HomeMy WebLinkAbout27. ScreencheckFEIR80Responset8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-1
Final EIR
8.0 RESPONSE TO COMMENTS
Section 8 is organized as follows:
8.1 Introduction
8.2 Format of the Response to Comments: This section describes the format and
organization of the comments received on the Draft Environmental Impact Report
(EIR) and Recirculated Draft EIR Sections, and the responses to those comments.
8.3 Index of Comments Received on the Draft EIR: This section provides a list of
the comments received on the Draft EIR by a member of the public, agency,
company, or organization, and lists the unique number for each commenter.
8.4 Response to Comments Received on the Draft EIR: This section provides
individual responses to comments received on the Draft EIR provided in letters and
oral testimony.
8.5 Index of Comments Received on the Recirculated Draft EIR Sections: This
section provides a list of the comments received on the Recirculated Draft EIR
Sections by a member of the public, agency, company, or organization, and lists
the unique number for each commenter.
8.6 Response to Comments Received on the Recirculated Draft EIR Sections: This
section provides responses to comment received on the Recirculated Draft EIR
Sections provided in written letters and emails.
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 Avila
Ranch Development Project and has prepared written responses to the written comments
received during the public comment period. Responses to verbal comments made at the
two public hearings for the Project have also been prepared. These responses, as well as
necessary revisions to the Final EIR have been produced by Amec Foster Wheeler,
Environment and Infrastructure, Inc. in coordination with direction from the City of San
Luis Obispo.
Comments received during the extended 55-day public comment period for the Draft EIR,
beginning November 23, 2016 and ending January 18, 2017, included written comment
letters from 98 individuals, 11 agencies/organizations, as well as the Applicant and one
Planning Commissioner. After receiving several comments from members of the public,
the comment period for the Draft EIR was extended for 10 additional days to account for
the holiday schedule. Oral testimonies were received from 26 individuals, along with five
Planning Commissioners during both public hearings held on December 14, 2016 and
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January 11, 2017. In addition, portions of Section 4.0, Other CEQA Sections, were
recirculated to include pages within Section 4.3.3, Energy Conservation. The recirculated
pages were made available for public comment from February 21, 2017 to April 7, 2017.
In accordance with 2017 CEQA Statute and Guidelines, this section provides a written
response to each of these received comments, and describes any revisions to the EIR due
to accepted comments and suggestions as well as reasoned analysis in response to specific
comments and suggestions that were not accepted.
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
and as directed by the City. 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.
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 notation is made in the response indicating that the text is revised. Changes
in the 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 FORMAT OF THE RESPONSE TO COMMENTS
Comments received on the Draft EIR are organized by written comments, then oral
testimonies. Each comment letter or e-mail, and testimony is assigned a unique
identification with each comment individually numbered as well. Individual comments and
issues within each comment letter or e-mail are numbered individually along the margins
in Section 8.3.
8.3 INDEX OF COMMENTS RECEIVED ON THE DRAFT EIR
Table 8-1 lists all agencies, organizations, companies, and individuals that provided written
and oral comments on the Draft EIR. As described above, each comment letter is assigned
a unique nomenclature based on commenter name or organization, and each comment was
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assigned a number. For example, Comment JS-1 is the first substantive comment in the
Comment Letter received from John Smith; “JS” represents the commenter; the “1” refers
to the first comment in that letter.
Table 8-1. Index of Comments Received on the Draft EIR
Commenter
Number Name of Commenter Comment and Response
to Comment Location
Oral Testimonies at Public Commission Hearing (December 14, 2016)
1. Ronald Malak – Commissioner 8-17
2. Hemalata Dandekar – Commissioner 8-19
3. Chuck Stevenson – Commissioner 8-20
4. Daniel Knight – Commissioner 8-23
5. Anne Wyatt 8-23
6. Carolyn Smith 8-24
7. Joffre Capell – San Luis Obispo Council of Governments 8-25
8. Lea Brooks – Bike SLO County 8-25
9. Mila Vujovich-LaBarre 8-26
10. Myron Amerine 8-28
11. Paul Rys 8-29
12. Rochelle Reed Smith 8-30
13. Sarah Flickinger 8-30
Oral Testimonies at Public Commission Workshop (January 11, 2017)
14. Ronald Malak - Commissioner 8-31
15. Hemalata Dandekar – Commissioner 8-32
16. Chuck Stevenson – Commissioner 8-33
17. Daniel Knight – Commissioner 8-33
18. Kim Bisheff – Commissioner 8-34
19. Camille Small 8-34
20. Darrell Goo 8-34
21. James Lopes 8-35
22. James Waldsmith 8-36
23. Karen Addalott – Heal SLO 8-36
24. Karen Krahl 8-38
25. Kathy Borland 8-40
26. Kayle Plourde 8-40
27. Lea Brooks – Bike SLO County 8-40
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Table 8-1. Index of Comments Received on the Draft EIR (Continued)
Commenter
Number Name of Commenter Comment and Response
to Comment Location
28. Mila Vujovich-LaBarre 8-42
29. Myron Amoreen 8-43
30. Pamela Krahl 8-44
31. Raul Rys 8-45
32. Rochelle Reed-Smith 8-46
33. Sarah Flickinger 8-46
34. Stanley Yusekiss 8-46
35. Steven Dorsey 8-47
Organizations
36. Gayle Totton (1) – Native American Heritage Commission 8-55
37. Heal SLO 8-58
38. Joffre Brubaker – SLOCOG 8-70
39. Kim Holmes – San Luis Unified School District 8-75
40. Larry Newland – Caltrans District 5 8-80
41. Leah Brooks (1) – Bike SLO County 8-94
42. Leah Brooks (2) – Bike SLO County 8-102
43. Ingrid Schumann and Melissa Guise – SLO Air Pollution
Control District
8-110
44. Sarah Flickinger (1) – Los Verdes Parks 1 & 2 Homeowner’s
Association
8-125
45. Violet Cavanaugh – Northern Chumash Tribe Council 8-131
Applicant
46. Stephen Peck – Peck Planning and Development 8-212
Individuals
47. Alex DeLeon 8-227
48. Allan Cooper (1) 8-231
49. Allan Cooper (2) 8-235
50. Ann Thurston 8-238
51. Annette Poole 8-240
52. Barbara and Kavin Greenwood 8-243
53. Barbara Farber (1) 8-245
54. Barbara Farber (2) 8-247
55. Bernie and Lorraine Luoma 8-249
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Table 8-1. Index of Comments Received on the Draft EIR (Continued)
Commenter
Number Name of Commenter Comment and Response
to Comment Location
56. Carolyn and Jim Park 8-251
57. Carolyn Smith 8-253
58. Cheryl McLean (1) 8-255
59. Cheryl McLean (2) 8-257
60. Christine Galliani 8-259
61. Dan Sirios 8-261
62. David and Joan Van 8-263
63. David Smith 8-265
64. Debbie Hoffman (1) 8-267
65. Debbie Jenson 8-270
66. Dennis Vavrek 8-272
67. Denny dAutremont 8-274
68. Dia Hurd (1) 8-277
69. Dia Hurd (2) 8-280
70. Dia Hurd (3) 8-282
71. Dorothy DeVries 8-284
72. Doug C. Hoffman 8-286
73. Eric Norrborn 8-288
74. Ernie Peterson 8-290
75. Evan Chechopoulos 8-292
76. G.R. Flores (1) 8-294
77. G.R. Flores (2) 8-296
78. Gale Garrison 8-298
79. Gaylord Chizek 8-300
80. Georgianne Kandler (1) 8-302
81. Georgianne Kandler (2) 8-304
82. Howard and Sandy Amborn 8-306
83. J.K. Waldsmith 8-308
84. Jaleah Brynn 8-310
85. James Lopes 8-316
86. James Ream 8-321
87. James Walker 8-323
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Table 8-1. Index of Comments Received on the Draft EIR (Continued)
Commenter
Number Name of Commenter Comment and Response
to Comment Location
88. Jean and Peter Smidth 8-325
89. Jennifer Klay (1) 8-327
90. Jim and Kay Rizzoli (1) 8-329
91. Jim and Kay Rizzoli (2) 8-331
92. Joan Adams 8-333
93. John and Susan Wimer 8-336
94. Julie Vallejo 8-339
95. Karen Krahl (1) 8-356
96. Karen Krahl (2) 8-363
97. Kathleen Dente 8-365
98. Kathy Borland (1) 8-368
99. Kathy Borland (2) 8-371
100. Katie Longabach 8-373
101. Kayla Plourde 8-375
102. Ken Kienow 8-377
103. Kristie and Matthew Barry 8-380
104. Linda Jankay 8-382
105. Lisa Sutherland 8-384
106. Lydia Mourenza 8-386
107. M. Farid Shahid 8-388
108. Mac Brinton 8-390
109. Margaret Baker 8-392
110. Mark Wheeler and Marge Barinka 8-398
111. Melanie Mattina 8-404
112. Melissa Cummins (Newman) 8-406
113. Mila Vujovich-La Barre 8-411
114. Nathan Stong 8-415
115. Niels Smidth 8-417
116. Orin Davis 8-419
117. Pamela Krahl 8-423
118. Patience Santos 8-427
119. Patty and Dean Rupprecht 8-429
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Table 8-1. Index of Comments Received on the Draft EIR (Continued)
Commenter
Number Name of Commenter Comment and Response
to Comment Location
120. Patty Smith (1) 8-431
121. Patty Smith (2) 8-434
122. Pete and Sandy Agalos 8-436
123. Peter Brazil 8-438
124. Phil Farber 8-441
125. Phyllis Martinelli 8-443
126. Rachelle Steiger and Hanson Steiger 8-447
127. Richard Schmidt 8-449
128. Rochelle and Reed Smith 8-451
129. Roger and Kathleen Eberhardt 8-453
130. Roland and Anita Smith 8-455
131. Ron Malak – Planning Commissioner 8-458
132. Russ Gordon 8-465
133. Scott Thorsov 8-467
134. Sharie Porter 8-469
135. Stefanie Hilstein 8-471
136. Stephanie Hicks 8-473
137. Teri Thulin 8-476
138. Terry Marshall 8-484
139. Terry Whitney 8-487
140. Tom and Maria Soles 8-489
141. Wayne Peterson (1) 8-492
142. Wayne Peterson (2) 8-497
143. Wendi Craig 8-505
144. William Palmer 8-508
8.4 RESPONSE TO COMMENTS
The following pages contain copies of the comment letters. Presented first is a copy of the
comment letter with vertical lines indicating the extent of specific numbered comments,
and on the subsequent pages are the corresponding numbered responses to individual
comments. Each comment is either responded to directly, provided a reference to a master
comment response or another comment response and/or a reference to changes in the EIR
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text to address the comment. Where comments were raised with regard to Project impacts
on transportation or the Transportation Impact Study prepared for this EIR, responses were
prepared by Central Coast Transportation Consulting traffic engineers in coordination with
City staff.
The following section provides “Master Comment Responses,” which are intended to
address questions and concerns regarding key topics in the Draft EIR that were addressed
in multiple public comments. Where appropriate, the responses to individual comments are
referred to one or another Master Comment Response, where a particular issue is addressed
more comprehensively.
8.4.1 Master Comment Responses
Master Comment Response 1 - Public Review Period: Several comments were received
regarding the public comment period and the timing and amount of time available for
public review of the Draft EIR. In response to public concerns regarding the duration and
timing of the public comment period, the Planning Commission extended the public
comment period for the Avila Ranch Development Plan Draft EIR by an additional 10 days
to account for the holiday schedule, overlapping release of the San Luis Ranch Specific
Plan Draft EIR, and allow for additional public review and input.
Notice of Availability (NOA) of the Draft EIR was provided to the public consistent with
CEQA Guidelines Section 15087. This included the publication of the NOA of the Draft
EIR and public hearing date in the San Luis Obispo Tribune on November 25, 2016. Copies
of the Draft EIR were also made available at City Hall, the local public library, and online.
Individuals that requested to be notified of the availability of the Draft EIR were included
on the NOA distribution list. However, a few commenters mentioned that they did not
receive the notice. Nonetheless, all state and local CEQA notification protocols were met.
Master Comment Response 2 - Impacts to Agricultural Land: Multiple comments were
received regarding impacts to agricultural land, the adequacy of mitigation to address those
impacts and the relationship of such mitigation to City policy. Discussion regarding the
loss of agricultural resulting from development of the Project site and mitigation measures
required to reduce such impacts are provided in Section 3.2, Agricultural Resources. As
discussed in this section, and addressed under Impact AG-1, the proposed Project would
result in the conversion of approximately 94.6 acres of land typically used for agriculture.
Of this agricultural land, Project development would result in the loss of a total of 71 acres
of prime farmland located both on- and offsite, including the proposed extension of
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Buckley Road. To mitigate this loss of prime agricultural soils, the EIR requires mitigation
through Applicant-funded acquisition of an offsite agricultural conservation easement or
the payment of in-lieu fees to the City for the acquisition and preservation of other
agricultural lands (see Mitigation Measure AG-1). This measure is consistent with adopted
City policy to address impacts to agricultural lands (e.g., Policies 1.8.1 and 1.9.2). Further,
although proposed mitigation would reduce the severity of impacts, the Project would
ultimately result in the permanent loss of 71 acres of prime farmland, which it would not
be feasible to replace or recreate. Therefore, impacts relating to the loss of agricultural
resources are considered significant and unavoidable.
With regard to Impact LU-3, the proposed Project is located within the City and is therefore
subject to compliance with the policies of the City General Plan. As delineated in City of
San Luis Obispo Urban Planning Area maps, the Project is located within the Urban
Reserve Line (URL) of the City. Land Use Policy 1.9.2 of the City General Plan requires
that development of agricultural land that is not acting as a receiver site for transfer of
development credit from prime agricultural land of equal quantity:
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.
As described in Impact LU-3 of Section 3.8.5.3, Project Impacts and Mitigation Measures,
the proposed Project would satisfy the criteria of Policy 1.9.2 through the implementation
of Mitigation Measure AG-1, which would require that the Applicant establish an offsite
agricultural conservation easement or pay in-lieu fees to a designated fund. This measure
would reduce the severity of the impact and assure consistency with adopted City policy.
Suitable offsite parcels with prime soils do exist within the URL and Greenbelt, according
to the City’s Natural Resources Manager.
Although impacts to farmlands could be partially mitigated through this measure, the
proposed Project would irretrievably commit 71 acres of prime farmland to development
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of commercial and residential uses. Implementation of Mitigation Measure AG-1 would
not fully mitigate such impacts since the lost agricultural land could not be replaced or
recreated.
Master Comment Response 3 - Flooding: Several comments requested further discussion
and analysis of flooding issues, including both on and offsite areas. As provided in Section
3.7, Hydrology and Water Quality, the EIR analyzes impacts associated with increased
runoff and onsite flooding of Tank Farm Creek as well as area south of the Project site at
the confluence of Tank Farm Creek with East Fork San Luis Obispo Creek.
For the proposed Project, realignment of Tank Farm Creek could only occur in
coordination with the restoration and development phases of the Chevron Tank Farm
Remediation and Development Project to the northeast as described in Section 2.6.8 of the
EIR. The Chevron Tank Farm Remediation and Development Project has had no activity
on the tract map in over a year (and may have been withdrawn). In addition, Chevron is
meeting with the Regional Water Quality Control Board (RWQCB) and other agencies
regarding a modified phased approach which could take up to ten years to complete the
remediation phase, absent any development. The planned remediation does not include, at
this point, the drainage improvements. At this stage, it is believed that the drainage
improvements needed to connect Tank Farm Creek directly from the Chevron site to the
Avila Ranch property are indefinitely deferred; consequently, the Mitigated Project
Alternative (MPA) has been developed.
Under the proposed Project, after completion of remediation within the Chevron Tank
Farm property, the Chevron Tank Farm property would retain larger quantities of water
within their site, thereby reducing peak flows entering the Project site. This would reduce
the total flows through Tank Farm Creek. As described in Impact HYD-2, peak flows were
projected for Tank Farm Creek at the confluence with East Fork San Luis Obispo Creek.
The hydrograph for the upstream portion of the Tank Farm Creek watershed, including the
Chevron Tank Farm property were added to the combined hydrograph for the area
downstream of the Chevron Tank Farm property remediation area (see Table 3.7-5). Based
on this analysis, flood flows in Tank Farm Creek would not increase by more than 5 percent
from the existing conditions for the design storms, and 100-year peak flows in the Tank
Farm Creek watershed would be reduced by approximately 12.3 percent. Mitigation
Measure HYD-2a (Master Drainage Plan) would ensure coordination of drainage
improvements with the Chevron Tank Farm property to the north, and establish the
schedule and timing of onsite improvements. The increase in impervious surfaces due the
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Project would result in runoff; however, the Project includes storm water conveyance and
retention infrastructure throughout the site installed beneath proposed Project roadways,
and a dual pocket park/bioretention basin, and a 12-foot swale at the northern Project
boundary. The retention basin/bioswale proposed within the southwestern portion of the
Project site would detain flood flows, reduce flooding at the intersection of Buckley
Road/Vachell Lane and promote groundwater recharge.
As described in Impact HYD-3, an approximately 200-foot long segment of the Buckley
Road Extension that would fall within the 100-year floodplain may be subject to occasional
flooding; however, no structures are proposed and no persons would be put at risk. This is
considered an adverse but less than significant impact after mitigation, including
implementation of the Master Drainage Plan that is a component of the proposed Project.
Mitigation Measures HYD-3a and HYD-3b require that plans for bridge, culvert, drainage
outfall, and other hydrological modifications to the existing creek channels must be
designed and constructed in compliance with the City’s Drainage Design Manual and
approved by the City Engineer, United States Army Corps of Engineers (USACE),
California Department of Fish and Wildlife (CDFW), and Central Coast RWQCB prior to
Project approval, and must meet City standards and policies. Review by these agencies
would ensure that structures and modifications could adequately handle flood flows
associated with a 50- or 100-year storm.
As discussed in Section 5.0, Alternatives under the MPA, the design of the MPA reflects
uncertainty surrounding the timing for completion of remediation and eventual
development of the Chevron Tank Farm Remediation and Development Project and
postponement of those efforts. Based on this uncertainty and change in circumstances, the
MPA includes revised flood protection measures based upon new hydrologic studies, and
does not rely on any drainage improvements on the Chevron Tank Farm property.
Master Comment Response 4 - Scope of Alternatives: Section 5.0, Alternatives,
provides discussion and consideration of a reasonable range of alternatives that would meet
Project Objectives and reduce or substantially lessen environmental impacts as required
under CEQA Section 15126.6. This alternatives analysis includes consideration of two No
Project Alternatives, the MPA, and a Business Park Alternative, as well as four (4) potential
alternatives that were rejected from further analysis due to their failure to meet basic Project
Objectives, inconsistency with City policies, and inability to reduce Project environmental
impacts. The MPA was included due to the Chevron Tank Farm Remediation and
Development Project delaying or not implementing regional hydrological improvements,
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the need to properly design and phase on and offsite transportation improvements and
requirements for improved creek protection. In addition, a discussion of an alternative that
would comply with the City of San Luis Obispo Land Use Element, which considers the
minimum development of only 500 units has been provided in Section 5.0 Alternatives
under alternatives considered but discarded because it would not meet the basic Project
Objectives to provide a broad mix of housing types, including workforce and affordable
housing (see Section 5.4.1).
Master Comment Response 5 - Housing Affordability: As discussed in Section 2.0,
Project Description, one of the primary objectives of the Project is to provide a variety of
housing opportunities for a wide range of socioeconomic
groups and affordability levels. As such, the Project currently includes a mix of market
rate, “workforce” and inclusionary affordable housing units through the provision of
different housing densities and designs. Provision of affordable housing to comply with
the City’s Inclusionary Housing Ordinance would be required to meet the standards of City
General Plan Policy LU 8.1.2 and the City’s Inclusionary Housing Ordinance. Under City
Ordinances, inclusionary housing would be required to constitute roughly 15 percent of all
housing, subject to any reductions available by Housing Element housing policies. Future
applicants for purchase or rental of such housing would be subject to review and approval
by the City, with ongoing monitoring to ensure compliance. Final unit types and
affordability levels would be determined by the City during the review process. Because
the Project would be required to be consistent with City inclusionary and affordable
housing policies, Project impacts related to the provision of affordable housing are
considered less than significant. Final pricing of these affordable units, would be subject
to review and approval by the City to ensure the affordability of these units to low and
moderate income households.
Master Comment Response 6 - Effects on Airport Operations: Multiple comments
were received regarding airport safety and potential Project impacts, including effects on
operation of the San Luis Obispo County Regional Airport (Airport). The Project would
include development of a mix of residential, office, and retail uses within the proximity of
the, within the Airport Land Use Plan for the San Luis Obispo County Regional Airport
(ALUP) Safety Areas and City Land Use and Circulation Elements (LUCE) designated
Airport Overlay Zones (AOZ). To determine consistency with the City LUCE and ALUP,
the Applicant submitted the Avila Santa Fe Ranch Airport Land Use Compatibility
Analysis Pre-Application (provided in Appendix N of the EIR) to the Airport Land Use
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Commission (ALUC). As identified during the review of the Project pre-application by the
ALUC, development of the Project would overlap several ALUP Safety Areas and would
fall entirely within the City LUCE AOZ 6. However, as discussed under Impact HAZ-3 in
Section 3.6, Hazards and Hazardous Materials, layout and design of the Project would be
consistent with the development restrictions for these safety and overlay zones, and the
Project would be consistent with the City LUCE and ALUP. Further, no development under
the Project would be located within the general approach zones for any of the airport
runways. Therefore, impacts related to development within close proximity to the airport
and associated airport hazards are considered less than significant. Refer to Section 3.6,
Hazards and Hazardous Materials and Impact HAZ-3 for detailed discussion of airport-
related hazards. In November, 2016, the Applicant submitted a formal application with the
ALUC for a formal determination of conformity with the ALUP. The Project was
determined to be consistent with the ALUP in December 2016 by the ALUC.
Master Comment Response 7 - Long Term Water Supply: Several residents expressed
concerns regarding the adequacy of long-term water supplies and effects on local
groundwater, particularly given the recent five-year drought. As described in Section 3.13,
Utilities, analysis of water availability for the Project is based upon a detailed Water Supply
Assessment (WSA), the City’s 2015 Urban Water Management Plan and review and
feedback from City staff. The City’s projected water demand within the Urban Water
Management Plan is based on the 10-year average of per capita water usage, which
accounts for cyclic water factors including years of drought, wet years, and normal years.
The WSA reviews available supply, Project water demand and the long-term balance
between supply and demand. While the City has been in a drought state, water usage varies
depending on the water cycle, and the EIR assesses average usage over a 10-year period.
Based upon a review of the long-term water supply, the WSA concludes that adequate
water is available to serve the Project. Regarding local groundwater resources, Project
implementation would substantially reduce historic demands on the local groundwater
basin as onsite agricultural water demand would decline significantly. Further, the Project
has been designed to include Low Impact Development standards to facilitate retention and
infiltration of runoff, as wells as use of a flood retention/ basin/ bioswale to retain and
recharge flood flows. While the replacement of the onsite well would continue to supply
more limited agricultural water demand, demand on local groundwater resources would be
greatly reduced. For further discussion of impacts to local groundwater, refer to Section
3.7, Hydrology and Water Quality, Impact HYD-6. Also, refer to the WSA in Appendix
M.
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Master Comment Response 8 - Traffic Impacts on Buckley Road: Several comments
were received regarding the Project’s contribution of traffic to Buckley Road and its
impacts to operation of various side street intersections and driveway, associated delays
and safety issues at such locations. Section 3.12, Transportation and Traffic of the Final
EIR has been amended to more fully address traffic capacity, operational and safety issues
along Buckley Road. In summary, the Project would contribute up to 490 trips per day to
the segment of Buckley Road east of Jespersen Road, and 500 trips per day to the segment
of Buckley west of Jespersen Road, based on Figure 5 of the Transportation Impact Study,
or ten percent of cumulative daily volumes, on Buckley Road east of Jespersen Road. Even
with the addition of Project traffic, these improved segments would operate at acceptable
levels of service (LOS) under City and County standards (refer to Table 3.12-9 in Section
3.12, Transportation and Traffic). East of Davenport Creek Road, the Project would
contribute 355 average daily trips (ADT) to Buckley Road at buildout, five percent of
cumulative daily volumes. With the Project in place, the ADT on Buckley Road under
Cumulative conditions is forecast to be 8,000 vehicles, well below the daily LOS D
capacity of 12,800 vehicles (Florida Department of Transportation 2012 Quality/Level of
Service Handbook Tables).
Traffic counts were obtained from the County of San Luis Obispo (SLO County Traffic
Count Database, http://www.slocounty.ca.gov/Assets/PW/Traffic/TrafficCountData.pdf)
to evaluate Davenport Creek Road at Buckley Road to determine if improvements are
warranted. Davenport Creek Road currently has an ADT of 1,280 vehicles, with volumes
of 131 AM and 142 PM peak hour trips. Buckley Road west of Santa Fe Road has an ADT
of 4,253 vehicles, with volumes of 470 AM and 503 PM peak hour trips. Unsignalized
intersections must operate at a deficient LOS and meet signal warrants to justify installation
of a traffic signal. With a major street peak hour volume of 503 vehicles, the minor street
would require a minimum of 215 peak hour vehicle trips to justify a signal warrant. The
volumes on Davenport Creek Road are substantially below the threshold necessary to
justify additional improvements.
The EIR also evaluates Project impacts at four intersections and one segment along
Buckley Road, and applies transportation standards from the City of San Luis Obispo,
County of San Luis Obispo, and Caltrans. Mitigation Measure TRANS-5 requires a Project
contribution towards improvements at the Buckley Road/State Route (SR) 227
intersection.
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With the exception of Noll Road, all public intersections along Buckley Road have
adequate sight distance for the posted speed limit to accommodate all street legal vehicles
including licensed farm equipment that is approved to operate on public streets. Noll Road
has limited sight distance due to the road curvature of Buckley Road at that intersection,
however Buckley has the appropriate advisory speed reduction signing and markings per
the California MUTCD for this condition. Under current conditions vegetation along the
shoulder does not obstruct the minimum stopping sight distance as prescribed in Chapter
200 of the Highway Design Manual and it is the responsibility of the respective public
agency to maintain vegetation within the public right of way so that it does not grow to the
point of obstructing visibility.
Master Comment Response 9 - Airport Noise Complaints: The EIR identifies potential
impacts relating to development of residential units within close proximity to the Airport,
where the Project may expose future residents to unacceptable noise levels. As discussed
under Impact NO-4 in Section 3.9, Noise, the Project would result in development of
residential uses only within the 50 dB Community Noise Equivalent Level (CNEL) airport
noise contour area. Within this area, the ALUP allows residential, commercial, park, and
open space uses. Further, the proposed Project would not develop residential units within
the 55 dB or 65 dB CNEL contour zones (see Figure 3.9-2). Instead, the Project would
develop open space land uses within these zones, consistent with ALUP allowable uses
within these airport noise contours. In addition, please note that as part of the Project
design, bedrooms, sleeping rooms, and living rooms and other noise-sensitive parts of R-3
dwelling units would be located on the side farthest from the noise source. Further, modern
construction techniques reduce interior noise levels by 25 decibels or more, limiting effects
on future residents and potential for complaints. Finally, the Project was determined to be
consistent with the ALUP in December 2016 by the ALUC, which included findings of
compatibility of proposed development with respect to airport noise.
Master Comment Response 10 - Airport Land Use Compatibility: As part of the Project
review process, the City and Applicant submitted a Project pre-application and a formal
application to the ALUC to determine consistency with the ALUP policies and regulations.
Detailed discussion of the Project’s compatibility with the ALUP and this pre-application
can be found in Appendix N, Avila Santa Fe Ranch Airport Land Use Plan Compatibility
Analysis Pre-Application. As part of the analysis of Project impacts relating to land use
planning, Section 3.8, Land Use, provides discussion of the Project’s compatibility with
the ALUP, and Section 5.0, Alternatives, provides discussion of the MPA’s conformity
with the ALUP. The ALUC made a final determination on December 21, 2016, that the
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Project, as well as the MPA, is consistent with the ALUP., and has been included in
Appendix N. Page 1-4 of the EIR has been amended to note this determination.
Master Comment Response 11 - Schools: Residents have expressed concern regarding
school capacity. Discussion of existing school facilities, enrollment capacities, and the
Project’s demand for public school services are provided in Section 3.11, Public Services,
Impact PS-3. As described in Section 3.11, capacity at existing schools was analyzed using
the SLCUSD Enrollment Projections Capacity Analysis 2014/2015 Update. Schools within
the region currently have remaining capacity. In 2014/2015, the SLCUSD did not load
three or more classrooms at each elementary school site, which could allow for additional
capacity if needed. Further, the district currently accepts intra-district open enrollment, so
students could be accommodated at other district schools upon request and availability.
Due to existing available capacity of local schools, the increase of 720 units (equating to
approximately 256 total K-12 students) is not anticipated to result in substantial adverse
effects on school services or enrollment. Further, to offset any potential impacts resulting
from the increase in school enrollment, the Project would be required to contribute
appropriate development fees as mandated under Government Code Section 65970.
Finally, the EIR analysis has been updated to acknowledge input from the SLCUSD based
on their comment letter on the EIR. Please also see Comment Letter 7, Kim Holmes and
Erik Prater, San Luis Coastal Unified School District (SLCUSD), which states that current
primary and secondary school facilities are adequate to serve the Avila Ranch
development, and Comment Response SLCUSD-1.
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8.4.2 Oral Testimonies
Oral testimony was received for the Project on December 14, 2016 and January 11, 2017
at the City of San Luis Obispo Planning Commission Hearing, where members of the
Planning Commission provided comment, followed by comments from the public. Below
outlines the comments received on the Project and responses to those comments.
December 14, 2016 Planning Commission Hearing - Commissioner Comments
Commenter 1 – Commissioner Ronald Malak
Comment Commissioner RM-1: Explain the purpose of the LOVR bypass.
Comment Commissioner RM-2: Were traffic counts done at the appropriate time to capture
potential impacts? Where they done prior to LOVR bridge completion? Did this make for
inaccurate conclusions?
Comment Commissioner RM-3: How will we deal with Prado overpass in the cumulative
analysis?
Comment Commissioner RM-4: Anaerobic digester on Buckley employs 150 personnel
that travel at peak hour. What kind of vehicles are these, and have their impacts been
considered? Shouldn’t there be a turn lane at Santa Fe to address these kinds of vehicles?
Comment Commissioner RM-5: What growth inducing effects will the Project have on
neighboring agricultural properties?
Comment Response Commissioner RM-1: The Los Osos Valley Road (LOVR)/U.S.
Highway 101 interchange improvements, or LOVR bypass, is a 3-lane arterial road which
would provide north and southbound on- and off-ramps to the U.S. Highway 101 at LOVR.
This overpass was developed to improve traffic operations and safety on LOVR and the
LOVR/U.S. Highway 101 interchange.
Comment Response Commissioner RM-2: Traffic counts were performed prior to
completion of the LOVR improvements. Because it was completed prior to completion of
the interchange improvements, the analysis in the Draft EIR reflects a worst case, with
LOS and overall operations reflective of pre-improvement conditions. However, text
within the Final EIR has been adjusted to clarify this matter and qualitatively address
operations post improvements.
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Comment Response Commissioner RM-3: The Prado Road interchange is included in
the Cumulative scenario consistent with the City's Circulation Element. The City and
Caltrans are currently studying the interchange and potential improvement designs as a part
of a separate process.
Comment Response Commissioner RM-4: The anaerobic digester is a County project,
with potential impacts being addressed as part of their permit process. The project is
included in the cumulative list for this EIR and as such, cumulative impacts are addressed
in the traffic study. The addition of a turn lane on Santa Fe Road would be requirement of
that project and the need for such mitigation would not be generated by traffic associated
with the Avila Ranch Project.
Comment Response Commissioner RM-5: Growth-inducing impacts are discussed in
Section 4.2 of Section 4.0, Other CEQA Sections. Infrastructure improvements, including
improvements to and extension of Buckley Road, Horizon Lane, and Earthwood Lane,
along with extending City sewer service to the edge of the urban area could also be
potentially growth inducing for adjacent agricultural land. New or improved roads would
facilitate improved access and circulation within the vicinity, while extending a major force
main to the southern edge of the property would potentially make sewer service available
to nearby agricultural properties. However, City Land Use Policy 1.13.1 prevents the
delivery of water and sewer services outside the City limits, and Land Use Policy 1.13.6
prohibits development of any new annexed land unless an adopted Development Plan is in
place. This policy framework would limit growth inducing effects of the Project to
neighboring County agricultural lands.
Further, roadway and utility extensions could facilitate the development of two currently
undeveloped and used for agriculture parcels zoned M-1, Industrial, to the west of the
Project site along Vachell Lane. Areas to the northwest of the Project site would be the first
to experience growth due to the improved access and circulation brought about by the
Project; these parcels are currently used for agriculture but are zoned for industrial land
uses.
The EIR also identifies growth-inducing effects such as the minor generation of
employment opportunities within the Town Center that may draw newcomers to the area.
Although the Project is estimated to house a population of approximately 1,649 persons,
construction of 720 housing units would alleviate the City’s increased housing demand,
and is thus not considered growth inducing. However, the 1,649 residents are expected to
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generate secondary impacts due to increased commuter traffic and associated air quality
impacts, particularly generation of GHGs.
Commenter 2 – Commissioner Hemalata Dandekar
Comment Commissioner HD-1: Not enough time to consider this because of the time of
the year.
Comment Commissioner HD-2: Buckley extension timing and feasibility is key issue.
Comment Commissioner HD-3: Transit and modal split is a big public question, and agree
we need a more robust analysis of this issue.
Comment Commissioner HD-4: Sewer. Need better answers for how it will work over time
to pump so much sewage uphill.
Comment Commissioner HD-5: Loss of agricultural land. More technical information
needed to address potential impacts.
Comment Commissioner HD-6: Would like to see the high-density housing more
distributed throughout the Project area, not all next to the industrial areas.
Comment Commissioner HD-7: The size of the lots could be refined. No difference from
the product mix that was originally suggested. When is the time we get these changes?
Comment Response Commissioner HD-1: Please refer to Master Comment Response 1.
Comment Response Commissioner HD-2: The Buckley Road Extension is proposed to
be completed as part of Phase 2 of the Project. Timing, construction phasing, Project
impacts, and mitigation measures relating to the Buckley Road Extension are discussed in
detail in Section 3.12, Transportation and Traffic, Impact TRANS-2. As described in this
section the extension of Buckley Road from Vachell to Higuera is not necessary to address
traffic impacts from Phase 1 of the Project.
Comment Response Commissioner HD-3: The Project was evaluated in the context of
the City's Bicycle Transportation Plan (BTP) and the City LUCE. The Project proposes
improvements to and provision of multi-modal facilities with the goal of reducing Project
vehicle dependency and achieving the modal split objectives of the LUCE. See Section 3.8,
Land Use, and Section 3.12, Transportation and Traffic.
Comment Response Commissioner HD-4: Additional discussion of maintenance issues
and energy demand associated with use of force mains and a sewage lift station have been
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added to the EIR. Impacts relating to wastewater infrastructure are discussed in Section
3.13, Utilities. As discussed in UT-1, the Project would be required to contribute
development impact fees to offset the effects of wastewater generation from new
development on the Tank Farm Lift Station. While estimated wastewater generation from
the Project is not anticipated to exceed existing infrastructure capacities and impacts are
considered less than significant, the EIR now discloses maintenance issues that may
generate environmental effects as well as energy demand.
Comment Response Commissioner HD-5: Detailed discussion of the Project’s effects
and impacts on agricultural lands and resources is provided in Section 3.2, Agricultural
Resources. Refer to Master Comment Response 2.
Comment Response Commissioner HD-6: This is not an environmental issue, but a
design issue that lies within the purview of the Planning Commission, whose input will be
forwarded to the City Council for consideration.
Comment Response Commissioner HD-7: This is not an environmental issue, but a
design issue that lies within the purview of the Planning Commission, whose input will be
forwarded to the City Council for consideration.
Commenter 3 – Commissioner Chuck Stephenson
Comment Commissioner CS-1: Why aren’t views from U.S. Highway 101 considered in
the EIR?
Comment Commissioner CS-2: Photo simulations would help… especially views from
Buckley Road.
Comment Commissioner CS-3: Why is there no agricultural buffer to the west along
Vachell? County standards might start with 500 feet and work backward if there is
mitigation through design; the eastern 150-foot buffer is not adequate either.
Comment Commissioner CS-4: Has consumption of energy used in force main pumping
been considered in the GHG emissions?
Comment Commissioner CS-5: Why wait until Phase 3 to put in the fire station if the need
is now?
Comment Commissioner CS-6: What is the mitigation for the Buckley Road/SR 227
impact?
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Comment Commissioner CS-7: When does the Vachell Lane/South Higuera Street
intersection get abandoned?
Comment Commissioner CS-8: Contribution to Higuera Street and Prado Road.
Comment Response Commissioner CS-1: As discussed in Section 3.1.2.4 of Section 3.1,
Aesthetics and Visual Resources, there are only distant glimpses of the Project site from
U.S. Highway 101 northbound, as the Project site is approximately 0.45 mile east of the
highway and vegetation and structures between the highway and the site obstruct or
breakup direct views of the site.
Comment Response Commissioner CS-2: Development of photo simulations to depict
the proposed Project was not requested for inclusion within the scope of the EIR analysis.
However, as part of his comment letter on the EIR, the Applicant’s agent submitted a
photosimulation from Buckley Road, which is included in Appendix S as part of the
Updated MPA Development Plan. In addition, the EIR analyzes the Project’s impacts from
key viewing areas (KVAs) based on their location within high viewer exposure from public
viewing locations near sensitive receptors, and describes how each KVA would be affected
by the Project (see Section 3.1.4.2). This is an accepted methodology for the determination
of aesthetics impacts. As described in Impact VIS-1, impacts to KVAs are identified as
adverse but less than significant.
Comment Response Commissioner CS-3: Additional discussion, impact analysis and
mitigation measure refinements to address this issue has been added to the EIR under
Impact AG-2, Section 3.2, Agricultural Resources. The southwest corner of the Project site
is bordered by fallow land west of Vachell Lane, which is outside of the City’s URL and
zoned by the County as Commercial Service. The site is owned by Caltrans and is not in
agricultural use such as the cultivation of row crops, vineyards and orchards. The County
General Plan and City General Plan require the designation of agricultural or open-space
transition buffers when new development is proposed adjacent to Agriculture zoned areas
(County General Plan Policy AGP17) or open lands (City General Plan Policy LU 1.4).
City General Plan Policy COS 8.3.2 requires that a minimum 50-foot transition area
“…shall be provided within the Project along the Project boundary with the URL…” The
Vachell Lane ROW and the setbacks on each side of Vachell Lane would provide the buffer
called for in COS Policy 8.3.2.
The proposed Project would be generally consistent with City policy regarding agricultural
setbacks as Vachell Lane, new bicycle lanes, crop setbacks from edge of road and
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residential landscaped areas would provide the required 50-foot setback, as long as new
homes are located on the eastern end of the five proposed lots that border Vachell Lane
opposite this agricultural operation.
The 150-foot buffer along the eastern boundary appears adequate under both City policy
and County Agricultural Buffer Policy. County policy accounts for “Hobby Farms”
or “Ranchettes” similar to those east of the site, with buffers in the range of 100 to 200 feet
which would fall within the 150 feet proposed as part of the Project (see Appendix T). For
a detailed discussion of conflicts with adjacent uses and provision of these buffers, refer to
the revised EIR and additional discussion and analysis in Impact AG-2 in Section 3.2,
Agricultural Resources.
