Luis Obispo has permitted a greater mix of housing than other communities and the region as a whole. The commenter provides some of the data results in Figure 1 and Table 3 of the comment letter. The information provided by the commenter does not require changes to the Draft EIR, but this information will be forwarded to the appropriate decision-makers for review and consideration. Response 38.4 The commenter states that the Draft EIR sections and figures do not clearly indicate the location of the affordable housing units within the Specific Plan Area. The commenter requests that this 8-332 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo information be included in the Final EIR. Section 5.2.2, Affordable Housing, of the Specific Plan specifies that deed-restricted affordable housing units will be located throughout the residential portion of the Specific Plan Area, including the single-family and multi-family residential development areas. This information does not inform the analysis of environmental effects of the project. However, this information will be forwarded to the appropriate decision-makers for review and consideration. Response 38.5 The commenter states that the description of surrounding land uses in Section 2.0, Project Description, incorrectly names the SLO Promenade as Central Coast Plaza Shopping Center in the description of uses located to the north of the project site and does not include the future RTA Transit Maintenance Facility, planned adjacent to the Homeless Services Center, to the east of the project site. The future RTA Maintenance Facility Project, east of the project site, has not been approved or adopted. Therefore, the Draft EIR does not include it as an existing surrounding land use. The shopping center to the north of the project site is referred to by both names mentioned by the commenter. The following revisions have been made in Section 2.0, Project Description, to clarify the reference to the shopping center: North: A post office is adjacent to the site at southwest corner of Madonna and Dalidio Road, zoned C-R-PD (Commercial Retail with a Planned Development overlay). The Central Coast Plaza Shopping Center (SLO Promenade) and Madonna Plaza Shopping Center, also zoned C-R-PD and C-R, are located immediately north of the site across Dalidio Drive. Laguna Lake Park and surrounding open space is across Madonna Road (zoned PF and C/OS-40, respectively). Response 38.6 The commenter notes the size and location of existing shopping centers located to the north of the project site (SLO Promenade and Madonna Plaza) and two shopping centers located to the west of the project site along Los Osos Valley Road (Prefumo Creek Commons and Irish Hills West). The commenter provides statistical evidence of a decrease in consumers shopping in brick-and-mortar stores with an increase in online shopping. The commenter states that the project’s addition of retail space to the existing retail space in the City may lead to negative effects to existing regional properties. The commenter references Policy SCS 2 of the SLOCOG 2014 RTP/SCS which aims to facilitate development and economic viability of communities in order to reduce trips and travel distances in the area. Furthermore, the commenter suggests that a comprehensive regional retail market analysis be conducted for the project before moving forward with the project. Section 15131 of the State CEQA Guidelines states that “economic or social effects of a project shall not be treated as significant effects on the environment.” This comment pertains to the economics of the proposed Specific Plan development, which does not reflect on the adequacy or content of the Draft EIR. The information and request raised by the commenter will be forwarded to the appropriate decision-makers for review and consideration. Response 38.7 The commenter states that in their Draft EIR scoping letter of November 17, 2015, the 2014 RTP/SCS recommends construction of an overcrossing and interchange at Prado Road and this is fulfilled by the mitigation in the Draft EIR. The commenter states that anticipated funding constraints may limit SLOCOG’s ability to contribute to highway improvement projects in the 8-333 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo near/mid-term, but that SLOCOG will continue to work with its member jurisdictions to program projects according to their funding priorities, SLOCOG policies, and the limits of funding. The commenter states that for future programming cycles, a regional share of the Prado Road Overpass project could compete for SLOCOG discretionary funding. The commenter states that the ultimate design of the Prado Road Overpass and/or Interchange is being reviewed as part of the PSR/PDS process involving the City, Caltrans, and SLOCOG. The commenter notes that the Draft EIR indicates two travel lanes in each direction for Prado Road/Dalidio Drive and the Specific Plan indicates pedestrian accommodations and a Class I bike facility on the overcrossing as recommended in the City Bicycle Transportation Plan. The commenter notes that the 2014 RTP/SCS provides the following policy: HSR 7. Coordinate with Caltrans and local jurisdictions to include intermodal strategies with improvements to state highways and regionally significant routes including bike lanes, pedestrian access, public transit, shuttle stops, and park-and-ride lots. Refer to Master Response 2 for a discussion of the funding and feasibility of the Prado Road Overpass mitigation. Intermodal strategies will be coordinated with Caltrans and local jurisdictions and included as presented in the Specific Plan, including pedestrian and bicycle accommodations on the Prado Road Overpass. Response 38.8 The commenter states that the Draft EIR identifies significant and unavoidable impacts to the U.S. 101 mainline under cumulative plus project conditions. The commenter states that the 2014 RTP/SCS recommends the construction of auxiliary lanes and asks whether there is any discussion of auxiliary lanes in the Draft EIR. The Multimodal Transportation Impact Study (Appendix L) does not identify significant impacts along the U.S. 101 mainline operations under cumulative conditions. Although there are deficiencies in the cumulative baseline (no project) conditions, the project does not exceed the impact threshold of 5 percent based on Caltrans impact significance methodology. However, since the project does conflict with the adopted City policy and LOS standards, cumulative project-added traffic along the U.S. 101 mainline segments was determined to result in a significant unavoidable impact. The selection of potential design options is currently being processed as part of the PSR for the Prado Road Overpass/Interchange in coordination with the City and Caltrans (Section 501.3 of the Caltrans Highway Design Manual). Geometric design options such as auxiliary lanes, grade separated ramps, and collector-distributor roads are examples of offsetting measures that are being considered. Auxiliary lanes were not considered as part of the Multimodal Transportation Impact Study, as the mainline analysis did not present a project significant impact based on standard Caltrans thresholds. Response 38.9 The commenter notes that the City has a Circulation Element goal to