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HomeMy WebLinkAboutComment Received 07-12-2017 - Avila Ranch (General) (Peck, Los Verdes Parks 1 & 2 HOAs)Peck Planninky and Develaplmenf, LLC Planning Development Economics Stephen Pock, AItP RCCEIVE D President CITY OF SAN LUIS OBISPO July 12, 2017 City of San Luis Obispo Community Development Department 919 Palm Street San Luis Obispo, CA 93401-3218 JUL 12 2017 COMMUNITY DEVELOPMENT RE: June 28, 2017 Draft Comment Letter from Los Verdes Park 1 Homeowners' Association, Inc. and Los Verdes Park 2 Homeowners' Association, Inc. We have reviewed the June 28, 2017 correspondence from the Los Verdes Park 1 Homeowners' Associ- ation, Inc. and Los Verdes Park 2 Homeowners' Association, Inc. (collectively, "Los Verdes") commenting on the Avila Ranch Final EIR ("FEIR"). We understand a representative of Los Verdes has withdrawn the letter, but offer the following responses to the Los Verdes comments, for the purpose of clarifying the record. • The comment states that the FEIR should include more specific analysis of the project's impacts on neighborhoods in the vicinity of the project. The comment further states the Transportation Improvement Phasing Plan (MM TRANS -2a) and air quality and noise control plans should not be deferred and should be subject to public review. The Transportation Improvement Plan is an implementation component of the EIR and is not intended to defer mitigation or to delay the analysis of the mitigations to a later date. MM TRANC 2a states that "The Applicant shall create and submit a Transportation Improvement Phasing Plan to the City for re- view and approval, and shall ensure that construction of the Project follows the sequential phasing or- der utilized in the TIS for such improvements. The Plan shall address the timing and general design of all on and offsite transportation improvements." (See FOR page 3.12-45.) The mitigation ensures that the project is phased in the same manner as the EIR analysis. The Transportation Improvement Plan is to be a special implementation component of the Public Improvement Plans for each phase of the project. The Public Hearing Draft of the Development Plan (FEIR Appendix D), the Specific Plan, and the FOR set forth the timing of each of the mitigation measures with respect to final map recordation and/or build- ing permit issuance. These are the concrete and measurable thresholds required by CEQA. There is no deferred mitigation. The comment states that the traffic (MM TRANS -4) and air quality mitigation should be subject to public review. The comment further states that alignments and approaches to the intersec- tion of S. Higuera Street should be subject to public input and oversight because they impact parcels not adjacent to the intersection. The improvements to be implemented by the project are clearly identified in the either the FEIR, the Traffic Impact Study, FEIR Appendix D, or the Development Plan. Consultation with adjacent property owners is required to provide notification to the affected property owners about potential traffic con- trol impacts, timing of construction and related issues. The actual design, scope, and effectiveness of the mitigation measures is covered in the FOR and project documents. Consultation is not for the pur- pose of designing the improvements, but of coordinating improvements. No improvements will be on the west side of Higuera and no consultations or coordination is therefore necessary with Los Verdes. (See FEIR Chapter 3.12, Transportation and Traffic.) Intersection design will be done in accordance with city improvement plan standards and standard engineering practice as applied by licensed Traffic Engi- neers and Civil Engineers. (See FEIR pages 3.12-53.) The Transportation Improvement Plan will conform to the required elements set forth in the FEIR, which has been subject to public review. (Please see FOR pages 3.12-52 to 3.12-53.) The identified the elements of the plan to be included include the following: o Prepare a detailed improvement plan for Horizon Lane to bring this road into conformance with City standards for a commercial collector of width between 44 to 60 feet from Suburban Road to the Project boundary (3.12-52 to 53.) o Design and improve the intersection of Horizon Lane/Suburban Road to be consistent with Engi- neering Standards and Specification - Uniform Design Criteria City Engineering Design Standards. o Complete the Earthwood Lane Extension to the Project site as part Phase 1. o Prepare a detailed phasing plan that identifies reasonable timing of such improvements for Sub- urban Road, Horizon Lane, and Earthwood Lane. The improvements contained in the Development Plan meet these criteria. The comment states the proposed mitigation measure of a