Comment Response Commissioner CS-4: Greenhouse gas emissions associated with the
operation of force mains serving the Project site have been added to the revised EIR. Please
note that Project operational emissions and GHGs were found to be significant and the EIR
includes a full range of mitigation measures to reduce emissions, such as utilizing energy
and water efficient fixtures (see Mitigation Measures AQ-2a and AQ-2b).
Comment Response Commissioner CS-5: Timing for development of a fire station to
meet the fire and emergency service demands created by the Project was determined in
consultation with the Fire Department and is based on the City Fire Master Plan prepared
in 2009 and updated in 2016. As stated in the Fire Master Plan, and Interim Fire Station
would be required when 50 percent of the residential units are occupied in Fire Station 5’s
primary service area. This would occur at Phase 3 of the Project.
Comment Response Commissioner CS-6: The current proposal for improvements to the
Buckley Road/SR 227 intersection would involve construction of a roundabout. Discussion
of impacts and mitigation for impacts to the Buckley Road/SR 227 intersection is provided
in Section 3.12, Transportation and Traffic. Refer to Impact TRANS-5 and Mitigation
Measure TRANS-5. The Transportation Impact Study in Appendix P found that Project-
generated traffic would have a relatively minor contribution to impacts at this intersection,
and Mitigation Measure TRANS-5 would require the payment of pro-rata fair share fees to
the County to fund improvements to this intersection. However, the EIR identifies a
significant impact in advance of completion of these improvements.
Comment Response Commissioner CS-7: The installation of left turns restrictions in and
out of the South Higuera Street/Vachell Lane intersection would occur after the Buckley
Road Extension is completed and operational in Phase 2. Refer to Mitigation Measure
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TRANS-2b in Section 3.12, Transportation and Traffic. This would prevent outside traffic
from being rerouted into the Project, and allowing site access on Earthwood Lane to
adequately serve the development in Phase 1.
Comment Response Commissioner CS-8: Project impacts to the Prado Road/South
Higuera Street intersection are discussed in Section 3.12, Transportation and Traffic and
described in detail in the Transportation Impact Study in Appendix P. As depicted in Figure
3.12-2 and described in Impact TRANS-7, the Prado Road/South Higuera Street
intersection would have an acceptable LOS, but would exceed queuing capacity at the
northbound left-turn lane, which currently exceeds capacity. AASP standards and AASP
fee program include the addition of a second northbound left-turn lane at Prado Road/South
Higuera Street intersection to provide for adequate queuing capacity. The City’s
Transportation Fee Program includes the widening of Prado Road Creek Bridge west of
South Higuera Street to facilitate these improvements and further improve traffic flows at
this location. Mitigation Measure TRANS-7a requires the Applicant to design and
construct a second northbound left-turn lane at this intersection, and pay a fair share
contribution to widening the Prado Road Creek Bridge. After implementation of this
mitigation, impacts at this intersection would be less than significant.
Commenter 4 – Commissioner Daniel Knight
Comment Commissioner DK-1: Many people report that they had not heard about this
meeting or even knew it had been released. At least seven people would have shown up to
speak.
Comment Response Commissioner DK-1: The City has looked into issues regarding
noticing of the Project and public hearings, and has determined that all noticing was in
compliance with state and local requirements. Please refer to Master Comment Response 1.
December 14, 2016 Planning Commission Hearing - Public Comments
Commenter 5 – Anne Wyatt
Comment AW-1: The Avila Ranch EIR is a big document and there was not enough time
to wade through it.
Comment AW-2: I am concerned about traffic and air quality and the fact that we need to
work towards the 20 percent modal split. Need more analysis to achieve this. For example,
what if we made South Higuera Street a Class IV bike facility? What about making Prado
a bike/pedestrian crossing? Need to have bike connection all the way along Buckley Road.
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Comment AW-3: Need more robust bikeway analysis to achieve modal split.
Comment Response AW-1: In response to public concerns regarding the duration and
timing of the public comment period, please refer to Master Comment Response 1.
Comment Response AW-2: For discussion of Project impacts to air quality and
transportation, refer to Section 3.3, Air Quality and Greenhouse Gas Emissions, and
Section 3.12, Transportation and Traffic. With regard to achieving LUCE goal for 20
percent modal split by bike, refer to Commenter 10, Comment Response MA-3.
Comment Response AW-3: The adequacy of bicycle facilities is addressed in Impact
TRANS-11 of Section 3.12, Transportation and Traffic.
Commenter 6 – Carolyn Smith
Comment CS-1: San Luis Ranch and Avila Ranch EIRs together is unfair to the public.
Comment CS-2: Protection of agricultural land is important. Loss of agricultural land is
bad.
Comment CS-3: I agree with the Air Quality Class I Impacts.
Comment CS-4: Some of the traffic mitigations on South Higuera Street will lead to longer
queue times.
Comment CS-5: ALUC has not approved the Project. Concerned about proximity to
runway 7-25. Could be a death sentence for the airport. Noise and complaints from
residents of Avila Ranch will shut things down.
Comment Response CS-1: Your opposition to the Project is noted. In response to public
concerns regarding the duration and timing of the public comment period, please refer to
Master Comment Response 1.
Comment Response CS-2: Project impacts to agricultural resources are discussed in
Section 3.2, Agricultural Resources.
Comment Response CS-3: Thank you, your comment has been noted.
Comment Response CS-4: Mitigation measures proposed at intersections along South
Higuera Street are proposed to reduce or address impacts resulting from development of
the Project. Any impacts which may result from implementation of these improvements
are addressed in the Transportation Impact Study provided in Appendix P.
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Final EIR
Comment Response CS-5: Refer to Master Comment Response 9 and Commenter 118,
Comment Response PK-7.
Commenter 7 – Joffre Capell, SLOCOG
Comment JC-1: How much of the Buckley Road Extension would the developer fund? Are
they relying on funds through SLOCOG?
Comment JC-2: If competing for SLOCOG funding, the Project may find that the money
just might not be there because of competition from other projects.
Comment Response JC-1: The Project Applicant plans to contribute 100 percent of the
funding for the Buckley Road Extension and the Buckley frontage improvements from
Vachell Lane to the eastern property line. This represents almost two-thirds of the total
costs estimated by SLOCOG to improve the corridor from Broad Street to Higuera Street.
By comparison, the Project’s fair share of these improvements would be 20 to 25 percent
of the cost of corridor improvements. No City or SLOCOG funds from transportation
impact fees would also be utilized.
Comment Response JC-2: The Project does not propose to fund the Buckley Road
Extension from any SLOCOG funds. Please refer to Commenter 7, Comment Response
JC-1, above.
Commenter 8 – Lea Brooks
Comment LB-1: Fill gaps in the regional bikeway network, and when will the gaps be
filled? There is no assurance to improvements east of the Project site.
Comment LB-2: Adding more turn lanes will discourage bike use. Need a different
approach to mitigation.
Comment LB-3: Need more incentives in the Project to take transit and discourage taking
cars.
Comment Response LB-1: Direct Project improvements and those required as part of
mitigation would include both on and offsite bicycle lanes, including over one mile along
Buckley Road and additional lanes on Vachell, Earthwood and Horizon Lanes, Suburban
Road and South Higuera Street. However, gaps in the regional network, such as along
Buckley Road east of the site would remain. Discussion of improvements and mitigation
measures designed to improve connectivity in the regional bicycle network within and
around the Project site is provided in Section 3.12, Transportation and Traffic. As provided
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in Impact TRANS-12 and Impact TRANS-14, the proposed Project would result in adverse
effects to the regional bicycle network surrounding the Project site. Proposed mitigation
measures and bicycle facility improvements are designed to mitigate the Project’s impacts
on regional bicycle facilities and maintain consistency with the BTP and AASP. While
gaps in the bicycle transportation network may exist outside the area impacted by the
Project, the Project cannot be required to remedy deficiencies which are not substantially
affected by the Project. The Project’s Buckley Road improvements comprise
approximately 30 percent of the total length from Higuera Street to Broad Street/SR 227.
Improvements in the bicycle transportation network east of the Project site would require
coordination and planning between the City and the County, as specified in the AASP.
Comment Response LB-2: The City strives to design turn lane modifications in a manner
that does not unduly conflict with bicycle traffic. The City uses signage, green painted
zones, and roadway/ bicycle lane restriping to ensure that turn lane additions or extensions
do not conflict with bicycle lane use.
Comment Response LB-3: The Project as well as required EIR mitigation measures
include multiple incentives and physical improvements to encourage residents to use transit
and facilitate bicycle and pedestrian circulation. The Project includes multiple Class I
bicycle paths, onroad Class II bicycle lanes, pedestrian linkages and is located in close
proximity to jobs and shopping. The Project would also facilitate extension of transit lines,
include transit stops and be required to provide shuttle service or other enhanced transit
options.
Commenter 9 – Mila Vujovich-LaBarre
Comment MVL-1: EIR can’t ignore cumulative effects, especially on Prado Road. Impacts
are illegally being piecemealed into several Project EIRs. This issue needs its own EIR.
Comment MVL-2: Avila Ranch is not affordable housing.
Comment MVL-3: Lower income housing nearest runway will generate complaints that
could jeopardize airports.
Comment MVL-4: Water availability. Concerned that we don’t have enough.
Comment MVL-5: School availability. Loss of Diablo will reduce revenue leading to cuts.
Where will Avila kids go to school.
Comment MVL-6: Protect agricultural land.
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Comment MVL-7: Project does not propose enough parking.
Comment MVL-8: Additional bicycle lanes are needed.
Comment MVL-9: Project should use solar and sustainable materials.
Comment Response MVL-1: The EIR provides a complete discussion of the cumulative
impacts of pending development projects, with substantial modeling, analysis and
discussion of cumulative impacts to local roads and intersections, including Prado Road,
in Section 3.12, Transportation and Traffic.
Comment Response MVL-2: Refer to Master Comment Response 5.
Comment Response MVL-3: Refer to Master Comment Response 6.
Comment Response MVL-4: Detailed discussion of availability of City water supplies,
Project water demand, and impacts associated with implementation of the Project on these
water supplies is provided in Section 3.13, Utilities. Refer to Impact UT-2 and Master
Comment Response 7. The EIR and the Water Supply Assessment prepared for the Project
concluded that adequate water supplies are available for the Project currently and at full
buildout of the LUCE.
Comment Response MVL-5: The EIR has been updated to discuss the pending closure of
Diablo Canyon and its relationship to school operations. Impacts and discussion relating to
public school services are provided in Section 3.11, Public Services. Please also refer to
Master Comment Response 11.
Comment Response MVL-6: Refer to Master Comment Response 2 and Section 3.2,
Agricultural Resources, for discussion of impacts to agricultural lands and mitigation
measures design to reduce Project impacts to these resources.
Comment Response MVL-7: As discussed in Section 2.6.5.4 of Section 2.0, Project
Description, the Project would provide a minimum of 820 parking spaces for the 398 R-1
and R-2 units and would provide adequate parking to meet the parking requirements
provided in the City Zoning Ordinance for R-3 and R-4 units. Further, Section 3.0 of the
Avila Ranch Development Plan (Appendix D) provides detailed discussion of parking
requirements and parking designs.
Comment Response MVL-8: The adequacy of bicycle facilities is addressed in Impact
TRANS-11 of Section 3.12, Transportation and Traffic.
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Comment Response MVL-9: As analyzed in this EIR, the proposed Project would include
solar photovoltaic cells on at least 50 percent of the units, as well as use of recycled water.
For a complete discussion of Project design with regard to sustainable practices, refer to
Section 2.6.4 of Section 2.0, Project Description.
Commenter 10 – Myron Amerine
Comment MA-1: Need full Class II bike lanes the full length of Buckley from 227 to
Higuera.
Comment MA-2: Suburban to Earthwood bike lane needs to be in there.
Comment MA-3: Needs to meet LUCE goal of 20 percent bike mode share.
Comment MA-4: Safe routes to school. Need connectivity to schools from the Project.
Comment MA-5: City and County need to work together to complete Buckley Road.
Comment MA-6: Project needs to provide better offsite connectivity for bikes and ADA to
other parts of the town. Buckley is key.
Comment Response MA-1: Refer to Commenter 8, Comment Response LB-1.
Comment Response MA-2: Mitigation Measure TRANS-4 requires the Applicant to
coordinate with property owners along Suburban Road and City staff to prepare a detailed
improvement plan for Suburban Road. This plan shall address widening of substandard
sections of the roadway, completion of missing sidewalks, installation of street trees,
pedestrian crossings, and other improvements which would include bicycle facilities.
Coordination between property owners, the Applicant, and City staff shall determine the
necessity and feasibility of bicycle improvements along this road segment.
Comment Response MA-3: It is an objective of the City to meet a goal of 20 percent of
resident trips are meet through bicycle transportation. As discussed in Section 2.0, Project
Description, and Section 3.12, Transportation and Traffic, the Project includes features
and mitigation measures designed to encourage residents to travel by bicycle or other
alternative modes of transportation. The Project and required mitigation measures would
include development of a substantial network of on and offsite bicycle facilities to facilitate
bicycle mobility for future residents.
Comment Response MA-4: The Project and required mitigation measures would include
development of a substantial network of on and offsite bicycle facilities which would
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improve safety along routes to schools However, gaps would remain that will be addressed
through the implementation of the capital improvement programs for the City and the
County and the implementation of AASP policies 6.3.8 and 6.3.10, and implementation of
the Circulation Element and BTP. Please refer also to Commenter 43, Comment Response
LB1-6.
Comment Response MA-5: Thank you, your comment has been noted.
Comment Response MA-6: Mitigation measures proposed in Section 3.12,
Transportation and Traffic, are found to be sufficient to reduce the Project’s anticipated
impacts on bicycle and pedestrian facilities. However, gaps would remain that would
require action by the City or County to address. Please refer also to Commenter 43,
Comment Response LB1-6.
Commenter 11 – Paul Rys
Comment PR-1: Public needs to communicate more times before we get to the FEIR. Not
enough opportunities to discuss. Another hearing should be held.
Comment PR-2: Sewer capacity in SLO is exceeded every time it rains.
Comment PR-3: City manager said we need to engage in community to build trust and
confidence. The EIR consultants are working for the City; who is working for the rest of
us?
Comment PR-4: A lot of people mistrust this Project and are threatening a law suit.
Comment PR-5: Many people couldn’t be here tonight or were not noticed. The Project
needs more outreach.
Comment Response PR-1: Your opposition to the Project is noted. In response to public
concerns regarding the duration and timing of the public comment period, please refer to
Master Comment Response 1.
Comment Response PR-2: Refer to Section 3.13, Utilities, for discussion of existing
wastewater infrastructure operations and operations, and Project impacts to this system.
Comment Response PR-3: Thank you, your comment has been noted.
Comment Response PR-4: Thank you, your comment has been noted.
Comment Response PR-5: Refer to Master Comment Response 1.
8.0 RESPONSE TO COMMENTS
8-30 Avila Ranch Development Project
Final EIR
Commenter 12 – Rochelle Reed-Smith
Comment RRS-1: Speed limit on Buckley is 40, not 55. Correct this.
Comment RRS-2: Need to address Ventura/Vachell intersection since this is a key access
to town.
Comment RRS-3: Anaerobic waste facility will add 38 ADT of large greenwaste trucks into
Buckley. Dangerous on such a narrow road.
Comment RRS-4: Need to extend Buckley in Phase 1 not 2.
Comment Response RRS-1: The posted speed for Buckley Road is 55 mph. Appropriate
sections of the text have been revised, but this change does not affect the analysis or
mitigation included in the document. Note that the Project proposes Class II bicycle lanes
along the Buckley Road frontage. See Section 2.6.5, Circulation and Figure 2-5. Impacts
to cyclists and the bicycle network are addressed in Impact TRANS-11, Section 3.12,
Transportation and Traffic and were found to be less than significant after the
implementation of mitigation measures.
Comment Response RRS-2: Project impacts to Venture Drive/Vachell Lane intersection
are discussed in detail in Section 3.12, Transportation and Traffic, and the Transportation
Impact Study prepared for this EIR (Appendix P).
Comment Response RRS-3: Refer to Commenter 1, Comment Response RM-4 from the
December 14th Planning Commission Hearing.
Comment Response RRS-4: The Transportation Impact Study prepared for the Project
concluded that all intersections would operate at an acceptable LOS without the Buckley
Road Extension through Phase 1 of the Project (EIR Page 3.12-44), and therefore it was
concluded that the Buckley Road Extension did not need to be implementation before
Phase 2 of the Project. .
Commenter 13 – Sarah Flickinger
Comment SF-1: Onsite percolation acreage. Do we have enough to allow recharge when
flood plain is reduced?
Comment SF-2: Why was Los Verdes Drive/LOVR not included in the analysis? There’s
an impact there.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-31
Final EIR
Comment SF-3: Suburban and Higuera at the corner of LOVR. There are homes there near
these intersections that will be subject to noise, air quality, and light from new traffic. These
issues need to be addressed.
Comment Response SF-1: The proposed Project would include use of Low Impact
Development standards, including water retention and groundwater recharge facilities.
When combined with a substantial decrease in long term extraction from the onsite water
well, the Project may improve water balance in the groundwater basin. For discussion of
groundwater recharge and onsite percolation, refer to Section 3.7, Hydrology and Water
Quality. As discussed in this section, implementation of the Project would result in the
development of additional impermeable surfaces which could adversely affect
groundwater recharge and onsite drainage patterns. However, development of new
impervious surfaces would only incrementally affect groundwater recharge (see Impact
HYD-6). Further, mitigation proposed in Section 3.7, Hydrology and Water Quality, would
ensure that Project impacts related to groundwater recharge, percolation, flooding, and
runoff would be reduced to a less than significant level.
Comment Response SF-2: The Project analyzed the intersections that would be affected
from increased traffic originating from the Project site. The Los Verdes Drive/LOVR is
addressed as part of the discussion of impacts along LOVR from South Higuera Street to
the U.S. Highway 101 interchange as operation of this private driveway is governed by
through volumes along LOVR. Please refer to Section 3.12, Transportation and Traffic.
Comment Response SF-3: Please refer to Commenter 45, Comment Response SF-13.
January 11, 2017 Planning Commission Hearing – Commissioner Comments
Commenter 14 – Commissioner Ronald Malak
Comment Commissioner RM-1: Are Uber and self-driving cars part of the analysis?
Comment Commissioner RM-2: Are we using VMT or LOS? Not supposed to use LOS,
right?
Comment Commissioner RM-3: Noise, odor, and air quality impacts on Suburban Road?
Comment Commissioner RM-4: Solar and EV on homes is good.
Comment Commissioner RM-5: How significant are air quality impacts going to be?
8.0 RESPONSE TO COMMENTS
8-32 Avila Ranch Development Project
Final EIR
Comment Commissioner RM-6: Alternatives – why did we do an alternative at 360 units
not 500 when it would be inconsistent with the LUCE. Why not look at a 500-unit
alternative and compare to the 720-unit Project?
Comment Response Commissioner RM-1: As discussed in the January 11th hearing, the
multi-modal analysis partially accounts for these trips.
Comment Response Commissioner RM-2: Pursuant to SB 743 and the requirement for
discussion of vehicle miles traveled (VMT) analysis, the EIR provides detailed discussion
of the Project's estimated VMT in Section 3.12.4.2 of Section 3.12, Transportation and
Traffic, in which the Project would contribute an additional 65,000 daily VMT, or
approximately 72 VMT per household. Further, consistent with the requirements in the
City's Transportation Impact Study guidelines, Appendix P provides discussion and
analysis of Project VMT starting on page 67 of the Transportation Impact Study.
Comment Response Commissioner RM-3: While the EIR identifies significant but
mitigable impacts to traffic along Suburban Road, resulting from increase in up to 1,594
ADT, the Project is not anticipated to exceed any thresholds related to noise, light, or air
quality specific to this road segment. While new traffic utilizing this roadway would be the
primary source of noise, light, and air emissions at Suburban Road, it is anticipated
secondary effects from increased traffic would only incrementally affect primarily
commercial land uses located along this roadway. However, a brief discussion of these
secondary effects has been added to the EIR.
Comment Response Commissioner RM-4: Thank you, your comment has been noted.
Comment Response Commissioner RM-5: Air pollutant emissions and quality impacts
will exceed adopted thresholds, even after mitigation. For discussion of impacts to air
quality, refer to Section 3.3, Air Quality and Greenhouse Gas Emissions.
Comment Response Commissioner RM-6: The EIR has been amended to include a 500-
unit alternative, within the considered and discarded analysis. This discussion provides
details on consistency of such an alternative with LUCE goals, Project objectives and
effectiveness in reducing environmental impacts. Please also refer to Master Comment
Response 4.
Commenter 15 – Commissioner Hemalata Dandekar
Comment Commissioner HD-1: Explain what the timeline is for restriping lanes as part of
mitigation.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-33
Final EIR
Comment Commissioner HD-2: Don’t think we thought through the need for housing vs.
traffic in the LUCE deliberations. LUCE is not sacrosanct.
Comment Response Commissioner HD-1: In general, such improvements are linked to
Project phases when such impacts would occur. For discussion of the timing of restriping
as part of mitigation to address traffic impacts, refer to Section 3.12, Transportation and
Traffic.
Comment Response Commissioner HD-2: The Project is required to comply with the
General Plan and development regulations in effect at the time that the application is
accepted as complete. A conformity analysis is included in Section 3.8, Land Use of the
EIR, Section 3.8.4 that analyzes the Project’s consistency with key Circulation Element
policies.
Commenter 16 – Commissioner Chuck Stevenson
Comment Commissioner CS-1: Consider a second right-turn lane from South Higuera to
South Street, since it is dangerous transition from Madonna. When are the long-term traffic
mitigation measures going to happen? Are there interim improvements possible to allow
for a second right turn?
Comment Commissioner CS-2: Explain the Project’s impact to Buckley/227.
Comment Response Commissioner CS-1: The suggested improvement has been
considered. However, a second right-turn lane from South Higuera Street to South Street
is not necessary for the level of impact associated with the Project or for the full buildout
of the General Plan.
Comment Response Commissioner CS-2: Please refer to Impact TRANS-5 in Section
3.12, Transportation and Traffic and Master Comment Response 8 regarding impacts to
Buckley Road/SR 227.
Commenter 17 – Commissioner Daniel Knight
Comment Commissioner DK-1: Impacts from the Project on Buckley to the east are not
that big, however traffic on Buckley is bad right now.
Comment Response Commissioner DK-1: Refer to Master Response 8 regarding the
Project’s impact on Buckley Road.
8.0 RESPONSE TO COMMENTS
8-34 Avila Ranch Development Project
Final EIR
Commenter 18 – Commissioner Kim Bisheff
Comment Commissioner KB-1: Explain trip generation and reduction methodology.
Comment Response Commissioner KB-1: An explanation of trip generation and
reduction methodology is provided in the TIS included in Appendix P of this EIR.
January 11, 2017 Planning Commission Hearing – Public Comments
Commenter 19 – Camille Small
Comment CS-1: Did the development come with 300 homes, but the City wanted more?
Comment CS-2: Streets will be too dangerous for bikes—so don’t plan for them.
Comment CS-3: We need housing!
Comment CS-4: City is trying to make money on this. City staff is developing this plan that
doesn’t respect the values of the people who live here.
Comment CS-5: Need more affordable student housing and this isn’t it.
Comment Response CS-1: Thank you and we appreciate your comments on the EIR.
However, this comment does not pertain to any inadequacies within the EIR and is not a
CEQA-related concern.
Comment Response CS-2: The EIR addresses impacts to bicycle facilities and provides
mitigation measures where the Project would result in adversely significant impacts on the
connection, access, and safety of these facilities. Detailed discussion of impacts to bicycle
facilities and mitigation measures designed to address these impacts are provided in
Section 3.12, Transportation and Traffic, Impact TRANS-11.
Comment Response CS-3: Thank you, your comment has been noted.
Comment Response CS-4: Your comments are noted.
Comment Response CS-5: Refer to Master Comment Response 5 regarding your
comment on affordable housing.
Commenter 20 – Darrell Goo
Comment DG-1: Traffic is bad around Los Verdes Parks.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-35
Final EIR
Comment DG-2: Agree that the LOVR bypass from Buckley extension would solve traffic
problems. The cost of this improvement should be shared.
Comment DG-3: Need multimodal traffic.
Comment Response DG-1: The EIR recognizes and discusses existing traffic conditions
along South Higuera Street and LOVR within the vicinity of the Los Verdes neighborhoods
(see Section 3.12.2.3 in Section 3.12, Transportation and Traffic). Due to the critical access
to U.S. Highway 101 provided at LOVR, it is anticipated that a considerable portion of
Project-related traffic would utilize intersections and road segments within this area, and
contribute towards greater traffic congestion and queue at these facilities (see Impact
TRANS-8). To address impacts resulting from implementation of the Project at these
intersections and road segments, the EIR proposes several mitigation measures which
include payment of fair share fees and intersection improvements. With implementation of
these mitigation measures, existing deficient roadway and intersection operations along
LOVR would be improved to a sufficient level, even with additional trips generated by the
Project, and impacts would be reduced to a less than significant level.
Comment Response DG-2: Thank you, your comment has been noted.
Comment Response DG-3: The Project proposes improvements to and provision of multi-
modal facilities with the goal of reducing Project vehicle dependency and achieving the
modal split objectives of the LUCE. See Section 3.8, Land Use, and Section 3.12,
Transportation and Traffic.
Commenter 21 – James Lopes
Comment JL-1: The Project is overbuilt for infrastructure and setting.
Comment JL-2: There are too many Class I impacts. The Project is out of scale and not
appropriate. The City should come up with a new mitigated project that is consistent with
the General Plan. This new project should avoid all Class I impacts.
Comment Response JL-1: The EIR provides a detailed analysis of Project infrastructure
requirements and where needed provides mitigation measures to ensure the adequacy of
required infrastructure. The Project is consistent with the LUCE designations and goals for
the site and such levels of development have been anticipated for this setting by the City.
Comment Response JL-2: City decision-makers will consider this EIR and associated
Class I (“significant and unavoidable”) impacts during review of the Project. City decision-
8.0 RESPONSE TO COMMENTS
8-36 Avila Ranch Development Project
Final EIR
makers will balance potential impacts with Project benefits (e.g., new housing, habitat
restoration) and be required to issue findings and overriding considerations that justify
approval of the Project given Project impacts. In addition, the EIR, in Section 5.0,
Alternatives, considers and analyzes a Mitigated Project Alternative (MPA), which would
include redesign of key Project elements intended to reduce environmental impacts
identified in the EIR for the proposed Project. For instance, features of the Project would
be redesigned with a key focus on achieving greater consistency with the City General Plan
and ALUP than the proposed Project. While the MPA would result in substantially less
severe impacts, the MPA would not reduce all impacts to a less than significant level, and
several Class I impacts would occur to agricultural resources, air quality and greenhouse
gas emissions, noise, and transportation. However, due to the less severe impact of this
Project on the environment, and the greater consistency with the City General Plan and
ALUP, the MPA was identified as the environmentally superior alternative. However, it is
the discretion of City decision makers to approve or deny the Project or any of its
alternatives. For further discussion of the MPA and other alternatives considered in this
analysis, refer to Section 5.0, Alternatives.
Commenter 22 – James Waldsmith
Comment JW-1: What about impacts to agricultural pursuits south of Buckley Road?
Comment JW-2: Traffic along Buckley Road is dangerous.
Comment Response JW-1: As discussed under Impact AG-2 in Section 3.2, Agricultural
Resources, the proposed Project would result in potential conflicts in land use compatibility
with agricultural lands south of Buckley Road, leading to potential indirect or secondary
impacts. Conflicts with these agricultural parcels would be partially remedied through
Project design features, particularly through the development of the 300-foot wide open
space buffer located along the southern boundary of the site. In addition, mitigation
measures AG-2a and AG-2b are provided to mitigate these impacts to a less than significant
level, and would include measures to address and reduce conflicts with adjacent
agricultural lands. Refer to Impact AG-2.
Comment Response JW-2: Please refer to Master Comment Response 8.
Commenter 23 – Karen Aydelott
Comment KA-1: Air pollution generated that exceeds more than the Climate Action Plan
of 2001.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-37
Final EIR
Comment KA-2: Biological impacts degrade public health.
Comment KA-3: Traffic will exceed GP thresholds and the Project is located in an area far
from services and schools. This leads to air quality issues, accidents, and stress related
disorders.
Comment KA-4: Project does not meet City infill standards.
Comment Response KA-1: The EIR discloses potential impacts resulting from
construction and operational air pollutant emissions, and the Project consistency with the
City’s Climate Action Plan under Impact AQ-4 in Section 3.3, Air Quality and Greenhouse
Gas Emissions. As provided in this impact discussion, while the Project would exceed
established SLO APCD air quality thresholds, the Project is considered consistent with the
goals and policies of the Climate Action Plan after considering the implementation of
Project design features and environmental impact mitigation measures oriented towards
reducing construction and transportation related air emissions.
Comment Response KA-2: Thank you and we appreciate your comments on the EIR.
Although the Project could impact biological resources, such impacts would be fully
mitigated. In addition, the Project, along with required mitigation measures, would restore
and enhance habitats along Tank Farm Creek, several segments of which are currently
degraded. Future residents and the public would be able to experience these restored
habitats through several miles of off-road multiple use trails that extend through these
planned open space areas. These trails would be attractive for walking, jogging and bike
riding, activities which could potentially benefit public health.
Comment Response KA-3: Project generated traffic would exceed General Plan standards
at several locations, almost all of which can be mitigated. In addition, it should be noted
that much of the site is within a 0.25-mile walk or bicycle ride of a large neighborhood
shopping center that includes a market, restaurants and various retail shops and services.
The Project would include design features and mitigation measures designed to reduce the
Projects impact on local roadways, intersections, and the regional transportation network
to a less than significant level. These design features and mitigation measures would
include intersection improvements, improvements to pedestrian facilities, development of
bicycle facilities which connect the regional bicycle transportation network within the area,
and other measures designed to reduce the Project’s impact on the pedestrian, bicycle, and
vehicle network. Refer to Section 3.12, Transportation and Traffic. With regard to access
to schools, while it is acknowledged that the Project is not located within easy walking
8.0 RESPONSE TO COMMENTS
8-38 Avila Ranch Development Project
Final EIR
distance of schools and the regional bicycle path systems requires improvements to
promote safe cycling. However, the Project is located within an approximate 2.5-mile
radius or a 5 to 10 minute drive of several K-12 grade schools (see Section 3.11, Public
Services). The school district has confirmed (email from Ryan Pinkerton, Asst.
Superintendent) that bus service will be provided to the site for elementary school and
middle school students. Mitigation measures designed to reduce the Project’s impact on
regional transportation systems would have the effect of improving operations of several
roadways and intersections utilized to access local services. Further, the Project would
include multiple design features that would promote regional access to and from the site,
including multimodal opportunities, and connections to the bicycle and transit network.
Comment Response KA-4: The Project is consistent with LUCE goals and policies after
mitigation and this level of development was specifically planned for the uses proposed
under the LUCE.
Commenter 24 – Karen Krahl
Comment KK-1: Pulling horse trailers onto Buckley Road is dangerous, and Project traffic
will make this worse.
Comment KK-2: Vehicles can’t get onto Hidden Springs easily from Buckley Road because
of traffic.
Comment KK-3: The Project will affect the rural way of life.
Comment KK-4: Air quality impacts will affect people with breathing and health problems.
Comment KK-5: Need traffic infrastructure in place before development.
Comment KK-6: The Project is not keeping with the City General Plan.
Comment Response KK-1: Please refer to Master Comment Response 8.
Comment Response KK-2: Please refer to Master Comment Response 8.
Comment Response KK-3: While the Project would result in effects to the visual
character, residential density, roadway operations, etc. on the surrounding local rural areas,
the EIR identifies design features and mitigation measures which would reduce the Project
effects on the physical environmental characteristics of local rural life. For instance, the
Project would develop residential, retail, and commercial uses in closer proximity to and
oriented towards the existing commercial and industrial development in the southern areas
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-39
Final EIR
of the City, and retain a substantial open-space buffer between new development and
existing rural residential and agricultural parcels located to the south and east. Therefore,
with implementation of these features and the mitigation measures provided in this EIR,
the Project is not anticipated to substantially affect the quality and life of nearby rural areas.
Refer to Section 2.0, Project Description, Section 3.1, Aesthetics and Scenic Resources,
Section 3.2, Agricultural Resources, Section 3.8, Land Use and Planning, Section 3.9,
Noise, and Section 3.12, Transportation and Traffic.
Comment Response KK-4: As discussed under Impact AQ-3, impacts to human health
may result from the emission of diesel particulate matter (DPM) and other toxic air
contaminants (TACs) during construction of operation of the Project. In the event that a
Project would exceed SLO APCD’s thresholds of significance for DPM emissions, as
described in Section 3.3.4.1, the Project may be required to prepare a Health Risk
Assessment to identify the Project’s risk to nearby sensitive receptors. The EIR identifies
potential impacts related to the emission of known toxic air contaminants, and the exposure
to nearby sensitive receptors under Impact AQ-3. As discussed under this impact, the
Project would comprise residential and local-serving retail and office uses which are not
considered uses that would generate a substantial amount of known TACs, and would not
pose a risk to sensitive receptors, or affect the health of individuals within or outside the
Project vicinity. Impacts are considered less than significant in this regard. Refer to Impact
AQ-3 in Section 3.3, Air Quality and Greenhouse Gas Emissions.
Comment Response KK-5: Cumulative land use and roadway network improvements
were evaluated consistent with the City's Land Use and Circulation Elements, based on
existing conditions known at the time of release of the Notice of Preparation. Traffic
mitigations that are required for full buildout of the Project (720 homes and 15,000 square
feet of commercial) are to be implemented in Phases 1, 2, and 4 of the Project, well ahead
of the actual impact from the Project. The EIR concluded that the implementation of the
Project in the short term (Phase 1) would not adversely impact any intersections or road
segments in the community.
Comment Response KK-6: The Project is required to comply with the General Plan and
development regulations in effect at the time that the application is accepted as complete.
A conformity analysis is included in Section 3.8, Land Use and Planning of the EIR,
Section 3.8.4 that analyzes the Project’s consistency with key General Plan policies.
8.0 RESPONSE TO COMMENTS
8-40 Avila Ranch Development Project
Final EIR
Commenter 25 – Kathy Borland
Comment KB-1: The comment period for this Project should be longer.
Comment KB-2: All county residents beyond the site take Buckley. This is going to make
things worse on 227. There is no mitigation to address impacts along Vachell.
Comment KB-3: How can you approve this Project with so many Class I impacts?
Comment KB-4: 720 homes is way too large.
Comment Response KB-1: Refer to Master Comment Response 1.
Comment Response KB-2: With regard to impacts along SR 227, Section 3.12,
Transportation and Traffic and the Transportation Impact Study provided in Appendix P
anticipate that Project increase traffic along SR 227 by approximately 118 daily trips. See
also Master Comment Response 8.
Comment Response KB-3: This comment is best addressed towards City decision makers
and does not pertain to any deficiencies in the EIR or CEQA-related matters.
Comment Response KB-4: Thank you and we appreciate your comments on the EIR.
Comments on overall Project size or design are best directed to City decision-makers.
Commenter 26 – Kayla Plourde
Comment KP-1: The intersection of Buckley Road/227 is often backed up.
Comment KP-2: Need more safety and traffic controls on the many small intersections on
Buckley.
Comment KP-3: Need to take care of the needs of the rural people who live south of
Buckley.
Comment Response KP-1: Please refer to Impact TRANS-5 within Section 3.12,
Transportation and Traffic and Master Comment Response 8.
Comment Response KP-2: Please refer to Master Comment Response 8.
Comment Response KP-3: Please refer to Master Comment Response 8.
Commenter 27 – Lea Brooks
Comment LB-1: How are bikes supposed to get to Tank Farm Road?
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-41
Final EIR
Comment LB-2: Aren’t Class II bike lanes on Buckley required?
Comment LB-3: Why is right-of-way for bikeways not required?
Comment Response LB-1: A detailed discussion of the existing and proposed bicycle
network is provided in Section 3.12, Transportation and Traffic. Bicyclists are expected to
reach Tank Farm Road by taking Short Street, Cross Street, and Long Street from Suburban
Road.
Comment Response LB-2: A future Class II bicycle lane was identified in the City’s
Bicycle Transportation Plan (BTP) along Buckley Road, however, the Project currently
proposes a Class I bicycle path and Class II bicycle lanes along this segment of Buckley
Road extending from the Project site’s eastern boundary to Vachell Lane. The south side
of Buckley Road between Vachell Lane and the east Project boundary will include Class
II bicycle lanes as well as a bicycle bridge on the south side of the Tank Farm
Creek/Buckley Road bridge (see Figure 3.12-7 within Section 3.12, Transportation and
Traffic). The Buckley Road Extension will have Class II bicycle lanes in the east and west
directions, as well as a Class I bicycle path. As discussed in detail under Impact TRANS-
11 of Section 3.12, Transportation and Traffic, alignment of a Class II bicycle lane within
the Buckley Road right-of-way (ROW) presents unique challenges to the feasibility and
design of this bicycle network segment. For instance, development of a Class II bicycle
facilities along this stretch would necessitate widening of the Tank Farm Creek Bridge and
widening the Buckley Road ROW by 30 to 45 feet to the north, into Tank Farm Creek to
comply with roadway and Class II bicycle lane design standards to provide adequate space
for the safe and effective movement of vehicles and bicycle across this bridge crossing.
Widening of this crossing would require collaboration between multiple agencies,
substantial additional funding and ROW acquisition, federal permitting for biological and
creek impacts, and could have the potential effect of resulting in substantial impacts to the
water quality, hydrology, species, and habitat of Tank Farm Creek and adjacent features.
Therefore, the EIR finds that the most feasible approach to supporting connection in the
regional transportation network along this segment is to provide a Class I bicycle path
within the proposed open space buffer area of the Project site (see Figure 2-2). Impact
TRANS-11 of the EIR identifies that while this is the most feasible approach, this feature
of the Project would be inconsistent with the AASP and BTP. However, the EIR provides
Mitigation Measure TRANS-11, requiring construction of single bridges for bicycles
instead of roadway widening, which would ensure consistency with the BTP and AASP.
8.0 RESPONSE TO COMMENTS
8-42 Avila Ranch Development Project
Final EIR
Comment Response LB-3: Project features and mitigation measures relating to
improvements to bicycle facilities would require the provision of ROW for these facilities.
Several of these improvements would be located within roadway ROW, such as
improvements along Vachell Lane and South Higuera Street, while other improvements
would require dedication of bicycle lane ROW separate from existing roadway ROW.
Refer to Section 3.12, Transportation and Traffic for discussion of these improvements
and design requirements.
Commenter 28 – Mila Vujovich-LaBarre
Comment MVL-1: Agree with the Class I impacts identified in the EIR.
Comment MVL-2: Omitted Chevron improvements will make it even worse.
Comment MVL-3: Need an EIR for Prado Road from Madonna to Broad Street.
Comment MVL-4: I don’t think the housing will be affordable.
Comment MVL-5: Complaints from residents will hurt the airport.
Comment MVL-6: Airport overflights have not been mitigated.
Comment MVL-7: Not enough water for this Project. EIR doesn’t address this.
Comment MVL-8: School impacts will happen because of lack of funding and development
will make it worse.