achieve a mode split of 20 percent bicycle, 12 percent transit, and 18 percent walking/carpool/other forms. The commenter states the proposed project accords with these priorities and there is potential to implement TDM strategies. The commenter states that it is surprising that almost all external person trips in the Draft EIR and the Multimodal Transportation Impact Study are assumed to be 8-334 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo auto trips, and that, based on the distances to surrounding destinations and multimodal accommodations presented in the Specific Plan, the external mode split could be more robust. The modal split for the project trip generation was derived based on the City’s Travel Demand Model and presents a conservative approach for the multimodal analysis. The City’s Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. Response 38.10 The commenter states that their scoping letter suggested that the Draft EIR should consider TDM strategies, including encouragement and education about non-single-occupancy-vehicle travel modes, as potential mitigation measures. The commenter states that they have not identified any TDM programs or projects proposed for the San Luis Ranch development. SLOCOG/ SLO Regional Rideshare requests that the project be required to develop a TDM plan to reduce trips generated by on-site residential uses and on-site office uses, and construction activities. The commenter states that as the region’s primary TDM manager, SLO Regional Rideshare is available to coordinate and work with occupants and/or the developer on implementation on all TDM programs and plans. The City’s Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. Based on the San Luis Ranch Specific Plan, the proposed mixed-used development would result in a 20 percent internal capture rate in the PM peak hour, with incentives to take alternate modes of transportation. These multimodal incentives include a transit ‘hub’ that would directly serve the development, Class I bike trails located internally to the project site with access to adjacent proposed land uses and existing communities, additional parks and recreational uses for the new residents and guests, and bicycle and pedestrian accommodations on site. The TDM measures would be implemented per General Plan requirements in the development application process. 8-335 heal slo COALITION PARTNERS: Bike SLO County Boys and Girls Club —South County Cal Poly State University Art and Design Department Center for Sustainability Food Science & Nutrition Department Kinesiology Department STRIDE CenCal Health City of San Luis Obispo Parks and Recreation Community Action Partnership of SLO Community Foundation of San Luis Obispo County Dairy Council of California Diringer & Associates First 5 San Luis Obispo County Food Bank Coalition of SLO County French Hospital Medical Center Lucia Mar Unified School District One Cool Earth Rideshare — Safe Routes to School San Luis Sports Therapy SLO Council of Governments SLO County Departments: Board of Supervisors Health Commission Planning and Building Public Health SLO County Office of Education Meeting:. ~----- — item: `p _ 1 l - January 22, 2017 TO: Doug Davidson, Deputy Director RECEIVED CITY OF SAN LUIS OBISPO JAN 3 1 2011 COMMUNITY DEVELOPMENT FROM; HEAL SLID - Healthy Communities Work Group RE: San Luis Ranch Draft EIR HEAL SLO is the SLO County obesity prevention coalition and its mission is to increase healthy eating and regular physical activity among County residents through policy, behavioral and environmental changes. In carrying out that mission, a subcommittee called the Healthy Communities Work Group provides reports to Planning staff from a healthy community's perspective on proposed land development projects, ordinance and general plan amendments, and special projects. The group's objective is to provide research and evidence -based recommendations to planning commissions in order to create a healthy place for all residents to live, work, and play. Thank you for the opportunity to comment on the San Luis Ranch Draft EIR. We are pleased to see the DEIR's emphasis on connecting bikeways and pedestrian connections on site and for adjacent development. In the Final EIR, we would like to see Safe Routes to School completely addressed. Because of this development's proximity to C.L. Smith Elementary School and Laguna Middle School, it is critical to identify and develop a safe, convenient, and feasible way for students to safely walk or bike to school. Using active transportation to get to school has been shown to be correlated with healthy weight and positive health outcomes (1). The Community Foundation SLO County The Healthy Communities Workgroup is concerned that, according to theUCCooperativeExtension Draft EIR, the proposed San Luis Ranch Project will generate air pollution YMCA of SLO County beyond that allowed by the County Climate Action Plan of 2001, both during the projected construction period and after all available mitigations are applied. The conclusion from the Draft EIR is that these emission impacts will be "significant and unavoidable." This is simply unacceptable. In the Final EIR, we would like to see a sustainability plan and the SLO City Council's goal of a "net -zero carbon city" addressed. Greenhouse gas emissions are contributing to climate change, which has myriad negative health impacts such as increasing rates of asthma and heat -related illness 2)• Similarly, the Draft EIR projects inconsistencies with City policies designed to protect biological and agricultural resources, leading to potential degradation of public health. Research has shown that loss of prime agricultural land and residential development in close proximity to agricultural operations can threaten human health. 1. Saelens, Brian E., and Susan L. Handy. "Built Environment Correlates of Walking: A Review." Medicine and science in sports and exercise 40.7 Suppl (2008): 5550—S566. PMC. Web. 9 Nov. 2016. 2. Haines, A., & Patz, J. (2004). Health effects of climate change. JAMA, 291(1), 99-103. HEAL-SLO is the SLO County obesity prevention coalition and its mission is to increase healthy eating and regular physical activity among County residents through policy, behavioral and environmental changes. In carrying out that mission, a subcommittee called the Healthy Communities Work Group provides responses to Planning staff from a healthy community's perspective on proposed land development projects, ordinance and general plan amendments, and special aroiects. 