second lane on Los Osos Valley Road was the subject a settlement agreement between the two HOAs, the City of San Luis Obispo and CALTRANS. The comment states that the addition of a lane on Los Osos Valley Road requires no- tification of all parties. The comment states that the additional lane on Los Osos Valley Road is only needed if the LOVR Bypass is not constructed and requests that Commissioners direct Staff to prioritize the LOVR Bypass as the preferred mitigation for this area. The Settlement Agreement does not limit the number of lanes on Los Osos Valley Road ("LOVR"), alt- hough it does obligate the City to monitor traffic. (See FEIR pages 3.12-64 and 8-127.) To the contrary, LOVR is designated as a four lane Arterial in the city's General Plan and development of it in another fashion would result in impacts to other facilities. (General Plan Circulation Element, page 2-25 Appen- dix E.) The FOR clarifies that although an additional lane is planned, it will not be immediately required. The FEIR traffic section and staff reports clarify that the dual right turn lanes on southbound Higuera at LOVR are no longer necessary in Phase 1 of the project. The lanes will only be necessary if additional receiving lanes are needed for secondary turn lanes that are constructed at the Higuera/LOVR intersec- tion. The narrative of the final EIR has been modified to address that on pages 3.12-63 through 3.12-65. The development of LOVR bypass as an alternative to classifying LOVR as a 4 -lane arterial was reviewed in the recent LUCE update and it was concluded that this facility was necessary and appropriate for the development of the new "Creekside" development portions of the City north and south of LOVR west of the Los Verdes residential development, but not as a regional or communitywide circulation facility. This facility is not needed for the mitigation of traffic impacts from Avila Ranch. The Transportation Im- pact Study ("TIS") prepared for the FEIR describes that development of additional lanes on LOVR and Higuera in conformance with the General Plan will mitigate the impacts associated with cumulative im- pacts at General Plan buildout. (See FEIR Appendix P, page 58.) The project will contribute its fair share to those improvements. (See FEIR pages 3.12-65 through 3.12-66.) The TIS describes the LOVR bypass as an alternative, but that alternative is dependent on the develop- ment of Creekside project area, further environmental study, concurrence by the County and amend- ment of the both the City and the County General Plans. (See FOR pages 8-128, 8-461.) As described in Section 3.12, Transportation and Traffic, and Appendix P, the LOVR bypass has not yet been planned or approved, and implementation of this extension is dependent on completion of a pro- ject feasibility study and eventual provision of funding. The LOVR project is also not adopted in either the City or County General Plan, and the City does not have rights of way acquired, or a funding source. The comment speculates that additional northbound lane on LOVR would be hazard to residents and opposes any such restriping. The TIS concluded that LOVR will operate adequately with the project's impacts. (See FEIR Appendix P, page 58.) The comment does not offer any substantial evidence to support the conclusion that addi- tional lanes on LOVR will constitute a traffic engineering hazard. The City is obligated under the Settle- ment Agreement to continually monitor the segment of LOVR in front of Los Verdes, and to design the LOVR/Higuera intersection so that gaps are created for existing traffic from Los Verdes. (See FOR page 3.12-64.) • The commenter states that the intersection of Los Verdes Drive at Los Osos Valley Road should have been evaluated in the FEIR and that increased traffic will pose a safety concern. The com- ment states that the addition of project will have impacts to the safety of Los Verdes Park resi- dents at the intersection of Los Verdes Drive and Los Osos Valley. The comment states that the addition of project traffic should warrant signalization at Los Verdes Drive prior to completion of Phase 1. 