Comment MVL-9: No logical bike or pedestrian plan to go into the next decade.
Comment Response MVL-1: Thank you, your comment has been noted.
Comment Response MVL-2: As part of the cumulative analysis, the EIR identifies and
considers the Project’s impacts with relation to recently approved or pending projects within
the City. This list of cumulative projects considered in the EIR analysis is provided in Table
3.0-1 of Section 3.0, Environmental Impact Analysis and Mitigation Measures, and includes
the Chevron Tank Farm Remediation and Development Project that was approved by the
City in 2013. As such, cumulative Project impact discussions include consideration of this
project. With regard to the Chevron Tank Farm Remediation and Development Project, while
the application has not yet been withdrawn, no activity has occurred ion over a year and its
appears that Chevron may instead request implementation of a gradual remediation plan over
a ten year period. Refer to Master Comment Response 3.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-43
Final EIR
Comment Response MVL-3: This comment does not relate to the Avila Ranch
Development Project EIR.
Comment Response MVL-4: Thank you and we appreciate your comments on the EIR.
Planned affordable housing will be subject to City regulatory requirements regarding sales
or rental prices as well as monitoring by City staff. See Master Comment Response 5.
Comment Response MVL-5: Refer to Master Comment Response 9.
Comment Response MVL-6: Airport safety and noise have been fully considered in the
EIR and the Project has been determined by the ALUC to comply with the adopted ALUP.
See Master Comment Responses 6 and 9.Comment Response MVL-7: Refer to Master
Comment Response 7.
Comment Response MVL-8: Refer to Master Comment Response 11.
Comment Response MVL-9: Direct Project improvements and those required as part of
mitigation would include both on and offsite bicycle lanes and pedestrian facilities.
Discussion of improvements and mitigation measures designed to improve connectivity in
the regional bicycle network within and around the Project site is provided in Section 3.12,
Transportation and Traffic. Proposed mitigation measures and bicycle facility
improvements are designed to mitigate the Project’s impacts on regional bicycle facilities
and maintain consistency with the BTP and AASP.
Commenter 29 – Myron Amerine
Comment MA-1: Don’t have adequate bike access and safety on Higuera Street with all
these new multiple right turn lanes on Higuera.
Comment MA-2: Why is it all about vehicles? Remove a lot of overkill parking
requirements.
Comment Response MA-1: As part of the requirement of transportation mitigation
measures requiring restriping of several intersections along South Higuera Street to provide
additional turn lanes, plans for these improvements would be reviewed and approved by
City staff to ensure compliance with City design standards and compatibility with existing
facilities. Such requirements would ensure that these improvements would not adversely
affect bicycle travel, access, or safety at existing Class II bicycle lanes along South Higuera
Street. Refer Mitigation Measures TRANS-6, TRANS-7a, and TRANS-7b in Section 3.12,
Transportation and Traffic.
8.0 RESPONSE TO COMMENTS
8-44 Avila Ranch Development Project
Final EIR
Comment Response MA-2: To remain consistent with City development standards and
regulations (Chapter 17.16 of the City Municipal Code), parking facilities for the Project
have been designed and provided in accordance with these standards. However, the Project
includes additional features and improvements that promote multimodal transportation
(walking, bicycle, transit) opportunities for future employees, residents, and visitors
oriented towards reducing the reliance on personal vehicles.
Commenter 30 – Pamela Krahl
Comment PK-1: The EIR violates the County’s General Plan and the City General Plan
policies related to agricultural resources, traffic, air quality, and safety.
Comment PK-2: The Project is not compatible with the airport.
Comment PK-3: Significant airplane noise will affect proposed residential uses.
Comment PK-4: Traffic needs to consider multiple smaller peaks, not just AM and PM
peak hours.
Comment PK-5: Traffic at the Buckley/227 intersection is a nightmare.
Comment Response PK-1: The EIR assesses impacts related to inconsistency with relevant
plans and policies, including the City General Plan, relevant portions of the County’s General
Plan, the ALUP, and AASP. As the Project is located within the limits of the City, the Project
is subject to the jurisdiction of the City and relevant City rules and regulations, which does
not include the County General Plan. In order to assess impacts related to potential
inconsistency with relevant land use planning documents, the EIR provides a detailed
consistency analysis in Section 3.8, Land Use and Planning. As provided in this section and
discussed in Table 3.8-7, Table 3.8-8, and Table 3.8-9, the Project was found to be consistent
with the goals and policies of the City General Plan, ALUP, and AASP, including those
related to agricultural resources, traffic, air quality, safety, parks and open space, land use,
utilities, etc. See also Master Comment Response 2.
Comment Response PK-2: Refer to Master Comment Response 10.
Comment Response PK-3: The EIR identifies potential impacts relating to development
of residential units within close proximity to the airport, where the Project may expose
future residents to unacceptable noise levels. As discussed under Impact NO-4 in Section
3.9, Noise, the Project would development residential uses within the 50 dB CNEL airport
noise contour area. Within this area, the ALUP allows residential, commercial, park, and
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-45
Final EIR
open space uses. Further, the proposed Project would not development residential units
within the 55 dB or 65 dB CNEL contour zones (see Figure 3.9-2). Instead, the Project
would develop open space land uses within these zones, consistent with ALUP allowable
uses within these airport noise contours. See also Master Comment Response 9.
Comment Response PK-4: The EIR evaluates traffic flows and congestion during the AM
and PM peaks hours as that is when roads and intersections are potentially most congested.
Although there may be other peaks that occur (e.g., construction trade traffic, school
traffic), these peak hours represent the time when potential Project traffic impacts may be
at their greatest. Therefore, any impacts that occur during other lesser peaks would be less
substantial and are addressed in the analysis of the primary peak hours.
Comment Response PK-5: Refer to Impact TRANS-5 within Section 3.12,
Transportation and Traffic and Master Comment Response 8.
Commenter 31 – Paul Rys
Comment PR-1: The Project should avoid Class I impacts.
Comment PR-2: South county residents will use Buckley to shortcut to the other side of
SLO based on GPS units saying the Broad or Higuera are gummed up.
Comment PR-3: Other roads that access Buckley will become more dangerous.
Comment PR-4: The Project would result in the affects to the quality of life from the loss
of agricultural land. The City General Plan says to keep this area as agricultural land.
Comment PR-5: Don’t be fooled by “it’s zoned BP now”.
Comment PR-6: Don’t just go by what the law says, go by what you see.
Comment Response PR-1: The EIR identifies impacts of the Project and determines the
significance of the impact based on exceedances of established thresholds. Given the
significant impacts identified within the EIR, the City would therefore be required to adopt
a Statement of Overriding Considerations to weigh the Project’s impacts against the
Project’s benefits. Per CEQA Section 15093, “If the specific economic, legal, social,
technological, or other benefits, including region-wide or statewide environmental
benefits, of a proposed project outweigh the unavoidable adverse environmental effects,
the adverse environmental effects may be considered ‘acceptable.’” City Council would
evaluate the Project’s significant Class I impacts against the Project’s merits and make the
final determination.
8.0 RESPONSE TO COMMENTS
8-46 Avila Ranch Development Project
Final EIR
Comment Response PR-2: Please refer to Master Comment Response 8.
Comment Response PR-3: Please refer to Master Comment Response 8.
Comment Response PR-4: Refer to Master Comment Response 2.
Comment Response PR-5: Thank you and we appreciate your comment. However, this
comment does not pertain to any inadequacies within the EIR and is not a CEQA-related
concern.
Comment Response PR-6: Thank you and your comments are noted.
Commenter 32 – Rochelle Reed Smith
Comment RRS-1: Traffic on Buckley is loaded with big trucks and farm machinery. Need
to account for that.
Comment Response RRS-1: Please refer to Master Comment Response 8.
Commenter 33 – Sarah Flickinger
Comment SF-1: More traffic on Suburban will affect traffic, air quality and noise to homes
on the west side of S. Higuera at the end of Suburban.
Comment SF-2: Can’t assume a turn lane on LOVR is possible.
Comment SF-3: Traffic is very difficult around Los Verdes, and mitigation is not adequate.
Comment Response SF-1: Refer to Commenter 13, Comment Response SF-2.
Comment Response SF-2: There is no evidence to suggest that the turn lane at LOVR is
infeasible.
Comment Response SF-3: Your comment has been noted. Additional discussion has been
included under Impact TRANS-8 in Section 3.12, Transportation and Traffic.
Commenter 34 – Stanley Yucikas
Comment SY-1: Don’t give any more agricultural land for development that does not
promote infill.
Comment Response SY-1: Thank you, the City decision makers will consider your
comment.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-47
Final EIR
Commenter 35 – Steven Dorsey
Comment SD-1: How will you put bike lanes on Earthwood? This is not possible. A lot of
mitigation proposed is not feasible.
Comment SD-2: The Project would result in a traffic nightmare.
Comment SD-3: If BP would generate 30,000 trips, the Planning Commission would not
allow development without proper access. We don’t have adequate access for these
residential trips. Fix access before allowing development.
Comment Response SD-1: As part of Project to address access to and from the site, the
Project would provide a full connection to Suburban Lane through the extension of
Earthwood Lane which would include bicycle lanes or shared lane markings consistent
with the City’s bicycle transportation plan. As part of Mitigation Measure TRANS-4, the
Applicant would develop an improvement plan for this road segment to development the
Earthwood Lane extension in conformance with City standards for a residential collector
road with pedestrian and bicycle improvements. This improvement plan would be reviewed
and approved by City staff prior to approval to ensure appropriate improvements meet City
design standards. Refer to Impact TRANS-2 and TRANS-4 in Section 3.12, Transportation
and Traffic. With regard to the feasibility of proposed mitigation measures, these measures
were developed in close coordination with the City (Lead Agency) to ensure their
effectiveness and feasibility.
Comment Response SD-2: The EIR provides a detailed and thorough analysis of impacts
relating to traffic, transportation, and circulation in Section 3.12, Transportation and
Traffic. Further, a detailed Transportation Impact Study was prepared by registered
transportation professionals, which assess the impacts of the Project on local transportation
systems, and provides mitigation measures designed to reduce Project impacts were
feasible (see Appendix P). As discussed in Section 3.12, Transportation and Circulation,
the Project would substantially result in significant but mitigable impacts to the local
vehicle, pedestrian, and cyclist environment. However, the Project would result in some
significant and unavoidable impacts (see Impacts TRANS-5 and TRANS-15).
Comment Response SD-3: Implementation of the proposed Project is expected to result
in approximately 5,904 ADT, resulting from development of new residential, retail, and
commercial uses. The EIR and the Transportation Impact Study provided in Appendix P
do not identify an increase in traffic by up to 30,000 ADT under either the Project or its
alternatives. The alternative with the greatest potential trip generation appears to be
8.0 RESPONSE TO COMMENTS
8-48 Avila Ranch Development Project
Final EIR
Residential Plus Business Park Land Use Alternative, which would generate roughly 9,583
ADT (please refer to Table 5-24).
With regards to transportation and traffic facilities, the EIR analyzes the Project impact
from increases in traffic on local roadways and intersections, and identifies impacts that
would occur as a result of implementation of this Project. Section 3.12, Transportation and
Traffic provides mitigation designed to address the Project’s relative impact in the most
applicable and feasible manner, to ensure the Project’s impacts would be reduced to a less
than significant level. Where mitigation could not feasibly reduce impacts of the Project,
impacts are considered significant and unavoidable (Class I). However, these impacts are
typically identified for transportation facilities that would require coordination between
multiple authoritative agencies, and where the Project would contribute towards a
cumulatively considerable impact when considering the effects of other approve or pending
projects. Refer to Section 3.12, Transportation and Traffic.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-49
Final EIR
8.4.3 Organizations
NAHC-5
NAHC-4
NAHC-3
NAHC-2
NAHC-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-55
Final EIR
Commenter 36 – Gayle Totton, Native American Heritage Commission
Comment Response NAHC-1: The City of San Luis Obispo initiated requests for
consultation from Tribal agencies on November 3, 2016. City staff has received a request
for tribal consultation in accordance with AB 52. Confidential consultation is ongoing. To
date, no information has been received through consultation which would require further
analysis in the Cultural Resources evaluation or modification of mitigation measures.
Section 3.5, Cultural Resources, has been updated to include discussion of the City’s
conformance with tribal consultation requirements.
Comment Response NAHC-2: Please refer to Commenter 36, Comment Response
NAHC-1.
Comment Response NAHC-3: Please refer to Commenter 36, Comment Response
NAHC-1.
Comment Response NAHC-4: Please refer to Commenter 36, Comment Response
NAHC-1.
Comment Response NAHC-5: Please refer to Commenter 36, Comment Response
NAHC-1.
HealSLO
-1
HealSLO
-2
8.0 RESPONSE TO COMMENTS
8-58 Avila Ranch Development Project
Final EIR
Commenter 37 – Heal SLO
Comment Response HealSLO-1: The commenter correctly asserts that the Project would
result in significant air quality impacts as described in Impact AQ-4, Section 3.3, Air
Quality and Greenhouse Gas Emissions, and the loss of agricultural land as described in
Impact AG-1, Section 3.2, Agricultural Resources. The City would therefore be required
to adopt a Statement of Overriding Considerations to weigh the Project’s significant air
quality emissions, loss of agricultural resources, and traffic impacts against the Project’s
benefits. The LUCE Update EIR identified air quality impacts as being significant and
unavoidable; as an implementing action of the General Plan, and LUCE in particular, the
Project also has a significant and unavoidable impact. While this impact is not new, nor
particular to the Project, the City is required to disclose that implementation of the LUCE
with the Project is a significant and unavoidable impact. Per CEQA Section 15093, “If the
specific economic, legal, social, technological, or other benefits, including region-wide or
statewide environmental benefits, of a proposed project outweigh the unavoidable adverse
environmental effects, the adverse environmental effects may be considered ‘acceptable’”.
Regarding the Project’s consistency with the City’s agricultural and biological resources
policies, Section 3.8.4, Consistency with Plans and Policies, analyzes the Project’s
consistency with City policies and found the Project to be consistent with policies
pertaining to agricultural and biological resources after the implementation of mitigation
measures identified within Section 3.2, Agricultural Resources, and 3.4, Biological
Resources. See further discussion under Impact LU-3 in Section 3.8, Land Use and
Planning.
Lastly, the commenter correctly asserts that the Project would result in increased traffic on
local roadways in excess of General Plan thresholds. These impacts to local roads including
Vachell Lane, Earthwood Lane, Horizon Lane, and Suburban Road are described in Impact
TRANS-4 in Section 3.12, Transportation and Traffic. The EIR found that with
implementation of mitigations, including Mitigation Measure TRANS-4 (improvement
plan for local roadways) and Mitigation Measure TRANS-2a (Transportation Improvement
Phasing Plan), residual impacts would be less than significant. Further information is also
available within Appendix P, Transportation Impact Study.
Comment Response HealSLO-2: Thank you, your comment has been noted. However,
this comment does not address any specific impact discussion or suggest any deficiencies
in the EIR analysis, and is not a CEQA related issue.
January 18, 2017
City of San Luis Obispo
Community Development Department
Attn: Tyler Corey, Principal Planner
919 Palm Street
San Luis Obispo, CA 93401-3218
Subject: Avila Ranch Development Project – Draft Environmental Impact Report (DEIR)
Project # SPEC/ER 1318-2015
State Clearinghouse #2015081034
Dear Mr. Corey:
The San Luis Obispo Council of Governments (SLOCOG) submits the following comments on the
Draft Environmental Impact Report (DEIR) of the Avila Ranch Development Project (hereby
referenced as “Project”).
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.”
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 4, with a range of 500 to 700 new
housing units. SLOCOG’s 2035 Preferred Growth Scenario assumes 450 housing units (at Avila
Ranch); this can be interpreted as an assumption that 450 units (of the total units proposed) are
built, acknowledging a potentially slower pace of development, and hence may not represent
build-out of the project. Table 2 shows how the three scenarios varied in the level of new
growth assigned to Avila Ranch area.
Table 2. New Housing Allocated to Avila Ranch (Special Focus Area 4)
Scenario Scenario Name New housing units New jobs
2035 Scenario 1 Business As Usual Scenario 210 du 0 jobs
2035 Scenario 2 Preferred Growth Scenario 450 du 30 jobs
2035 Scenario 3 Aggressive Scenario 410 du 27 jobs
Housing mix
The Project provides a mix of housing product with a residential density range of 6.0 units per
acre to 26.5 units per acre, representing small- and medium-lot single-family detached housing,
single-family attached/condo housing, and multi-family housing. 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 other
communities and the region as a whole.
Figure 1 shows the share of new housing units permitted by type of unit 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 (R-1, R-2, R-3, and
R-4), 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).
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
*Note: MF Apartment housing product proposed for development in R-4 is represented as unit size rather than lot size.
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 (42.4% versus 12%). The project also proposes a
greater share of SF Attached/Condo than what was permitted between 2000 and 2014 (25.7%
versus 20%).
Proposed
Residential
Land Uses
Number of
units
Share of
units Range of lot sizes*
Housing Product Type
(as compared to SLOCOG
Building Permit Survey)
R-1 105 14.6% 4,000 to 8,000 sq. ft. SF Detached (Medium-Lot)
R-2 305 42.4% 1,350 to 2,000 sq. ft. SF Detached (Small-Lot)
R-3 185 25.7% 1,100 to 1,700 sq. ft. SF Attached/Condo
R-4 125 17.4% 650 to 1,150 sq. ft. MF Apartment
720 100.0%
Location of town center
In a review of the Land Use Plan (Figure 2-2 in the Project Description), the proposed town
center is not located in the center of the development. Although the neighborhood commercial
center may provide some basic goods and services to residents in the project area, its current
location in the eastern portion of the project may lead to longer travel distances for a majority
of the new residents.
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 a modification to the land use plan that would result in locating the town
center at the intersection of Venture Drive and Earthwood Lane, as well as moving the
development of the town center to an earlier phase of the development. This intersection
represents a more centralized location within the development, and could facilitate reduced
travel distances and more walking and biking trips to this location.
SLOCOG recognizes that the suggested location spans three phases (1, 2, and 3), so if the town
center were relocated to the Venture Drive/Earthwood Lane intersection, it would require an
adjustment to the development phasing.
Connections to existing adjacent uses
In a review of the Land Use Plan (Figure 2-2 in the Project Description), SLOCOG suggests that a
bike and pedestrian connection be considered at the northern edge of the development to
connect to the Sports Warehouse existing employment center.
Policy SCS 1 of the SLOCOG 2014 RTP/SCS states “Improve mobility through a combination of
strategies and investments to accommodate anticipated growth in transportation demand and
reduce current and projected levels of congestion.”
An existing example of this type of connection can be found between the Marigold Center
development and the residential development immediately east of Marigold Center. This type
of connection shortens travel distances to adjacent and existing destinations and would provide
a bike and pedestrian connection to a warehouse facility with many employees and four
existing retail storefronts.
Effect of school trips
Section 3.11.1.3 lists the closest schools to the development. Table 3.11-2 lists the San Luis
Coastal Unified School District’s (SLCUSD) capacity, enrollment, and % utilization. P. 3.11-7
states: “SLCUSD currently provides intra-district open enrollment, which allows parents a
request to enroll their children at any district school; the district approves requests on a space-
available basis. Pp. 3.11-19 and -20 evaluate the impact on public school enrollment, present
student generation projections, and discuss impact fees.
SLOCOG-1
SLOCOG-2
SLOCOG-3
Although DEIR Appendix P includes trip generation, distribution, and assignment, which should
reflect home-based school trips, the DEIR should at least include a qualitative discussion of the
influence of the distance of the closest schools on mode choice and traffic. This discussion
should reflect input from the school district and other applicable stakeholders.
SLOCOG acknowledges that it is difficult to know the precise influence in the absence of
knowing where students living at Avila Ranch would attend elementary school. (In the case of
middle and high school, the estimated number of students – 36 and 69, respectively – would
have more of a known impact, with Laguna Middle School and San Luis High School being the
closest at those respective levels.) However, SLOCOG seeks to promote mode options for
school trips, as described in the following RTP/SCS goal.
Ch. 6, Goal #3 of the SLOCOG 2014 RTP/SCS states: “Provide safe and efficient connections for
biking and walking between transportation modes such as Park & Ride lots, transit facilities, and
other destinations for vehicles (shopping, schools, employment); as well as providing
recreational activities such as walking and biking.”
Transportation/Traffic
SR 227 Operations Study: background
Policy HSR 11 of the SLOCOG 2014 RTP/SCS states: “Work with Caltrans and other
transportation partners to develop corridor management concepts that integrate context
sensitive solutions that reflect community values in the planning and construction of projects.”
In December 2016, the SLOCOG Board approved the State Route 227 Operations Study (“227
Study”), which recommends operational improvements to address congestion, side street
access, multimodal level of service, and safety along SR 227 between the San Luis Obispo city
limits and Price Canyon Rd. The study used Caltrans’ Smart Mobility Framework and benefit-
cost analysis to estimate the most cost-effective set of improvements among two alternatives:
a widening-plus-signalization corridor and a roundabout corridor concept.
The roundabout corridor was found to be the most cost-effective. Specifically, the study states:
Based on the technical analyses performed as part of this study, the effectiveness of the
corridor to accommodate existing and future vehicular demand was determined to be
currently constrained by the inefficiency of the existing intersection control types. Per
the Smart Mobility Framework process, a detailed Benefit-Cost (B/C) analysis of the
operational, safety, emissions, and costing characteristics at each study intersections
indicate that the Roundabout Corridor Concept yields the greatest estimated return on
SLOCOG-4
investment (highest B/C). Based on the B/C results, roundabouts will provide the most
efficient intersection control through the corridor that best balances operations and
capacity in concert with resource preservation, safety, emissions, maintenance, and
overall cost.
The 227 Study makes several phased recommendations, which are presented in the appendix of
this letter.
SR 227/Buckley Rd. intersection
P. 3.12-53 summarizes SLOCOG’s 2014 RTP-SCS and the 227 Study.
Note that the 2014 RTP/SCS includes the widening of SR 227 from two to four through lanes
(with left turn channelization) from Aero Drive to Los Ranchos Road in its financially-
constrained Tier I list of capital improvements. This project recommendation was considered in
the 227 Study, which ultimately found that improved intersection operations through
roundabout control would be more cost-effective, as discussed above.
The following revisions are suggested to the language on the SR 227 Operations Study:
“Additionally, the SR 227 Operations al Analysis Study currently under way is being, led
by SLOCOG in coordination with the County, City, and Caltrans, was approved by the
SLOCOG Board in December 2016. The study is focuses d on analyzing short-, medium-,
and long-term improvements along SR 227 to improve traffic congestion, side street
access, multimodal conditions, and safety, including improvements to this [Buckley/SR
227] intersection. The study recommends the conversion of the intersection from a
signalized intersection to a multi-lane roundabout (widening at 200 feet plus taper from
up/down stream of intersection, including signage, illumination, and striping for
pedestrian/bike crossings). This roundabout would include City of San Luis Obispo
Gateway signage and treatments…”
While a preferred alternative for the intersection has not yet been identified by an
environmental document, the recommendation of a multi-lane roundabout, associated
features, and the Edna-Price Canyon Trail at this intersection suggests that MM-TRANS-5 should
be revised as follows:
“The AASP shall be amended to include a fee program for improvements to the Buckley
Road/SR 227 intersection. Upon establishment of a fee program for improvements to
this intersection within the AASP, the Applicant shall pay a pro-rata fair share fee to
fund the installation of additional northbound and southbound lanes conversion to a
multi-lane roundabout, with accommodations for the Edna-Price Canyon Trail, at the
Buckley Road/SR 227 intersection. The City shall collect the fair share fee and coordinate
SLOCOG-5
SLOCOG-6
payment of Project fair share fees to help fund improvements with the County and/ or
Caltrans.”
Turning movement counts and cumulative plus project volumes
In reviewing projected turning movement counts at the SR 227/Buckley intersection, SLOCOG
wishes to point out a substantial amount of traffic growth shown under the Cumulative Plus
Project Conditions for some turning movements, compared to the SR 227 Study.
Table 4. Comparison of selected turning movement counts at SR 227 and Buckley Rd., Avila
Ranch DEIR, Appendix P (Transportation Impact Study), and SR 227 Operations Study
Leg West North South
Study Year / peak hour EBR EBL SBR SBT NBL NBT
Avila Ranch DEIR - TIS Existing AM 113 35 59 426 198 1077
Avila Ranch DEIR - TIS Existing PM 282 50 26 1047 76 468
Avila Ranch DEIR – TIS Project-only trips AM 6 3 1 - 2 -
Avila Ranch DEIR – TIS Project-only trips PM 4 2 3 - 7 -
Avila Ranch DEIR - TIS Cumulative plus proj AM 175 83 151 750 355 1400
Avila Ranch DEIR - TIS Cumulative plus proj PM 361 72 203 1500 267 800
SR 227 Study Existing AM 110 27 51 458 214 1297
SR 227 Study Existing PM 280 48 28 1074 64 503
SR 227 Study 2025 Interim AM 111 27 53 498 215 1359
SR 227 Study 2025 Interim PM 312 52 29 1212 68 577
SR 227 Study 2035 horizon AM 112 27 54 538 215 1421
SR 227 Study 2035 horizon PM 343 55 29 1350 72 650
While the two studies’ existing conditions counts appear to be similar, the cumulative-plus-
project figures (Appendix P, Fig. 10) appear to show an outsized increase for some turning
movements. For example, Existing PM for southbound right jumps from 26 to 203 under
cumulative-plus-project. Can the increase in trips projected from General Plan buildout and the
City’s travel demand model be confirmed as to the scale and extent of the increase?
Buckley Rd. extension
The Buckley Rd. extension from Vachell Ln. to Higuera St. is included as a Regional Route Tier 1
in the 2014 RTP-SCS (Project # CEN-RORS-1006).
Additionally, Policy HSR 11 of the 2014 RTP/SCS states: “Work with local jurisdictions to
develop a well-connected street and road system, with parallel and/or alternative routes
adjacent to major highways.”
SLOCOG therefore supports the inclusion of the Buckley Rd. extension, as recommended by the
Airport Area Specific Plan and included in the development plan. SLOCOG further supports the
SLOCOG-6
Cont.
SLOCOG-7
Appendix
Selected major phased recommendations in the SR 227 Operations Study
x Los Ranchos Road/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings) [short term]
x Crestmont Drive/SR 227 – subject to immediate-term coordination, install operational
improvements consistent with the Highway Design Manual (considered an interim
improvement prior to roundabout control) subject to Caltrans safety evaluation and
determination, engineering discretion and approval to provide safe ingress and egress
through this intersection [short term]
x Buckley Road/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings). This roundabout would include City of San Luis Obispo
Gateway signage and treatments [short term]
x Rehabilitate pathway from Los Ranchos Road to Crestmont Drive to become part of the
Edna-Price Canyon Trail. Install signage warning bicyclists of private driveway/s south of
Crestmont Drive [short term]
x Construct Edna-Price Canyon Trail from Crestmont Drive to Tank Farm Road based on
the Preferred Alignment adopted by SLOCOG [short and mid term]
x Convert SR 227/Farmhouse Lane to a four-legged intersection (convert to two-way stop
control in interim) [short term]
x Restripe northbound SR 227 for two through lanes between Farmhouse Lane to just
south of Kendall Road (widening would not entail any additional ROW) [short term]
x Restrict turn movements from Kendall Road to right-in/right-out and left-in, and provide
median channelization to restrict the left-out movement [short term]
x Farmhouse Lane/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings) [long term]
x Crestmont Drive/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings) [long term]
x Widen southbound SR 227 for four through lanes from Farmhouse Lane to just south of
Kendall Road [long term]
Link to full study: http://slocog.org/highways-streets-roads/State-Route-227
8.0 RESPONSE TO COMMENTS
8-70 Avila Ranch Development Project
Final EIR
Commenter 38 – Jeff Brubaker, San Luis Obispo Council of Governments
(SLOCOG)
Comment Response SLOCOG-1: The site layout a location of the Town Center is
constrained by several environmental factors, including the location of Tank Farm Creek,
Airport Safety Area designations with the site, the presence of known cultural resources,
and the provision of adequate open space buffers. Due to these constraints, relocation of
the Town Center may result in significant environmental impacts to Tank Farm Creek, land
use compatibility, airport safety, or cultural resources. Most notably, relocation of the
Town Center and proposed residential units to support placement of the Town Center in
the center of the Project site could result in adverse impacts associated with development
of residential units within an airport safety zone, subjecting future residents to increased
potential for risk of harm from potential aircraft hazards. With the provision of the Town
Center, neighborhood commercial land uses would be available to serve local residents and
minimize external trips to other retail centers. In addition, it should be noted that much of
the Project site is within 0.25 mile of an existing neighborhood shopping center that could
be accessed by future residents through as short walk or bike ride.
Comment Response SLOCOG-2: Refer to Commenter 38, Comment Response
SLOCOG-1. Relocation of the Town Center to the intersection of Venture
Drive/Earthwood Lane would displace several residential units and could result in
placement of residential units within incompatible airport safety zones, introducing
residents to increased potential for aircraft hazards. Further, due to residential density
restrictions in the eastern portion of the Project site, the relocation of the Town Center
would ultimately result in a decrease of residential units, and would reduce the Project’s
ability to meet LUCE goals and Project Objectives for provision of housing.
Comment Response SLOCOG-3: As described in the Section 2.6.5, Circulation, the
Project includes 3 miles of bicycle paths that provide bicycle and pedestrian circulation.
This includes bicycle and pedestrian facilities along the proposed Jespersen Road
Extension leading to the northern edge of the Project site. As part of Mitigation Measure
TRANS-4, Section 3.12, Transportation and Traffic, the bicycle and pedestrian
connections would be provided along the Horizon Lane Extension at the northern portion
of the Project site to connect to the Suburban Road industrial area. This mitigation measure
also requires improvements to pedestrian facilities along Suburban Road. Mitigation
Measures TRANS-10a through TRANS-10c identified with the EIR include improvements
such as Americans with Disabilities Act (ADA) compliant walkways and completion of
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-71
Final EIR
missing sidewalk gaps on Suburban Road and bicycle lanes along Earthwood Lane to
Suburban Road.
Comment Response SLOCOG-4: The Draft EIR includes a qualitative and quantitative
discussion of the school impacts. It is noted that the School District will provide bus service
to the site. The school district will continue to review the attendance boundaries to balance
school impacts throughout the local attendance areas. With regards to the influence of local
schools on transportation mode choice, it is difficult to predict the mode of travel parents
or students would take to travel to and from a specific location, and as such, is not required
to be quantified or qualified under CEQA. However, Project design and mitigation
measures related to transportation and circulation would serve to reduce impacts from
Project vehicle trips, improve roadway safety, improve bicycle facility connectivity,
promote multi-modal opportunities, and improve the pedestrian and vehicle environment.
Refer to Section 3.12, Transportation and Traffic, for detailed discussion of transportation,
pedestrian, and bicycle facilities, operations, and impacts as such issues and impacts are
discussed throughout this section.
Comment Response SLOCOG-5: Per CEQA Section 15125, the environmental setting
established for analysis within this EIR has been prepared based upon existing information
available at the time of publication of the Notice of Preparation (NOP). The EIR has been
updated to reflect the most recently available information regarding the SR 227 Operations
Study was approved by SLOCOG in December of 2016.
Comment Response SLOCOG-6: Please see Comment Response SLOCOG-7 below.
Comment Response SLOCOG-7: The Avila Ranch Transportation Impact Study applied
the City's Travel Demand Model to develop future year forecasts while the SR 227 Study
applied the SLOCOG Regional Travel Demand Model. Where the Project and Cumulative
Project scenario would result in impacts to this intersection, the Project would be required
to provide a fair share contribution to planned improvements at SR 227/Buckley Road
consistent with the SR 227 Study. The volumes used in the Avila Ranch Transportation
Impact Study are generally higher than those in the SR 227 study, resulting in a more
conservative analysis. The growth forecast on Buckley Road is in large part attributable to
the Buckley Road Extension to South Higuera Street which would accommodate
substantial existing and future non-Project related traffic, with Project traffic only
comprising a component of such future volumes.
SLCUSD-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-75
Final EIR
Commenter 39 – Kim Holmes and Erik Prater, San Luis Coastal Unified School
District
Comment Response SLCUSD-1: Thank you and we appreciate your comments on the
EIR. It is acknowledged that the SLCUSD believes current primary and secondary school
facilities are adequate to serve the Avila Ranch development. This is consistent with the
EIR’s finding that the Project’s impact to school enrollment would be less than significant.
Please see Section 3.11, Public Services, Impact PS-3 for more information on the Project’s
effects on school enrollment.
The commenter’s approval of additional housing provided by the Project is noted and
relevant discussion has been added to the text of the EIR. Please see Section 3.10,
Population and Housing, for more information on the Project’s provision of housing.
CALTRANS
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1-7
CALTRANS
1-7 Cont.
CALTRANS
1-8
8.0 RESPONSE TO COMMENTS
8-80 Avila Ranch Development Project
Final EIR
Commenter 40 – Larry Newland, Caltrans, District 5
Comment Response CALTRANS1-1: The existing conditions analysis reflects
conditions at the time of issuance of the NOP, which occurred prior to the LOVR
interchange reconfiguration. While the EIR employs a reasonable worst case analysis of
pre-reconfiguration setting at the LOVR interchange, it discloses completion of the
improvements. The Project would not add more than 100 peak hour trips to any
merge/diverge or mainline direction.
Comment Response CALTRANS1-2: Existing traffic conditions provided in this EIR
and utilized for assessment of Project impacts to transportation and traffic were based on
data retrieved at the time of issuance of the NOP and preparation of the Draft EIR. Project
trip distribution to U.S. Highway 101 mainline is below thresholds established in the
Caltrans Guide for preparation of Traffic Impact Study Guidelines. Although not a nexus
to this Project, U.S. Highway 101 mainline operations are being evaluated as a part of the
Prado Road interchange studies that are currently underway.
Comment Response CALTRANS1-3: Prado Road/U.S. Highway 101 facilities and the
need for full interchange is currently under investigation, separate from this Project.
Comment Response CALTRANS1-4: The Project would add less than 50 peak hour trips
to the U.S. Highway101/South Higuera Street interchange, less than the Caltrans standard
which would trigger the requirement for review of and potential for impacts to this
intersection. Mitigation Measure TRANS-5 requires a pro-rata fair share contribution
towards improvements at the Buckley Road/SR 227 intersection, which would occur
consistent with the 2016 SR 227 Operations Study.
Comment Response CALTRANS1-5: Section 3.12, Transportation and Traffic, has been
revised to include a brief qualitative discussion of the Project's impacts from school-based
trips and the likelihood for preferred mode of travel to and from local schools.
Comment Response CALTRANS1-6: Please refer to Master Comment Response 3
regarding flooding. Please note that Section 3.7.2.2, Hydrology and Water Quality,
describes both the Federal Emergency Management Agency (FEMA) 100-year floodplain
that traverses the Project site as well as including modeled existing and post Project 100-
year storm conditions within the site. Please note that as part of the Project’s permit
process, the Applicant would consult the local Floodplain Administrator and petition
FEMA for approval of floodplain map revisions consistent with the 100-year floodplain
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-81
Final EIR
conditions based on as-built conditions at the time of Project completion. See Appendix E
and Figure 3.7-1 for further information.
Comment Response CALTRANS1-7: Thank you, your comment has been noted.
Comment Response CALTRANS1-8: The Class I path crossings of intersections,
including that for the Caltrans maintenance yard driveway, would conform to industry
standard practices for design at intersections, including controls specified by Chapter 1000
of the Highway Design Manual. Line of sight and stopping distances would be adequate
for both cyclists and maintenance yard traffic.
In addition to the above comment letter, Mr. Newland attached a copy of the Caltrans letter
dated September 14, 2015 that was originally submitted at the time of the NOP for the
Avila Ranch Development Project EIR. Responses to this letter are provided below.
CALTRANS
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1-11
CALTRANS
1-11 Cont.
CALTRANS
1-12
CALTRANS
1-13
CALTRANS
1-14
CALTRANS
1-15
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-85
Final EIR
Comment Response CALTRANS1-9: The Transportation Impact Study provided in
Appendix P of the EIR evaluated impacts to Caltrans facilities in accordance with the
Department's Guide for the Preparation of Traffic Impact Studies.
Comment Response CALTRANS1-10: Section 3.12, Transportation and Traffic, and as
analyzed in the Transportation Impact Study (Appendix P), describes and utilizes the most
current City, County, and Caltrans standards of significance for transportation facilities.
As described in Section 3.12.4.1, Thresholds of Significance, the unacceptable service
standard for City and County facilities is LOS E or worse, while the unacceptable service
standard for Caltrans facilities is LOS D or worse.
Comment Response CALTRANS1-11: The analysis evaluates the U.S. Highway
101/LOVR ramp junctions and SR 227/Buckley Road intersections. Project trip
distribution to U.S. Highway 101 mainline is below thresholds established in the Caltrans
Guide for preparation of Traffic Impact Study Guidelines, and therefore are found not to
have potential to create a measurable adverse impact. Although a nexus for analysis of this
Project’s impacts does not exist, U.S. Highway 101 mainline operations are being
evaluated as a part of the Prado Road interchanges studies that are currently underway by
the City.
Comment Response CALTRANS1-12: The Avila Ranch Development Project
incorporates multi-modal transportation elements into the Project design, including
approximately 3 miles of new off-road Class I bicycle paths and on-road Class II bicycle
lanes, as well as pedestrian walkways and improved transit service to the site. Although
located in the southern area of the City, the site is within walking distance of a large full
service shopping center with a market, retail and service outlets and restaurants as well as
several light industrial and office park employment centers. The Project, as well as required
mitigation measures in the EIR, would include substantial offsite improvements to
pedestrian facilities and bicycle lanes to provide linkages to these nearby uses. Further
enabling future Project residents to walk or bike to such destinations. Alternative modes of
transportation are analyzed within Section 3.12, Transportation and Traffic.
Comment Response CALTRANS1-13: Thank you, your comment has been noted.
Comment Response CALTRANS1-14: Analysis of the Project’s impacts to airport
operations included review of the Caltrans Airport Land Use Planning Handbook published
by the Division of Aeronautics and airport operations is addressed in Impact HAZ-3 in
Section 3.6, Hazards and Hazardous Materials. As described in Impact HAZ-3, impacts
8.0 RESPONSE TO COMMENTS
8-86 Avila Ranch Development Project
Final EIR
are found to be less than significant as the proposed development is consistent with the
population and density standards specified in the Handbook. See also Master Comment
Response 6.
Comment Response CALTRANS1-15: Thank you, comments regarding the acquisition
of lands for the extension of Buckley Road are noted.
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Cont.
8.0 RESPONSE TO COMMENTS
8-94 Avila Ranch Development Project
Final EIR
Commenter 41 – Lea Brooks, Bike SLO County, January 18th Letter
Comment Response LB1-1: The Project would include numerous improvements to the
bicycle network consistent with the City's Bicycle Transportation Plan (BTP), including a
Class I path on the north side of Buckley Road along the project frontage and Class II
bicycle lanes on Buckley Road along the Project frontage extending for almost one mile to
South Higuera Street. However, while future Project residents would incrementally
contribute to the demand for Class II bicycle lanes along Buckley Road east of the Project
site, the Project would not create significant impacts related to such incremental demand
and cannot be required to pay for such improvements. Please see the updated discussion in
Section 3.12, Transportation and Traffic, of the EIR, as well as the new recommended
mitigation measure suggesting that the City and county work together to complete this gap
in the system.