8-336 heal Oslo HFrt17Idy F.4?1 4Cr1',+E LI'd1NG COALITION PARTNERS: Bike SLO County Boys and Girls Club — South County Cal Poly State University Art and Design Department Center for Sustainability Food Science & Nutrition Department Kinesiology Department STRIDE CenCal Health City of San Luis Obispo Parks and Recreation Community Action Partnership of SLO Community Foundation of San Luis Obispo County Dairy Council of California Diringer & Associates First 5 San Luis Obispo County Food Bank Coalition of SLO County French Hospital Medical Center Lucia Mar Unified School District One Cool Earth Rideshare — Safe Routes to School San Luis Sports Therapy SLO Council of Governments SLO County Departments: Board of Supervisors Health Commission Planning and Building Public Health SLO County Office of Education The Community Foundation SLO County UC Cooperative Extension YMCA of SLO County Furthermore, San Luis Obispo County is consistently ranked as having one of the highest rates of bicycle collisions in the State by the Office of Traffic and Safety. This project will add significant vehicle traffic to an already congested and dangerous roadway, further increasing the risk to cyclists and pedestrians. Additionally, traffic is known to increase stress, which is associated with negative health outcomes. From a health perspective, the proposed San Luis Ranch development poses many significant health threats to the community of San Luis Obispo. Thank you for the opportunity to review this project. CC: City of San Luis Obispo Planning Commission 1. Saelens, Brian E., and Susan L. Handy. "Built Environment Correlates of Walking: A Review." Medicine and science in sports and exercise 40.7 Suppl (2008): S550-5566. PMC. Web. 9 Nov. 2016. 2. Haines, A. , & Patz, J. (2004). Health effects of climate change. JAMA, 291(1), 99-103. HEAL-SLO is the SLO County obesity prevention coalition and its mission is to increase healthy eating and regular physical activity among County residents through policy, behavioral and environmental changes. In carrying out that mission, a subcommittee called the Healthy Communities Work Group provides responses to Planning staff from a healthy community's perspective on proposed land development projects, ordinance and general plan amendments, and special oroiects. 8-337 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 39 COMMENTER: Healthy Communities Work Group, HEAL SLO DATE: January 31, 2017 Response 39.1 The commenter states the mission and objective of HEAL SLO. The commenter expresses support for the bicycle and pedestrian connections included in the project. The commenter requests that safe routes to nearby schools are addressed in the Final EIR. The commenter notes that the use of active transportation to get to school is correlated with healthy weight and positive health outcomes. As discussed in Section 4.12, Transportation, mitigation measures for project-related impacts to multimodal circulation include construction of parallel Class I facilities to accommodate pedestrians, including schoolchildren, and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing protected access for all modes of travel. Response 39.2 The commenter states that the Draft EIR concludes the project’s air pollution emissions would exceed what is allowed by the County Climate Action Plan of 2001, resulting in a significant and unavoidable impact. The commenter requests a sustainability plan in the Final EIR that addresses SLO City Council’s goal of a “net-zero carbon city.” It is not clear whether the commenter intends to refer to the SLOAPCD 2001 Clean Air Plan or to the City’s 2012 Climate Action Plan. Impact AQ-1 in Section 4.3, Air Quality, discusses the project’s consistency with the 2001 Clean Air Plan, and finds that the project would be inconsistent with the Clean Air Plan even with incorporation of Mitigation Measure AQ-1, which would result in a significant and unavoidable impact. In addition, as noted in Response 25.1, SLOAPCD has subsequently recommended that the project be considered consistent with the 2001 Clean Air Plan, with incorporation of the mitigation included in the Draft EIR for air quality impacts, which includes provisions to encourage telecommuting, fugitive dust control measures, emissions control measures for construction equipment, operational emission reduction measures from the SLOAPCD CEQA Air Quality Handbook, and off-site mitigation requirements. Nonetheless, in order to provide a conservative evaluation of the project’s potential regional air quality impact, the Final EIR acknowledges a significant and unavoidable impact related to Clean Air Plan consistency and decision-makers would need to adopt a Statement of Overriding Considerations setting forth why the project’s benefits outweigh this impact, if the project is to be approved. The project’s impact with regard to GHG emissions and climate change is described in Section 4.6, Greenhouse Gas Emissions. The Draft EIR determined that the project would be consistent with the City’s 2012 Climate Action Plan and impacts related to GHG emissions would be less than significant. While not required by the analysis or conclusions of the Draft EIR, the commenter’s recommendation that the project include a sustainability plan will be forwarded to the appropriate decision-makers for review and consideration. 8-338 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 39.3 The commenter states that the Draft EIR identifies inconsistencies with City policies designed to protect biological and agricultural resources, and that as a result, the project would lead to degradation of public health. The commenter states that locating residential development in close proximity to agricultural operations would threaten human health. The project’s consistency with applicable City policies is discussed in Section 4.9, Land Use/Policy Consistency, which identifies that the project would be consistent with General Plan policies related to biological and agricultural resources. The project’s potential impacts associated with locating residential development in close proximity to agricultural operations is discussed in Impact AG-3 in Section 4.2, Agricultural Resources, which describes that with implementation of agricultural buffers, compliance with standard SLOAPCD dust control measures and City policies, and implementation of mitigation requiring City-approved agricultural conflict- avoidance measures including agricultural fencing, buffers, and buffer landscaping (refer to Mitigation Measures AG-3[a] through AG-3[c]), this impact would be reduced to a less-than- significant level. Response 39.4 The commenter states that San Luis Obispo County is consistently ranked as having one of the highest rates of bicycle collisions in the State, and that the project would add significant vehicle traffic to an already congested and dangerous roadway, further increasing risks to bicyclists and pedestrians. The commenter states that traffic is known to increase stress, which is associated with negative health outcomes, and that the project poses many significant health threats to the community. Mitigation measures for project-related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing safe and convenient access for all modes of travel. The City’s Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. Analysis of collision data is not within the scope of this project, which is consistent with CEQA Guidelines. 