3 Traffic impacts to the segment of LOVR west of Higuera was studied in the TIS and in the FOR. The TIS and EIR concluded that there will be no significant impacts to that roadway segment. The mitigations proposed for Avila Ranch are specific to its own impacts in the Existing+Project scenarios. Under the Cumulative Scenario the implementation of improvements in the General Plan and other pending or reasonably foreseeable projects are included, as is permitted. The Mitigation of the immediate impacts of the project are not dependent on other projects. The city is already obligated under the Settlement Agreement to monitor impacts to Los Verdes (with or without Avila Ranch) and to provide for adequate breaks in the traffic for access. The additional improvements that are necessary for the project, includ- ing the retiming of the LOVR/Higuera signal and the directional signage on Buckley/Higuera. The emergency access to the project is within the 4 -minute travel time standard established by the City. (See Map 3 of the Fire Master Plan). The Avila Ranch project will also provide an onsite Fire Station so that the emergency access and response times will be improved. (FEIR page 3.11-17.) The Resolution of the limited access points to the existing Los Verdes parks is beyond the scope of this project. Finally, the intersection of Los Verdes Drive at Los Osos Valley Road was not studied because the City does not have adopted intersection standards for the intersection of private drives and classified City roads. Impacts to the segment of LOVR west of the Higuera were studied and found to be less than sig- nificant with implementation of the General Plan. (See FOR Appendix P, page 58.) Signal warrant anal- ysis was not considered because of the lack of thresholds in the General Plan. The project also does not qualify under any of the standard warrants contained in the Caltrans Manual for Uniform Traffic Control Devices (MUTCD). Comment claims that mitigation measures in the FEIR are duplicative of mitigation measures in the LOVR Interchange project and cannot be double -counted. As described in Section 3.12, Transportation and Traffic, and Appendix P, the LOVR bypass has not yet been planned or approved, and implementation of this extension is dependent on completion of a pro- ject feasibility study and eventual provision of funding. The LOVR project is also not adopted in either the City or County General Plan, and the City does not have rights of way acquired, or a funding source. g The comment states that the noise, light pollution and air quality impacts from project traffic on Los Osos Valley Road on the Los Verdes neighborhoods are not adequately addressed or miti- gated in the FOR. The comment proposes an acoustic and light -blocking sound wall along both Los Verdes parks' frontages facing LOVR prior to completion of Phase 1. Landscape features may be used in addition to the sound walls to further mitigate air quality, noise and light impacts as warranted by future phases. Innovative solutions such as CityTree by Greencity Solutions (https://greencitysoIutions.de/en/solutions/#section1bottom). The comment also requests fu- ture monitoring of sound and air quality in the existing neighborhoods. The FOR analyzes the air quality, light and noise impacts of the project's additional traffic. (See FOR pages 3.1-28 to 3.1-29; 3.3-21; 3.3-31; and 3.9-28.) The FEIR concluded that impacts were less than sig - 4 nificant in these areas. (See Comment Response SF -2 on FEIR page 8-125.) The comment does not pro- vide any evidence that the proposed mitigation measures are feasible. The Comment states that the LOVR bypass is the preferred mitigation for the project and states that a constraints analysis is attached. The comment also questions the accuracy of the cumula- tive impact analysis based on uncertainty with respect to the construction of the LOVR Bypass and the Prado Road Interchange. As noted above, the LOVR bypass at present is not a feasible mitigation, and will not be until the City and County General Plans area amended to include it. It will also require coordination with Caltrans to determine the impacts to the SR101 ramps. The City General Plan designates LOVR as a 4 -lane Arterial to supportdevelopment of the General Plan and is the only feasible alternative to address traffic im- pacts. The project will pay its fair share of those improvements are required. Please note that the con- straints analysis referenced in the comment letter was not attached. In addition, the cumulative trans- portation conditions are stated in Appendix P, pages 57-58: o Full access freeway interchange will be constructed at Prado Road and U.S. 101 Freeway. o Prado Road will be extended to connect Madonna Road to Broad Street. Prado Road and South Higuera Street will be expanded to provide second east and westbound through lanes, new north and southbound right turn lanes, and dual left turn lanes on all approaches. o With and without the Los Osos Valley Road bypass. This extension is dependent on a final feasi- bility study to be conducted as part of development of the parcels it would cross. The difference between the two scenarios only affects the intersections of LOVR at Higuera and Buckley at Hi- guera. An operational assessment of both those scenarios is provided in this section. (See also FOR page 3.12-81. Respectfully Submitted, Thank you, ... Std hen 'J? AICP For Avila Ranch, LLC