Comment Response LB1-2: To address Project impacts to the intersection of Buckley
Road/SR 227, Mitigation Measure TRANS-5 would require a Project contribution towards
improvements at this intersection, this may be accomplished by amending the AASP fee
program to include this improvement. The City would verify the inclusion of the fee
program within the AASP and collect the Applicant's fair share fees; the City would then
coordinate with the County and/or Caltrans. Regarding the "Buckley Road gap", refer to
Commenter 41, Comment Response LB1-1.
Comment Response LB1-3: As discussed in Section 2.6.5 of Section 2.0, Project
Description, and within Section 3.12, Transportation and Traffic, the Applicant would
develop all segments within the Project site, and the Project would be consistent with the
policies and goals of the City’s BTP. It is outside the scope of this EIR and speculative to
determine the impacts associated with failure of the City or County to develop these
facilities.
Comment Response LB1-4: Pedestrian and bicycle mitigations were developed consistent
with the City's Transportation Impact Study guidelines, which allow for the development
of parallel off-street facilities to serve non-auto trips.
Comment Response LB1-5: Pedestrian and bicycle mitigations were developed consistent
with the City's Transportation Impact Study guidelines, which allow for the development
of parallel off-street facilities to serve non-auto trips. These development fees would be
paid by the Applicant to the City to fund the improvement to facilities impacted by the
Project, in which case the City would then proceed with implementing necessary
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-95
Final EIR
improvements. Improvement design and timing would be determined by appropriate City
staff once appropriate funds have been received.
Comment Response LB1-6: A discussion of student access to local schools by walking
or bicycles has been added to the EIR. The Project was analyzed for consistency with
policies of the City’s General Plan Circulation Element, the BTP, and AASP relating to the
provision of bicycle facilities. Through the development of bicycle facilities as part of the
Project and the inclusion of Mitigation Measure TRANS-11, the Project was determined
to be consistent with these policies.
Comment Response LB1-7: Pursuant to SB 743 and the requirement for discussion of
VMT analysis, the EIR provides detailed discussion of the Project's estimated VMT in
Section 3.12.4.2 of Section 3.12, Transportation and Traffic, in which the Project would
contribute an additional 65,000 daily VMT, or approximately 72 VMT per household.
Further, consistent with the requirements in the City's Transportation Impact Study
guidelines, Appendix P provides discussion and analysis of Project VMT starting on page
67 of the Transportation Impact Study.
Comment Response LB1-8: The Project's proposed bicycle facilities and network
improvements have been evaluated for consistency with the City's BTP and according to
standards set forth in the City's Transportation Impact Study guidelines. While the EIR
assesses impacts associated with cumulative effect of known pending or approved projects,
impacts associated with denial of the proposed Tank Farm Project are not provided, as it
would be overreaching for an EIR to anticipate the direct effects associated with
disapproval of another project.
Comment Response LB1-9: Please see Comment Response LB1-8.
Comment Response LB1-10: The Project's proposed bicycle facilities and network
improvements have been evaluated for consistency with the City's BTP and according to
standards set forth in the City's Transportation Impact Study guidelines. Currently
Suburban Road is not designated as a bicycle facility as the commenter notes and there is
no nexus between the Project and revisions to the BTP along this roadway. However,
updates to the BTP are being considered separately, and Suburban Road may be
reclassified to provide bicycle facilities.
Comment Response LB1-11: The Project's proposed bicycle facilities and network
improvements have been evaluated for consistency with the City's BTP and according to
standards set forth in the City's Transportation Impact Study guidelines. The bridge
8.0 RESPONSE TO COMMENTS
8-96 Avila Ranch Development Project
Final EIR
described by the commenter is in the County's jurisdiction and necessary improvements to
these facilities would be subject to review and implementation by appropriate County
agencies.
Comment Response LB1-12: The revised Development Plan and mitigations in the EIR
contain many of these improvements (refer to Mitigation Measure AQ-2b, Table 3.3-9 in
Section 3.3, Air Quality and Greenhouse Gas Emissions for air quality mitigations to be
included). Specifically, with reference to the proposed list, the Project will participate in
SLOCOG’s Rideshare Program, provide free bikes for each dwelling unit, provide an
onsite car sharing program, provide adequate storage area for bikes in each garage, provide
for reduced parking on small units, provide onsite transit improvements, and
bicycle/pedestrian connections through Project cul-de-sacs.
Comment Response LB1-13:As described throughout the EIR, the Project and required
EIR mitigation measures would include substantial on and offsite improvements to enhance
multi-modal connectivity and encourage the use of alternative modes of transportation.
These include the construction of offsite bicycle and pedestrian facilities and network
connections that directly related to Project impacts. However, the Project cannot be
required to fund improvements that do not have a reasonable relationship to Project
impacts. City decision makers will consider Project consistency with local and regional
transportation plans, and coordination with SLO Transit authorities during final review of
the Project and impose conditions of approval deemed appropriate to address remaining
concerns.
Comment Response LB1-14: As discussed in Section 5.0, Alternatives, this EIR provides
analysis of a reasonable range of alternatives for consideration by City decision-makers,
per CEQA Section 15126.6. The chosen range of alternatives provided in this analysis are
based on those alternatives which could feasibly attain most of the basic objectives of the
LUCE and the Project. Refer also to Master Response 4.
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Cont.
LB2-13
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8.0 RESPONSE TO COMMENTS
8-102 Avila Ranch Development Project
Final EIR
Commenter 42 – Lea Brooks, Bike SLO County, December 12th Letter
Comment Response LB2-1: The Project, when combined with required mitigation
measures from the EIR, would include completion of substantial on and offsite pedestrian
and bicycle facilities. Although key gaps in the system would remain, a number of
important new facilities would be provided and existing facilities upgraded or extended.
Further, implementation and construction of bicycle facility connections and
improvements proposed as part of the Project would occur during phased construction of
the Project, as described under Impact TRANS-2. To ensure that improvements occur
during each appropriate phase of construction, Mitigation Measure TRANS-2a requires the
Applicant to submit a Transportation Improvement Phasing Plan to the City. This plan shall
address the timing and general design of all on and off-site transportation improvements.
This measure will require each improvement or connection is developed prior to approval
and initiation of the next phase of development.
Comment Response LB2-2: The Project was evaluated in the context of the City's BTP
and the City LUCE. The Project proposes improvements to and provision of multi-modal
facilities with the goal of reducing Project vehicle dependency and achieving the modal
split objectives of the LUCE. See Section 3.8, Land Use and Planning, and Section 3.12,
Transportation and Traffic.
Comment Response LB2-3: Pedestrian and bicycle mitigations were developed consistent
with the City's Transportation Impact Study guidelines, which allow for the development
of parallel off-street facilities to serve non-auto trips.
Comment Response LB2-4: The Project was evaluated in the context of the City's BTP.
Connection of these facilities would be subject to development of the Chevron Tank Farm
property and project construction phasing and improvement schedules. Impacts associated
with bicycle connections as part of the Chevron Tank Farm Remediation and Development
Project would be addressed in the environmental document provided for this Project.
Comment Response LB2-5: The Project was evaluated in the context of the City's BTP.
As required under Mitigation Measure TRANS-5, the AASP would be amended to include
a fee program to the Applicant to contribute fair share fees to fund improvements to the
Buckley Road/SR 227 intersection. Refer to discussion of Impact TRANS-5 in Section
3.12, Transportation and Traffic. See also Master Comment Response 8.
Comment Response LB2-6: Suburban Road does not currently support any designated
bicycle facilities and has not been identified for any proposed facilities as part of the City’s
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-103
Final EIR
Bicycle Transportation Plan. Mitigation Measure TRANS-4 requires developing detailed
improvement plans for Horizon Lane, Earthwood Lane and Suburban Road, “including
roadway, bicycle and pedestrian improvements.” Development of this plan would offer the
City, property owners and members of the community the opportunity to refine the required
level of bicycle improvements in this area.
Comment Response LB2-7: As noted in Mitigation Measure TRANS-8a, the Project is
located within the LOVR Interchange Sub Area fee program, and is required to contribute
fees towards improvements within this interchange sub area. There is no nexus to the
Project for additional improvements beyond what is currently adopted or identified in the
EIR. Additional improvements maybe undertaken by the City outside the scope of the
Project.
Comment Response LB2-8: The Project was evaluated in the context of the City's BTP.
As required under Mitigation Measure TRANS-5, the AASP would be amended to include
a fee program to the Applicant to contribute fair share fees to fund improvements to the
Buckley Road/SR 227 intersection. Refer to discussion of Impact TRANS-5 in Section
3.12, Transportation and Traffic. Transportation and Improvement design and timing
would be determined by appropriate County or Caltrans staff once appropriate funds have
been received.
Comment Response LB2-9: Impacts to bicycle facilities were evaluated according the
applicable City policies, and mitigations developed as needed to remediate Project impacts
to the traffic, pedestrian, and bicycle environment and ensure the adequate operation and
safety of these facilities to the maximum extent feasible of the Project.
Comment Response LB2-10: South Higuera Street currently supports standard Class II
bicycle lanes. Discussion of additional improvements to ensure the safety of cyclists along
this roadway, have been added to the EIR. See Section 3.12, Transportation and Traffic,
Impact TRANS-11.
Comment Response LB2-11: Pedestrian and bicycle mitigations were developed
consistent with the City's Transportation Impact Study guidelines, which allow for the
development of parallel off-street facilities to serve non-auto trips. The Applicant would
be responsible for Project-Class I and II bicycle lanes only and the EIR assesses impacts
associated with Project-related bicycle facilities and integration into the existing bicycle
network. Improvement design and timing for offsite bicycle facilities would be determined
by the City of County once appropriate funds have been received.
8.0 RESPONSE TO COMMENTS
8-104 Avila Ranch Development Project
Final EIR
Comment Response LB2-12: Refer to Commenter 41, Comment Response LB1-3.
Comment Response LB2-13: Refer to Commenter 41, Comment Response LB1-12.
APCD-1
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8.0 RESPONSE TO COMMENTS
8-110 Avila Ranch Development Project
Final EIR
Commenter 43 – Ingrid Schumann and Melissa Guise, San Luis Obispo County Air
Pollution Control District (APCD)
Comment Response APCD-1: As described under Impact AQ-1, implementation of the
proposed Project would result in the exceedance of APCD Tier 1 quarterly threshold;
however, emissions are estimated to be below the established Tier 2 quarterly thresholds
(refer to Table 3.3-7 in Section 3.3, Air Quality and Greenhouse Gas Emissions). While
Mitigation Measures AQ-1a (Construction Activity Management Plan [CAMP]), AQ-1b
(low or no volatile organic compound [VOC] paint), and AQ-1c (offsite mitigation
strategies) would reduce emissions from Project construction, implementation of proposed
mitigation measures would not reduce construction-related air emissions below the Tier 1
quarterly threshold, and impacts are therefore considered significant and unavoidable.
Nevertheless, this impact discussion has been revised for clarification of the Impact AQ-1
determination.
Comment Response APCD-2: Appropriate sections of Mitigation Measure AQ-1a have
been revised to require submittal of the CAMP to APCD for review and approval.
Comment Response APCD-3: The recommended language regarding dust control
management has been incorporated into Mitigation Measure AQ-1a (CAMP). Further,
please note edits indicating that the Applicant would use recycled water or onsite well
water for construction dust control and not City potable water.
Comment Response APCD-4: Mitigation Measure AQ-1a has been revised to include the
recommended language regarding the implementation of Tier 3 and Tier 4 off-road
equipment and 2010 on-road compliant engines. However, as a conservative approach to
air quality analysis, the air emissions model run for the Project will continue to assume use
of the most readily available equipment at the time of Project construction (Tier 2
equipment). While the air emissions calculations modeled mitigated Project construction
emissions using Tier 2 equipment, anticipated air emissions resulting from construction of
the Project exceed APCD’s Tier 1 threshold for ROG + NOx by a substantial margin.
Therefore, potential reductions in emissions that would result from the implementation of
Tier 3 and Tier 4 equipment are disclosed in the revised analysis but are not assumed for
purposes of impact determination. Based on this approach, as part of a reasonable worst
case analysis as required under CEQA, the EIR continues to assume that construction
related emissions would not be reduced below APCD Quarterly Tier 2 thresholds for ozone
precursors and that impacts would therefore remain significant and unavoidable.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-111
Final EIR
Comment Response APCD-5: As requested, Mitigation Measure AQ-1b has been revised
to include the recommendation for extended coating applications to reduce daily and
quarterly VOC thresholds.
Comment Response APCD-6: Refer to Comment Response APCD-4.
Comment Response APCD-7: As requested, Tables 3.3-8 and 3.3-10 of Section 3.3, Air
Quality and Greenhouse Gas Emissions, have been updated with Project operational
annual emissions and are compared to the CEQA thresholds.
Comment Response APCD-8: As requested, Table 3.3-9 and Mitigation Measure AQ-2b
has been revised to remove the words “potentially appropriate” and requires incorporation
of all feasible mitigation measures provided in Table 3-5 of the San Luis Obispo County
APCD CEQA Air Quality Handbook.
Comment Response APCD-9: As requested, the Requirements and Timing section of
Mitigation Measure AQ-2b has been edited to reflect the correct table number (Table 3.3-
9).
Comment Response APCD-10: As discussed in Impact AQ-2 of Section 3.3, Air Quality
and Greenhouse Gas Emissions, and presented in Appendix H, air emissions modeling
performed for the Project shows exceedances of APCD thresholds for operational
emissions. Although air emissions modeling performed through CalEEMod incorporated
all quantifiable mitigation measures into Project analysis, mitigated Project emissions
would continue to exceed APCD daily thresholds. While some offsite mitigation measures
and design features could result in further air emissions reductions, these reductions cannot
be demonstrably quantified to reduce calculated air emissions below APCD thresholds.
Therefore, using a reasonable worst case analysis as required under CEQA, impacts would
continue to be identified as significant and unavoidable.
Comment Response APCD-11: Use of Tier 3 and Tier 4 equipment wherever feasible has
been included under Mitigation Measure AQ-1a, as part of the CAMP.
Comment Response APCD-12: The Project would result in the development of a mix of
urban and residential development, consisting of 720 residential units, 15,000 square feet
(sf) of commercial development, and 18 acres of open space/park areas. While the San Luis
Obispo County APCD CEQA Air Quality Handbook methodology for quantification of
greenhouse gas (GHG) emissions requires amortizing emissions over 50 years for
residential projects, the Project assumes a conservative approach in amortizing emissions
8.0 RESPONSE TO COMMENTS
8-112 Avila Ranch Development Project
Final EIR
over 25 years due to the nature of the mixed commercial and residential development. This
approach represents a reasonable worst case analysis since amortization of emissions over
a 25-year period would reflect higher concentration and frontloading of construction-
related GHG emissions.
Comment Response APCD-13: Mitigation measures that are required to reduce impacts
related to the release of GHG emissions and improve consistency with the Climate Action
Plan include: Mitigation Measures AQ-2a (water conservation strategy, solid waste, and
fugitive dust measures), AQ-2b (measures in Table 3-5 of the APCD CEQA Air Quality
Handbook), TRANS-2d (Class II bicycle lanes), TRANS-2f (Buckley Road frontage