8-339 8-340 860 Pacific St, Suite 105, San Luis Obispo, CA 93401 | bikeslocounty.org City of San Luis Obispo Community Development Department Attn: John Frickenbach and Doug Davidson 919 Palm Street San Luis Obispo CA 93401-3218 ddavidson@slocity.org Dear Mr. Frickenbach and Mr. Davidson: Re: San Luis Draft Environmental Impact Report Jan. 30, 2017 Bike SLO County appreciates the opportunity to comment on the San Luis Ranch Draft Environmental Impact Report (DEIR). We are supported by more than 4,800 individuals throughout the region who believe safer complete roads for biking, walking and driving are essential to communitywide well-being. Bike SLO County supports denser housing for people who want to live closer to their jobs in the City so they don't have to commute long distances, and riding a bicycle, walking and/or taking transit are viable options. We are pleased to see that the DEIR emphasizes bikeways and pedestrian connections on site and to adjacent and close-by destinations, all of which contribute to reduced vehicle trips and vehicle trips traveled. We support the mitigation measures that encourage people to use multi-modal transportation options, including a bicycle-share program, vanpools and neighborhood electric vehicles. The projection of 32 driving miles per household per day is a significant decrease from the City average of 54 per day. Despite the DEIR’s proposed mitigations, San Luis Ranch is projected to generate nearly 17,000 additional motor vehicle trips per day in an area already suffering from traffic congestion. The added traffic results in a number of significant and unavoidable environmental impacts, including to air quality and traffic. We find these impacts unacceptable, and believe they can be mitigated to below a level of significance by: Placing more emphasis on and incentives to use multi-modal transportation options to destinations beyond adjacent and close-by destinations, including downtown San Luis Obispo, San Luis Obispo High School, Cal Poly and worksites in the vicinity of the County Regional Airport. Recognizing that changing transportation preferences and technology will further reduce driving miles per household. 8-341 860 Pacific St, Suite 105, San Luis Obispo, CA 93401 | bikeslocounty.org The Final EIR needs to address three major City goals that the San Luis Obispo City Council established on Jan. 28, 2017, for the next two-year budget cycle: Housing: Facilitate increased production of all housing types designed to be economically accessible to the area workforce and low and very low-income residents, through increased density and proximity to transportation corridors in alignment with the Climate Action Plan. Multi-Modal Transportation, including prioritizing implementation of the Bicycle Master Plan, pedestrian safety and the Short-Range Transit Plan. Climate Action: Implement the Climate Action Plan, assess requirements to achieve a net-zero carbon city" target and implement cost-effective measures, including implementation of a sustainability coordinator and formation of a green team. We request that the Final EIR analyze a new green project that incorporates the City Council’s new goals and addresses how San Luis Ranch will help the City achieve the 20 percent trips-by-bike goal in the Land Use and Circulation Elements and the Climate Action Plan and the 20 percent mode share objective in the Bicycle Transportation Plan. The San Luis Ranch Specific Plan states the following: The SLO Bicycle Transportation Plan puts forth the need for a Class I crossing of Hwy 101 between Los Osos Valley Road and Madonna Road. San Luis Ranch Specific Plan development shall consider as part of the Prado Road connection, either a bicycle/pedestrian only crossing , or a motor vehicle crossing with both Class I and Class II facilities. The SLO Bicycle Transportation Plan looks to provide connectivity from the planned “Prado East extension to Broad” project, as a main east/west connector across town to shopping and, most notably, Laguna Middle School (see Figure 6.13). San Luis Ranch Specific Plan development is only responsible for its fair share of improvements in the San Luis Ranch Specific Plan Area. The Final EIR must address a glaring gap in the bicycle transportation network: a Class I crossing of Highway 101 near Marsh Street for a direct connection to downtown. San Luis Obispo urgently needs a safe and convenient crossing of Highway 101 between downtown and the Laguna Lake area for people of all abilities on bicycles. Access to the Madonna bike path is so perilous at both ends that experienced bicyclists avoid it, and Laguna Middle School students rarely consider it as a viable option for travel to school. The DEIR identifies the Prado Road connection as a crossing for people on bikes and states that San Luis Ranch is responsible for financing its fair share of the project. For people on bikes traveling back and forth between the Laguna Lake area and downtown, the Prado Road connection is not direct and requires riding on heavily congested Higuera Street where additional and extended turn lanes are proposed at intersections 8-342 860 Pacific St, Suite 105, San Luis Obispo, CA 93401 | bikeslocounty.org as mitigation for the Avila Ranch project. Even if San Luis Ranch is not responsible for financing all or part of a Highway 101 crossing for people on bikes near Marsh Street, the Final EIR must address it as a significant environmental impact because it represents a significant barrier. Another barrier to people on bicycles is the San Luis Ranch DEIR’s proposed mitigation to add and extend turn lanes to intersections to increase capacity for motor vehicles. Multiple turn lanes pose safety risks to people on bicycles and discourage bicycling. The City Bicycle Transportation Plan states that “intersections can be significant barriers for bicyclists, depending on the bicyclist skill level and the complexity and volume of the intersection traffic.” We cite the San Luis Obispo Council of Governments (SLOCOG) 2013 bicycle use survey found that the majority of County bicycle riders fall into three major categories: Strong and Fearless (14.6%): Defined as someone comfortable riding on almost any road or intersection in the county regardless of road conditions, traffic speed and volume. Enthused and Confident (31.3%): Defined as someone comfortable riding on certain roads with wide shoulders, bicycle lanes and easy-to-navigate intersections. Interested but Concerned (27.9%): Defined as someone only comfortable riding away from motor vehicles or on roads with bicycle lanes, neighborhood streets with low traffic speed and volume, and on bicycle paths. The full survey is posted at: http://slocog.org/sites/default/files/SLOCOG-Bike-Barriers-Survey-Analysis-Report.pdf The City needs the “enthused and confident” and “interested but concerned” categories to reach the 20 percent trips-by-bike goal in the LUCE and Climate Action Plan and the 20 percent mode share objective in the Bicycle Transportation Plan. Bike SLO County is also concerned there won’t be enough developer fee contributions, including San Luis Ranch’s fair share, to build the Prado Road connection as proposed in the DEIR. The failure of Measure J, the half -cent sales tax measure on the November 2016 ballot, and a significant reduction in SLOCOG’s funding sources and flexibility in how funding can be spent present other challenges. In addition, the City of San Luis Obispo received a large allocation of regional funds for the Los Osos Valley Road interchange project, which means regional funds will be distributed to other jurisdictions in the near future. If the Prado Road isn’t built as proposed, the overpasses at Madonna Road and Los Osos Valley roads will take on the added traffic resulting from San Luis Ranch. 