improvements), TRANS-10a through TRANS-10c (sidewalk improvements), TRANS-11
(bicycle bridges), and TRANS-12 (SLO Transit service).
Comment Response APCD-14: Impact AQ-5 discusses the Project’s consistency with
land use and transportation control measures (TCMs). However, consistent with the
findings and methodology for air quality analysis of the City’s 2014 LUCE Update EIR,
the Avila Ranch EIR found that the increase in traffic and population within the Project
site could create increases in emissions that would be potentially inconsistent with the
existing 2001 Clean Air Plan.1 As required under CEQA, the EIR is based on a reasonable
worst case analysis for this issue, so this impact is considered significant and unavoidable.
That said, the City Council may consider the APCD’s opinion that impacts related to the
Clean Air Plan are considered significant but mitigable in the context of potential findings
it would need to make related to possible Project approval.
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).
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SF-12
Cont.
SF-16
SF-15
SF-22
SF-21
SF-20
SF-19
SF-18
SF-17
SF-24
SF-23
SF-22
Cont.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-125
Final EIR
Commenter 44 – Sarah Flickinger, Los Verdes Parks 1&2 Homeowner’s Association
Comment Response SF-1: Thank you, your comment has been noted. Section 3.12,
Transportation and Traffic has been updated to note that the Los Verdes Park
developments are “planned urban developments” (PUDs).
Comment Response SF-2: While the proposed Project would incrementally increase
traffic and associated noise, light, glare and emissions at the South Higuera Street/LOVR
intersection, Project-generated traffic would constitute approximately less than five percent
of the total daily traffic volumes at this intersection. Because Project traffic would
constitute a relatively minor change from the existing environmental baseline and would
not individually or cumulatively exceed any City or other agency thresholds of
significance, such impacts would not be considered significant. However, to more fully
address this concern, additional discussion of such potential impacts to nearby residential
uses and neighborhoods has been added to discussion of Impact VIS-4 in Section 3.1,
Aesthetics and Visual Resources and discussion of Impact TRANS-8 in Section 3.12,
Transportation and Traffic.
Comment Response SF-3: The settlement agreement is discussed in Section 3.12.2.3 and
under Impact TRANS-8. Mitigation Measures TRANS-8a and TRANS-13 requiring
payment of fees as part of the Sub Area fee program and TIF for improvements to the
LOVR road segment and LOVR/South Higuera Street intersection were prepared to be
consistent with the requirements of this agreement.
Comment Response SF-4: Refer to Commenter 44, Comment Response SF-3.
Comment Response SF-5: Proposed mitigation measures are designed to reduce impacts
to South Higuera Street/LOVR associated with Project-generated traffic. Because the 2014
LUCE Update EIR was a City-wide program level document and precise details of the
Avila Ranch Development Plan were not available during the LUCE update, impact
assessment and associated mitigation measures were by necessity general. Inclusion of
additional mitigation measures in the Avila Ranch Development Project EIR to reduce
Project impacts that were not identified in the City LUCE Update EIR, does not result in
inconsistency with the LUCE or the previous Program EIR. Further, the LUCE Update EIR
and the Circulation Element have identified this segment of LOVR as a four-lane divided
arterial, and the Transportation Impact Study and mitigations are consistent with this
designation; no change in this designation is necessary to accommodate the Project. Tiering
of such Project-level EIRs off of previously prepared more general Program EIRs, with
8.0 RESPONSE TO COMMENTS
8-126 Avila Ranch Development Project
Final EIR
associated more focused impact analysis and mitigation measures is both required and
encouraged under CEQA Section 15152.
Comment Response SF-6: Section 5.0, Alternatives, provides discussion and
consideration of a reasonable range of alternatives that would generally meet the basic
objectives of the Project or reduce impacts to environmental resources. Consideration of a
reduced development alternative, consistent with the lower levels of development
permitted under the LUCE (i.e., 500 units), would not meet the basic Project Objectives to
provide a broad mix of housing types, including workforce and affordable housing, and
was therefore not considered for further analysis. Refer to Comment Response SF-5. The
proposed Project is designed to provide a wide range of housing types to meet housing
demand from low, moderate and upper income households consistent with the goals of the
LUCE. Providing such a mix of housing would help the City improve the overall jobs
housing balance, increase provision of affordable housing, reduce the need for long
distance commuting from less expensive communities and associated energy demand and
air pollutant/ GHG emissions. Provision of affordable and workforce housing would also
help meet LUCE goals to provide housing for essential service workers such as nurses,
firefighters, law enforcement personnel, teachers as well as lower income families.
Development of the proposed Project would require substantial investment to address
required improvements such as flood protection and on and offsite transportation and
utility/public service improvements. These fixed site development costs are in part
subsidized development of market rate housing. Substantial reductions in density have the
potential to affect the ability of the Project to both complete expensive on and offsite
improvements and thus sustain provision of a mix of a wide range of smaller more
affordable units, as well as directly reducing the total number of workforce and affordable
housing units provided. While it is beyond the scope of this EIR to address these economic
issues, direct reductions in the amount of housing provided would reduce the Project’s
ability to meet LUCE housing goals.
Comment Response SF-7: The changes to westbound LOVR could be accomplished
without adjusting the median.
Comment Response SF-8: The study locations were identified and evaluated consistent
with the City's Transportation Impact Study guidelines. The Draft EIR evaluates the
roadway segment adjacent to the Los Verdes development and the adjacent signalized
intersections. As addressed in Impact TRANS-8, the reconstruction of the LOVR/U.S.
Highway 101 interchange alleviated the conditions along this segment of LOVR,
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-127
Final EIR
subsequently alleviating conditions at the Los Verdes Drive/LOVR intersection, as
configuration of the LOVR/South Higuera Street intersection would facilitate turning
movement access to Los Verdes Drive for residents of Los Verdes neighborhoods. Refer
to discussion of Impact TRANS-8 in Section 3.12, Transportation and Traffic.
Comment Response SF-9: Refer to Commenter 44, Comment Response SF-8.
Comment Response SF-10: As discussed under Section 3.12.4.2 of Section 3.12,
Transportation and Traffic, “the segment of LOVR from South Higuera Street to 450 feet
north of Los Verdes Drive… currently operates and would continue to operate under the
Project at LOS F.” As provided in Mitigation Measure TRANS-8a, the Project is located
within the LOVR Interchange Sub Area fee program, which would require the Applicant
pay fees for the improvement of this road segment. With implementation of this mitigation
measure, along with implementation of Mitigation Measure TRANS-8b, the Project’s
contributing impact to this road segment would be reduced to a less than significant level.
Refer to Impact TRANS-8.
Comment Response SF-11: Project impacts to intersections and road segments along
LOVR from South Higuera Street to 450 feet north of Los Verdes Drive would be mitigated
by improvements funded under the LOVR Interchange Sub Area Fee Program. As
discussed in detail in Section 3.12, Transportation and Traffic, such improvements would
include addition or extension of turn lanes along South Higuera Street at LOVR. Such
improvements would need to be consistent with the requirements of the settlement
agreement between the Los Verdes Park Homeowners Associations and the City. However,
although subject to feedback from the homeowners association, the settlement agreement
does not in any way legally restrict the City’s options to make appropriate changes to the
lane configurations or other measures consistent with its authority and responsibility, and
consistent with the designations for these roadways in the General Plan.
Comment Response SF-12: The existing conditions analysis reflects conditions at the
time of issuance of the NOP, which occurred prior to the LOVR interchange
reconfiguration. The reconfiguration has been incorporated as mitigation where
appropriate as noted by the commenter.
Comment Response SF-13: With respect to Project impacts on the Los Verdes
neighborhoods, refer to Commenter 44, Comment Response SF-2. With regard to impacts
related to increases in noise and air emissions from additional vehicle traffic along road
segments fronting these neighborhoods, projected increases in Project generated traffic on
8.0 RESPONSE TO COMMENTS
8-128 Avila Ranch Development Project
Final EIR
these roadways would not substantially increase air pollutant emissions, noise levels, or
light or glare that would result in potentially significant impacts, as the Project would result
in negligibly increases in vehicle movement operations along this road segment. Therefore,
while the Project may exceed established thresholds on a regional basis, additional
mitigation measures to address potential impacts at this specific location are not warranted.
Comment Response SF-14: Construction traffic, including construction traffic along
Suburban Road, is addressed within Impact TRANS-1. The EIR identifies Mitigation
Measure TRANS-1, implementation of a Construction Transportation Management Plan,
to address construction impacts to the surrounding road network. Refer to Commenter 44,
Comment Response SF-13 regarding impacts associated with noise, air quality, and
aesthetics.
Comment Response SF-15: Individual mitigation measures provide detailed discussion
of the mitigation plan requirements and timing, responsibility for monitoring, and
evaluation of residual impacts. The Mitigation Monitoring and Reporting Program
(MMRP) provided as part of the Final EIR further summarizes the mitigation plan
requirements, appropriate timing of mitigation, and responsible implementing and
monitoring parties.
Comment Response SF-16: The Cumulative Conditions section of Appendix P evaluates
conditions with and without the LOVR Bypass. This project is a separate discretionary
action requiring separate review and approval by City and County authorities and could
not feasibly be implemented as a mitigation to this Project.
Comment Response SF-17: Thank you and we appreciate your comments on the EIR.
Please refer to Master Comment Response 1.
Comment Response SF-18: The proposed Project was analyzed for consistency with the
City General Plan, and was found to be consistent after implementation of Project
mitigation measures included in this EIR. Please refer to Table 3.8-7 in Section 3.8, Land
Use and Planning.
Comment Response SF-19: Refer to Commenter 44, Comment Response SF-18.
Comment Response SF-20: Refer to Commenter 44, Comment Response SF-11. The
commenter states their opinion of the scope and authority of the Settlement Agreement.
Although subject to review and discussion with the homeowners association, the City
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-129
Final EIR
retains all rights and responsibilities to manage traffic operations that it deems necessary
for public safety and growth per Section 4 of the Settlement Agreement.
Comment Response SF-21: Refer to Commenter 44, Comment Response SF-10 and SF-
13.
Comment Response SF-22: Comments received during the public scoping period and
responses to these comments are provided in Appendix B. This EIR was prepared in
conformance with the 2016 CEQA Statutes and Guidelines. Per Section CEQA Section
15088, this section evaluates and provides written response to comments received during
public review of the Draft EIR. Under CEQA, only comments received during public
review of the Draft EIR, or during Recirculation of the EIR or sections of the EIR require
a response. As allowed under Section 15083, the City chose to initiate early consultation
with members of the public to address potential foreseeable problems that would arise later
on in the CEQA process. Comments received during public scoping process may be used
to guide analysis within the EIR, but do not require preparation of written responses to
these comments. With regards to the Chevron Tank Farm Remediation and Development
Project, please see Master Comment Response 3.
Comment Response SF-23: The traffic counts were collected as a part of the City's
biennial traffic count program. Each year's counts are compared to prior years as a part of
a quality control check. Traffic volumes on the study roadways were reviewed and found
to be reasonable and reflective of typical conditions without construction.
Comment Response SF-24: Refer to Commenter 44, Comment Response SF-17.
"$ " " # !
#"" " #!!
City of San Luis Obispo,
Tyler Corey
Principal Planner
Hello Tyler,
Northern Chumash Tribal Council would like formal consultations regarding the CA SLO 2798/H
Please contact us at your earliest convenience.
Regards,
Violet Cavanaugh
Vice Chairwoman
Northern Chumash Tribal Council
67 South Street
San Luis Obispo, Ca 93401
760-549-3532
NCTC-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-131
Final EIR
Commenter 45 – Violet Cavanaugh, Northern Chumash Tribal Council
Comment Response NCTC-1: Tribal consultation with the Northern Chumash Tribal
Council has been initiated for the Project. Confidential consultation is ongoing. To date,
no information has been received through consultations which would warrant
further/additional analysis in the Cultural Resources evaluation or modification of Project
impacts or mitigation measures.
8.0 RESPONSE TO COMMENTS
8-132 Avila Ranch Development Project
Final EIR
8.4.4 Applicant
PPD-1
PPD-2
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PPD-3
PPD-4
PPD-5
PPD-6
PPD-7
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ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϯ
WĂŐĞ ^ͲϭϮ /ŵƉĂĐƚdƌĂŶƐͲϭϯƐŚŽƵůĚďĞƐĞƉĂƌĂƚĞĚƐŽƚŚĂƚŝƚŝƐĐůĞĂƌƚŚĂƚƚŚĞŝŵƉƌŽǀĞŵĞŶƚŽĨƵĐŬͲ
ůĞLJͬϮϮϳŝƐƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞďĞĐĂƵƐĞƚŚĞŝŵƉƌŽǀĞŵĞŶƚŝƐŽƵƚƐŝĚĞƚŚĞũƵƌŝƐĚŝĐͲ
ƚŝŽŶŽĨƚŚĞŝƚLJƚŽĞŶĨŽƌĐĞ͕ǁŚĞƌĞĂƐƚŚĞ>KsZͬ^ŽƵƚŚ,ŝŐƵĞƌĂŝŵƉƌŽǀĞŵĞŶƚƐĂƌĞǁŝƚŚŝŶ
ŝƚLJũƵƌŝƐĚŝĐƚŝŽŶ͘
WĂŐĞ ^Ͳϭϰ dŚĞĚŝƐĐƵƐƐŝŽŶŽĨƚŚĞDŝƚŝŐĂƚŝŽŶWƌŽũĞĐƚůƚĞƌŶĂƚŝǀĞƐŚŽƵůĚƉƌŽǀŝĚĞĂĚŝƐĐƵƐƐŝŽŶŽĨƚŚĞ
ƌĞĂƐŽŶĨŽƌĂĚĞƚĂŝůĞĚĚŝƐĐƵƐƐŝŽŶŽĨŝƚ͕ƚŚĂƚƚŚĞWƌŽũĞĐƚŚĂĚƐĞǀĞƌĂůĨĞĂƐŝďŝůŝƚLJŝƐƐƵĞƐƚŚĂƚ
ĚŝƌĞĐƚĞĚĐŽŶƐŝĚĞƌĂƚŝŽŶŽĨƚŚĞDW͕ĂŶĚƚŚĂƚƚŚĞĂƉƉůŝĐĂŶƚǁŽƵůĚŶŽǁĐŽŶƐŝĚĞƌƚŚĂƚƚŚĞ
ƉƌŽũĞĐƚĨŽƌĨŽƌŵĂůĐŽŶƐŝĚĞƌĂƚŝŽŶ͘dŚĞĂůƚĞƌŶĂƚŝǀĞƐĚŝƐĐƵƐƐŝŽŶŵĂLJĂůƐŽŶĞĞĚƚŽĂĚĚĂĚŝƐͲ
ĐƵƐƐŝŽŶŽĨĂƌĞĚƵĐĞĚƉƌŽũĞĐƚĂůƚĞƌŶĂƚŝǀĞ;ϱϮϱĚǁĞůůŝŶŐƵŶŝƚƐͿƚŚĂƚŝƐǁŝƚŚŝŶƚŚĞƌĂŶŐĞŽĨ
'WƉŽůŝĐŝĞƐ͘dŚŝƐĚŝƐĐƵƐƐŝŽŶƐŚŽƵůĚĂůƐŽĐŽŶƐŝĚĞƌƚŚĞŝŶĚŝƌĞĐƚ ŝŵƉĂĐƚƐ;͞ĚŝƐƉůĂĐĞŵĞŶƚ͟Ϳ
ŽĨƌĞĚƵĐŝŶŐƚŚĞĚĞǀĞůŽƉŵĞŶƚŽŶƚŚĞƐŝƚĞĂŶĚǁŚĞƚŚĞƌĞdžŝƐƚŝŶŐWƉƌŽƉĞƌƚŝĞƐǁŽƵůĚďĞ
ĐŽŶǀĞƌƚĞĚƚŽƌĞƐŝĚĞŶƚŝĂů͕ŽƌǁŚĞƚŚĞƌĚĞǀĞůŽƉŵĞŶƚǁŽƵůĚŶĞĞĚƚŽƚĂŬĞƉůĂĐĞŽƵƚƐŝĚĞƚŚĞ
hZ>ƚŽƉƌŽǀŝĚĞƚŚĞŚŽƵƐŝŶŐĐĂůůĞĚĨŽƌŝŶƚŚĞ>h ͘^ĞĞĐŽŵŵĞŶƚƐŽŶƚŚĞƌĞůĂƚŝǀĞƐƵƉĞƌŝͲ
ŽƌŝƚLJŽĨƚŚĞĂůƚĞƌŶĂƚŝǀĞƐ͘
WĂŐĞϭͲϰ EŽƚĞƚŚĂƚƚŚĞŝƌƉŽƌƚ>ĂŶĚhƐĞŽŵŵŝƐƐŝŽŶĨŽƵŶĚƚŚĂƚƚŚĞDWĂŶĚWƌŽũĞĐƚǁĞƌĞŝŶ
ĐŽŶĨŽƌŵĂŶĐĞǁŝƚŚƚŚĞ>hWŝŶĞĐĞŵďĞƌ͕ϮϬϭϲ͘^ĞĞƚƚĂĐŚŵĞŶƚϮ͘
WĂŐĞϮͲϭϭ dŚĞ'ĞŶĞƌĂůWůĂŶŵĞŶĚŵĞŶƚĞŶƚŝƚůĞŵĞŶƚƐŚŽƵůĚŝŶĐůƵĚĞƚŚĞƌĞͲĚĞƐŝŐŶĂƚŝŽŶŽĨĂƌĞĂ
ƌŽĂĚǁĂLJƐƚŽĐŽŶĨŽƌŵǁŝƚŚƉƌŽũĞĐƚƌŽĂĚǁĂLJǀŽůƵŵĞƐĂŶĚŶĞŝŐŚďŽƌŚŽŽĚĐŽŵƉĂƚŝďŝůŝƚLJ͕
ŝŶĐůƵĚŝŶŐĚĞƐŝŐŶĂƚŝŶŐsĂĐŚĞůůĂŶĚ^ƵďƵƌďĂŶĂŶĚŽŵŵĞƌĐŝĂůŽůůĞĐƚŽƌƐ͕sĞŶƚƵƌĞĂŶĚ
ĂƌƚŚǁŽŽĚĂƐZĞƐŝĚĞŶƚŝĂůŽůůĞĐƚŽƌƐ͕ĂŶĚ:ĞƐƉĞƌƐĞŶĂƐĂZĞƐŝĚĞŶƚŝĂůƌƚĞƌŝĂů͘
WĂŐĞϮͲϭϮ dŚĞ>hWŽŶĨŽƌŵŝƚLJĚŝƐĐƵƐƐŝŽŶƐŚŽƵůĚďĞƵƉĚĂƚĞĚƚŽŝŶĚŝĐĂƚĞƚŚĂƚƚŚĞ>hĨŽƵŶĚƚŚĞ
ƉƌŽũĞĐƚŝŶĐŽŶĨŽƌŵĂŶĐĞǁŝƚŚƚŚĞ>hW͕ĂŶĚĂĚĚƚŚĞ&ŝŶĂůEŽƚŝĐĞŽĨĞƚĞƌŵŝŶĂƚŝŽŶ͘^ĞĞ
ƚƚĂĐŚŵĞŶƚϮ͘
WĂŐĞϮͲϮϬ &ŽŽƚŶŽƚĞϮŝŶƚĞƌŵŝdžĞƐŵĞĚŝĂŶĨĂŵŝůLJŝŶĐŽŵĞĂŶĚŵĞĚŝĂŶŚŽƵƐĞŚŽůĚŝŶĐŽŵĞ͘dŚĞLJĂƌĞ
ĚŝĨĨĞƌĞŶƚŝŶĐŽŵĞŵĞƚƌŝĐƐ͘tŚŝĐŚŽŶĞŝƐŝƚ͍
WĂŐĞϮͲϯϳ dŚĞŽĨĨƐŝƚĞƐĞǁĞƌůŝŶĞǁŽƵůĚďĞĞdžƚĞŶĚĞĚǁĞƐƚĂůŽŶŐ^ƵďƵƌďĂŶZŽĂĚ͘dŚĞĞdžƚĞŶƐŝŽŶ
ĞĂƐƚǁŽƵůĚŐŽƚŚƌŽƵŐŚƉƌŝǀĂƚĞƉƌŽƉĞƌƚLJĂŶĚŝƐŶŽƚĨĞĂƐŝďůĞ͘^ĞĞƚŚĞĞǀĞůŽƉŵĞŶƚWůĂŶ
ĂŶĚ&ŝŐƵƌĞϮͲϵŽĨƚŚĞ /Z͘dŚĞĞĂƐƚĞƌŶĂůŝŐŶŵĞŶƚǁĂƐĞǀĂůƵĂƚĞĚǁŝƚŚŝƚLJƐƚĂĨĨĂŶĚƚŚĞ
ĂƉƉůŝĐĂŶƚĂŶĚŝƚǁĂƐĚĞƚĞƌŵŝŶĞĚƚŚĂƚĞdžƚĞŶĚŝŶŐƚŚĞůŝŶĞŝŶƚŚŝƐĚŝƌĞĐƚŝŽŶǁŽƵůĚŶŽƚƉƌŽͲ
ǀŝĚĞƐĞǁĞƌƐĞƌǀŝĐĞƚŽĂŶLJƵŶƐĞǁĞƌĞĚƵƐĞƌƐ;ďĞĐĂƵƐĞŽĨĚĞƉƚŚĂŶĚƚŚĞůĞŶŐƚŚŽĨƚŚĞ
ĨŽƌĐĞŵĂŝŶͿ͕ĂŶĚƚŚĞĂůŝŐŶŵĞŶƚǁĞŶƚƚŚƌŽƵŐŚƉƌŝǀĂƚĞƉƌŽƉĞƌƚLJĂŶĚǁŽƵůĚĚŝƐƌƵƉƚĞdžŝƐƚͲ
ŝŶŐƵƚŝůŝƚŝĞƐŝŶƚŚĞtŚŝƚƐŽŶ/ŶĚƵƐƚƌŝĂůWĂƌŬ͘
PPD-8
PPD-9
PPD-10
PPD-11
PPD-12
PPD-13
PPD-14
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϰ
&ŝŐƵƌĞϮͲϴ ŽƌƌĞĐƚƚŚŝƐĨŝŐƵƌĞƐŽƚŚĂƚƚŚĞ,ƌƵŶƐŝŶƚŚĞƐŽƵƚ ŚŵŽƐƚĞĂƐƚͲǁĞƐƚZͲϭƌŽĂĚ;,ƵŐŚĞƐ
ZŽĂĚͿ͘
ŶǀŝƌŽŶŵĞŶƚĂů/ŵƉĂĐƚƐĂŶĚDŝƚŝŐĂƚŝŽŶDĞĂƐƵƌĞƐ
dĂďůĞϯ͘ϬͲϭ ŝƐĐƵƐƐŝŽŶŽĨƚŚĞǁŝƚŚĚƌĂǁĂůŽĨƚŚĞŚĞǀƌŽŶĚĞǀĞůŽƉŵĞŶƚĂŶĚƌĞƐƚŽƌĂƚŝŽŶƉůĂŶƐ͘^ĞƚƵƉ
ƚŚĞĨĂĐƚƵĂůĐĂƐĞĨŽƌƚŚĞĐŽŶƐŝĚĞƌĂƚŝŽŶŽĨƚŚĞDWŝŶƐƚĞĂĚŽĨƚŚĞWƌŽũĞĐƚ͍
WĂŐĞϯ͘ϭͲϴ ĞůĞƚĞĚŝƐĐƵƐƐŝŽŶŽĨ^ϳϰϯŚĞƌĞ͘/ƚŝƐŽƵƚŽĨƉůĂĐĞ͘
WĂŐĞϯ͘ϭͲϭϬ ĞůĞƚĞ,ŝůůƐŝĚĞWŽůŝĐŝĞƐ͘dŚĞƉƌŽũĞĐƚŝƐŶŽƚŝŶĂ,ŝůůƐŝĚĞƌĞĂ͘
WĂŐĞϯ͘ϭ͘Ͳϭϭ ĚĚK^WŽůŝĐLJϳ͘ϳ͘ϵƌĞŐĂƌĚŝŶŐƌĞĞŬ^ĞƚďĂĐŬƐŚĞƌĞ͘
WĂŐĞϯ͘ϭͲϮϭ ŽƌƌĞĐƚƚŚĞĨŽůůŽǁŝŶŐƐƚĂƚĞŵĞŶƚ͘ϭϱϬĂĐƌĞƐŝƐŶŽƚĂŶĂĐĐƵƌĂƚĞƐƚĂƚĞŵĞŶƚŽĨůĂŶĚĐŽŶǀĞƌͲ
ƐŝŽŶ͗͞WƌŽũĞĐƚĚĞǀĞůŽƉŵĞŶƚǁŽƵůĚĐŽŶǀĞƌƚϭϱϬĂĐƌĞƐŽĨĂŐƌŝĐƵůƚƵƌĂůůĂŶĚƐĐĂƉĞĂŶĚŽƉĞŶ
ƐƉĂĐĞƚŽĂŵŝdžŽĨŵŽƌĞƵƌďĂŶͲƐƵďƵƌďĂŶƵƐĞƐ͕ŝŶĐůƵĚŝŶŐϲϴ͘ϮϯĂĐƌĞƐŽĨŵŝdžĞĚĚĞŶƐŝƚLJƌĞƐͲ
ŝĚĞŶƚŝĂůƵƐĞƐ͕ϭϲĂĐƌĞƐŽĨĚĞǀĞůŽƉĞĚƉĂƌŬůĂŶĚ͕ĂŶĚϯ͘ϯϰĂĐƌĞƐŽĨĐŽŵŵĞƌĐŝĂůĚĞǀĞůŽƉͲ
ŵĞŶƚ͖ŚŽǁĞǀĞƌ͕ϱϱ͘ϯĂĐƌĞƐŽĨƚŚĞƐŝƚĞ;ϯϳƉĞƌĐĞŶƚͿǁŽƵůĚƌĞŵĂŝŶŝŶƵŶĚĞǀĞůŽƉĞĚŽƉĞŶ
ƐƉĂĐĞĂŶĚĂŐƌŝĐƵůƚƵƌĞ͘͟
WĂŐĞϯ͘ϭͲϮϮ ĚĚƉŚŽƚŽƐŝŵĨŽƌƵĐŬůĞLJĨƌŽŶƚĂŐĞŚĞƌĞ͘ĞĨŽƌĞĂŶĚĂĨƚĞƌƉŝĐƚƵƌĞƐĂƌĞŝŶƚƚĂĐŚŵĞŶƚϯ͘
WĂŐĞϯ͘ϯͲϮϵ DDYͲϭĐŝƐƌĞĚƵŶĚĂŶƚĂŶĚƵŶŶĞĐĞƐƐĂƌLJ͘dŚĞƉƌŽũĞĐƚŝŶĐůƵĚĞƐĂůůŽĨƚŚĞĨĞĂƐŝďůĞŵŝƚŝŐĂͲ
ƚŝŽŶŵĞĂƐƵƌĞƐƌĞƋƵŝƌĞĚďLJƚŚĞW YŝƌYƵĂůŝƚLJ,ĂŶĚŬƚŽƌĞĚƵĐĞƚŚĞƐĞǀĞƌŝƚLJ
ŽĨƚŚĞƐŝŐŶŝĨŝĐĂŶƚŝŵƉĂĐƚƐƚŽƚŚĞŐƌĞĂƚĞƐƚĞdžƚĞŶƚĨĞĂƐŝďůĞ͕ĂƐƐŚŽǁŶŝŶdĂďůĞϯ͘ϯͲϵ͘/ŶĂĚͲ
ĚŝƚŝŽŶ͕dĂďůĞϯ͘ϯͲϵƐŚŽƵůĚĂůƐŽŝŶĐůƵĚĞƚŚĞƌĞůĂƚŝǀĞƌĞĚƵĐƚŝŽŶŝŶĂŝƌĞŵŝƐƐŝŽŶĂƐƐŽĐŝĂƚĞĚ
ǁŝƚŚĞĂĐŚŵĞĂƐƵƌĞ͕ĂŶĚŝĚĞŶƚŝĨLJƚŚŽƐĞƚŚĂƚŚĂǀĞŶŽƋƵĂŶƚŝĨŝĂďůĞƌĞĚƵĐƚŝŽŶŝŶĂŝƌƋƵĂůŝƚLJ
ŝŵƉĂĐƚƐ͘
dĂďůĞϯ͘ϯͲϵ dĂďůĞƐŚŽƵůĚĚĞŵŽŶƐƚƌĂƚĞŚŽǁƚŚĞƉƌŽũĞĐƚŵĞĞƚƐŽƌĞdžĐĞĞĚƐƚŚĞŵĞĂƐƵƌĞ͘DĞĂƐƵƌĞϮϬ
ƐŚŽƵůĚďĞĐŽƌƌĞĐƚĞĚƚŽďĞĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞWƐŽƚŚĂƚϱϬйŽĨƚŚĞƵŶŝƚƐ;ĂůůƵŶŝƚƐŶŽƚ
ũƵƐƚƚŚĞƐŝŶŐůĞͲĨĂŵŝůLJƵŶŝƚƐͿĂƌĞƚŽďĞŽƵƚĨŝƚƚĞĚǁŝƚŚƐŽůĂƌWsƐLJƐƚĞŵƐ͘
WĂŐĞϯ͘ϯͲϯϴ ŽƌƌĞĐƚƚŚĞƌĞĨĞƌĞŶĐĞŝŶZĞƋƵŝƌĞŵĞŶƚƐĂŶĚdŝŵŝŶŐƚŽƌĞĨĞƌƚŽdĂďůĞϯ͘ϯͲϵ͕ŶŽƚϯ͘ϯͲϭϬ͘
WĂŐĞϯ͘ϯͲϰϳ dŚĞĨŝŶĚŝŶŐƵŶĚĞƌŝƌYƵĂůŝƚLJŶĞĞĚƐƚŽďĞĞdžƉĂŶĚĞĚ͘dŚĞŝŶĐŽŶƐŝƐƚĞŶĐLJŝŶƚŚĞƉŽƉƵůĂͲ
ƚŝŽŶƉƌŽũĞĐƚŝŽŶƐŝƐďĞĐĂƵƐĞƚŚĞŝƌYƵĂůŝƚLJWůĂŶŚĂƐŶŽƚďĞĞŶƵƉĚĂƚĞĚŝŶϭϱLJĞĂƌƐ͕ƐŝŶĐĞ
PPD-15
PPD-16
PPD-17
PPD-18
PPD-19
PPD-20
PPD-21
PPD-22
PPD-24
PPD-25
PPD-26
PPD-23
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϱ
ŝƚƐĨŝƌƐƚĂĚŽƉƚŝŽŶŝŶϮϬϬϭ͘ƐŶŽƚĞĚŽŶWĂŐĞϰͲϱϲŝŶƚŚĞ>h /Z͞dŚĞŵŽƐƚĐƵƌƌĞŶƚǀĞƌͲ
ƐŝŽŶŽĨƚŚĞůĞĂŶŝƌWůĂŶŝŶĐůƵĚĞƐƉŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶƐĂŶĚĂŐƌŽǁƚŚƌĂƚĞĨŽƌƚŚĞŝƚLJ
ŽĨ^ĂŶ>ƵŝƐKďŝƐƉŽŝŶŚĂƉƚĞƌϮ͕WůĂŶŶŝŶŐƌĞĂĂŶĚŝƌĂƐŝŶĞƐĐƌŝƉƚŝŽŶ͕dĂďůĞϮͲϭĂŶĚ
dĂďůĞϮͲϮ͕ƌĞƐƉĞĐƚŝǀĞůLJ͘dŚĞƉƌŽũĞĐƚĞĚƉŽƉƵůĂƚŝŽŶĨŽƌϮϬϭϱŝŶƚŚĞůĞĂŶŝƌWůĂŶŝƐ
ϰϴ͕ϰϵϵ͕ǁŝƚŚĂŐƌŽǁƚŚƌĂƚĞŽĨϮϮйĨƌŽŵϭϵϵϱƚŽϮϬϭϱ͘dŚĞƉƌŽũĞĐƚŝŽŶƐŝŶƚŚĞŵŽƐƚƌĞͲ
ĐĞŶƚůĞĂŶŝƌWůĂŶŚĂǀĞŶŽƚďĞĞŶƵƉĚĂƚĞĚďĞLJŽŶĚϮϬϭϱ͖ƚŚƵƐ͕ƚŚĞƉƌŽũĞĐƚĞĚƉŽƉƵůĂƚŝŽŶ
ĂƐƐŽĐŝĂƚĞĚǁŝƚŚƚŚĞ>h hƉĚĂƚĞŝŶϮϬϭϱŝƐƵƐĞĚĨŽƌĚĞƚĞƌŵŝŶŝŶŐĐŽŶƐŝƐƚĞŶĐLJĂůŽŶŐǁŝƚŚ
ƚŚĞŽǀĞƌĂůůŐƌŽǁƚŚƌĂƚĞ͘dŚĞƉƌŽũĞĐƚĞĚƉŽƉƵůĂƚŝŽŶĨŽƌƚŚĞ>h hƉĚĂƚĞŝŶϮϬϭϱŝƐ
ϰϲ͕ϰϱϲ͕ĂƐƐŚŽǁŶŝŶdĂďůĞϰŽĨƚŚĞƵƉĚĂƚĞĚ>ĂŶĚhƐĞ^ĞĐƚŝŽŶ͘dŚŝƐǀĂůƵĞŝƐĂƉƉƌŽdžŝͲ
ŵĂƚĞůLJϮ͕ϬϬϬůĞƐƐƚŚĂŶƚŚĞǀĂůƵĞĂƐƐƵŵĞĚŝŶƚŚĞůĞĂŶŝƌWůĂŶ͘/ŶĂĚĚŝƚŝŽŶ͕ƚŚĞŐƌŽǁƚŚ
ƌĂƚĞŶŽƚĞĚŝŶůĞĂŶŝƌWůĂŶǁĂƐϮϮйŽǀĞƌĂϮϬͲLJĞĂƌƉĞƌŝŽĚĨƌŽŵϭϵϵϱƚŽϮϬϭϱ͘dŚĞ
ŐƌŽǁƚŚƌĂƚĞĨŽƌƚŚĞ>h hƉĚĂƚĞŽǀĞƌĂϮϬͲLJĞĂƌƉĞƌŝŽĚĨƌŽŵϮϬϭϱƚŽϮϬϯϱǁŽƵůĚĂůƐŽďĞ
ϮϮй͘,ŽǁĞǀĞƌ͕ŝƚŝƐŝŵƉŽƌƚĂŶƚƚŽŶŽƚĞƚŚĂƚƚŚĞϮϬϯϱƉƌŽũĞĐƚŝŽŶƐŝŶƚŚĞ>h hƉĚĂƚĞĐĂŶͲ
ŶŽƚďĞĚŝƌĞĐƚůLJĐŽŵƉĂƌĞĚƚŽƉƌŽũĞĐƚŝŽŶƐĨŽƌƚŚĞƐĂŵĞLJĞĂƌŝŶƚŚĞůĞĂŶŝƌWůĂŶďĞĐĂƵƐĞ
LJĞĂƌϮϬϭϱŝƐƚŚĞŵŽƐƚƌĞĐĞŶƚLJĞĂƌĐƵƌƌĞŶƚůLJƐŚŽǁŶ͘͟dŚĞĂŶĂůLJƐŝƐƐŚŽƵůĚŶŽƚĞƚŚĂƚƚŚĞ
ƉƌŽũĞĐƚŝƐĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞŽŶĞƉĞƌĐĞŶƚŐƌŽǁƚŚŐƵŝĚĞůŝŶĞĐŽŶƚĂŝŶĞĚŝŶƚŚĞ>h ͘dŚĂŶ
ĂŶĂůLJƐŝƐŝŶ^ĞĐƚŝŽŶϯ͘ϭϬŽĨƚŚĞ /ZŝŶĚŝĐĂƚĞƐƚŚĂƚƚŚĞƉƌŽũĞĐƚǁŝůůŶŽƚĐŽŶƚƌŝďƵƚĞƚŽĂĐƵͲ
ŵƵůĂƚŝǀĞƉŽƉƵůĂƚŝŽŶĂŶĚŚŽƵƐŝŶŐŝŶĐƌĞĂƐĞƚŚĂƚǁŝůůĞdžĐĞĞĚƚŚĞŽŶĞƉĞƌĐĞŶƚŐƌŽǁƚŚƌĂƚĞ
ŝŶƚŚĞ>h ĂŶĚƚŚĞůĞĂŶŝƌWůĂŶ͘dŚĞĐŽƌƌĞĐƚŝŽŶĨŽƌƚŚŝƐǁŽƵůĚďĞĨŽƌƚŚĞůĞĂŶŝƌ
WůĂŶƚŽďĞƵƉĚĂƚĞĨŽƌĂŶŽƚŚĞƌϭϱͲLJĞĂƌƉƌŽũĞĐƚŝŽŶƉĞƌŝŽĚ͕ďƵƚƚŚĂƚŝƐŽƵƚƐŝĚĞŽĨƚŚĞƌĞͲ
ƐƉŽŶƐŝďŝůŝƚLJĂŶĚĂƵƚŚŽƌŝƚLJŽĨƚŚĞŝƚLJ͘
dŚĞĨŝŶĚŝŶŐĂůƐŽŶĞĞĚƐƚŽŝĚĞŶƚŝĨLJƚŚĂƚĂůůĨĞĂƐŝďůĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐŝŶƚŚĞŝƚLJůŝͲ
ŵĂƚĞĐƚŝŽŶWůĂŶĂŶĚdĂďůĞϯ͘ϯͲϵŽĨƚŚĞ /ZŚĂǀĞďĞĞŶŝŵƉůĞŵĞŶƚĞĚĂŶĚƚŚĂƚƚŚĞƌĞŝƐ
ƐƚŝůůĂƌĞƐŝĚƵĂůƐŝŐŶŝĨŝĐĂŶƚŝŵƉĂĐƚ͕ĂŶĚƚŚĂƚƚŚĞƐĞǀĞƌŝƚLJŚĂƐďĞĞŶƌĞĚƵĐĞĚƚŽƚŚĞŐƌĞĂƚĞƐƚ
ĚĞŐƌĞĞĨĞĂƐŝďůĞ͘
WĂŐĞϯ͘ϰͲϯϮ ŚĞĐŬĨŽƌĐŽŶƐŝƐƚĞŶĐLJŝŶŐƌĂĚŝŶŐƌĞĨĞƌĞŶĐĞƐƚŽĐƵďŝĐLJĂƌĚƐ͗ϳϮϳ͕ϭϲϮǀ͘ϯϯϬ͕ϯϬϬ͘ůĂƌŝĨLJ
ƚŚĂƚƚŚĞůŽǁĞƌŶƵŵďĞƌƌĞĨĞƌĞŶĐĞƐ͞ĐƵƚ͟Žƌ͞Ĩŝůů͕͟ǁŚŝůĞƚŚĞŚŝŐŚĞƌŶƵŵďĞƌƌĞĨĞƌĞŶĐĞƐ
ƚŽƚĂůĐƵƚ͕Ĩŝůů͕ƚƌĞŶĐŚƐƉŽŝůƐĂŶĚŚŽƵƐĞĨŽƵŶĚĂƚŝŽŶƐƉŽŝůƐ͘
WĂŐĞϯ͘ϰͲϲϯ ŽƌƌĞĐƚƌĞĨĞƌĞŶĐĞƚŽ͞ŝŽDDͲϰ͟ŝŶƐƚĞĂĚŽĨ͞ŝŽDDϰĂĂŶĚϰď͘͟dŚĞƌĞŝƐŽŶůLJĂŝŽ
DDͲϰ͘
WĂŐĞϯ͘ϰͲϲϱ DDŝŽͲϱĂƐŚŽƵůĚďĞĐůĂƌŝĨŝĞĚƚŚĂƚŝůůƵŵŝŶĂƚŝŽŶůĞǀĞůƐƐŚĂůůŶŽƚĞdžĐĞĞĚϭĨŽŽƚͲĐĂŶĚůĞ͕Žƌ
ƚŚĞůŽǁĞƐƚĨĞĂƐŝďůĞůĞǀĞůĂďŽǀĞϭĨŽŽƚͲĐĂŶĚůĞĂƐĚĞƚĞƌŵŝŶĞĚďLJƚŚĞŝƚLJ͘/ƚŝƐĂƐƐƵŵĞĚ
ƚŚĂƚĂĐŚŝĞǀŝŶŐƚŚĞϭĨŽŽƚͲĐĂŶĚůĞůĞǀĞůŝƐĂĚĞƋƵĂƚĞŵŝƚŝŐĂƚŝŽŶ͘
WĂŐĞϯ͘ϲͲϳ dŚĞƐŽŝůƐĞŶŐŝŶĞĞƌŝŶŐƌĞƉŽƌƚĨŽƌƚŚĞƵĐŬůĞLJ džƚĞŶƐŝŽŶƐŚŽǁƐƚŚĂƚŶŽƌŵĂůĨƵŐŝƚŝǀĞĚƵƐƚ
ĐŽŶƚƌŽůŵĞĂƐƵƌĞƐĂƌĞĂĚĞƋƵĂƚĞ͘dŚĞƌĞƉŽƌƚƐƚĂƚĞĚƚŚĂƚ͞EĂƚƵƌĂůůLJŽĐĐƵƌƌŝŶŐĂƐďĞƐƚŽƐ
;EKͿŚĂƐďĞĞŶĨŽƵŶĚƚŽŽĐĐƵƌǁŝƚŚŝŶƐĞƌƉĞŶƚŝŶĞƌŽĐŬ͘&ŽƌŵĂƚŝŽŶĂů^ĞƌƉĞŶƚŝŶŝƚĞŵĂƚĞͲ
ƌŝĂůǁĂƐĞŶĐŽƵŶƚĞƌĞĚĂƚƐŽŵĞŽĨƚŚĞĞdžĐĂǀĂƚŝŽŶƐĚƵƌŝŶŐŽƵƌĨŝĞůĚĞdžƉůŽƌĂƚŝŽŶ͘'ŝǀĞŶƚŚĞ
ůŽĐĂůŝnjĞĚŶĂƚƵƌĞŽĨ^ĞƌƉĞŶƚŝŶŝƚĞĂƚƚŚĞƐŝƚĞ͕ǁĞĂŶƚŝĐŝƉĂƚĞŐƌĂĚŝŶŐŝŶƐĞƌƉĞŶƚŝŶĞƌŽĐŬƚŽ
ďĞůĞƐƐƚŚĂŶϭĂĐƌĞ͘͟hŶĚĞƌƚŚŽƐĞĐŝƌĐƵŵƐƚĂŶĐĞƐŶŽƌŵĂůĨƵŐŝƚŝǀĞĚƵƐƚĐŽŶƚƌŽůŵĞĂƐƵƌĞƐ
ĂƌĞĂĚĞƋƵĂƚĞĨŽƌŵŝƚŝŐĂƚŝŽŶ͘WůĞĂƐĞĐŝƚĞƚŽƚŚĞƌĞƉŽƌƚ͘
PPD-26
Cont.
PPD-27
PPD-28
PPD-29
PPD-30
PPD-31
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϲ
WĂŐĞϯ͘ϳͲϴ dŚĞ /ZƐŚŽƵůĚĐůĂƌŝĨLJƚŚĂƚƚŚĞDWŝƐŶŽǁǁŚĂƚǁŝůůďĞďƵŝůƚ͘ŝƐĐƵƐƐŝŽŶƐŚŽƵůĚďĞ
ĂĚĚĞĚĨŽƌƌĂŝŶĂŐĞĨŽƌŚĞǀƌŽŶdĂŶŬ&Ăƌŵ͘/ƚŝƐƵŶĚĞƌƐƚŽŽĚƚŚĂƚƚŚĞĂƉƉůŝĐĂƚŝŽŶĨŽƌĂŶͲ
LJƚŚŝŶŐŽƚŚĞƌƚŚĂŶƚŚĞƌĞŵĞĚŝĂƚŝŽŶŚĂƐďĞĞŶǁŝƚŚĚƌĂǁŶĂŶĚƚŚĞƚŝŵŝŶŐĂŶĚƐĐŽƉĞĂŶĚ
ĂŶLJŽŶƐŝƚĞƐƚŽƌŵĚƌĂŝŶĂŐĞŝƐŝŶĚĞƚĞƌŵŝŶĂƚĞ͘WƌŽũĞĐƚƉƌŽĐĞĞĚĞĚŽƌŝŐŝŶĂůůLJŝŶƌĞůŝĂŶĐĞŽŶ
ƚŚĞŚĞǀƌŽŶĂƉƉƌŽǀĂůƐ͕ďƵƚŝƚǁĂƐůĂƚĞƌĚŝƐĐŽǀĞƌĞĚƚŚĂƚƚŚĞǁŽƌŬǁŽƵůĚŶŽƚďĞƉĞƌͲ
ĨŽƌŵĞĚďLJŚĞǀƌŽŶ͕ĂŶĚŚĞǀƌŽŶǁŽƵůĚŶŽƚůĞƚƚŚĞǁŽƌŬďĞƉĞƌĨŽƌŵĞĚďLJŽƚŚĞƌƐŽŶƚŚĞ
ƉƌŽƉĞƌƚLJ͘
&ŝŐƵƌĞϯ͘ϳͲϮ dŚŝƐĨŝŐƵƌĞŝƐŶŽƚƌĞĨĞƌĞŶĐĞĚĂŶLJǁŚĞƌĞŝŶƚŚĞƚĞdžƚĂŶĚĚŽĞƐŶŽƚĂƉƉĞĂƌƚŽĐŽŶƚƌŝďƵƚĞƚŽ
ƚŚĞĚŝƐĐƵƐƐŝŽŶ͘
WĂŐĞϯ͘ϳͲϱϮ dŚĞĚŝƐĐƵƐƐŝŽŶŽĨƌĞĚƵĐĞĚŐƌŽƵŶĚǁĂƚĞƌƉĞƌĐŽůĂƚŝŽŶĂŶĚƐƵƉƉůŝĞƐƐŚŽƵůĚďĞĞdžƉĂŶĚĞĚƚŽ
ĨƵůůLJĚŝƐĐƵƐƐƚŚĞŽŶͲƐŝƚĞƌĞƚĞŶƚŝŽŶŽĨƌƵŶŽĨĨĂŶĚŝŶĐƌĞĂƐĞƐŝŶŐƌŽƵŶĚǁĂƚĞƌůĞǀĞůƐ͘hŶĚĞƌ
ƚŚĞ>/ƌĞŐƵůĂƚŝŽŶƐŵŽƐƚŽĨƚŚĞƌƵŶŽĨĨǁŽƵůĚďĞĚĞƚĂŝŶĞĚŽŶƐŝƚĞĂŶĚƉĞƌĐŽůĂƚĞĚŝŶ>/
ďĂƐŝŶĂŶĚďŝŽͲƐǁĂůĞƐ͘&ƵƌƚŚĞƌŐƌŽƵŶĚǁĂƚĞƌĞdžƚƌĂĐƚŝŽŶĨƌŽŵƚŚĞŽŶƐŝƚĞĂŐǁĞůůǁŽƵůĚďĞ
ƌĞĚƵĐĞĚƵŶĚĞƌƚŚĞWƌŽũĞĐƚĂŶĚƚŚĞDWƐŝŶĐĞƚŚĞƚŽƚĂůŶƵŵďĞƌŽĨŝƌƌŝŐĂƚĞĚĂĐƌĞƐǁŽƵůĚ
ďĞƌĞĚƵĐĞĚĨƌŽŵĂƉƉƌŽdžŝŵĂƚĞůLJϭϰϬĂĐƌĞƐƚŽϯϱĂĐƌĞƐ͘'ƌŽƵŶĚǁĂƚĞƌǁŽƵůĚůĞǀĞůƐǁŝůů
ŝŶĐƌĞĂƐĞďĞĐĂƵƐĞŽĨƚŚĞƌĞĚƵĐƚŝŽŶŝŶĂŐƌŝĐƵůƚƵƌĂůŐƌŽƵŶĚǁĂƚĞƌĞdžƚƌĂĐƚŝŽŶ͘hŶĚĞƌƚŚĞ
ƉƌŽũĞĐƚ͕ĂŶĚǁŝƚŚƚŚĞƌĞƋƵŝƌĞĚ>/ƐƚƌĂƚĞŐŝĞƐŶĞƚǁĂƚĞƌŐĂŝŶǁŽƵůĚďĞĂƉƉƌŽdžŝŵĂƚĞůLJϭϯϬ
&;ƌĞƚĂŝŶĞĚƌĂŝŶĨĂůůŽĨϭϱϳ&ůĞƐƐϮϳ&ŽĨĂŐƵƐĂŐĞͿ͕ĐŽŵƉĂƌĞĚƚŽƚŚĞϭϬϵ&ŽĨĐƵƌͲ
ƌĞŶƚƌĞƚĂŝŶĞĚŐƌŽƵŶĚǁĂƚĞƌ;ϭϵϵ&ŽĨƌĞƚĂŝŶĞĚƌĂŝŶĨĂůůĐŽŵƉĂƌĞĚƚŽϵϬ&ŽĨĂŐŐƌŽƵŶĚͲ
ǁĂƚĞƌĞdžƚƌĂĐƚŝŽŶ͘^ĞĞĂƚƚĂĐŚĞĚĂŶĚďĞůŽǁ͘
PPD-32
PPD-33
PPD-34
PPD-35
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϳ
WĂŐĞϯ͘ϴͲϯϬ dŚĞƉƌŽũĞĐƚŝƐĐŽŶƐŝƐƚĞŶƚ͕ĂĨƚĞƌŵŝƚŝŐĂƚŝŽŶ͕ǁŝƚŚWŽůŝĐLJϲ͘ϲ͘ϭ͘ĞůĞƚĞƌĞĨĞƌĞŶĐĞƐƚŽ͞ƉŽͲ
ƚĞŶƚŝĂůůLJĐŽŶƐŝƐƚĞŶƚ͟Žƌ͞ƉŽƚĞŶƚŝĂůůLJŝŶĐŽŶƐŝƐƚĞŶƚ͟ĂƐƚŚŽƐĞƚĞƌŵƐĂƌĞĂƉƉƌŽƉƌŝĂƚĞĨŽƌĂŶ
EKW͕/ŶŝƚŝĂů^ƚƵĚLJŽƌƐĐŽƉŝŶŐĚŽĐƵŵĞŶƚ͕ďƵƚŶŽƚĂĨƚĞƌĂŶĂůLJƐŝƐĂŶĚĞǀĂůƵĂƚŝŽŶ͘
WĂŐĞϯ͘ϴͲϰϭ ^ĞĐƚŝŽŶƌĞĨĞƌƐƚŽƚŚĞƉŽƚĞŶƚŝĂůŝŶĐŽŶƐŝƐƚĞŶĐLJŽĨŶŽƚĐŽŵƉůĞƚŝŶŐƚŚĞůĂƐƐ//ďŝŬĞůĂŶĞƐ
ƚŚƌŽƵŐŚƚŚĞƵĐŬůĞLJͬdĂŶŬ&ĂƌŵƌĞĞŬďƌŝĚŐĞ͘ƐŶŽƚĞĚŝŶƚŚĞd/^͕͞dŚŝƐƐĞŐŵĞŶƚŝƐŽƵƚͲ
ƐŝĚĞŽĨƚŚĞŝƚLJůŝŵŝƚƐƐŽƚŚĞŵƵůƚŝŵŽĚĂůƚŚƌĞƐŚŽůĚŽĨƐŝŐŶŝĨŝĐĂŶĐĞĚŽĞƐŶŽƚĂƉƉůLJ͘dŚĞ
ƉƌŽũĞĐƚƉƌŽƉŽƐĞƐƚŽĐŽŶƐƚƌƵĐƚĂƉĂƌĂůůĞůůĂƐƐ/ƉĂƚŚĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞŝƚLJ͛ƐdW͕ǁŚŝĐŚ
ǁŽƵůĚĂĚĚƌĞƐƐƚŚŝƐĚĞĨŝĐŝĞŶĐLJ͘͟dŚŝƐƐĞŐŵĞŶƚŝƐĂůƐŽŽƵƚƐŝĚĞŽĨƚŚĞhZ>͕^K/ĂŶĚƚŚĞŝƚLJ
ůŝŵŝƚƐĂŶĚƚŚĞƌĞĨŽƌĞŽƵƚƐŝĚĞŽĨƚŚĞŝƚLJ͛ƐƉůĂŶŶŝŶŐũƵƌŝƐĚŝĐƚŝŽŶĂŶĚƚŚĞdWĚŽĞƐŶŽƚĂƉͲ
ƉůLJ͘dŚĞůĂƐƐ/ďŝŬĞƉĂƚŚƉƌŽǀŝĚĞƐƚŚĞŶĞĐĞƐƐĂƌLJǁĞƐƚďŽƵŶĚĐŽŶŶĞĐƚŝŽŶĨŽƌƌŝĚĞƌƐ͘DŝƚŝͲ
ŐĂƚŝŽŶƐŚŽƵůĚďĞƌĞĨĞƌĞŶĐĞĚŝŶƚŚĞĨŽƌŵŽĨƚŚĞƌĞĐŽŵŵĞŶĚĞĚƌĞůŽĐĂƚŝŽŶŽĨƚŚĞdĂŶŬ
&ĂƌŵƌĞĞŬďŝŬĞďƌŝĚŐĞƚŽĂƉŽŝŶƚϮϱϬĨĞĞƚƐŽƵƚŚͬƐŽƵƚŚǁĞƐƚƚŽƌĞĚƵĐĞƚŚĞůĞŶŐƚŚŽĨƚŚĞ
ĚŝǀĞƌƐŝŽŶŶŽƌƚŚŽĨdĂŶŬ&ĂƌŵƌĞĞŬ͘
>KddzW dKd>Z ;Ϳ йZ d/E Ύ Z d/E ;/EͿ
KW E^W ϱϬ͘Ϯ ϴϬй ϲϲ͘ϲϳ
WZ<ϭϳ͘ϵ ϴϬй Ϯϯ͘ϳϳ
Wh>/&/>/d/ ^Ϭ͘ϲ ϱϬй Ϭ͘ϱϬ
ZͲϭKE ϭϯ͘ϭ ϱϬй ϭϬ͘ϴϳ
ZͲϭKE Ϯϳ͘ϴ ϱϬй Ϯϯ͘Ϭϳ
ZͲϭKE ϭϮ͘Ϯ ϱϬй ϭϬ͘ϭϯ
ZͲϭKE ϰ ϱϬй ϯ͘ϯϮ
ͲE ϭ͘ϵ ϱϬй ϭ͘ϱϴ
Wh>/ZKt Ϯϭ͘ϯ ϱϬй ϭϳ͘ϲϴ
dKd>Z ϭϰϵ
dKd>Z d/E ΎΎ ϭϱϳ͘ϱϴ
ƌĂǁŶ ϯϱ ;Ϯϳ͘ϯϵͿ
EĞƚtĂƚĞƌ'ĂŝŶ ϭϯϬ͘ϭϵ
>KddzW dKd>Z ;Ϳ йZ d/E Ύ Z d/E ;/EͿ
KW E^W ϭϰϵ͘ϵ ϴϬй ϭϵϵ͘Ϭϳ
WZ<ϴϬй Ͳ
Wh>/&/>/d/ ^ϱϬй Ͳ
ZͲϭKE ϱϬй Ͳ
ZͲϭKE ϱϬй Ͳ
ZͲϭKE ϱϬй Ͳ
ZͲϭKE ϱϬй Ͳ
ͲE ϱϬй Ͳ
Wh>/ZKt ϱϬй Ͳ
dKd>Z ϭϰϵ͘ϵ
dKd>Z d/E ΎΎ ϭϵϵ͘Ϭϳ
ƌĂǁŶ ϭϭϱ ;ϵϬ͘ϬϬͿ
EĞƚtĂƚĞƌ'ĂŝŶ ϭϬϵ͘Ϭϳ
WƌĞͲĞǀĞůŽƉŵĞŶƚ
WŽƐƚĞǀĞůŽƉŵĞŶƚ
PPD-36
PPD-37
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϴ
^ŝŵŝůĂƌůLJ͕ƚŚĞŽƵŶƚLJŝĐLJĐůĞDĂƐƚĞƌWĂŶĂƉƉůŝĞƐĂůŽŶŐƚŚĞƵĐŬůĞLJZŽĂĚ džƚĞŶƐŝŽŶĂŶĚĂ
ůĂƐƐ//ĨĂĐŝůŝƚLJŽŶůLJ;ĂŶĚŶŽƚĂůĂƐƐ/ďŝŬĞƉĂƚŚͿŝƐŝŶĚŝĐĂƚ ĞĚĨŽƌƚŚĞƐƚƌĞƚĐŚƵĐŬůĞLJZŽĂĚ͘
ŽŵƉůĞƚŝŽŶŽĨĞŝƚŚĞƌƚŚĞůĂƐƐ/ŽƌƚŚĞůĂƐƐ//ĨĂĐŝůŝƚLJĂůŽŶŐƚŚĞƵĐŬůĞLJZŽĂĚ džƚĞŶƐŝŽŶ
ǁŽƵůĚďĞŝŶĐŽŶĨŽƌŵĂŶĐĞǁŝƚŚƚŚĞŽƵŶƚLJŝĐLJĐůĞDĂƐƚĞƌWĂŶĂŶĚƚŚĞĨŝŶĚŝŶŐƐŽĨƚŚĞ
d/^͘
WĂŐĞϯ͘ϴͲϰϲ dŚĞƉƌŽũĞĐƚŝƐĐŽŶƐŝƐƚĞŶƚ͕ǁŝƚŚŵŝƚŝŐĂƚŝŽŶ͕ǁŝƚŚ^WWŽůŝĐLJϯ͘Ϯ͘ϭϲ͘ĞůĞƚĞƚŚĞƌĞĨĞƌĞŶĐĞ
ƚŽ͚WĂƌƚŝĂůůLJŽŶƐŝƐƚĞŶƚ͘͟dŚĞƉƌŽũĞĐƚŝƐĂůƐŽĨƵůůLJĐŽŶƐŝƐƚĞŶƚǁŝƚŚ^WWŽůŝĐLJϯ͘Ϯ͘ϭϴ
ƐŝŶĐĞŝƚǁŝůůƉƌŽƚĞĐƚĂŐůĂŶĚƐƚŚƌŽƵŐŚĐŽŶƐĞƌǀĂƚŝŽŶĞĂƐĞŵĞŶƚƐ͘
WĂŐĞϯ͘ϴͲϱϳ dŚĞĞǀĂůƵĂƚŝŽŶŽĨ>hͲϯŝƐŵŝdžĞĚƵƉǁŝƚŚƚŚĞůŽƐƐŽĨĂŐůĂŶĚ͘>hͲϯĞǀĂůƵĂƚĞƐƚŚĞ'WƉŽůŝĐLJ
ƚŽƉƌŽǀŝĚĞĂŐĐŽŶƐĞƌǀĂƚŝŽŶĞĂƐĞŵĞŶƚƐǁŚĞŶĂŐůĂŶĚŝƐĐŽŶǀĞƌƚĞĚ͘^ƵĐŚĂŐĐŽŶƐĞƌǀĂƚŝŽŶ
ĞĂƐĞŵĞŶƚƐĂƌĞďĞŝŶŐƉƌŽǀŝĚĞĚƉĞƌƚŚĞƉŽůŝĐLJ͘dŚĞŝŵƉĂĐƚƚŚĂƚŝƐƵŶĂǀŽŝĚĂďůĞŝƐƚŚĞŝŵͲ
ƉĂĐƚƵŶĚĞƌ'Ͳϭ͕ŶŽƚĂůƐŽ>hͲϯ͘WůĞĂƐĞĐŽƌƌĞĐƚĂŶĚĐůĂƌŝĨLJ͘
WĂŐĞϯ͘ϴͲϲϬ EŽƚĞƚŚĂƚƚŚĞĚŝƐƚƌŝĐƚŚĂƐĂŐŐƌĞŐĂƚĞĞdžĐĞƐƐĐĂƉĂĐŝƚLJĂƚĂůůŐƌĂĚĞůĞǀĞůƐĂŶĚƌĞŐƵůĂƌůLJĂĚͲ
ũƵƐƚƐĂƚƚĞŶĚĂŶĐĞďŽƵŶĚĂƌŝĞƐƚŽƌĞͲĚŝƐƚƌŝďƵƚĞƐƚƵĚĞŶƚƐĨƌŽŵǀĂƌŝŽƵƐĂƚƚĞŶĚĂŶĐĞĂƌĞĂƐ͘
EŽƚĞĂůƐŽƚŚĂƚǀŝůĂZĂŶĐŚŝƐǁŝƚŚŝŶƚŚĞďƵƐƐŝŶŐĂƌĞĂĨŽƌďŽƚŚ>ĂŐƵŶĂDŝĚĚůĞ^ĐŚŽŽůĂŶĚ
>ŽƐZĂŶĐŚŽƐ ůĞŵĞŶƚĂƌLJ^ĐŚŽŽů͕ĂŶĚŽƚŚĞƌĞůĞŵĞŶƚĂƌLJƐĐŚŽŽůƐ͘&ŝŶĂůůLJ͕ŶŽƚĞƚŚĂƚ^ϱϬ
ƐƚĂƚĞƐƚŚĂƚƉĂLJŵĞŶƚŽĨŝŵƉĂĐƚĨĞĞƐŝƐĐŽŶƐŝĚĞƌĞĚĨƵůůŵŝƚŝŐĂƚŝŽŶĨŽƌĂŶLJƐĐŚŽŽůŝŵƉĂĐƚƐ͘
^ĞĞƚƚĂĐŚŵĞŶƚϰ͘
WĂŐĞϯ͘ϵͲϮϳ hƉĚĂƚĞdĂďůĞϯ͘ϵͲϭϳƚŽƌĞĨůĞĐƚĐƵƌƌĞŶƚŵĞĂƐƵƌĞĚƐĞŐŵĞŶƚǀŽůƵŵĞƐĨŽƌsĂĐŚĞůůĂŶĚƵĐŬͲ
ůĞLJZŽĂĚ;ϰ͕ϴϰϲdĂŶĚϰ͕ϳϮϴd͕ƌĞƐƉĞĐƚŝǀĞůLJͿ͕ĂŶĚĐŽŶĨŝƌŵƉƌŽũĞĐƚĞĚdƐǁŝƚŚƚƌĂĨͲ
ĨŝĐŵŽĚĞů͘WĞĂŬŚŽƵƌƉƌŽũĞĐƚŝŽŶƐŝŶ&ŝŐƵƌĞϭϬŽĨƚŚĞd/^ƐƵŐŐĞƐƚůŽǁĞƌǀŽůƵŵĞƐĨŽƌ
sĂĐŚĞůůĂŶĚƐůŝŐŚƚůLJŚŝŐŚĞƌůĞǀĞůƐĨŽƌƵĐŬůĞLJZŽĂĚ͘ůƐŽ͕ĂĚĚƚŚĂƚƚŚĞĂĐŽƵƐƚŝĐƐƐƚƵĚLJ
ĐŽŶĐůƵĚĞĚƚŚĂƚƚŚĞďĞƌŵĂůŽŶŐWŚĂƐĞϱǁŽƵůĚƌĞĚƵĐĞŶŽŝƐĞĞdžƉŽƐƵƌĞďLJϭϬĚ;Ϳ͕ĂŶĚ
ƚŚĂƚƚŚĞĚĞƐŝŐŶŐƵŝĚĞůŝŶĞƐƐƉĞĐŝĨLJƚŚĂƚƚŚĞƐĞƵŶŝƚƐƐŚŽƵůĚďĞƐŝŶŐůĞƐƚŽƌLJŝĨŶĞĐĞƐƐĂƌLJĨŽƌ
ƐŽƵŶĚĂŶĚŶŽŝƐĞŵŝƚŝŐĂƚŝŽŶ͘
WĂŐĞϯ͘ϵͲϯϭ EŽƚĞƚŚĂƚƌƵďďĞƌŝnjĞĚĂƐƉŚĂůƚŵĂLJƌĞƐƵůƚŝŶĂϱͲϴĚ;ͿƌĞĚƵĐƚŝŽŶŝŶǀĞŚŝĐůĞŶŽŝƐĞ͘ůƐŽ͕
ŶŽƚĞƚŚĂƚƵĐŬůĞLJZŽĂĚŝƐŝŶƚŚĞŽƵŶƚLJĂŶĚŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨƚ ŚŝƐƌĞƋƵŝƌĞŵĞŶƚĚĞͲ
ƉĞŶĚƐŽŶĂĐĐĞƉƚĂŶĐĞŽĨƚŚŝƐĐŽŶĚŝƚŝŽŶĂŶĚĞƐƚĂďůŝƐŚŵĞŶƚŽĨĂĚĞ ƐŝŐŶƐƚĂŶĚĂƌĚďLJƚŚĞ
ŽƵŶƚLJWƵďůŝĐtŽƌŬƐŝƌĞĐƚŽƌ͘ĂƐĞĚŽŶĚŝƐĐƵƐƐŝŽŶƐǁŝƚŚƚŚĞŽƵŶƚLJWƵďůŝĐtŽƌŬƐĞͲ
ƉĂƌƚŵĞŶƚ͕ŝƚŝƐďĞůŝĞǀĞĚƚŚĂƚƚŚŝƐŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞŝƐĞĨĨĞĐƚŝǀĞĂŶĚĨĞĂƐŝďůĞ͘dŚĞ
ĂĐŽƵƐƚŝĐƐƌĞƉŽƌƚŝŶĚŝĐĂƚĞƐƚŚĂƚƚŚĞƉƌŽƉŽƐĞĚďĞƌŵĂŶĚͬŽƌĐƌĞĞŬǀĞŐĞƚĂƚŝŽŶ͕ŽƌƚŚĞĂĚĚŝͲ
ƚŝŽŶĂůƐĞƚďĂĐŬƐŽŶƚŚĞĞĂƐƚĞŶĚŽĨƚŚĞƉƌŽũĞĐƚǁŝůůĨƵůůLJŵŝƚŝŐĂƚĞƚŚĞƌŽĂĚŶŽŝƐĞŝŵƉĂĐƚƐ
ĨƌŽŵƵĐŬůĞLJZŽĂĚǁŝƚŚŽƵƚƚŚĞƌƵďďĞƌŝnjĞĚĂƐƉŚĂůƚ͘/ŶĐůƵƐŝŽŶŽĨƚŚĞƌƵďďĞƌŝnjĞĚĂƐƉŚĂůƚ
ǁŝůůƌĞĚƵĐĞƚŚĞŶŽŝƐĞůĞǀĞůƐůŽǁĞƌƚŚĂŶƚŚŽƐĞǁŝƚŚƚŚĞŽŶƐŝƚĞŵŝƚŝŐĂƚŝŽŶƚŚĂƚŝƐĂůƌĞĂĚLJ
ŝŶĐůƵĚĞĚ͘
WĂŐĞϯ͘ϭϬͲϭ EŽƚĞŝŶƐĞĐƚŝŽŶϯ͘ϭϬ͘ϭƚŚĂƚ>hWŽůŝĐLJϭ͘ϱƌĞƋƵŝƌĞƐƚŚĂƚƚŚĞũŽďƐŚŽƵƐŝŶŐďĂůĂŶĐĞƐŚĂůůŶŽƚ
ǁŽƌƐĞŶĨŽƌŝƚƐĐƵƌƌĞŶƚůĞǀĞůŽĨϭ͘ϴ͗ϭ;ŝŶĐůƵĚŝŶŐŝƚLJ͕ĂůWŽůLJĂŶĚDĞŵƉůŽLJŵĞŶƚĂŶĚ
ŝƚLJŚŽƵƐŝŶŐͿ͘ůƐŽ͕ŶŽƚĞƚŚĂƚƚŚĞƉŽůŝĐLJƌĞĨĞƌƐƚŽ͞ĞŶƌŽůůŵĞŶƚ͟ƐŽƚŚĂƚƵĞƐƚĂĂŶĚĂůͲ
WŽůLJĞŶƌŽůůŵĞŶƚŝƐĨĂĐƚŽƌĞĚŝŶƚŽƚŚĞũŽďƐͲŚŽƵƐŝŶŐďĂůĂŶĐĞĞƋƵĂƚ ŝŽŶ͘
PPD-38
PPD-39
PPD-40
PPD-41
PPD-42
PPD-43
PPD-44
PPD-45
PPD-46
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϵ
dĂďůĞϯ͘ϭϭͲϮ ŚĞĐŬĂƌŝƚŚŵĞƚŝĐŝŶdĂďůĞ͘dŽƚĂůĐĂƉĂĐŝƚLJŝƐĐĂůĐƵůĂƚĞĚƚŽďĞϰ͕ϯϳϮƐƚƵĚĞŶƚƐĐŽŵƉĂƌĞĚƚŽ
ĐƵƌƌĞŶƚĞŶƌŽůůŵĞŶƚŽĨϯ͕ϴϭϰĨŽƌĞůĞŵĞŶƚĂƌLJŐƌĂĚĞƐ͕ĂŶĚ,^ŐƌĂĚĞƐƚŽƚĂůϯ͕ϰϯϰĐĂƉĂĐŝƚLJ
ĐŽŵƉĂƌĞĚƚŽϮ͕ϮϵϴĞŶƌŽůůŵĞŶƚ͕ĂƐƐŚŽǁŶŝŶƚƚĂĐŚŵĞŶƚEŽϰ͘EŽƚĞĂŶĚĐĂůĐƵůĂƚĞĞdžĐĞƐƐ
ĐĂƉĂĐŝƚLJŝŶ^ĂŶ>ƵŝƐKďŝƐƉŽƐĐŚŽŽůƐĨŽƌĐŽŵƉĂƌŝƐŽŶ͘ůƐŽ͕ƵƉĚĂƚĞƚŽŝŶĐůƵĚĞϮϬϭϱͲϮϬϭϲ
ĚĂƚĂƚŚĂƚŝƐĂǀĂŝůĂďůĞ͘ůƐŽ͕ĨŽƌĂŵĞĂŶŝŶŐĨƵůĐŽŵƉĂƌŝƐŽŶŐƌŽƵƉƚŚĞ^>KĞůĞŵĞŶƚĂƌLJ
ƐĐŚŽŽůƐƚŽƐŚŽǁƚŚĂƚƚŚĞƌĞŝƐĂŐŐƌĞŐĂƚĞĐĂƉĂĐŝƚLJŝŶƚŚĞƐĐŚŽŽůƐƚŚĂƚƐŚĂƌĞĂƚƚĞŶĚĂŶĐĞ
ďŽƵŶĚĂƌŝĞƐ͘^ŝŶƐŚĞŝŵĞƌ͕^ŵŝƚŚ͕>ŽƐZĂŶĐŚŽƐĂŶĚ,ĂǁƚŚŽƌŶĞŚĂǀĞĐŽŵďŝŶĞĚĐĂƉĂĐŝƚLJŽĨ
ϭ͕ϳϵϲƐƚƵĚĞŶƚƐĐŽŵƉĂƌĞĚƚŽƚŽƚĂůĐƵƌƌĞŶƚĞŶƌŽůůŵĞŶƚŽĨϭ͕ϱϵϲŝŶƚŚĞϮϬϭϱͲϮϬϭϲƐĐŚŽŽů
LJĞĂƌ͘^ĞĞƚƚĂĐŚŵĞŶƚϰ͘
dĂďůĞϯ͘ϭϮͲϰ hƉĚĂƚĞĂŶĚͬŽƌŵŽĚŝĨLJƚŚŝƐƚĂďůĞƚŽƌĞƉŽƌƚƐĞŐŵĞŶƚǀŽůƵŵĞƐƐŽƚŚĂƚƚŚĞƌĞŝƐĂĚŝƌĞĐƚƌĞͲ
ƉŽƌƚŝŶŐŽĨĞdžŝƐƚŝŶŐĂŶĚƉƌŽũĞĐƚĞĚǀŽůƵŵĞƐŽŶƌŽĂĚǁĂLJƐƚŽĞŶƐƵƌĞĐŽŵƉůŝĂŶĐĞǁŝƚŚ>h
ǀŽůƵŵĞƌĞƐƚƌŝĐƚŝŽŶƐ͘/ŶĐůƵĚĞǀŽůƵŵĞƐƚĂŬĞŶŝŶĞĐĞŵďĞƌϮϬϭϲ;ĂƚƚĂĐŚĞĚͿĨŽƌĐŽŵƉĂƌŝͲ
ƐŽŶĂŶĚƵƉĚĂƚĞ͞ƉŽƐƚ>KsZŝŶƚĞƌĐŚĂŶŐĞ͟ŝŵƉƌŽǀĞŵĞŶƚƐ͘^ĞĞƚƚĂĐŚŵĞŶƚϱ͘
dĂďůĞϯ͘ϭϮͲϮϰ EŽƚĞƚŚĂƚƚŚĞŽƵŶƚLJŚĂƐĂĚŽƉƚĞĚĂŝĐLJĐůĞDĂƐƚĞƌWůĂŶƚŚĂƚĂƉƉůŝĞƐƚŽĂƌĞĂƐŽƵƚƐŝĚĞŽĨ
ƚŚĞŝƚLJĂŶĚƚŚĞhZ>͕ĂƐŶŽƚĞĚŝŶƚŚĞ /Z͘dŚĞůĂƐƐ/ĚŝǀĞƌƐŝŽŶĨƌŽŵůĂƐƐ//ďŝŬĞůĂŶĞƐŽŶ
ƵĐŬůĞLJĞĂƐƚŽĨsĂĐŚĞůůŝƐŝŶĐŽŶĨŽƌŵĂŶĐĞǁŝƚŚƚŚĞŽƵŶƚLJŝŬĞWůĂŶƐŝŶĐĞŝƚƉƌŽǀŝĚĞƐĂ
͞ƐƵƉĞƌŝŽƌ͟ĂŶĚƐĂĨĞƌƉĂƚŚŽĨƚƌĂǀĞů͕ĂŶĚƚŚĂƚĞŝƚŚĞƌĂůĂƐƐ/ŽƌůĂƐƐ//͕ŽƌďŽƚŚ͕ĂůŽŶŐƚŚĞ
ƵĐŬůĞLJ džƚĞŶƐŝŽŶŝŶŝƐĐŽŶĨŽƌŵĂŶĐĞǁŝƚŚŽƵŶƚLJŝĐLJĐůĞDĂƐƚĞƌWůĂŶ͕ĂĐĐŽƌĚŝŶŐƚŽƚŚĞ
ŽƵŶƚLJ͘
WĂŐĞϯ͘ϭϮ͘ͲϮϵ ĚĚ&ŝŐƵƌĞϱĨƌŽŵƚŚĞd/^ƚŽƐŚŽǁƚŚĞĂůůŽĐĂƚŝŽŶŽĨƚƌŝƉƐĨƌŽŵƚŚĞƉƌŽũĞĐƚƚŽĂƌĞĂƌŽĂĚͲ
ǁĂLJƐ͘^ĞĞƚƚĂĐŚŵĞŶƚϲ͘ŽŶǀĞƌƚWDͬDƉĞĂŬĚĂƚĂƚŽdĨŽƌĞĂĐŚŽĨƵƐĞĂŶĚƌĞĨĞƌͲ
ĞŶĐĞ͘ůƐŽ͕ŶŽƚĞŶŽƚƚŚĞƚƌŝƉŐĞŶĞƌĂƚŝŽŶĚŝƐĐƵƐƐŝŽŶƚŚĂƚƚŚĞƚƌŝƉŐĞŶĞƌĂƚŝŽŶƌĂƚĞƐƵƐĞĚ
ĨŽƌƚŚĞƉƌŽũĞĐƚĂƌĞĨƵůů/d ƚƌŝƉƌĂƚĞƐǁŚŝĐŚŚĂǀĞŶŽƚďĞĞŶĂĚũƵƐƚĞĚĨŽƌůŽĐĂůĐŽŶĚŝƚŝŽŶƐ
ƐƵĐŚĂƐŝŶĐƌĞĂƐĞĚďŝŬĞŽƌƚƌĂŶƐŝƚ͕ŽƌĂĚũƵƐƚĞĚĨŽƌƚŚĞWƌŽũĞĐƚ͛ƐĐŽŶĚŝƚŝŽŶƐĂŶĚƚŚĞƌĞĨŽƌĞ
ĚĞŵŽŶƐƚƌĂƚĞŵŽƌĞƚƌŝƉƐƚŚĂŶĂƌĞůŝŬĞůLJƚŽŽĐĐƵƌ͘^ĞĞƚƚĂĐŚŵĞŶƚϳ͘;^ĞĞƉŽƐƐŝďůĞĂĚͲ
ũƵƐƚŵĞŶƚƐŝŶƚƌŝƉŐĞŶĞƌĂƚŝŽŶĂŶĚsDdĂƐƐŽĐŝĂƚĞĚǁŝƚŚǀĂƌŝŽƵƐŵŝƚŝŐĂƚŝŽŶĂŶĚƐƚƌĂƚĞŐŝĞƐ
ŝŶƚŚĞYƐĞĐƚŝŽŶ͘Ϳ
WĂŐĞϯ͘ϭϮͲϯϯ ƐŶŽƚĞĚŝŶƉƌĞǀŝŽƵƐĐŽŵŵĞŶƚƐ͕ƚŚĞƐĞĐƚŝŽŶŽŶsDdŽǀĞƌƐƚĂƚĞƚŚĞsDdĨŽƌƚŚĞƉƌŽũĞĐƚ
ĂŶĚƐŚŽƵůĚďĞƌĞǀŝƐĞĚƚŽƌĞůLJŽŶƚŚĞsDdĞƐƚŝŵĂƚĞƐƉƌĞƉĂƌĞĚĨŽƌĂů DŽĚ͘tŚŝůĞƚŚŝƐ
ŵĂLJďĞĐŚĂƌĂĐƚĞƌŝnjĞĚĂƐĂ͞ǁŽƌƐƚĐĂƐĞ͟ƐĐĞŶĂƌŝŽĨŽƌĚŝƐĐƵƐƐŝŽŶƉƵƌƉŽƐĞƐ͕ƚŚŝƐƐŚŽƵůĚďĞ
ĐŽƌƌĞĐƚĞĚƐŽƚŚĂƚƚŚŝƐ͞ƌĞƉŽƌƚŝŶŐŽŶůLJ͟ƉƌŽǀŝĚĞƐĂĨĂŝƌĂŶĚĂĐĐƵƌĂƚĞĞƐƚŝŵĂƚĞƚŚĂƚŝƐĐŽŶͲ
ƐŝƐƚĞŶƚǁŝƚŚŽƚŚĞƌsDdĚĂƚĂƌĞƉŽƌƚĞĚŝŶƚŚĞ /ZŝŶƚŚĞĂů DŽĚĞƐƚŝŵĂƚĞƐĂŶĚƚŚĂƚ
ƋƵĂŶƚŝĨŝĞƐƚŚĞƌĞůĂƚŝǀĞďĞŶĞĨŝƚƐŽĨǀĂƌŝŽƵƐŵŝƚŝŐĂƚŝŽŶƐƚƌĂƚĞŐŝĞƐ͘ŽƚŚƚŚĞ^ƚĂƚĞKĨĨŝĐĞ
ŽĨWůĂŶŶŝŶŐĂŶĚZĞƐĞĂƌĐŚ;KWZͿĂŶĚƚŚĞĂůŝĨŽƌŶŝĂŝƌZĞƐŽƵƌĐĞƐŽĂƌĚ;ZͿƌĞĐŽŐŶŝnjĞ
Ăů DŽĚĂƐƚŚĞƉƌĞĨĞƌƌĞĚƚŽŽůĨŽƌƚŚŝƐƉƵƌƉŽƐĞǁŚĞƌĞƚƌŝƉͲďĂƐĞĚĞƐƚŝŵĂƚĞƐĂƌĞƵƐĞĚ͘
KWZĨƵƌƚŚĞƌƌĞĐŽŵŵĞŶĚƐƵƐŝŶŐƚŚĞĂůŝĨŽƌŶŝĂ^ƚĂƚĞdƌĂǀĞůĞŵĂŶĚDŽĚĞů;^dDͿdͲ
ƐƉĞĐŝĨŝĐƚƌŝƉůĞŶŐƚŚĞƐƚŝŵĂƚĞƐǁŚĞŶƵƐŝŶŐƚŚŝƐƚŽŽů͕ĂŶĚƚŚĞĂůŝĨŽƌŶŝĂŝƌZĞƐŽƵƌĐĞƐ
ŽĂƌĚ;ZͿĨƵƌƚŚĞƌƌĞĐŽŵŵĞŶĚƐƚŚĂƚƚŚĞŵŝƚŝŐĂƚŝŽŶĞƐƚŝŵĂƚŝŽŶƚŽŽůŝŶĂů DŽĚďĞ
ĂƵŐŵĞŶƚĞĚďLJŵŝƚŝŐĂƚŝŽŶƐĞƐƚŝŵĂƚĞƐĐŽŶƚĂŝŶĞĚŝŶƚŚĞŝƌ'ƌĞĞŶŚŽƵƐĞ'ĂƐYƵĂŶƚŝĨŝĐĂƚŝŽŶ
DĞƚŚŽĚŽůŽŐLJ;ϮϬϭϱͿĨŽƌƉƌŽũĞĐƚĚĞŶƐŝƚLJ͕ƉƌŽũĞĐƚǁĂůŬĂďŝůŝƚLJ͕ƚƌĂŶƐŝƚĂĐĐĞƐƐŝďŝůŝƚLJ͕ƚƌĂĨĨŝĐ
ĐĂůŵŝŶŐĨĞĂƚƵƌĞƐ͕ƚƌĂŶƐŝƚ͕ŚŽƵƐŝŶŐ͕ůĂŶĚƵƐĞ͕ďŝŬĞƉĂƚŚ͕ƉĞĚĞƐƚƌŝĂŶĨĂĐŝůŝƚLJĂŶĚĂĨĨŽƌĚĂďůĞ
ŚŽƵƐŝŶŐĨĞĂƚƵƌĞƐŽĨĂƉƌŽũĞĐƚ͘dŚĞsDdĞƐƚŝŵĂƚŝŽŶŵĞƚŚŽĚƌĞƉŽƌƚĞĚŝŶƚŚĞƚĞdžƚŽĨƚŚĞ
/ZĚŽĞƐŶŽƚĂĐĐŽƵŶƚĨŽƌĂŶLJŽĨƚŚĞĂďŽǀĞ͕ĂŶĚĂů DŽĚŚĂƐůŝŵ ŝƚĞĚĂďŝůŝƚLJƚŽĞƐƚŝŵĂƚĞ
PPD-47
PPD-48
PPD-49
PPD-50
PPD-51
PPD-52
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϭϬ
sDdďĞŶĞĨŝƚƐĨƌŽŵǀĂƌŝŽƵƐĂŝƌƋƵĂůŝƚLJĂŶĚƚƌĂŶƐƉŽƌƚĂƚŝŽŶƐƚƌĂƚĞŐŝĞƐ͘ĚĚŝƚŝŽŶŽĨƚŚĞ
''YDŵŝƚŝŐĂƚŝŽŶƐŝƐŶĞĐĞƐƐĂƌLJƚŽƉƌŽǀŝĚĞĨƵůůĚŝƐĐůŽƐƵƌĞŽĨƉŽƚĞŶƚŝĂůŶĞƚŝŵƉĂĐƚƐďĞĨŽƌĞ
ĂŶĚĂĨƚĞƌŵŝƚŝŐĂƚŝŽŶ͘
KWZĐŽŶƐŝĚĞƌƐƚŚĞƵƐĂŐĞŽĨĂů DŽĚĂƐĂĐĞŶƚƌĂůĨĞĂƚƵƌĞŽĨ^ϳϰϯŝŵƉůĞŵĞŶƚĂƚŝŽŶ͘
dŚĞƌĞǀŝƐĞĚŐƵŝĚĞůŝŶĞƐƐƚĂƚĞƚŚĂƚ͙͞ĂŐĞŶĐŝĞƐĐĂŶƵƐĞƚƌĂǀĞůĚĞŵĂŶĚŵŽĚĞůƐŽƌƐƵƌǀĞLJ
ĚĂƚĂƚŽĞƐƚŝŵĂƚĞĞdžŝƐƚŝŶŐƚƌŝƉůĞŶŐƚŚƐĂŶĚŝŶƉƵƚƚŚŽƐĞŝŶƚŽƐŬĞƚĐŚŵŽĚĞůƐƐƵĐŚĂƐĂů Ͳ
DŽĚƚŽĂĐŚŝĞǀĞŵŽƌĞĂĐĐƵƌĂƚĞƌĞƐƵůƚƐ͘tŚĞŶĞǀĞƌƉŽƐƐŝďůĞ͕ĂŐĞŶĐŝĞƐƐŚŽƵůĚŝŶƉƵƚůŽĐĂůͲ
ŝnjĞĚƚƌŝƉůĞŶŐƚŚƐŝŶƚŽĂƐŬĞƚĐŚŵŽĚĞůƚŽƚĂŝůŽƌƚŚĞĂŶĂůLJƐŝƐƚŽƚŚĞƉƌŽũĞĐƚůŽĐĂƚŝŽŶ͘͟dŚĞ
ŐƵŝĚĞůŝŶĞƐĂůƐŽƐƚĂƚĞƚŚĂƚƚŚĞƌĞƐŚŽƵůĚďĞĐŽŶƐŝƐƚĞŶĐLJďĞƚǁĞĞŶƚŚĞŵŽĚĞůƐƵƐĞĚƚŽĚĞͲ
ƚĞƌŵŝŶĞƚƌŝƉŐĞŶĞƌĂƚŝŽŶ͕ĂŝƌƋƵĂůŝƚLJĂŶĚsDd͘
ĂƐĞĚŽŶƚŚĞĂďŽǀĞ͕ƚŚĞsDdĞƐƚŝŵĂƚĞƐƉƌĞƉĂƌĞĚĨŽƌƚŚĞĂů DŽĚŵŽĚĞůƚŚĂƚĂƌĞĂůͲ
ƌĞĂĚLJĐŽŶƚĂŝŶĞĚŝŶƚŚĞ /ZƐŚŽƵůĚďĞƵƐĞĚǁŚĞŶĞƐƚŝŵĂƚŝŶŐĂŶĚƌĞƉŽƌƚŝŶŐsDd͕ďĞĨŽƌĞ
ĂŶĚĂĨƚĞƌŵŝƚŝŐĂƚŝŽŶ͘ĂƐĞĚŽŶƚŚĞWƌŽũĞĐƚĂů DŽĚŝŶƉƉĞŶĚŝdž,͕ƚŚĞĚĂŝůLJsDdĨŽƌ
ƚŚĞƉƌŽũĞĐƚŝƐϰϰ͕ϬϰϮŵŝůĞƐƉĞƌĚĂLJ͕ŽƌϲϭŵŝůĞƐĂĚĂLJƉĞƌŚŽƵƐĞŚŽůĚ͖ĨŽƌƚŚĞWƌŽũĞĐƚǁŝƚŚ
ŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐ;ĂůƚŚŽƵŐŚŶŽƚĂůůŵŝƚŝŐĂƚŝŽŶƐŵĞĂƐƵƌĞƐŚĂǀĞƋƵĂŶƚŝĨŝĞĚsDdďĞŶĞͲ
ĨŝƚƐͿ͕ƚŚĞƚŽƚĂůŝƐϯϲ͕ϱϱϵŵŝůĞƐƉĞƌĚĂLJ͕ŽƌϱϬ͘ϴŵŝůĞƐƉĞƌŚŽƵƐĞŚŽůĚƉĞƌĚĂLJ͘^ĞĞƚƚĂĐŚͲ
ŵĞŶƚϴ͘ĂƐĞĚŽŶƚŚĞDŝƚŝŐĂƚĞĚWƌŽũĞĐƚĂů DŽĚŝŶƉƉĞŶĚŝdžY͕ƚŚĞĚĂŝůLJsDdĨŽƌƚŚĞ
DŝƚŝŐĂƚĞĚWƌŽũĞĐƚŝƐϰϯ͕ϴϮϱŵŝůĞƐƉĞƌĚĂLJ͕ŽƌϲϬŵŝůĞƐĂĚĂLJƉĞƌŚŽƵƐĞŚŽůĚ͖ĨŽƌƚŚĞDŝƚŝͲ
ŐĂƚĞĚWƌŽũĞĐƚǁŝƚŚŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐ;ŶŽƚĂůůŵŝƚŝŐĂƚŝŽŶƐŵĞĂƐƵƌĞƐŚĂǀĞƋƵĂŶƚŝĨŝĞĚ
sDdďĞŶĞĨŝƚƐͿ͕ƚŚĞƚŽƚĂůŝƐϯϲ͕ϯϮϵŵŝůĞƐƉĞƌĚĂLJ͕ŽƌϱϬ͘ϰŵŝůĞƐƉĞƌŚŽƵƐĞŚŽůĚƉĞƌĚĂLJ͘
^ĞĞƚƚĂĐŚŵĞŶƚϵ͘dŚĞƐĞĂů DŽĚĞƐƚŝŵĂƚĞƐĂƌĞǀĞƌLJĐŽŶƐĞƌǀĂƚŝǀĞďĞĐĂƵƐĞƚŚĞLJĂƐͲ
ƐƵŵĞƚŚĞŽƵŶƚLJǁŝĚĞ,ŽŵĞͲtŽƌŬŝƐƚĂŶĐĞŽĨϭϯŵŝůĞƐƉĞƌƚƌŝƉ͕ƌĂƚŚĞƌƚŚĂŶƚŚĞƚƌĂĨĨŝĐ
ĂŶĂůLJƐŝƐnjŽŶĞƐƉĞĐŝĨŝĐƚƌŝƉůĞŶŐƚŚǀĂůƵĞƐƌĞĐŽŵŵĞŶĚĞĚďLJKWZĨƌŽŵĂůƚƌĂŶƐ͛ϮϬϭϱĂůŝͲ
ĨŽƌŶŝĂ^ƚĂƚĞĞŵĂŶĚDŽĚĞůƚƌŝƉůĞŶŐƚŚǀĂůƵĞƐĨŽƌ^ŽƵƚŚ^ĂŶ>ƵŝƐKďŝƐƉŽ͘dŚĞsDdĨŽƌ
ďŽƚŚƚŚĞDŝƚŝŐĂƚĞĚWƌŽũĞĐƚǁŝƚŚŵŝƚŝŐĂƚŝŽŶƐĂŶĚƚŚĞWƌŽũĞĐƚǁŝƚŚŵŝƚŝŐĂƚŝŽŶƐŝƐůĞƐƐƚŚĂŶ
ƚŚĞĐƵƌƌĞŶƚĐŝƚLJǁŝĚĞĂǀĞƌĂŐĞŽĨϱϰsDdƉĞƌŚŽƵƐĞŚŽůĚƉĞƌĚĂLJ͘
ƐĚŝƌĞĐƚĞĚďLJZĂŶĚKWZ͕sDdŝŶƉƵƚƐƚŽƚŚĞĂŝƌƋƵĂůŝƚLJŵŽĚĞůƐŚŽƵůĚďĞďĂƐĞĚŽŶ
^dDůŽĐĂůdƚƌŝƉůĞŶŐƚŚĨĂĐƚŽƌƐ͘dŚŝƐǁŽƵůĚŵĞĂŶƚŚĂƚĨŽƌƐŽƵƚŚ^>K;^dDdƐ
ϯϯϯϮĂŶĚϯϯϯϯͿƚŚĞŶŽŵŝŶĂůŚŽŵĞͲďĂƐĞĚƚƌŝƉůĞŶŐƚŚƐƐŚŽƵůĚďĞϲ͘ϰŵŝůĞƐĨŽƌǁŽƌŬƚƌŝƉƐ͕
ϯ͘ϰŵŝůĞƐĨŽƌ͞ŽƚŚĞƌ͟ƚƌŝƉƐĂŶĚϯ͘ϯŵŝůĞƐĨŽƌƐŚŽƉƉŝŶŐƚƌŝƉƐ͘WƌŽũĞĐƚĞĚsDdƐŚŽƵůĚďĞĚĞͲ
ƚĞƌŵŝŶĞĚǁŝƚŚĂƉƉƌŽƉƌŝĂƚĞĂĚũƵƐƚŵĞŶƚĨŽƌƚŚĞĨŽůůŽǁŝŶŐĞdžŝƐƚŝŶŐƉƌŽũĞĐƚĨĞĂƚƵƌĞƐƚŚĂƚ
ŵĂLJŶŽƚďĞƋƵĂŶƚŝĨŝĞĚŝŶƚŚĞĂů DŽĚ͕ďƵƚĐĂŶďĞĞƐƚŝŵĂƚĞĚďLJ'ƌĞĞŶŚŽƵƐĞ'ĂƐYƵĂŶͲ
ƚŝĨŝĐĂƚŝŽŶDĞƚŚŽĚŽůŽŐLJ͗
Ă͘WƌŽũĞĐƚĚĞŶƐŝƚLJŝƐŵŽƌĞƚŚĂŶƚŚĞďĂƐĞůŝŶĞϳ͘ϲƵŶŝƚƐƉĞƌĂĐƌĞ͘WƌŽũĞĐƚŶĞƚĚĞŶƐŝƚLJŝƐ
ĞƐƚŝŵĂƚĞĚĂƚϭϯƵŶŝƚƐƉĞƌŶĞƚĂĐƌĞ͘ϰ͘ϱйsDdƌĞĚƵĐƚŝŽŶŝƐĂƐƐŽĐŝĂƚĞĚǁŝƚŚƚŚŝƐ͘
ď͘dƌĂŶƐŝƚƐŚĂƌĞ͘dŚĞƌĞŝƐŝŶĐƌĞĂƐĞĚƚƌĂŶƐŝƚƐŚĂƌĞďĞĐĂƵƐĞŽĨƉƌŽdžŝŵŝƚLJƚŽďƵƐƐƚŽƉƐĂŶĚ
ƚƌĂŶƐŝƚƌŽƵƚĞƐ͘ĨŝǀĞƉĞƌĐĞŶƚƚƌĂŶƐŝƚƐŚĂƌĞƐŚŽƵůĚďĞĂƐƐƵŵĞĚ͕ĂďŽǀĞƚŚĞďĂƐĞůŝŶĞ
ϭ͘ϯƉĞƌĐĞŶƚ͘
Đ͘,ŽƵƐŝŶŐĂĨĨŽƌĚĂďŝůŝƚLJ͘dŚƌĞĞŚƵŶĚƌĞĚƵŶŝƚƐĂƌĞĐŽŶƐŝĚĞƌĞĚĂĨĨŽƌĚĂďůĞƚŽůŽǁĂŶĚ
ŵŽĚĞƌĂƚĞŝŶĐŽŵĞŚŽƵƐĞŚŽůĚƐ͕ĞŝƚŚĞƌďLJĚĞƐŝŐŶŽƌĐŽŶƚƌĂĐƚ͘dŚŝƐǁŽƵůĚƌĞƐƵůƚŝŶĂ
ϭ͘ϳйƌĞĚƵĐƚŝŽŶŝŶsDd;ϯϬϬͬϳϮϬΎϰйͿ͘
PPD-52
Cont.
PPD-53
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϭϭ
Ě͘WƌŽũĞĐƚŽƌŝĞŶƚĂƚŝŽŶĂƌŽƵŶĚĂďŝŬĞĐŽƌƌŝĚŽƌ͘Ϭ͘ϮϱйƌĞĚƵĐƚŝŽŶŝŶsDd͘
Ğ͘WƌŽũĞĐƚďŝŬĞƉĂƚŚĐŽŶŶĞĐƚŝŽŶƐ͘ŶĂĚĚŝƚŝŽŶĂůϮ͘ϮϱйƌĞĚƵĐƚŝŽŶ;Ϯ͘ϱйƚŽƚĂůĨŽƌďŝŬĞ
ĨĂĐŝůŝƚŝĞƐͿ͘
Ĩ͘ĚĚĞĚŝŶƚĞƌƐĞĐƚŝŽŶĚĞŶƐŝƚLJ͘dŚĞƌĞĂƌĞϵϬŝŶƚĞƌƐĞĐƚŝŽŶƐƉĞƌƐƋƵĂƌĞŵŝůĞĐŽŵƉĂƌĞĚƚŽ
ƚŚĞŶŽƌŵŽĨϯϲ͘dŚĞƌĞƐƵůƚƐŝŶĂϲ͘ϱйsDdƌĞĚƵĐƚŝŽŶ͘
Ő͘WĞĚŶĞƚǁŽƌŬĂŶĚĐŽŶŶĞĐƚŝŽŶƐ͘ϮйsDdƌĞĚƵĐƚŝŽŶ͘
Ś͘dƌĂĨĨŝĐĐĂůŵŝŶŐŽŶĂůůƐƚƌĞĞƚƐ͕ƌĞƐƵůƚŝŶŐŝŶĂϭйsDdƌĞĚƵĐƚŝŽŶ͘
ŝ͘ŝŬĞůĂŶĞĚĞŶƐŝƚLJŝŶĞdžĐĞƐƐŽĨϬ͘ϯϰŵŝůĞƐƉĞƌƐƋƵĂƌĞŵŝůĞ͘dŽƚĂůŽŶƐŝƚĞďŝŬĞůĂŶĞƐĂŶĚ
ďŝŬĞƉĂƚŚƐ;ůĂƐƐ/ĂŶĚůĂƐƐ//ŽŶůLJͿĂƌĞϯϴ͘ϵϳůĂŶĞŵŝůĞƐƉĞƌƐƋƵĂƌĞŵŝůĞ͕ĐŽŵƉĂƌĞĚ
ƚŽƚŚĞĞdžŝƐƚŝŶŐĐŝƚLJǁŝĚĞĂǀĞƌĂŐĞŽĨϯ͘ϭϵůĂŶĞŵŝůĞƐƉĞƌƐƋƵĂƌĞŵŝůĞ͘ĚĚĞĚďŝŬĞĨĂĐŝůͲ
ŝƚLJƌĞĚƵĐƚŝŽŶŽĨϰ͘ϭйŽĨsDdZ͘
ũ͘^ĐŚŽŽůďƵƐƐĞƌǀŝĐĞ͘^ĂŶ>ƵŝƐŽĂƐƚĂůƉƌŽǀŝĚĞƐďƵƐƐĞƌǀŝĐĞƚŽĞ ůĞŵĞŶƚĂƌLJƐƚƵĚĞŶƚƐ
ŽƵƚƐŝĚĞŽĨϭЪŵŝůĞƐ͕ĂŶĚƚŽ:ƌ,ŝŐŚƐƚƵĚĞŶƚƐŽƵƚƐŝĚĞŽĨϮŵŝůĞƐ͘dŚĞƉƌŽũĞĐƚƋƵĂůŝĨŝĞƐ
ĨŽƌďŽƚŚ͘ĂƐĞĚŽŶƚŚŝƐƚŚĞƌĞŝƐĂϯϴйƐĂǀŝŶŐƐŝŶƐĐŚŽŽůsDd͕Žƌϰ͘ϰйƐĂǀŝŶŐƐŝŶƚŽƚĂů
sDdĂƚĂϭϴйƐĐŚŽŽůsDdƐŚĂƌĞŽĨƚŽƚĂůsDdĂŶĚĂĚũƵƐƚŵĞŶƚĨŽƌƚƌŝƉůĞŶŐƚŚ͘
dŽƚĂůƌĞĚƵĐƚŝŽŶƐĨŽƌŵŝƚŝŐĂƚŝŽŶƐĂŶĚĨĞĂƚƵƌĞƐŝŶƚŚĞƉƌŽũĞĐƚƌĞƐƵůƚŝŶƌĞĚƵĐƚŝŽŶƐŝŶ
ƚŚĞĂů DŽĚsDdĞƐƚŝŵĂƚĞƐŽĨϯϭ͘ϱй͘DŽĚĞƐŚĂƌĞ͕ƚƌŝƉůĞŶŐƚŚĂŶĚƉĂƐƐͲďLJĨĂĐƚŽƌƐ
ƐŚŽƵůĚďĞĂĚũƵƐƚĞĚƚŽƌĞĨůĞĐƚƚŚĞůŽĐĂůͲƐĞƌǀŝŶŐŶĂƚƵƌĞŽĨƚŚĞƚŽǁŶĐĞŶƚĞƌƵƐĞƐ͘
WĂŐĞϯ͘ϭϮͲϰϬ dŚĞƐĞŐŵĞŶƚĂŶĂůLJƐŝƐŝƐŶŽƚĐůĞĂƌƌĞůĂƚŝǀĞƚŽ'ĞŶĞƌĂůWůĂŶĐŽŶĨŽƌŵŝƚLJƚŚƌĞƐŚŽůĚƐ͘ĚĚĂ
ƚĂďůĞƚŚĂƚƐŚŽǁƐƚŚĞƉƌŽũĞĐƚĞĚƌŽĂĚǁĂLJd͕ƚŚĞĞdžŝƐƚŝŶŐƌŽĂĚǁĂLJd͕ĂŶĚƚŚĞĂƉƉůŝĐĂͲ
ďůĞ'ĞŶĞƌĂůWůĂŶƚŚƌĞƐŚŽůĚ͘ůƐŽ͕ƉůĞĂƐĞƉƌŽǀŝĚĞĂƉƌŽũĞĐƚŝŽŶĨŽƌ:ĞƐƉĞƌƐĞŶƚŽĚĞƚĞƌŵŝŶĞ
ǁŚĂƚƚŚĞƉƌŽũĞĐƚŝŽŶƐĂƌĞĨŽƌƚŚĂƚĨĂĐŝůŝƚLJďĂƐĞĚŽŶĐŽŶǀĞƌƐŝŽŶŽĨƉĞĂŬŚŽƵƌƉƌŽũĞĐƚŝŽŶƐ
ŽƌƐĞŐŵĞŶƚƉƌŽũĞĐƚŝŽŶƐĨƌŽŵƚŚĞƚƌĂĨĨŝĐŵŽĚĞů͘
WĂŐĞϯ͘ϭϮͲϰϵ ^ĂŵĞŝƐƐƵĞĂƐĂďŽǀĞ͘WƌŽǀŝĚĞĂƚĂďůĞƚŚĂƚĐŽŵƉĂƌĞƐƉƌŽũĞĐƚŝŽŶƐǁŝƚŚ'WƚŚƌĞƐŚŽůĚƐ͘
^ŚŽǁĂƉƉƌŽƉƌŝĂƚĞƐƚƌĞĞƚĐůĂƐƐŝĨŝĐĂƚŝŽŶ͘
WĂŐĞϯ͘ϭϮͲϱϲ hŶĚĞƌWůĂŶZĞƋƵŝƌĞŵĞŶƚƐĂŶĚdŝŵŝŶŐĨŽƌDDdƌĂŶƐϳͲĂ͕ƚŚĂƚƚŚĞĞĂƌůLJƉŚĂƐĞƐŽĨƚŚĞ
ƉƌŽũĞĐƚĚŽŶŽƚĂĚĚƐƵďƐƚĂŶƚŝĂůůLJƚŽƚŚĞƋƵĞƵĞĂŶĚĚŽŶŽƚĚĞŐƌĂĚĞƚŚĞŝŶƚĞƌƐĞĐƚŝŽŶ>K^͕
ĂŶĚƚŚĂƚWŚĂƐĞƐϭƚŚƌŽƵŐŚϯŵĂLJďĞĐŽŶƐƚƌƵĐƚĞĚǁŝƚŚŽƵƚƐƵďƐƚĂŶƚŝĂůĚĞŐƌĂĚĂƚŝŽŶŽĨƚŚĞ
ŝŶƚĞƌƐĞĐƚŝŽŶĨƌŽŵƚŚĞWƌŽũĞĐƚ͘dŚĞƌĞĨŽƌĞ͕ŝĨƚŚĞ^>K^ĂŶ>ƵŝƐƌĞĞŬďƌŝĚŐĞǁŝĚĞŶŝŶŐŝƐ
ĚĞůĂLJĞĚ͕ƚŚĞWtŝƌĞĐƚŽƌŵĂLJĚĞĨĞƌƚŚĞƐĞŝŵƉƌŽǀĞŵĞŶƚƐƵŶƚŝůƚŚĞLJĂƌĞĐŽŵƉůĞƚĞĚ͕ďƵƚ
ƚŚĂƚƚŚĞLJŵĂLJŶŽƚďĞĚĞĨĞƌƌĞĚďĞLJŽŶĚƚŚĞĞŶĚŽĨWŚĂƐĞϯŽĨƚŚĞƉƌŽũĞĐƚ͘
WĂŐĞϯ͘ϭϮͲϲϰ ůĂƌŝĨLJƚŚĂƚƚŚĞƉƌŽũĞĐƚƉƌŽƉŽƐĞƐƚŚĞŝŶƐƚĂůůĂƚŝŽŶŽĨĞĂƐƚďŽƵŶĚůĂƐƐ//ďŝĐLJĐůĞůĂŶĞƐŽŶ
ƵĐŬůĞLJĨƌŽŵsĂĐŚĞůůƚŽƚŚĞĞĂƐƚƉƌŽƉĞƌƚLJďŽƵŶĚĂƌLJ͘ůĂƌŝĨLJ͕ǁŝƚŚĂŶĞdžŚŝďŝƚŝĨŶĞĐĞƐͲ
ƐĂƌLJ͕ƚŚĂƚƚŚĞǁĞƐƚďŽƵŶĚůĂƐƐ//ǁŝůůƚƌĂŶƐŝƚŝŽŶƚŽĂůĂƐƐ/ƚŚĂƚǁŝůůŐŽŽǀĞƌĂŶĚŶŽƌƚŚŽĨ
dĂŶŬ&ĂƌŵƌĞĞŬĂƐĐůŽƐĞƚŽƚŚĞdĂŶŬ&ĂƌŵƌĞĞŬĂƐŝƐƉƌĂĐƚŝĐĂďůĞ;ϯϱ͛ĐƌĞĞŬƐĞƚͲ
ďĂĐŬͬǁŝůĚůŝĨĞĐŽƌƌŝĚŽƌͿůƐŽŶŽƚĞƚŚĂƚƚŚĞŽƵŶƚLJDWĂƉƉůŝĞƐĂůŽŶŐƵĐŬůĞLJZŽĂĚ͕ĂŶĚ
ĐŽŶƐƚƌƵĐƚŝŽŶŽĨƚŚĞůĂƐƐ/ĨĂĐŝůŝƚLJŽŶƚŚĞŶŽƌƚŚƐŝĚĞŽĨƵĐŬůĞLJZŽĂĚŝŶƐƚĞĂĚŽĨĂĐŽŶƚŝŶƵͲ
ŽƵƐůĂƐƐ//;ĂŶĚŶŽůĂƐƐ/ͿĂƐƉƌĞƐĐƌŝďĞĚďLJƚŚĞŽƵŶƚLJWůĂŶŝƐĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞ
ŽƵŶƚLJŝĐLJĐůĞDĂƐƚĞƌWůĂŶ͕ĂŶĚĨƵƌƚŚĞƌƚŚĂƚƚŚĞůĂƐƐ//ǁŝůůďĞŝŶƐƚĂůůĞĚĂƚƐƵĐŚƚŝŵĞŝŶ
PPD-53
Cont.