8-343 860 Pacific St, Suite 105, San Luis Obispo, CA 93401 | bikeslocounty.org The DEIR also assumes that the Avila Ranch project will be approved as proposed. The San Luis Ranch Final EIR should address the environmental impacts of significant changes or delays in Avila Ranch. Sincerely, Lea Lea Brooks, Advocate Bike SLO County 8-344 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 40 COMMENTER: Lea Brooks, Bike SLO County DATE: January 31, 2017 Response 40.1 The commenter states their support for the project, citing the projects emphasis on bikeways and pedestrian connections. The commenter acknowledges and supports the mitigation measures that encourage the use of multi-model transport options. The commenter’s support will be forwarded to the appropriate decision-makers for review and consideration. Response 40.2 The commenter states that despite the mitigation included in the Draft EIR, the project is projected to generate nearly 17,000 additional vehicle trips per day, resulting in significant and unavoidable impacts to air quality and traffic. The commenter states that these impacts can be mitigated to below a level of significance by placing more emphasis on and incentives to use multi-modal transportation and recognizing that changing transportation preferences and technology will further reduce driving miles per household. The project’s potential impacts to air quality are discussed in Section 4.3, Air Quality, and the projects potential impacts to traffic are discussed in Section 4.12, Transportation. Emphasis on multi-modal transportation is recognized in the Multimodal Transportation Impact Study. For example mitigation measures for project-related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. These improvements would provide the infrastructure needed to connect to existing and planned facilities as presented in the City’s Bicycle Transportation Plan, and incentivize the use of alternative transportation modes to destinations such as downtown, CalPoly, and the regional airport. The Specific Plan also includes Class I and Class II connections to the Bob Jones Trail through the project site with parks and open space, providing safe and convenient access for all modes of travel. The Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. Response 40.3 The commenter states that the EIR needs to address three City goals, established on January 28, 2017 for the next two-year budget cycle, related to housing variety, multi-modal transportation, and climate action planning. As stated in Section 2.0, Project Description, two of the project objectives are to: 1) Create significant entry-level, workforce housing opportunities within the City that is specifically “affordable by design”; and 2) Implement a walkable-bikeable neighborhood design that is integrated with public transit access and open space amenities that encourage alternative modes of transportation. The project has been designed to meet these objectives, which would help to achieve the City’s new housing and multimodal transportation goals. In addition, as described in Section 4.6, Greenhouse Gas Emissions, the project would be consistent with the City of San Luis Obispo 2012 Climate Action Plan. No revisions to the Draft 8-345 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo EIR are required. However, the commenter’s recommendations will be forwarded to the appropriate decision-makers for review and consideration. Response 40.4 The commenter requests that the Final EIR analyze a new green project that incorporates the City Council’s new goals and addresses how the project will help the City achieve the 20 percent trips-by-bike goal in the Land Use and Circulation Elements and Climate Action Plan, and the 20 percent mode share objective in the City’s Bicycle Transportation Plan. Master Response 1 addresses the adequacy of the alternatives analysis included in the Draft EIR. The Bicycle Transportation Plan presents mechanisms to achieve the City’s multimodal goals, and the project would aid in implementing these goals with General Plan policy concurrence and TDM strategies. Response 40.5 The commenter states that Final EIR must address a gap in the bicycle transportation network: a Class I crossing of U.S. 101 near Marsh Street for direct connection to downtown. The commenter states that the City urgently needs a safe and convenient crossing of U.S. 101 for bicyclists between the Laguna Lake area and downtown, as the existing access to the Madonna bike path is dangerous at both ends. Connections related to Marsh Street are outside of the scope of the traffic analysis for this project because project generated traffic was not forecasted to cause or exacerbate deficiencies at this location. Mitigation measures for project-related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. These improvements would provide the infrastructure needed to connect to existing and planned facilities across U.S. 101 between Laguna Lake and downtown as presented in the City’s Bicycle Transportation Plan. Response 40.6 The commenter states that the Draft EIR identifies Prado Road connection as a crossing for people on bikes and the project is responsible for its fair share of related improvements. The commenter states that the Prado Road connection is not direct for those traveling between Laguna Lake and downtown, and requires riding on heavily congested S. Higuera Street where additional and extended turn lanes are proposed at intersections, including mitigations for Avila Ranch. The commenter states that the Final EIR must address challenges for bicyclists crossing U.S. 101 as a significant environmental impact because it represents a significant barrier. The Multimodal Transportation Impact Study addresses bicycle connections across U.S. 101 within the vicinity of the project. Mitigation measures reflecting these bicycle connections for project- related impacts include construction of parallel Class I facilities to accommodate pedestrians and bicycles along Madonna Road, Los Osos Valley Road, Prado Overcrossing, and South Higuera Street. The parallel Class I facility along Higuera is projected to connect to the Bob Jones Trail closer to U.S. 101, and would provide safe, convenient, and efficient travel along this route. These improvements would provide the infrastructure needed to connect to existing and planned facilities across U.S. 101 between Laguna Lake and downtown as presented in the City’s Bicycle Transportation Plan. 8-346 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 40.7 The commenter states that another barrier to bicyclists is the Draft EIR mitigation to add and extend turn lanes at intersections to increase capacity for motor vehicles. The commenter states that multiple turn lanes pose safety risks to bicyclists and discourage bicycling. The commenter notes that the City’s Bicycle Transportation Plan states that intersections can be significant barriers depending on the bicyclist skill level and complexity and volume of the intersection, and references the findings of the SLOCOG 2013 bicycle use survey. Refer to Response 26.3 for a description of Bicycle Transportation Plan mechanisms to achieve the City’s multimodal goals and potential bicycle conflicts with intersections and multiple turn lanes. Response 40.8 The commenter sates that Bike SLO County is concerned there won’t be enough