PPD-54
PPD-55
PPD-56
PPD-57
PPD-58
PPD-59
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϭϮ
ƚŚĞĨƵƚƵƌĞǁŚĞŶƚŚĞďƌŝĚŐĞŝƐǁŝĚĞŶĞĚ͘&ƵƌƚŚĞƌ͕ƚŚĂƚŝŶƐƚĂůůĂƚŝŽŶŽĨĞŝƚŚĞƌƚŚĞůĂƐƐ/Žƌ
ƚŚĞůĂƐƐ//ŝƐĐŽŶƐŝƐƚĞŶƚǁŝƚŚŽƵŶƚLJŝŬĞDĂƐƚĞƌWůĂŶĂŶĚƚŚĞĨŝŶĚŝŶŐƐƵŶĚĞƌƚŚĞd/^͘
dĂďůĞϯ͘ϭϮͲϭϯ ŽůƵŵŶŚĞĂĚĞƌƌĞĨĞƌƐƚŽ͞ džŝƐƚŝŶŐEŽWƌŽũĞĐƚ͟ĂŶĚ͞ džŝƐƚŝŶŐнWƌŽũĞĐƚ͘͟ŽƌƌĞĐƚƚŽƌĞĂĚ
͞EĞĂƌdĞƌŵEŽWƌŽũĞĐƚ͟ĂŶĚ͞EĞĂƌdĞƌŵнWƌŽũĞĐƚ͘͟
dĂďůĞϯ͘ϭϮͲϭϰ ŽůƵŵŶŚĞĂĚĞƌƌĞĨĞƌƐƚŽ͞ džŝƐƚŝŶŐ͟ĂŶĚ͞ džŝƐƚŝŶŐнWƌŽũĞĐƚ͘͟ŽƌƌĞĐƚƚŽƌĞĂĚ͞EĞĂƌ
dĞƌŵ͟ĂŶĚ͞EĞĂƌdĞƌŵнWƌŽũĞĐƚ͘͟
WĂŐĞϯ͘ϭϮͲϲϴ WĂƌĂŐƌĂƉŚƌĞĨĞƌƐƚŽ^ĞĐƚŝŽŶϯ͘ϭϮ͘ϱ͘dŚŝƐƐĞĐƚŝŽŶĚŽĞƐŶŽƚĞdžŝƐƚ;^ĞĐƚŝŽŶϯ͘ϭϮĞŶĚƐǁŝƚŚ
^ĞĐƚŝŽŶϯ͘ϭϮ͘ϰͿ͘WůĞĂƐĞĐŽƌƌĞĐƚƚŚŝƐƌĞĨĞƌĞŶĐĞƚŚƌŽƵŐŚŽƵƚ͘
WĂŐĞϯ͘ϭϮͲϲϵ džƉůĂŝŶƚŚĂƚdƌĂŶƐϭϯŝƐĐŽŶƐŝĚĞƌĞĚƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞďĞĐĂƵƐĞƵĐŬůĞLJĂŶĚϮϮϳ
ŝƐŽƵƚƐŝĚĞŽĨƚŚĞŝƚLJ͛ƐũƵƌŝƐĚŝĐƚŝŽŶ͖ƚŚĂƚƚŚĞŝƚLJǁŝůůĚŽǁŚĂƚŝƚĂďůĞƚŽĚŽͶĐŽůůĞĐƚĨĂŝƌ
ƐŚĂƌĞĨĞĞƐĂŶĚĐŽŶƚƌŝďƵƚĞƚŽƚŚĞŝŵƉƌŽǀĞŵĞŶƚŽĨƚŚĞƉƌŽũĞĐƚ͖ďƵƚ͕ƚŚĂƚƚŚĞŝƚLJĐĂŶŶŽƚ
ŐƵĂƌĂŶƚĞĞĐŽŵƉůĞƚŝŽŶ͕ďƵƚŚĂƐĞŶĨŽƌĐĞĚŵŝƚŝŐĂƚŝŽŶƐƚŚĂƚĂƌĞƵŶĚĞƌŝƚƐĐŽŶƚƌŽů͘&ƵƌƚŚĞƌ͕
ƚŚĂƚŝƚƌĞĐŽŵŵĞŶĚƐƚŽƚŚĞƌĞƐƉŽŶƐŝďůĞĂŐĞŶĐŝĞƐƚŚĂƚƚŚĞƐĞŝŵƉƌŽǀĞŵĞŶƚƐďĞƉůĂŶŶĞĚ͕
ĨƵŶĚĞĚĂŶĚŝŶƐƚĂůůĞĚ͘
dĂďůĞϯ͘ϭϯͲϮ hƉĚĂƚĞĐƵƌƌĞŶƚƐƚŽƌĂŐĞǀŽůƵŵĞƐƉĞƌϭͬϭϬͬϮϬϭϳƌĞƉŽƌƚƐ͕ŝŶĐůƵĚŝŶŐϭϳ͕ϯϱϴ&ĨŽƌtŚĂůĞ
ZŽĐŬ͕ϳ͕ϰϬϵ&ĨŽƌ^ĂůŝŶĂƐ͕ĂŶĚϮϭϬ͕ϲϱϬ&ĨŽƌEĂĐŝŵŝĞŶƚŽ͕ĂƐƌĞƉŽƌƚĞĚŽŶƚŚĞŝƚLJ͛Ɛ
ǁĞďƐŝƚĞ͘hƉĚĂƚĞƚĞdžƚŽŶƚŚĞƉĂŐĞĨŽůůŽǁŝŶŐƚŚĞƚĂďůĞ͘
WĂŐĞϯ͘ϭϯͲϭϴ WŽůŝĐLJϯ͘ϳ͘ϰĚŽĞƐŶŽƚĂƉƉĞĂƌƚŽĂƉƉůLJƚŽƚŚĞƉƌŽũĞĐƚƉƌŽƉŽƐĂů͘
WĂŐĞϯ͘ϭϯͲϮϭ /ŶĐůƵĚĞƌĞĨĞƌĞŶĐĞĂŶĚĚĞƐĐƌŝƉƚŝŽŶƚŽƚŚĞhƌďĂŶtĂƚĞƌDĂŶĂŐĞŵĞŶƚWůĂŶ͕ĞƐƉĞĐŝĂůůLJƚŽ
ƌĞĐĞŶƚůLJĂŵĞŶĚĞĚŚĂƉƚĞƌϴƚŚĂƚƐĞƚƐŽƵƚƚŚĞtĂƚĞƌ^ŚŽƌƚĂŐĞŽŶƚŝŶŐĞŶĐLJWůĂŶĂŶĚƚŚĞ
ǀĂƌŝŽƵƐĂĐƚŝŽŶƐƵŶĚĞƌǀĂƌŝŽƵƐƐƚĂŐĞƐŽĨĚƌŽƵŐŚƚ͘EŽƚĞƚŚĂƚƚŚĞWƌŽũĞĐƚt^ƉƌŽũĞĐƚƐ
ƚŚĂƚƚŚĞƉƌŽũĞĐƚĂůƌĞĂĚLJŵĞĞƚƐƚŚĞ͞ƌŝƚŝĐĂů^ƚĂŐĞ͟ĂůůŽƚŵĞŶƚŐŽĂůƐŽĨϰϴŐĂůůŽŶƐƉĞƌĚĂLJ
ƉĞƌƉĞƌƐŽŶ͘^ĞĞƚƚĂĐŚŵĞŶƚϭϬ͘
WĂŐĞϯ͘ϭϯͲϯϲ EŽƚĞƚŚĂƚƚŚĞƉƌŽũĞĐƚƐĞǁĞƌƌŽƵƚĞŝƐǁĞƐƚĞƌůLJĂůŽŶŐ^ƵďƵƌďĂŶ͕ŶŽƚ͞ĞĂƐƚĞƌůLJ͘͟dŚĞĞĂƐƚͲ
ĞƌůLJƌŽƵƚĞŐŽĞƐƚŚƌŽƵŐŚƉƌŝǀĂƚĞƉƌŽƉĞƌƚLJĂŶĚƐĞŶƐŝƚŝǀĞŚĂďŝƚĂƚ͕ĂŶĚǁŽƵůĚĐŽŶĨůŝĐƚǁŝƚŚ
ĞdžŝƐƚŝŶŐƵƚŝůŝƚŝĞƐŝŶƚŚĞtŚŝƚƐŽŶ/ŶĚƵƐƚƌŝĂůWĂƌŬ͘
WĂŐĞϰͲϰ hŶĚĞƌ'ƌŽǁƚŚ/ŶĚƵĐŝŶŐ/ŵƉĂĐƚƐ͕ĚŝƐĐƵƐƐƚŚĂƚƵƚŝůŝƚŝĞƐǁŝůůŶŽƚďĞƉƌŽǀŝĚĞĚŽƵƚƐŝĚĞŽĨƚŚĞ
hZ>ŽƌĐŝƚLJůŝŵŝƚƐ͕ĂŶĚƚŚĂƚŵŽƐƚŽĨƚŚĞƉƌŽƉĞƌƚLJƚŽƚŚĞƐŽƵƚŚŽĨƵĐŬůĞLJŚĂƐĂůƌĞĂĚLJ
ďĞĞŶƉůĂĐĞĚŝŶĂtŝůůŝĂŵƐŽŶĐƚĐŽŶƚƌĂĐƚŽƌĂŶŐŽŶƐĞƌǀĂƚŝŽŶĞĂƐĞŵĞŶƚƐ͘
WĂŐĞϰͲϳ ^ĞĐƚŝŽŶϰ͘ϯ͘ϯƐŚŽƵůĚďĞĂĚĚĞĚƚŽĚŽĐƵŵĞŶƚƚŚĞ /Z͛ƐĨŝŶĚŝŶŐƐǁŝƚŚƌĞŐĂƌĚƚŽ ŶĞƌŐLJ
ZĞƐŽƵƌĐĞƐ͘dŚŝƐĂŶĂůLJƐŝƐĂŶĚŝŶĨŽƌŵĂƚŝŽŶŝŶĨŽƵŶĚŝŶƚŚĞ>h /Z͕ƌĞĨĞƌĞŶĐĞĚŝŶƚŚĞ
EKWĂŶĚŝŵƉĂĐƚĞǀĂůƵĂƚŝŽŶ͕ĂŶĚƚŚĞĂů DŽĚĞƐƚŝŵĂƚĞƐƉƌŽǀŝĚĞĚĨŽƌƚŚĞWƌŽũĞĐƚĂŶĚ
ƚŚĞDW͘dŚĞĨŽůůŽǁŝŶŐŝŶĨŽƌŵĂƚŝŽŶĨƌŽŵƚŚĞ>h /ZƐŚŽƵůĚďĞĂĚĚĞĚƚŽƚŚĞ^ĞĐƚŝŽŶ
ϰ͘ϯ͘ϯ͗
͞ĞǀĞůŽƉŵĞŶƚŽĨƌĞƐŝĚĞŶƚŝĂůĂŶĚŶŽŶͲƌĞƐŝĚĞŶƚŝĂůƵƐĞƐŝĚĞŶƚŝĨŝĞĚďLJƚŚĞ>h hƉĚĂƚĞ
ǁŽƵůĚƌĞƋƵŝƌĞƚŚĞƵƐĞŽĨŶŽŶƌĞŶĞǁĂďůĞďƵŝůĚŝŶŐŵĂƚĞƌŝĂůƐĂŶĚĞŶĞƌŐLJ͕ĂŶĚƚŚĞůŽŶŐͲ
ƚĞƌŵŽĐĐƵƉĂŶĐLJĂŶĚƵƐĞŽĨƉƌŽƉŽƐĞĚƌĞƐŝĚĞŶƚŝĂůĂŶĚŶŽŶƌĞƐŝĚĞŶƚŝĂůǁŽƵůĚŝƌƌĞǀĞƌƐŝďůLJ
ŝŶĐƌĞĂƐĞůŽĐĂůĚĞŵĂŶĚĨŽƌŶŽŶͲƌĞŶĞǁĂďůĞĞŶĞƌŐLJƌĞƐŽƵƌĐĞƐ͘dŚĞƵƐĞŽĨďƵŝůĚŝŶŐŵĂƚĞƌŝͲ
ĂůƐĂŶĚůŽŶŐͲƚĞƌŵĞŶĞƌŐLJƵƐĞƚŚĂƚǁŽƵůĚƌĞƐƵůƚĨƌŽŵƚŚĞŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨƚŚĞ>h
PPD-59
Cont.
PPD-60
PPD-61
PPD-62
PPD-63
PPD-64
PPD-65
PPD-66
PPD-67
PPD-68
PPD-69
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϭϯ
hƉĚĂƚĞǁŽƵůĚŶŽƚƌĞƐƵůƚŝŶƚŚĞƵƐĞŽĨŶŽŶͲƌĞŶĞǁĂďůĞƌĞƐŽƵƌĐĞƐŝŶĂǁĂƐƚĞĨƵůŵĂŶŶĞƌ͕
ĂŶĚǁŽƵůĚŶŽƚďĞĞdžĐĞƐƐŝǀĞŝŶĐŽŶƐŝĚĞƌĂƚŝŽŶŽĨƚŚĞĂĚĚŝƚŝŽŶĂůƉŽƉƵůĂƚŝŽŶŽĨƚŚĞĐŝƚLJƚŚĂƚ
ǁŽƵůĚďĞƐĞƌǀĞĚďLJƚŚĞƵƐĞŽĨƚŚŽƐĞƌĞƐŽƵƌĐĞƐ͘dŚĞƌĞĨŽƌĞ͕ƚŚĞƉƌŽƉŽƐĞĚ>h hƉĚĂƚĞ
ǁŽƵůĚŶŽƚƌĞƐƵůƚŝŶƐŝŐŶŝĨŝĐĂŶƚŝƌƌĞǀĞƌƐŝďůĞĞŶǀŝƌŽŶŵĞŶƚĂůĞĨĨĞĐƚƐƌĞůĂƚĞĚƚŽƚŚĞƵƐĞŽĨ
ŶŽŶͲƌĞŶĞǁĂďůĞƌĞƐŽƵƌĐĞƐ͘
͞dŚĞƉƌŽƉŽƐĞĚŝƌĐƵůĂƚŝŽŶ ůĞŵĞŶƚhƉĚĂƚĞŝĚĞŶƚŝĨŝĞƐƐĞǀĞŶƚĞĞŶƉŽƚĞŶƚŝĂůƐƚƌĞĞƚŶĞƚͲ
ǁŽƌŬĐŚĂŶŐĞƐƚŚĂƚŵĂLJďĞĐŽŶƐŝĚĞƌĞĚĨŽƌĨƵƚƵƌĞŝŵƉůĞŵĞŶƚĂƚŝŽŶ͘/ŶŐĞŶĞƌĂů͕ƚŚĞƉƌŽͲ
ƉŽƐĞĚƐƚƌĞĞƚŶĞƚǁŽƌŬĐŚĂŶŐĞƐǁŽƵůĚĞŶŚĂŶĐĞĞdžŝƐƚŝŶŐǀĞŚŝĐůĞ͕ďŝĐLJĐůĞĂŶĚƉĞĚĞƐƚƌŝĂŶ
ĐŝƌĐƵůĂƚŝŽŶ͖ĞůŝŵŝŶĂƚĞĂƉƌĞǀŝŽƵƐůLJƉƌŽƉŽƐĞĚďƌŝĚŐĞŽǀĞƌƚŚĞhŶŝŽŶWĂĐŝĨŝĐƌĂŝůƌŽĂĚ
ƚƌĂĐŬƐ͖ƉƌŽǀŝĚĞŵŝŶŽƌƐƚƌĞĞƚƌĞĂůŝŐŶŵĞŶƚƐĂŶĚĐŽŶŶĞĐƚŝŽŶƐ͖ĂůƚĞƌĞdžŝƐƚŝŶŐ,ŝŐŚǁĂLJ
ϭϬϭͬ^ƚĂƚĞZŽƵƚĞϭƌĂŵƉƐĂŶĚŝŶƚĞƌĐŚĂŶŐĞƐ͖ĂŶĚĐŽŶǀĞƌƚŽŶĞͲǁĂLJƐƚƌĞĞƚƐƚŽƚǁŽͲǁĂLJ
ĐŝƌĐƵůĂƚŝŽŶ͘dŚĞƐĞƚLJƉĞƐŽĨƐƚƌĞĞƚŶĞƚǁŽƌŬĐŚĂŶŐĞƐǁŽƵůĚƌĞƐƵůƚŝŶůŽĐĂůŝnjĞĚŝŵƉƌŽǀĞͲ
ŵĞŶƚƐŝŶƚĞŶĚĞĚƚŽĞŶŚĂŶĐĞƚƌĂŶƐƉŽƌƚĂƚŝŽŶĂŶĚŵŝŶŝŵŝnjĞĐŝƌĐƵůĂƚŝŽŶͲƌĞůĂƚĞĚĐŽŶĨůŝĐƚƐ͘͟
ĂƐĞĚŽŶƚŚĞĞǀĂůƵĂƚŝŽŶŝŶƚŚĞŝƌYƵĂůŝƚLJĂŶĚ>ĂŶĚhƐĞƐĞĐƚŝŽŶƐƚŽƚŚĞ /Z͕ĂŶĚƚŚĞĂĚͲ
ĚŝƚŝŽŶĂůŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐ͕ƚŚĞWƌŽũĞĐƚǁŽƵůĚƌĞƐƵůƚŝŶĞŶĞƌŐLJƵƐĂŐĞƚŚĂƚŝƐƐŝŐŶŝĨŝͲ
ĐĂŶƚůLJůĞƐƐƚŚĂŶƚŚĂƚĂƐƐƵŵĞĚŝŶƚŚĞ>h /Z͕ĞdžŝƐƚŝŶŐĐŝƚLJƌĞŐƵůĂƚŝŽŶƐ͕ƚŚĞŝƚLJ͛ƐůŝͲ
ŵĂƚĞĐƚŝŽŶWůĂŶ͕ĂŶĚƚŚĞŽƚŚĞƌƌĞŐƵůĂƚŝŽŶƐ͘dŚĞ>h /ZĚĞƚĞƌŵŝŶĞĚƚŚĂƚƚŚĞŝŵƉĂĐƚ
ŽŶĞŶĞƌŐLJƌĞƐŽƵƌĐĞƐǁĂƐůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚĂŶĚƐŽƚŚĞWƌŽũĞĐƚ͛ƐĞdžĐĞĞĚĂŶĐĞŽĨƚŚŽƐĞ
ƐƚĂŶĚĂƌĚƐǁŝůůƌĞƐƵůƚŝŶĂůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚŝŵƉĂĐƚŽŶĞŶĞƌŐLJƌĞƐŽƵƌĐĞƐĨŽƌƚŚĞWƌŽũĞĐƚ͘
WĂŐĞϰͲϴ dŚĞƐĞĨŝŶĚŝŶŐƐƐŚŽƵůĚďĞĞdžƉĂŶĚĞĚƚŽƐƚĂƚĞƚŚĂƚĂůůĨĞĂƐŝďůĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐŚĂǀĞ
ďĞĞŶŝŶĐůƵĚĞĚŝŶƚŚĞƉƌŽũĞĐƚ͕ĂŶĚƚŚĂƚƚŚĞƌĞĂƌĞƐƚŝůůƌĞƐŝĚƵĂůŝŵƉĂĐƚƐ͕Žƌ͕ĂƐĂƉƉůŝĐĂďůĞ͕
ƚŚĂƚƚŚĞŵŝƚŝŐĂƚŝŽŶƐĂƌĞďĞLJŽŶĚƚŚĞĐŽŶƚƌŽůŽĨƚŚĞŝƚLJ͘
WĂŐĞϱͲϭ ŝƐĐƵƐƐŚĞƌĞƚŚĞĚĞǀĞůŽƉŵĞŶƚĂŶĚŶĞĐĞƐƐŝƚLJŽĨƚŚĞDWƌĞƐƵůƚŝŶŐĨƌŽŵƚŚĞǁŝƚŚĚƌĂǁĂů
ŽĨƚŚĞŚĞǀƌŽŶƌĞƐƚŽƌĂƚŝŽŶĂŶĚĚĞǀĞůŽƉŵĞŶƚƉůĂŶƐ͕ĂŶĚƚŚĞƵŶĐĞƌƚĂŝŶƚLJĂŶĚŝŶĨĞĂƐŝďŝůŝƚLJ
ŽĨĂƐƐƵŵŝŶŐƚŚĞŚĞǀƌŽŶĚƌĂŝŶĂŐĞŝŵƉƌŽǀĞŵĞŶƚƐ͘
WĂŐĞϱͲϯ dŚĞĞdžƚĞŶƚŽĨƚŚĞ͞ŶŽŝƐĞƐĞŶƐŝƚŝǀĞƌĞƐŝĚĞŶƚŝĂůƵƐĞƐ͟ŝƐŽŶĞŚŽƵƐĞƚŚĂƚŝƐϭϱϬĨĞĞƚĨƌŽŵ
ƚŚĞĞĂƐƚƉƌŽƉĞƌƚLJůŝŶĞĂŶĚϯϬϬĨĞĞƚĨƌŽŵƚŚĞŶĞĂƌĞƐƚĚĞǀĞůŽƉĞĚƉŽƌƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚ͘
WĂŐĞϱͲϲ ĚĚƚŽƚŚĞ͞ůƚĞƌŶĂƚŝǀĞƐŽŶƐŝĚĞƌĞĚďƵƚŝƐĐĂƌĚĞĚ͟ĂŶĂůƚĞƌŶĂƚŝǀĞƚŚĂƚŝƐƌĞĚƵĐĞĚƉƌŽͲ
ũĞĐƚĂůƚĞƌŶĂƚŝǀĞƚŚĂƚǁŽƵůĚďĞĨĞĂƐŝďůĞƵŶĚĞƌƚŚĞƉŽůŝĐŝĞƐŝŶƚŚĞ>h ͘^ƵĐŚĂƉƌŽũĞĐƚ
ǁĂƐƌĞǀŝĞǁĞĚĚƵƌŝŶŐƚŚĞ>h ƌĞǀŝĞǁĂŶĚƚŚĞWƌĞͲƉƉůŝĐĂƚŝŽŶĂŶĚŝŶĐůƵĚĞĚϱϮϬͲϱϯϬ
ƵŶŝƚƐŽŶƚŚĞƉƌŽũĞĐƚƐŝƚĞ;ĂŶĚǁĂƐƉƌŽďĂďůLJƚŚĞďĂƐŝƐĨŽƌƚŚĞůŽǁĞƌƌĂŶŐĞŽĨĚĞǀĞůŽƉͲ
ŵĞŶƚͿ͘hŶĚĞƌƚŚŝƐĂůƚĞƌŶĂƚŝǀĞ͕ƚŚĞĨŽůůŽǁŝŶŐĐŚĂŶŐĞƐĂŶĚĞĨĨĞĐƚ ƐǁŽƵůĚďĞƉƌĞƐĞŶƚ͗
ϭ͘ůůƚŚĞZͲϮǁŽƵůĚďĞĚĞůĞƚĞĚĂŶĚZͲϭƵŶŝƚƐǁŽƵůĚďĞƉƵƚŝŶƚŚĞŝƌƉůĂĐĞ͘
Ϯ͘ZϯǁŽƵůĚďĞƌĞĚƵĐĞĚďLJϯϮƵŶŝƚƐ͕
ϯ͘ZϰǁŽƵůĚďĞƌĞĚƵĐĞĚďLJϲϱƵŶŝƚƐ;ĞƐƐĞŶƚŝĂůůLJƚŚĞĞĂƐƚƐŝĚĞŽĨ ĂƌƚŚǁŽŽĚͿ͕
ϰ͘>Žǁ/ŶĐŽŵĞZϯ/ŶĐůƵƐŝŽŶĂƌLJǁŽƵůĚďĞĚĞůĞƚĞĚ͘
ϱ͘WƌŽũĞĐƚǁŽƵůĚŚĂǀĞϱй>ŽǁŝŶƚŚĞZϰĂŶĚϭϬйDŽĚŝŶƚŚĞZϯ͘
PPD-69
Cont.
PPD-70
PPD-71
PPD-72
PPD-73
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϭϰ
ϲ͘Zϰ>Žǁ/ŶĐŽŵĞǁŽƵůĚďĞĐŚĂŶŐĞĚĨƌŽŵϮϰƚŽϮϳ͘
ϳ͘ZϯDŽĚŝŶĐŽŵĞǁŽƵůĚďĞĐŚĂŶŐĞĚĨƌŽŵϭϮƚŽϱϯ͘
ϴ͘ǀĞƌĂŐĞƵŶŝƚƐŝnjĞǁŽƵůĚŝŶĐƌĞĂƐĞĨƌŽŵϭ͕ϰϵϴ^&ƚŽϭ͕ϳϰϭ^&͕ĞƐƐĞŶƚŝĂůůLJƚŚĞƐĂŵĞ
ĂǀĞƌĂŐĞƵŶŝƚƐŝnjĞĂƐZŝŐŚĞƚƚŝͲ:ŽŶĞƐ͕^ĞƌƌĂDĞĂĚŽǁƐĂŶĚdŽƐĐĂŶĂ͘
ϵ͘WĂƌŬƐǁŽƵůĚďĞƌĞĚƵĐĞĚƚŽϭϮ͘ϮĂĐƌĞƐĨƌŽŵϭϴ͘EĞŝŐŚďŽƌŚŽŽĚWĂƌŬǁŽƵůĚďĞϱ͘ϳϱ
ĂĐƌĞƐ͕WĂƌŬƐ͕ĂŶĚ/ǁŽƵůĚďĞĞůŝŵŝŶĂƚĞĚ͖WĂƌŬƐ&ĂŶĚ'ǁŽƵůĚďĞĐƵƚŝŶŚĂůĨ͘
ϭϬ͘dŽƚĂůƵŶŝƚƐǁŽƵůĚďĞƌĞĚƵĐĞĚďLJϮϲ͘ϰƉĞƌĐĞŶƚĂŶĚĂǀĞƌĂŐĞĚĂŝůLJƚƌŝƉƐǁŽƵůĚďĞƌĞͲ
ĚƵĐĞĚďLJϮ͘ϯƉĞƌĐĞŶƚ͘,ŝŐŚĞƌŶƵŵďĞƌŽĨZͲϭƵŶŝƚƐǁŽƵůĚŵĂŝŶƚĂŝŶƚŽƚĂůƚƌŝƉŐĞŶĞƌͲ
ĂƚŝŽŶĂƚĂƌĞůĂƚŝǀĞůLJĐŽŶƐƚĂŶƚůĞǀĞů͕ĂŶĚŽĨĨƐŝƚĞƚƌĂĨĨŝĐŝŵƉĂĐƚƐǁŽƵůĚŶŽƚďĞƌĞͲ
ĚƵĐĞĚ͘
ϭϭ͘ǀŝůĂΖƐĐŽŶƚƌŝďƵƚŝŽŶƚŽƚŚĞ/ŶƚĞƌŝŵ&ŝƌĞ^ƚĂƚŝŽŶ;/ŶŝƚŝĂůŽŶƐƚƌƵĐƚŝŽŶĂŶĚKƉĞƌĂƚŝŽŶƐͿ
ĂŶĚƚŚĞƵĐŬůĞLJZŽĂĚ džƚĞŶƐŝŽŶǁŽƵůĚďĞƌĞĚƵĐĞĚďLJϮϬƚŽϮϱƉĞƌĐĞŶƚ͘
ϭϮ͘ǀĞƌĂŐĞƉƌŝĐĞŽĨƵŶŝƚŝŶƉƌŽũĞĐƚǁŽƵůĚŝŶĐƌĞĂƐĞϭϱͲϮϬйďĂƐĞĚŝŶŝŶĐƌĞĂƐĞĚƵŶŝƚƐŝnjĞ
ĂŶĚĐŽƐƚƐ͘
EŽƚĞƵŶĚĞƌƚŚŝƐĂůƚĞƌŶĂƚŝǀĞ͕ŽĨĨƐŝƚĞƚƌĂĨĨŝĐǁŽƵůĚŶŽƚďĞƌĞĚƵĐĞĚ͕ĐŽŶǀĞƌƐŝŽŶŽĨĂŐůĂŶĚ
ǁŽƵůĚŶŽƚďĞƌĞĚƵĐĞĚ;ƌĞƐŝĚĞŶƚŝĂůĚĞǀĞůŽƉĞĚƉŽƌƚŝŽŶŽĨƉƌŽƉĞƌƚLJǁŽƵůĚƐƚŝůůďĞĚĞǀĞůͲ
ŽƉĞĚͿ͕ĂŶĚƚŚĂƚϮϬϬĚǁĞůůŝŶŐƵŶŝƚƐǁŽƵůĚďĞĚŝƐƉůĂĐĞĚƚŽĂŶŽƚŚĞƌƉŽƌƚŝŽŶŽĨƚŚĞŝƚLJŽƌ
ƚŚĞŝŵŵĞĚŝĂƚĞŽƵŶƚLJĂƌĞĂƚŽŵĂŝŶƚĂŝŶƚŚĞƉƌŽũĞĐƚƐƵƉƉůLJŽĨŚŽƵƐŝŶŐƚŽďĞďƵŝůƚƵŶĚĞƌ
ƚŚĞZ,EĂŶĚƚŚĞ>h ͘/ƚǁŽƵůĚĂůƐŽƌĞƋƵŝƌĞĂĚĚŝƚŝŽŶĂůĨƵŶĚŝŶŐŽĨŝŵƉƌŽǀĞŵĞŶƚƐ
ĨƌŽŵƚŚĞŝƚLJĂŶĚŽƚŚĞƌƐ͘^ŝŶĐĞƚŚĞƉƌŽũĞĐƚǁŽƵůĚŶŽƚĂĚĚƌĞƐƐƐŝŐŶŝĨŝĐĂŶƚĞŶǀŝƌŽŶŵĞŶͲ
ƚĂůŝƐƐƵĞƐ͕ĂŶĚǁĂƐůĞƐƐĨĞĂƐŝďůĞƚŚĂŶƚŚĞƉƌŽũĞĐƚ͕ŝƚǁĂƐŶŽƚĞǀĂůƵĂƚĞĚĨƵƌƚŚĞƌ͘
WĂŐĞϱͲϮϮ EŽƚĞƚŚĂƚŝŶĞĐĞŵďĞƌ͕ϮϬϭϲƚŚĞ>hĨŽƵŶĚƚŚĂƚƚŚĞDWǁĂƐŝŶĐŽŶĨŽƌŵĂŶĐĞǁŝƚŚ
ƚŚĞ>hĂŶĚŝƐƐƵĞĚĂEŽƚŝĐĞŽĨŝƌƉŽƌƚ>ĂŶĚhƐĞŽŵŵŝƐƐŝŽŶĐƚŝŽŶ͘
WĂŐĞϱͲϮϲ ůĂƌŝĨLJƚŚĂƚƚŚĞƌĞůŽĐĂƚĞĚůĂƐƐ/ďŝŬĞƉĂƚŚŝƐŶŽƚĂĚũĂĐĞŶƚƚŽdĂŶŬ&ĂƌŵƌĞĞŬǁĞƐƚŽĨ
dĂŶŬ&ĂƌŵƌĞĞŬ͘/ƚŝƐĂĚũĂĐĞŶƚƚŽĂŶĚŶŽƌƚŚŽĨdĂŶŬ&ĂƌŵƌĞĞŬ͕ďƵƚŽƵƚƐŝĚĞƚŚĞϯϱͲ
ĨŽŽƚƌŝƉĂƌŝĂŶƐĞƚďĂĐŬĂŶĚĐƌŽƐƐĞƐƚŚĞĐƌĞĞŬϮϱϬƐŽƵƚŚŽĨƚŚĞWƌŽũĞĐƚ͛ƐƉƌŽƉŽƐĞĚĐƌŽƐƐŝŶŐ͘
ƐĐŽƌƌĞĐƚůLJŶŽƚĞĚ͕ƚŚĞd/^ŝŶĚŝĐĂƚĞĚƚŚĂƚƚŚŝƐůĂƐƐ/ĐŽŶŶĞĐƚŝŽŶǁŽƵůĚƌĞƐƵůƚŝŶĐŽŶͲ
ƐŝƐƚĞŶĐLJǁŝƚŚƚŚĞŝƚLJDW͘
WĂŐĞϱͲϮϵ dŚĞϮϬ͛ƐǁĂůĞĂƌĞĂǁŝůůŶŽƚďĞŵĂŝŶƚĂŝŶĞĚďLJĂŶ,K͕ďƵƚďLJƚŚĞ&͘
dĂďůĞϱͲϰ EŽƚĞƚŚĂƚWĂƌŬƐĂŶĚǁŝůůďĞĐŽŶƐƚƌƵĐƚĞĚŝŶWŚĂƐĞϭ͘WĂƌŬƐĂŶĚǁŽƵůĚďĞĐŽŶͲ
ƐƚƌƵĐƚĞĚŝŶWŚĂƐĞϮ͘WĂƌŬ ǁŽƵůĚďĞĐŽŶƐƚƌƵĐƚĞĚŝŶWŚĂƐĞϯ͘EŽƚĞƚŚĂƚƚŚĞůĂƐƐ/ďŝŬĞ
ƉĂƚŚǁŽƵůĚďĞĐŽŵƉůĞƚĞĚƚŽ͞:ĞƐƉĞƌƐŽŶ͟ĂƐƉĂƌƚŽĨƚŚĞWŚĂƐĞϯ͕ĂŶĚĐŽŵƉůĞƚĞĚƚŽŚĞǀͲ
ƌŽŶŝŶWŚĂƐĞϰǁŚĞŶ:ĞƐƉĞƌƐŽŶŝƐĐŽŶƐƚƌƵĐƚĞĚĂŶĚƚŚĞǀĞŚŝĐůĞďƌŝĚŐĞŽǀĞƌdĂŶŬ&Ăƌŵ
ƌĞĞŬŝƐĐŽŶƐƚƌƵĐƚĞĚ͘
PPD-73
Cont.