developer fee contributions, including the project’s fair share, to build the Prado Road Overpass connection due to the failed Measure J and a significant reduction in SLOCOG’s funding sources and limitations on the flexibility of funding allocations. The commenter notes that the City received a large allocation of regional funds for the Los Osos Valley Road Interchange project, and suggests that in the near future regional funds will be distributed to other jurisdictions. The commenter states that if the Prado Road Overpass isn’t built, the Madonna Road and Los Osos Valley Road overpasses will take on the added traffic resulting from the project. The commenter also states that the Draft EIR presumes that the Avila Ranch Project will be approved as proposed, and that the Final EIR should address the environmental impacts of delays or changes in Avila Ranch. Refer to Master Response 2 for a discussion of the funding, feasibility, and adequacy of the Prado Road Overpass mitigation. As described in Response 38.7, SLOCOG will continue to work with its member jurisdictions to program projects according to their funding priorities, SLOCOG policies, and the limits of funding. For future programming cycles, a regional share of the Prado Road Overpass could be defined, and compete for SLOCOG discretionary funding. Refer to Response 16.1 which discusses the cumulative effects of the project in combination with other planned projects and programs in the City. As stated therein, the Draft EIR uses the General Plan projection method that considers projects and programs included in the City’s General Plan Land Use and Circulation Elements. The General Plan projection method used in the Draft EIR is based on City-wide cumulative projections that establish conditions that would exist due to the build-out of the City’s General Plan including the buildout potential of the Avila Ranch Project as envisioned by the Land Use Element. Since changes or delays in the Avila Ranch Project cannot be reasonably projected at this time, the cumulative analysis in the Draft EIR provides the best available information relative to other planned programs and projects in the City. Response 40.9 The commenter states that the Draft EIR assumes the Avila Ranch Project will be approved as proposed, and suggests that the environmental impacts associated with changes or delays to the Avila Ranch Project should be addressed in the Final EIR. Refer to Responses 16.1 and 40.8 which discusses the cumulative effects of the project in combination with other planned projects and programs in the City. No changes are necessary for the Final EIR in response to this comment. 8-347 Meeting: From: Christian, Kevin Sent: Tuesday, January 31, 2017 9:11 AM To: Gardner, Erica; Bergman, Katelin Cc: Gallagher, Carrie Subject: FW: Draft EIR - San Luis Ranch Comments and Questions Erica: CC, send to Council—All, log and file Katelin: PC - post and distribute Item: S I, L b C -A P -- RECEIVED CITY Of SAN LUIS OBISPO JAN 3 1 2017 COMMUNITY DEVELOPMENT From: Mila Vujovich-LaBarre [ Sent: Monday, January 30, 2017 4:31 PM To: Advisory Bodies <advisorybodies@slocity.org> Cc: Lichtig, Katie <klichtig@slocity.org>; Harmon, Heidi <hharmon@slocity.org>; Pease, Andy <apease@slocity.org>; Rivoire, Dan <DRivoire@slocity.org>; Gomez, Aaron <agomez@slocity.org>; Christianson, Carlyn <cchristianson@slocity.org> Subject: Draft EIR - San Luis Ranch Comments and Questions To: Planning Commission - City of San Luis Obispo Cc: San Luis Obispo City Council Members Katie Lichtig - City Manager Re: Draft Environmental Impact Report (DEIR) San Luis Ranch Development From: Mila Vujovich-La Barre Date: January 30, 2017 Dear Planning Commission Members - Thank you for the opportunity to voice opinions about the Draft Environmental Impact Report (DEIR) for San Luis Ranch at the last two Planning Commission meetings. At the last Planning Commission meeting, some of you on the commission were asking very specific questions of both the developer and City staff. I am hoping that we all receive full, logical, comprehensive answers for your queries that mirrored mine. At the meeting, I did not hear the responses. This property on 131 -acres of Class 1 agricultural land is still located in the County of San Luis Obispo. It should not be annexed into the City until all of the questions are answered with verifiable data. Some members of the Land Use Circulation Element (LUCE) team envisioned that development at this site was good in theory. However, some have now questioned the practicality and feasibility of what is in the LUCE document. A majority of the LUCE members held steadfast to the fact that Prado Road was going to be a four -lane truck highway in accepting proposed development for both San Luis Ranch and Avila Ranch. That is what is in the approved and certified LUCE document. As I have said on numerous occasions, I have been asking for a comprehensive Environmental Impact Report (EIR) for Prado Road from Madonna to Broad Street for the last 15 years. It has never been done. It cannot be "segmented" or "piecemealed" any further without wreaking havoc with the traffic infrastructure throughout that part of town. In Curtin's California Land Use, it is stated that in Citizens Association, the court "held that `chopping up' a large project into many little ones, each with minimal impact on the environment, with the use of negative 8-348 declarations, did not comply with CEQA, as it would result in overlooking the cumulative environmental consequences, which could be disastrous. Citizens Association, 172 Cal. App. 3rd at 151. " So, thank you for asking the hard questions about Prado Road and the proposed traffic flow out Froom Ranch to Los Osos Valley Road. Please secure answers for: Who is going to fund Prado Road? Where are those funds now? Is Prado Road going to be an overpass or an interchange? In either scenario, as the road goes east towards Higuera, what path is it going to take? A layperson can go out onto to the existing Prado Road today and see with their own eyes and measure with a simple measuring tape that a four -lane truck highway, even one without bike lanes, simply does not fit. For San Luis Ranch to be allowed to go forward and to funnel all of the traffic onto Los Osos Valley Road via an extended Froom Ranch Road is the opposite of good planning. The traffic infrastructure cannot be an afterthought. This should be discussed now to avoid extreme congestion on Los Osos Valley Road. Everyone needs to remember that another development - the Madonna family's Continued Care Residential (CCR) Facility is also being proposed with traffic to also be funneled on to Los Osos Valley Road. In the current plans, Madonna's CCR also has 280 homes scheduled to be built. The traffic will become unbearable. Also, several of you, as commissioners, also asked about the supply of water for this development at the last meeting. Thank you. This epic drought is not over and I do not believe that an adequate water supply exists. I would also like to know if the sewer plant is in condition to handle the increased demand from these proposed residential and commercial units at San Luis Ranch. In closing, thank you for the opportunity to express my concerns again so that they can be addressed in the responses by the staff and development team. Sincerely, Mila Vujovich-La Barre Mila Vujovich-La Barre 650 Skyline Drive San Luis Obispo, CA 93405 8-349 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 41 COMMENTER: Mila Vujovich-LaBarre, Private Citizen DATE: January 31, 2017 Response 41.1 The commenter notes that in the Planning Commission public comment hearings for the project, Planning Commissioners asked questions of the project developer and City staff related to the project and associated environmental review. The commenter notes that the project site is located in the County of San Luis Obispo, and states that the site should not be annexed into the City until the Planning Commission’s questions are answered with verifiable data. Refer to Responses 41.2 through 41.6 for responses to the questions to which the commenter refers in these introductory remarks. Response 41.2 The commenter states that development on the project site was seen as a good thing during the preparation of City’s General Plan LUCE update (2014), but some people now question the practicality and feasibility of the 2014 LUCE and the policies and assumptions pertaining to the Prado Road Overpass. The commenter states that she has been requesting a comprehensive EIR for Prado Road from Madonna Road to Broad Street for 15 years and this request has not been met. The commenter states that a piecemeal environmental review of traffic impacts to this area will result in worse impacts to traffic infrastructure in this part of town than existing conditions. The Prado Road improvements are subsumed into the Circulation Element portion of the LUCE Update EIR, and EIRs for projects that would implement the segments of that roadway identified in the 2014 LUCE. Refer to Master Response 2 for a discussion of the timing of the Prado Road Overpass/Interchange mitigation and opportunities for public review of the Prado Road Overpass/Interchange. Response 41.3 The commenter asks who is going to fund Prado Road, where those funds are now, and whether the Prado Road connection to U.S. 101 is going to be an overpass or an interchange. The commenter asks what path Prado Road will take as the road goes east towards S. Higuera Street, and states that a four-lane highway, even without bicycle lanes, does not fit in the existing alignment. As described in Response 38.7, SLOCOG will continue to work with its member jurisdictions to program projects according to their funding priorities, SLOCOG policies, and the limits of funding. For future programming cycles, a regional share of the Prado Road Overpass could be defined, and compete for SLOCOG discretionary funding. Refer to Master Response 2 for a discussion of the funding and feasibility of the Prado Road Overpass mitigation. Based on the City’s General Plan, the Prado Road Overpass would align with the existing Prado Road east of U.S. 101 and connect to Dalidio Drive abutting the project site. Based on the City’s General Plan, and as stated in the Draft EIR, Prado Road between U.S. 101 and South Higuera Street is planned to be widened to a four-lane facility with Class II bike lanes under near-term conditions. 8-350 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response 41.4 The commenter states allowing the project to go forward and add traffic to Los Osos Valley Road via the extension of Froom Ranch Way is not good planning. The commenter states that issues with the traffic infrastructure should be discussed now to avoid extreme congestion on Los Osos Valley Road, taking into account other projects that would add traffic to Los Osos Valley Road. As described in Section 4.12, Transportation, and the Multimodal Transportation Impact Study (Appendix L), the project would have access from Madonna Road, Dalidio Drive/Prado Road, and Froom Ranch Way, as well as Los Osos Valley Road (refer to Figures 6A and 6B of Appendix L for the project trip distribution that was utilized in the Multimodal Transportation Impact Study). Response 41.5 The commenter states that the drought is not over and that adequate water supply may not be available to serve the project. Refer to Response 18.2 for a discussion of water sources available to serve the project. As discussed therein, and in Section 4.13, Water Resources, the City’s existing water supply would be sufficient to serve the project’s estimated demands. Response 41.6 The commenter questions whether the City’s Water Resource Recovery Facility (WRRF) is in condition to handle the increased demand from project development. As discussed in Section 4.14, Issues Addressed in the Initial Study, the WRRF is designed for an average dry weather flow capacity of 5.1 million gallons per day (MGD), and in 2015, average flows to the WRRF were approximately 3.5 MGD. The LUCE Update EIR determined that the project, in combination with other specific plan development in the City, would generate approximately 0.32 MGD of wastewater or approximately 20 percent of the WRRF dry weather flow capacity and 1.7 percent of the WRRF wet weather flow capacity. Impact fees would also be collected from the developer at the time building permits are issued to pay for capacity at the City’s WRRF. The fees are set at a level intended to offset the potential impacts of new residential units included in the project. Additionally, the project would generate wastewater within the current capacity of the City’s WRRF. As such, the WRRF would be able to service the wastewater demand from the project. 8-351 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo 8.5 RESPONSES TO COMMENTS ON THE DRAFT EIR RECIRCULATION As described in Section 8.1 above, Section 5.0, Other CEQA-Related Discussions, of the Draft EIR was recirculated for a 45-day public review period that began March 3, 2017 and concluded on April 17, 2017. The recirculated section was revised to include an updated discussion of energy use and conservation related to the project. The following responses are provided to the comments received in two comment letters written in response to the recirculated portions of the Draft EIR during the additional public review period. Responses to these comments have been prepared to address the environmental concerns raised by the commenters and to indicate where and how the recirculated portion of the Draft EIR addresses pertinent environmental issues. Responses are provided to all comments received on the recirculated portions of the Draft EIR during the additional public review period, but are not provided for additional comments on the remainder of the Draft EIR to which modifications were not made. 8-352 8-353 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 42 COMMENTER: C.R. Flores, Private Citizen DATE: Undated Response The commenter lists their concerns related to the project, which include farmland destruction, environment destruction, flood land encroachment, public safety, airport hazards, traffic, congestion, smog, and burdening local resources. This comment was submitted during the comment period for the recirculated portions of the Draft EIR, which the project’s potential energy impacts. This comment does not address issues related to energy consumption or efficiency, does not provide new information or evidence related to the Draft EIR’s analysis of energy impacts, and does not reflect on the adequacy or content of the Draft EIR. The concerns raised by the commenter will be forwarded to the appropriate decision-makers for review and consideration. 8-354     860 Pacific St, Suite 105, San Luis Obispo, CA 93401 | bikeslocounty.org   City of San Luis Obispo Community Development Department Atten: Brian Leveille, Senior Planner and John Rickenbach, Project Manager 919 Palm Street San Luis Obispo CA 93401-3218 bleveille@slocity.org jfrickenback@aol.com 17 April 2017 Re: San Luis Ranch Draft Environmental Impact Report, Recirculated Portions Dear Mr. Leveille and Mr. Rickenbach, Bike SLO County appreciates the opportunity to comment on the Recirculated Portions of the San Luis Ranch Draft Environmental Impact Report (DEIR) relating to energy impacts. We applaud the City for determining that additional analysis related to the project’s energy impacts was needed. Bike SLO County is supported by more than 4,800 individuals throughout the region who believe safer complete roads for biking, walking and driving are essential to communitywide well-being. Replacing personal motor vehicle trips with bicycle trips saves energy by reducing fuel consumption, reduces air pollution and traffic congestion and improves public health. It also helps the City achieve its 20 percent trips-by-bike goal in the Land Use and Circulation Elements and the Climate Action Plan and the 20 percent mode share objective in the Bicycle Transportation Plan. Bike SLO County reiterates our support for denser housing for people who want to live closer to their jobs in the City so they don't have to commute long distances, and for whom riding a bicycle, walking and/or taking transit are viable options. The DEIR emphasizes bikeways and pedestrian connections on site and to adjacent and close-by destinations, all of which contribute to reduced vehicle trips traveled. We support the mitigation measures that encourage people to use multi-modal transportation options, including a bicycle-share program, vanpools and neighborhood electric vehicles. Our main concern is connectivity for people on bikes or walking to destinations beyond the immediate and nearby vicinity of San Luis Ranch and the Los Osos Valley corridor. We note the following statement in the San Luis Ranch Specific Plan: The SLO Bicycle Transportation Plan puts forth the need for a Class I crossing of Hwy 101 between Los Osos Valley Road and Madonna Road. San Luis Ranch Specific Plan development shall consider as part of the Prado Road connection, either a bicycle/pedestrian only crossing, or a motor vehicle crossing with both Class I and Class II facilities. The SLO Bicycle Laguna (continued) 8-355     860 Pacific St, Suite 105, San Luis Obispo, CA 93401 | bikeslocounty.org   Transportation Plan looks to provide connectivity from the planned “Prado East extension to Broad” project, as a main east/west connector across town to shopping and, most notably, Middle School (see Figure 6.13). San Luis Ranch Specific Plan development is only responsible for its fair share of improvements in the San Luis Ranch Specific Plan Area. Bike SLO County recognizes that San Luis Ranch is only responsible for its fair share of improvements in the San Luis Ranch Specific Plan Area. However, the projected 17,000 additional motor vehicle trips per day in an area already suffering from traffic congestion highlights the need for additional multi-modal transportation options to and from the Madonna Lake area. We reiterate our request that the City of San Luis Obispo develop a time table and prioritize resources to address the gap in the bicycle transportation network between downtown and the Laguna Lake area in order to mitigate the negative affect that additional motor vehicle trips in this area will have upon the air quality and transportation congestion in our community. Without this vital connection in the City’s bicycle transportation network, more people will choose to travel between downtown and the Laguna Lake area by personal motor vehicle for safety reasons even though the distance is easily covered by bicycle or on foot. Bike SLO County is concerned that the Prado Road connection as proposed in the DEIR will not receive sufficient funding. Because the City of San Luis Obispo received a large allocation of regional funds for the Los Osos Valley Road interchange project, regional funds may be distributed to other jurisdictions in the near future, limiting funds available for the Prado Road overpass project. If the Prado Road overpass isn’t built, the overpasses at Madonna Road and Los Osos Valley roads will take on the added traffic resulting from San Luis Ranch further aggravating an existing problem. In addition to the Prado overpass, a separate connection that would greatly increase cycling and pedestrian transit between downtown and Laguna Lake would be a Class I crossing of Highway 101 near Marsh Street. An improved crossing at this location is needed to provide a safe way for people of all abilities on bicycles as well as for pedestrians to connect to the Madonna bike path. The existing crossing to the Madonna bike path is so perilous that experienced bicyclists avoid it, and Laguna Middle School students rarely consider it as a viable option for safe travel to school. Sincerely, Mike Bennett, LtCol USMC Ret. Executive Director Bike SLO County mike@bikeslocounty.org 8-356 San Luis Ranch Project EIR Section 8.0 Responses to Comments City of San Luis Obispo Response to Letter 43 COMMENTER: Mike Bennett, Executive Director, Bike SLO County DATE: April 17, 2017 Response The commenter states their appreciation to the City for providing additional discussion of the project’s energy impacts. The commenter states Bike SLO County’s support for dense housing to reduce commuting distances. The commenter notes that the Draft EIR emphasizes bikeways and pedestrian connections, which contribute to reduced vehicle trips, and states their support for mitigation measures that encourage people to use multimodal transportation options. The commenter states that there is a need for additional multimodal transportation options to and from the Madonna Lake area, and requests that the City prioritize resources to address a gap in the bicycle transportation network between downtown and the Laguna Lake area to mitigate the effect of additional motor vehicle trips in this area. The commenter states that Bike SLO County is concerned that the Prado Road Overcrossing would not receive sufficient funding, and would not be built. The commenter also recommends a Class I crossing of U.S. 101 near Marsh Street. This comment was submitted during the comment period for the recirculated portions of the Draft EIR, which the project’s potential energy impacts. This comment does not address issues related to energy consumption or efficiency, does not provide new information or evidence related to the Draft EIR’s analysis of energy impacts, and does not reflect on the adequacy or content of the Draft EIR. The concerns raised by the commenter will be forwarded to the appropriate decision-makers for review and consideration. In addition, refer to Responses 40.2 through 40.9, which address comments on similar issues provided by Bike SLO County in a previous letter submitted regarding this project. 8-357