PPD-74
PPD-75
PPD-76
PPD-77
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ŽŵŵĞŶƚƐŽĨǀŝůĂZĂŶĐŚ /ZWĂŐĞͮϭϱ
WĂŐĞϱͲϯϱ EŽƚĞƚŚĂƚƉƉĞŶĚŝdžYŝŶĐůƵĚĞƐĚĞƚĂŝůƐŽŶƚŚĞDWŝŶĐůƵĚŝŶŐƉƌŽũĞĐƚŐƌĂƉŚŝĐƐĂŶĚƐƚĂŶĚͲ
ĂƌĚƐ͕ƵƉĚĂƚĞĚďŝŽůŽŐŝĐĂůƐƚƵĚLJ͕ƵƉĚĂƚĞĚŝƌYƵĂůŝƚLJĂŶĂůLJƐŝƐ͕ƵƉĚĂƚĞtĂƚĞƌ^ƵƉƉůLJƐͲ
ƐĞƐƐŵĞŶƚ͕ĂŶƵƉĚĂƚĞĚsĞƐƚŝŶŐdĞŶƚĂƚŝǀĞDĂƉ͕ĂŶĚĂŶƵƉĚĂƚĞĚĚƌĂŝŶĂŐĞƐƚƵĚLJ͕ĂůůƚŽƚŚĞ
ƐĂŵĞĚĞƚĂŝůĂƐƚŚĞWƌŽũĞĐƚ͘
WĂŐĞϱͲϯϴ ŽŶĐůƵƐŝŽŶƵŶĚĞƌ>hͲϯŝƐŝŶĐŽƌƌĞĐƚ͘ůůůĂŶĚƵƐĞƉŽůŝĐŝĞƐĂƌĞĐŽŵƉůŝĞĚǁŝƚŚƌĞŐĂƌĚŝŶŐĂŐ
ĐŽŶƐĞƌǀĂƚŝŽŶ͘ŐŝŵƉĂĐƚƐƵŶĚĞƌ'ͲϭĂƌĞƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͕ďƵƚ>hŝŵƉĂĐƚƐ
ĂƌĞŶŽƚ͘
WĂŐĞϱͲϲϰ dŚĞƌĞĨĞƌĞŶĐĞƚŽDDEKͲϯĂƌĞƋƵŝƌŝŶŐƐƉĞĐŝĂůƚƌĞĂƚŵĞŶƚĨŽƌZͲϭĂŶĚZͲϮƵŶŝƚƐǁŝƚŚŝŶ
͞ϲϬϬĨĞĞƚ͟ŝƐŝŶĐŽƌƌĞĐƚ͘DDEKͲϯĂƌĞƋƵŝƌĞƐƚŚĂƚĨŽƌƵŶŝƚƐǁŝƚŚŝŶϯϬϬĨĞĞƚƉĞƌƚŚĞĂĐŽƵƐͲ
ƚŝĐƐƐƚƵĚLJ͘ŚĂŶŐĞƚŽďĞĐŽŶƐŝƐƚĞŶƚǁŝƚŚDDEKͲϯĂ͘
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PPD-78
PPD-79
PPD-80
PPD-81
PPD-82
PPD-83
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Chapter 1
Page 1-36
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The City shall ensure that continuous wildlife habitat – including corridors free of human disruption - are
preserved, and, where necessary, created.
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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.
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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.
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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.
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In the greenbelt, the City may allow, and the City shall encourage the County to allow, smaller parcel sizes
only when:
A. All new dwellings will be clustered contiguously;
B. At least 90% of the site area is permanently protected as open space;
C. Agricultural easements are placed on prime agricultural lands outside the cluster.
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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.
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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.
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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
d if the development contributes to the protection
of agricultural land in the urban reserve or greenbelt
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requirements of water consumers cannot be satisfied without depleting the water supply of the distributor to
the extent that there would be insufficient water for human consumption, sanitation, and fire protection.
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an immediate emergency, the declaration shall be made only after a public hearing at which consumers of
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their respective needs to said governing board.
CWC Section 352. Notice of the time and place of hearing shall be published pursuant to Section 6061 of
the Government Code at least seven days prior to the date of hearing in a newspaper printed, published,
and circulated within the area in which the water supply is distributed, or if there is no such newspaper, in
any newspaper printed, published, and circulated in the county in which the area is located.
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A. No person shall cause any water delivered by the city water system to flow away from property owned,
occupied or controlled by such person in any gutter, ditch or in any other manner over the surface of the
ground, so as to constitute water waste runoff.
B.“Water waste runoff” means water flowing away from property and which is caused by excessive
application(s) of water beyond reasonable or practical flow rates, water volumes or duration of application.
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2016 2017 2018
Available Water
Supply 12,622 12,622 12,622
127(6
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5(48,5('8:0367$1'$5',=('7$%/(6
Stages of Water Shortage Contingency Plan
Stage
Complete Both
Percent
Supply
Reduction1
Water Supply Condition
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1 One stage in the Water Shortage Contingency Plan must address a water shortage of 50%.
NOTES: Table 8-1 R.
8UEDQ:DWHU0DQDJHPHQW3ODQ
Restrictions and Prohibitions on End Uses
Stage Restrictions and Prohibitions on End Users
Penalty, Charge, or
Other
Enforcement?
Monitor Landscape - Restrict or prohibit runoff from landscape
irrigation
Warning Landscape - Limit landscape irrigation to specific times
Warning Landscape - Limit landscape irrigation to specific days
Warning CII - Lodging establishment must offer opt out of linen service
Warning CII - Restaurants may only serve water upon request
Warning Water Features - Restrict water use for decorative water
features, such as fountains
Monitor Other - Customers must repair leaks, breaks, and malfunctions
in a timely manner
Watch Other - Require automatic shut of hoses
Monitor Other - Prohibit use of potable water for construction and
dust control
NOTES: Table 8-2 (R).
8UEDQ:DWHU0DQDJHPHQW3ODQ
Stages of Water Shortage Contingency Plan - Consumption Reduction Methods
Stage Consumption Reduction Methods by Water Supplier
All Expand Public Information Campaign
Watch Offer Water Use Surveys
Watch Provide Rebates on Plumbing Fixtures and Devices
Watch Provide Rebates for Landscape Irrigation Efficiency
Watch Decrease Line Flushing
NOTES: Table 8-3 R.
Minimum Supply Next Three Years
2016 2017 2018
Available Water
Supply 12,622 12,622 12,622
NOTES: Table 8-4 R.
8.0 RESPONSE TO COMMENTS
8-212 Avila Ranch Development Project
Final EIR
Commenter 46 – Steven Peck, Peck Planning and Development, LLC
Comment Response PPD-1: Impact determinations are based on a detailed analysis
provided in the EIR, and supported by technical studies prepared for the Project and
provided in the appendices. The level of significance of an impact has been determined
using methodologies for environmental analysis as provided in each resource section, and
in compliance with the 2016 California Environmental Quality Act (CEQA) Statute and
Guidelines. Where needed to provide for consistent use of terms, some impact
classifications have been revised in several sections of the EIR. However, CEQA does not
stipulate that a mitigation measure that falls within the responsibility of another agency
renders the mitigation as infeasible and the impact as unavoidable and significant. Rather,
an EIR is required to identify physically feasible mitigation measure and the agency
responsible for implementation.
Comment Response PPD-2: Per CEQA, the EIR describes the effects associated with
implementation of a project to inform decision-makers of the environmental effects of that
project. The Avila Ranch Development EIR identifies the impacts of the Project, as it is
described in the Avila Ranch Development Plan, provided in Appendix D. The alternatives
analysis provided in Section 5.0, Alternatives, has been developed to identify, describe,
and assess a reasonable range of alternatives, as they compare to the Project, to provide
decision-makers additional information for consideration, and in the case of the MPA, there
is a sufficiently substantial analysis to allow for the potential approval of that option. It is
acknowledged that the Applicant wishes to purpose the MPA, and the City Council may
use the EIR to consider its potential approval. However, to modify the Project Description
in such a way to identify the MPA as the Applicant’s intended Project would confuse
reviewers and is contrary to the CEQA process as it is intended to play out. However, a
note will be added to the Introduction (Section 1.0, Introduction) and the introduction to
the alternatives analysis noting this stated preference and referring reviewers to this letter.
Comment Response PPD-3: A brief description of all alternatives has been added to the
Executive Summary. Please also refer to Comment Response PPD-2.
Comment Response PPD-4: The discussion of agricultural resources under Impact LU-3
correctly conveys the intent and meaning of City Policy 1.9.2. However, to avoid
confusion, the discussion in the Executive Summary has been amended to reflect the
discussion in Impact LU-3, which does not state that the policy requires that a development
recreate or replace lost agricultural land, merely that such land once lost cannot be recreated
or replaced. As described in Impact LU-3 of Section 3.8.5.3, Project Impacts and
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-213
Final EIR
Mitigation Measures, the proposed Project would satisfy the criteria of Policy 1.9.2 through
the implementation of Mitigation Measure AG-1, which would require that the Applicant
establish an offsite agricultural conservation easement or pay in-lieu fees to a designated
fund. While impacts to farmlands would be reduced through this measure, the proposed
Project would irretrievably commit 71 acres of prime farmland to development of
commercial and residential uses. However, implementation of Mitigation Measure AG-1
would reduce but not fully mitigate such impacts since the lost agricultural land could not
be replaced or recreated. Refer to Section 3.8, Land Use and Planning, Impact LU-3.
Comment Response PPD-5: With regard to impacts resulting from inconsistency with
adopted agricultural land protection policies, in order to use a conservative approach,
impacts would remain significant and unavoidable as the underlying physical
environmental impact would remain, even after mitigation. Additional discussion to
address this issue has been added to Impact LU-3 in Section 3.8, Land Use and Planning.
Comment Response PPD-6: As described under Impact AG-1 and Impact LU-3, the
proposed Project would result in significant and unavoidable impacts to prime agricultural
land as Mitigation Measure AG-1 would not fully mitigate impacts. Because the lost prime
agricultural soils may not be acquired within the URL or greenbelt area and because such
soils cannot be replaced or recreated, impacts would remain unavoidable and significant.
Further, both the utilities and public services sections clearly state that impacts would either
be less than significant or significant, but mitigable. Table ES-1 correctly summarizes
impacts and mitigation measures as they are described in the appropriate sections of the
EIR.
Comment Response PPD-7: Table ES-1 of the Executive Summary incorrectly described
the language of Impact PS-4, as provided in Section 3.11, Public Services. The language
of this impact has been revised to appropriate reflect the statement of impacts under PS-4.
This does not affect the level of impact or any conclusions described in the EIR.
Comment Response PPD-8: Detailed discussion as to why Impact TRANS-13 is
classified as significant and unavoidable is provided in Section 3.12, Transportation and
Traffic. To summarize, the impact is identified as unavoidable and significant because that
improvement is unfunded and unscheduled as well as being outside of City jurisdiction,
and thus cannot be assumed to be completed in a timely manner to address Project impacts.
Comment Response PPD-9: A sentence has been added to the MPA discussion in the
Executive Summary to address issues that drove development of MPA. A discussion of a
8.0 RESPONSE TO COMMENTS
8-214 Avila Ranch Development Project
Final EIR
Reduced Project Alternative of 500 units has been added to the Alternatives Considered
and Discarded discussion in the EIR.
Comment Response PPD-10: Page 1-4 has been amended to note this determination. The
final ALUP consistency determination on the Project was made on December 21, 2016,
and has been included in Appendix N.
Comment Response PPD-11: Comment noted. The suggested changes may be clarified
through the Project findings, and potentially found to be in conformance with the EIR
analysis, when the Project is ultimately considered for approval. Potential General Plan
Amendments for appropriate roadways are address in Section 3.12, Transportation and
Traffic.
Comment Response PPD-12: Refer to Comment Response PPD-9.
Comment Response PPD-13: The footnote in Section 2.6.3.1, Proposed Housing, has
been updated accordingly.
Comment Response PPD-14: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-15: Figure 2-8 has been updated accordingly.
Comment Response PPD-16: Table 3.0-1 is merely a listing of projects, with Chevron
Tank Farm listed as “tentative”. Such discussion would be more appropriate in the MPA.
Comment Response PPD-17: Thank you, your comment has been noted. However, SB
743 is at least indirectly applicable to this section due to its relationship to aesthetic
impacts.
Comment Response PPD-18: Discussion of Policy LU 6.4, Hillside Policies of the City
General Plan have been removed.
Comment Response PPD-19: Thank you, your comment has been noted. However, creek
setbacks are more appropriately discussed in Section 3.4, Biological Resources.
Comment Response PPD-20: Thank you, your comment has been noted. The description
is accurate, in the sense that the Project encompasses 150 acres, and the development must
be viewed in that context, where the portions left in open space or agriculture are an
important component to allow the development of the remainder of the site.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-215
Final EIR
Comment Response PPD-21: Thank you for your comment and suggested addition of a
submitted photosimulation. However, the accuracy of the attached photosimulation cannot
be independently confirmed. For example, there is no reference to exact location or
perspective to allow the viewer to discern exactly what portion of the development is being
viewed. As such, and as an Applicant submittal, it has been included in an appendix and
referenced in the Section 3.1, Aesthetics and Visual Resources. In addition, the
photosimulation does not appear to depict the proposed seven-foot tall landscaped berm
and at this stage cannot be verified for accuracy. Therefore, text on page 3.1-22 has been
amended to reference an Applicant submitted photosimulation included in the Update MPA
Development Plan provided in Appendix S, but the image has not been included in the text
of the EIR. Discussion of existing views of the Project site from Buckley Road are already
described under Key Viewing Areas 1-3 in section 3.1.4.2, Impact Assessment
Methodology.
Comment Response PPD-22: As described in Section 3.3, Air Quality under Impact AG-
1, the Project would result in the exceedance of APCD Quarterly Tier 1 thresholds for ROG
+ NOx and Diesel Particulate Matter (DPM). In accordance with APCD Significance
Criteria for Construction-Related Emissions, Mitigation Measure AQ-1c requires the
development of an offsite mitigation strategy in order to reduce mitigate construction-
related emissions with respect to ROG, NOx, and DPM. No requirements for inclusion of
offsite mitigation are provided in Table 3.3-9, so the inclusion of Mitigation Measure AQ-
1c is not redundant.
Comment Response PPD-23: The San Luis Obispo APCD CEQA Air Quality Handbook
does not establish a relative reduction in air quality emissions associated with
implementation of a specific measure, nor does it identify measures which have no
quantifiable reduction in air quality impacts. Therefore, such measures are not listed in
Table 3.3-9.
Comment Response PPD-24: Discussion of how the Project would include each standard
APCD mitigation measures is provided in Table 3.3-9. This table is a listing of mitigation
measure, not an assessment of Project conformity with such measures. Item 20 has been
amended to clarify that 50 percent of units would be outfitted with solar photovoltaic cells.
However, as discussed in Commenter 113, Comment Response MVL-10, pending the
planning and development review process and approval of the final Development Plan, the
final design of the Project may include additional energy conserving design features, such
as the provision of solar photovoltaic cells on up to 100 percent of the buildings.
8.0 RESPONSE TO COMMENTS
8-216 Avila Ranch Development Project
Final EIR
Comment Response PPD-25: Refer to Commenter 43, Comment Response APCD-9.
Comment Response PPD-26: The text has been amended to add additional discussion of
this issue. Refer to Commenter 43, Comment Response APCD-14.
Comment Response PPD-27: The text has been supplemented. The residual effect of
Impact AQ-5 after implementation of all feasible mitigation measures is significant and
unavoidable.
Comment Response PPD-28: Thank you, your comment has been noted and consistency
checks on grading references performed. Cut and fill volumes, as well as total grading
quantities, are correctly referenced.
Comment Response PPD-29: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-30: Thank you, your comment has been noted and text adjusted
as needed.
Comment Response PPD-31: Existing discussions of naturally occurring asbestos include
reference to the Soils Engineering Report prepared by GeoSolutions, Inc. in 2015 for the
Buckley Road Extension. Mitigation Measure HAZ-1 is provided to minimize impacts
associated with exposure to naturally occurring asbestos, and has been prepared based on
the recommendations for mitigation provided in the Soils Engineering Report, which will
be cited.
Comment Response PPD-32: Text has been clarified. Please also refer to Comment
Response PPD-2.
Comment Response PPD-33: Figure 3.7-2 shows the location of adjacent offsite
hydrologic features and their relation to the northern boundary of the site under
implementation of the Project. References to this figure have been included throughout the
section.
Comment Response PPD-34: Discussion of Project-related impacts to groundwater
recharge and the inclusion of Project features which would reduce the effects of decreased
onsite percolation is provided under Impact HYD-6. The discussion has been expanded to
address this issue.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-217
Final EIR
Comment Response PPD-35: The text in Impact HYD-6 has been expanded to address
this issue. However, it would be speculative to assume the Project would result in increases
in groundwater levels.
Comment Response PPD-36: Final consistency determinations are the responsibility of
the City Council, and the EIR is charged with identify potential inconsistencies. However,
Section 3.8, Land Use and Planning, has been revised to remove “Potentially” from some
determinations if the Project is clearly consistent, or inconsistent, with each policy.
However, the EIR identifies where potential for inconsistency remains.
Comment Response PPD-37: Final determination of consistency with this policy would
be made by the City Council. However, failure to complete a key segment of an important
Class II bicycle path has the potential to leave cyclists, particularly road bikers, with a key
gap in this path. Given high roadway speeds and narrow lane configuration, such a gap
could present hazards. A parallel Class I facility, with attendant pedestrian traffic, joggers
and slower cyclists may not capture road bikers who would be using this future regional
Class II facility, but provides an alternative to the planned connection in the City’s bicycle
transportation network. This route would accommodate cyclists and would also avoid the
expense and secondary environmental impacts to biological resources of widening the
bridge. The fact that this segment is outside City jurisdiction is irrelevant to consistency
with the clear intent of adopted City plans and policies.
Comment Response PPD-38: Thank you, your comment has been noted. See also
response PPD-37 above.
Comment Response PPD-39: Appropriate sections of the text have been adjusted.
However, final determination of consistency will be made by the City Council.
Comment Response PPD-40: Refer to Comment Responses PPD-4, 5 and 6. Further, final
determination of consistency will be made by the City Council.
Comment Response PPD-41: Text has been adjusted as needed. Discussion of public
services under Impact LU-3 relates to the Project’s consistency with City General Plan
policies. For additional discussion of public school services, district areas, school
capacities, and the payment of Project impact fees, refer to Section 3.11, Public Services.
Comment Response PPD-42: Text has been adjusted to address this comment.
8.0 RESPONSE TO COMMENTS
8-218 Avila Ranch Development Project
Final EIR
Comment Response PPD-43: A statement regarding the reduction in noise exposure from
the earthen berm has been included on the following page, under the discussion of
Exposure of Future Project Residents to High Noise Levels.
Comment Response PPD-44: A footnote has been added to Mitigation Measure NOI-3b
summarizing a standard reduction in road vehicle noise by 3-8 dB with the inclusion of
rubberized asphalt.
Comment Response PPD-45: Additional discussion has been added to address this issue.
The Plan Requirements and Timing for Mitigation Measure NOI-3b has been revised to
include review and approval of this measure by County Public Works staff.
Comment Response PPD-46: Additional discussion has been added to address this issue.
In addition, it is currently described in Land Use Policy 1.5, provided in Section 3.10.3,
Regulatory Setting, that the jobs-to-housing ratio includes college enrollment, and that the
gap between housing demand and supply should not increase (worsen).
Comment Response PPD-47: Information provided in this table is based on the school
capacity and enrollment data available at the time of production of the Draft EIR. However,
Table 3.11-2 has been updated with the correct total capacity and enrollment values for the
2014-2015 school year, and a column providing the remaining capacity in each school has
been included. Refer to Section 3.11, Public Services. While the submitted letter has
included school enrollment data for the 2015-2016 school year, this updated enrollment
data does not affect the impact analysis or mitigation measures included in this EIR. This
updated enrollment data can be located in Attachment 4 of the submitted letter.
Comment Response PPD-48: Appropriate revisions to the text have been made based on
the proposed suggestions. However, some suggested revisions have not been incorporated,
as these revisions would misrepresent the analysis provided in this EIR and the assessment
of Project transportation impacts provided as part of the Transportation Impact Study.
Comment Response PPD-49: County bicycle plans are acknowledged and discussed in
EIR. The proposed Project is located within the jurisdictional limits of the City, and is
therefore subject to the regulations and requirements of City-adopted plans and policies,
include the City Bicycle Transportation Plan. Please also see Comment Response PPD-37.
Comment Response PPD-50: Please see Figure 3.12-2 for a depiction of the anticipate
Project trip distribution along local roadways.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-219
Final EIR
Comment Response PPD-51: Discussion regarding trip generation has been added to
Section 3.12, Transportation and Traffic. See Segment and Intersection Operations.
Comment Response PPD-52: Thank you, your comment has been noted. However, the
discussion of VMT has been retained. The analysis of VMT provided in Section 3.12,
Transportation and Traffic, is based on the detailed technical analysis provided in the TIS,
and represents the most accurate available analysis of Project estimated VMT. VMT
estimates provided in Appendix H as a product of the Project air emissions analysis are
based on basic estimates calculated using default land use assumption values for VMT, and
are not entirely reflective of the proposed Project, existing transportation environment,
cumulative transportation conditions, multi-modal requirements, etc.
Comment Response PPD-53: Thank you for your comment and the suggested revisions.
However, the EIR and Transportation Impact Study currently include a detailed discussion
and analysis of Project estimated VMT using the VMT+ model which has been developed
by professional traffic engineers. Additional quantification of Project VMT using
Greenhouse Gas Quantification Methodology is not required.
Comment Response PPD-54: A table has been added to the text. City roadway operations
thresholds, as well as Caltrans roadway operation thresholds, are provided in Section 3.12,
Transportation and Traffic.
Comment Response PPD-55: Thank you, your comment has been noted.
Comment Response PPD-56: Refer to Comment Response PPD-53.
Comment Response PPD-57: Your comment is acknowledged.
Comment Response PPD-58: Appropriate sections of the text have been revised
accordingly. Please see also Comment Response PPD-37.
Comment Response PPD-59: A figure depicting proposed bicycle facilities has been
incorporated into this section. Please see also Comment Response PPD-37.
Comment Response PPD-60: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-61: Appropriate sections of the text have been revised
accordingly.
8.0 RESPONSE TO COMMENTS
8-220 Avila Ranch Development Project
Final EIR
Comment Response PPD-62: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-63: Please refer to Comment Response PPD-1 and PPD-8.
Comment Response PPD-64: Technical information and data utilized for the purpose of
this analysis is based on that information that was available at the time of production of the
Draft EIR. Under CEQA, description of the existing setting and information utilized in an
analysis should be based on information available at the time of initiation of environmental
review. An EIR analysis need not be updated with information from a report which has
been updated and approved during the Public Review process. However, a footnote has
been added to reflect this “real time” data.
Comment Response PPD-65: Policy LU 3.7.4 does not apply to the Project and text
regarding this policy has been removed from this section.
Comment Response PPD-66: Text has been amended accordingly. Appropriate
regulatory plans, policies, guidelines, and documents have been added to Section 3.7.3 in
Section 3.7, Hydrology and Water Quality.
Comment Response PPD-67: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-68: A statement regarding the Williamson Act status of lands
south of Buckley Road and east of Jespersen Road has been added to Section 4.2, Growth-
Inducing Impacts.
Comment Response PPD-69: A new section title Section 4.3.3, Energy Conservation, has
been added which summarizes and describes the Project’s less than significant effects on
energy resources and energy conservation. This discussion utilizes existing information
provided within Section 2.0, Project Description, Section 3.13, Utilities, Appendix H, and
detailed construction fuel consumption calculations included in Appendix H of the EIR to
support the conclusion of impacts on energy resources and energy conservation resulting
from implementation of the Project. Additional discussion provided in this section
concludes that the Project would result in less than significant impacts to energy
conservation, due to the commitment of energy resources in a manner that is typical of a
development of this size, the incremental increase in demand for energy services, and the
inclusion of Project design features which would promote sustainability and energy
conservation.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-221
Final EIR
Comment Response PPD-70: Section 4.4, Significant and Unavoidable Impacts, provides
a brief summary of the significant and unavoidable impacts identified Sections 3.1 through
3.13 of the EIR. Discussions as to why impacts would remain significant and unavoidable,
regardless of implementation of mitigation measures, are provided in the Residual Impact
discussions of the appropriate resources section.
Comment Response PPD-71: Comment noted. Text has been amended to briefly discuss
this issue.
Comment Response PPD-72: Thank you, your comment has been noted.
Comment Response PPD-73: Please see Comment Response PPD-8.
Comment Response PPD-74: A statement has been added to Section 5.4.2.2, Mitigated
Project Alternative, concluding the ALUC’s December decision regarding the Project and
MPA’s conformation with the AASP.
Comment Response PPD-75: The text has been adjusted as appropriate.
Comment Response PPD-76: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-77: Appropriate revisions to Table 5-4 in Section 5.0,
Alternatives, have been made.
Comment Response PPD-78: Appropriate sections of the text in Section 5.0, Alternatives,
have been revised.
Comment Response PPD-79: Please see Comment Responses PPD-4, 5 and 6. As
described in the Land Use and Planning analysis provided in Section 5.4.2.2, Mitigated
Project Alternative, the proposed MPA would improve consistency with land use planning
policies related to biological, and transportation resources; however, impacts to agriculture
would remain unavoidable and significant.
Comment Response PPD-80: Appropriate sections of the text have been revised
accordingly.
Comment Response PPD-81: Appropriate sections of the text have been revised
accordingly.
8.0 RESPONSE TO COMMENTS
8-222 Avila Ranch Development Project
Final EIR
Comment Response PPD-82: Appropriate sections of the text have been revised to
include discussion of the Residential Plus Business Park Land Use Alternative
inconsistency with the City LUCE with regard to commercial development.
Comment Response PPD-83: As discussed under Section 5.4.2.3, Residential Plus
Business Park Land Use Alternative, impacts to agricultural resources under the
Residential Plus Business Park Alternative would be similar to those anticipated under the
Project, as this alternative would result in a similar scale of development and a comparable
loss of prime soils. Impacts to biological resources are considered less than under the
Project, as realignment of Tank Farm Creek would not occur under this alternative and
several biological impacts would be entirely avoided. Summary of impacts under each
alternative and their comparison to the Project in Table 5-25 remain unchanged.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-223
Final EIR
8.4.5 Individuals
AD-1
AD-2
AD-3
AD
-4
AD
-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-227
Final EIR
Commenter 47 – Alex DeLeon
Comment Response AD-1: The Project would add fewer than ten peak hour trips to the
segment of SR 227 south of Buckley Road, which is less than one percent of the existing
traffic volume. Under Cumulative conditions, the Project would add less than thirty peak
hour trips to the SR 227 corridor, which corresponds to less than one percent of the forecast
Cumulative volume. Mitigation Measure TRANS-5 requires a Project contribution towards
improvements at the Buckley Road/SR 227 intersection consistent with SR 227 Operations
Study. Section 3.12, Transportation and Traffic, of the Final EIR provides an expanded
description of planned improvements to Buckley Road and SR 227; see also Figure 3.12-
2.
Comment Response AD-2: Construction traffic is discussed in detail under Impact
TRANS-1 and Mitigation Measure TRANS-1. As provided under this mitigation, the
Applicant will be required to prepare a detailed Construction Transportation Management
Plan to address issues of construction traffic safety and operations.
Comment Response AD-3: The Project would extend Buckley Road prior to connecting
to Vachell Lane in order to minimize increases in traffic on Vachell Lane and at the Vachell
Lane/South Higuera Street intersection. The EIR evaluates the Project as proposed and
identifies mitigation measures accordingly.
Comment Response AD-4: Thank you, your comment has been noted. See Comment
Response AD-3.
Comment Response AD-5: Thank you and we appreciate your comments on the EIR.
Construction traffic is discussed in detail under Impact TRANS-1 and Mitigation Measure
TRANS-1. Phase 1 of the Project would not connect to Vachell Lane in order to minimize
increases in traffic on Vachell Lane and at the Vachell Lane South Higuera Street
intersection. Due to the inability to assure the completion of improvements at Buckley/SR
227, restrictions on development until completion of this improvement could result in
serious delays or possible incompletion of the Project. Such a restriction could result in
direct conflict with Project objectives.
AC-1
AC-2
AC-3
AC-3
Cont.
AC-4
AC-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-231
Final EIR
Commenter 48 – Allan Cooper, January 10th Letter
Comment Response AC-1: The EIR analyzes and characterizes Project-related impacts
resulting from construction of the Project, as well as operation of the Project following
buildout. Your concurrence with the EIR’s findings of significant impacts to air quality,
noise, and transportation is noted. Please note that Project impacts to sewer, water, schools,
law enforcement, and fire protection services are also analyzed with the EIR and impacts
were found to be less than significant after the implementation of mitigation measures.
Project impacts on sewer and water are analyzed within Section 3.13, Utilities, Impacts
UT-3 and UT-1. Project impacts on schools, law enforcement, and fire protection services
are analyzed in Section 3.11, Public Services, Impacts PS-1, PS-2, and PS-3. Please also
refer to Master Comment Response 7 for a detailed response on impacts to water resources.
Comment Response AC-2: Both the California Government Code and CEQA are
intended to inform decision-makers when reviewing projects for approval. Section
65589.5(c) of the California Government Code 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.”
This section of the California Government Code does not prohibit the development of
agricultural lands, but serves to encourage local jurisdictions to consider the effects of these
developments prior to the approval of such projects.
Further, section 65589.5 (d) of the California Government Code states:
“A local agency shall not disapprove a housing development project… for very
low, low-, or moderate-income households, or an emergency shelter, or condition
approval in a manner that renders the project infeasible for development for the use
of very low, low-, or moderate-income households, or an emergency shelter,
including through the use of design review standards, unless it makes written
findings, based on substantial evidence in the record, as to one of the
following:…(4) The development project or emergency shelter is proposed on land
8.0 RESPONSE TO COMMENTS
8-232 Avila Ranch Development Project
Final EIR
zoned for agriculture or resources preservation that is surrounded on at least two
sides by land being used for agricultural or resources preservation purposes…”
Both sections of the California Government Code are intended to inform local agencies
when reviewing projects, and do not prohibit the development of agricultural lands. As this
EIR describes and discloses impacts to agricultural resources for City decision-makers to
considered in their approval of this Project, it is not considered to be inconstant with these
sections of the California Government Code. Please also see Master Comment Response 2
for further information on the loss of agricultural lands.
Comment Response AC-3: As requested, further clarification of the Project’s density
bonus has been added to Section 2.0, Project Description. For discussion of residential
density bonus as allowed under the City General Plan Land Use Element Policy 8.1.6,
please see Table 2-3 in Section 2.0, Project Description.
Comment Response AC-4: Refer to Comment Response AC-2.
Comment Response AC-5: As discussed in Comment Response AC-2, Section 65589.5
of the California Government Code informs the decisions of local agencies when reviewing
projects for possible approval. The EIR is therefore consistent with the California
Government Code and related City General Plan Housing Element Policies. For specific
discussion of the Project’s consistency with applicable policies of the City Housing
Element, refer to Table 3.8-7 in Section 3.8, Land Use and Planning.
AC2-1
AC2-2
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-235
Final EIR
Commenter 49 – Allan Cooper, December 14th Letter
Comment Response AC2-1: Please refer to Commenter 48, Comment Responses AC-2
and AC-3.
Comment Response AC2-2: Please refer to Commenter 48, Comment Responses AC-2.
AT-1
8.0 RESPONSE TO COMMENTS
8-238 Avila Ranch Development Project
Final EIR
Commenter 50 – Ann Thurston
Comment Response AT-1: Thank you and we appreciate your comments on the EIR.
Your opposition to the Project is acknowledged. Please refer to Master Comment Response
8 for a detailed discussion on your traffic concerns.
AP-
1
8.0 RESPONSE TO COMMENTS
8-240 Avila Ranch Development Project
Final EIR
Commenter 51 – Annette Poole
Comment Response AP-1: Thank you and we appreciate your comments on the EIR.
Your opposition to the Project is noted. Please refer to Master Comment Response 7 for a
detailed discussion of issues related to water supply. Please refer to Section 3.12,
Transportation and Traffic, for a detailed discussion of Project-related traffic impacts.
BKG-1
BKG-2
BKG-3
BKG-4
BKG-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-243
Final EIR
Commenter 52 – Barbara and Kevin Greenwood
Comment Response BKG-1: The loss of agricultural land is addressed in Master
Comment Response 2 and Section 3.2, Agricultural Resources, Impact AG-1. Mitigation
Measure AG-1 would require the Applicant to establish an offsite agricultural conservation
easement to offset the loss of agricultural lands under the Project. Regarding the character
of the site, changes to the character are analyzed and addressed in Section 3.1, Aesthetics
and Visual Resources, Impact VIS-2. This impact was found to be adverse but less than
significant.
Comment Response BKG-2: Refer to Commenter 42, Comment Response KB1-7.
Comment Response BKG-3: Impact TRANS-2 in Section 3.12, Transportation and
Traffic addresses impacts of phased Project development on transportation infrastructure
and identifies several mitigation measures to reduce impacts on infrastructure capacity. To
ensure that improvements occur during each appropriate phase of construction, Mitigation
Measure TRANS-2a requires the Applicant to submit a Transportation Improvement
Phasing Plan to the City to specify the timing and general design of all on- and offsite
transportation improvements. This measure will require each improvement or connection
is developed prior to approval and initiation of the next phase of development. Please also
note that left-turn restrictions at Vachell Lane/South Higuera Street are proposed under the
Project, as well as the inclusion of Class II bicycle lanes along Buckley Road. Prefer also
to Commenter 47, Comment Response AD-4.
Comment Response BKG-4: Thank you, your comment has been noted. As described in
Section 2.6.5.4, parking within the Project would be compliant with City development
standards in Chapter 17.16 of the Municipal Code. This includes onsite garages associated
with single family units, parking along proposed residential streets, parking areas for multi-
unit complexes, and parking areas for the Town Center and Neighborhood Park. Please
note that bicycle lanes are proposed along Buckley Road (see Section 2.6.5, Circulation).
Comment Response BKG-5: The planned reconfiguration of the intersection of Tank
Farm Road/Santa Fe Road would include replacement of the bridge in question. This
improvement is planned as a part of the redevelopment of the Chevron Tank Farm property.
BF
1-1
BF
1-2
BF
1-3
BF
1-4
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-245
Final EIR
Commenter 53 – Barbara Farber, January 15th Letter
Comment Response BF1-1: Thank you and we appreciate your comments on the EIR.
Your comments regarding traffic are noted. Please refer to Master Comment Response 8
for a detailed discussion on your traffic concerns.
Comment Response BF1-2: Thank you and we appreciate your comments on the EIR.
Please refer to Master Comment Response 7 for a detailed discussion on your water
availability concern.
Comment Response BF1-3: Thank you and we appreciate your comments on the EIR.
Please refer to Master Comment Response 9 for a detailed discussion on airport noise
impacts.
Comment Response BF1-4: Thank you and we appreciate your comments on the EIR.
Please refer to Section 3.12, Transportation and Traffic, Impact TRANS-2 for a detailed
response regarding traffic infrastructure.
BF
2-1
BF
2-2
BF
2-3
BF
2-4
BF
2-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-247
Final EIR
Commenter 54 – Barbara Farber, January 16th Letter
Comment Response BF2-1: Please refer to Master Comment Response 8.
Comment Response BF2-2: Please refer to Master Comment Response 7.
Comment Response BF2-3: Please refer to Master Comment Response 2 for a detailed
discussion of impacts to agricultural land related to the Project.
Comment Response BF2-4: Please refer to Master Comment Responses 6 and 9 regarding
your airport-related concerns.
Comment Response BF2-5: Your opposition to the Project is noted and will be directed
towards City decision-makers.
BLL-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-249
Final EIR
Commenter 55 – Bernie and Lorraine Luoma
Comment Response BLL-1: Please refer to Section 3.12, Transportation and Traffic,
Impact TRANS-2 for the analysis of Project phasing and the construction of traffic
infrastructure. Where appropriate, mitigation measures are proposed to ensure adequate
transportation infrastructure is in place, with implementation linked to appropriate Project
phases. Please refer to Master Comment Response 8 and Impact TRANS-5 for the Project’s
impact to the intersection of Buckley Road/SR 227.
CJP-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-251
Final EIR
Commenter 56 – Carolyn and Jim Park
Comment Response CJP-1: Please refer to Master Comment Response 8.
CS-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-253
Final EIR
Commenter 57 – Carolyn Smith
Comment Response CS-1: Please refer to Master Comment Response 1.
CM1-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-255
Final EIR
Commenter 58 – Cheryl McLean, December 13th Letter
Comment Response CM1-1: Your comments are noted. Please refer Master Comment
Response 2. The EIR addresses the Project’s impact to agricultural land within Section 3.2,
Agricultural Resources, Impact AG-1. Mitigation Measure AG-1 would require the
Applicant to establish an offsite agricultural conservation easement to offset the loss of
agricultural lands under the Project. As impacts to agricultural resources are identified as
significant and unavoidable, the City Council would be required to adopt a Statement of
Overriding Considerations to weigh the Project’s significant agricultural impacts against
the Project’s benefits if it were to approve the Project.
CM2-1
CM2-2
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-257
Final EIR
Commenter 59 – Cheryl McLean, January 11th Letter
Comment Response CM2-1: Your comments are noted. Please refer to Commenter 58,
Comment Response CM1-1.
Comment Response CM2-2: The EIR identifies impacts to water, sewer, air quality,
schools, police/fire services, and traffic and circulation in detail in Section 3.7, Hydrology
and Water Quality, 3.13, Utilities, Section 3.2, Air Quality and Greenhouse Gas Emissions,
Section 3.11, Public Services, and Section 3.12, Transportation and Traffic. For a detailed
response regarding impacts to water availability, see Master Comment Response 7. For a
detailed response regarding school capacity, see Master Comment Response 11.
CG-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-259
Final EIR
Commenter 60 – Christine Galliani
Comment Response CG-1: Project impacts to LOVR, Prado Road, South Higuera Street,
and Buckley Road, including impacts associated with cumulative development, are
described within Section 3.12, Transportation and Traffic.
Sirios-1
Sirios-2
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-261
Final EIR
Commenter 61 – Dan Sirios
Comment Response Sirios-1: Refer to Master Comment Response 8.
Comment Response Sirios-2: Impacts to air quality including emissions generated by
vehicle trips, and appropriate mitigation measures, are described in Section 3.3, Air Quality
and Greenhouse Gas Emissions. Noise impacts are described in Section 3.9, Noise. See
Impact NO-3 for a discussion on how Project-generated traffic affects noise levels. This
impact was found to be less than significant after implementation of Mitigation Measures
NO-3a (building design standards) and NO-3b (paving technology to reduce noise levels
for sensitive receptors near the roadway).
DJV-1
DJV-2
DJV-3
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-263
Final EIR
Commenter 62 – David and Joan Van
Comment Response DJV-1: The Project would add fewer than ten peak hour trips to the
segment of SR 227 south of Buckley Road, which is less than one percent of the existing
traffic volume. Under cumulative conditions, the Project would add less than thirty peak
hour trips to the SR 227 corridor, which corresponds to less than one percent of the forecast
Cumulative volume. These added trips would not substantially increase delays at the
intersection of the Crestmont and SR 227.
Comment Response DJV-2: SLOCOG's SR 227 Operations Study evaluates this corridor
and recommends improvements. The Project would contribute to the planned
improvements at Buckley Road/SR 227 per Mitigation Measure TRANS-5.
Comment Response DJV-3: Impact TRANS-2 in Section 3.12, Transportation and
Traffic, addresses impacts of phased Project development on transportation infrastructure
and identifies several mitigation measures to reduce impacts on infrastructure capacity.
Cumulative traffic impacts of the Project and other pending or planned projects are
discussed in Section 3.12.4.4, Transportation and Traffic, Impacts TRANS-13 through
TRANS-15.
DS-1
DS-2
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-265
Final EIR
Commenter 63 – David Smith
Comment Response DS-1: Please refer to Master Comment Response 8.
Comment Response DS-2: Please refer to Commenter 41, Comment Response LB1-1.
DH
-1
DH
-2
DH
-3
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-267
Final EIR
Commenter 64 – Debbie Hoffman
Comment Response DH-1: The Project would add fewer than ten peak hour trips to the
segment of SR 227 south of Buckley Road, which is less than one percent of the existing
traffic volume. Under Cumulative conditions, the Project would add less than thirty peak
hour trips to the SR 227 corridor, which corresponds to less than one percent of the forecast
Cumulative volume. The Project proposes to extend Buckley Road to South Higuera Street
and reconfigure South Higuera/Vachell Lane to allow right turns only as a part of Phase 2.
Under Phase 1 the Project would not provide a vehicular connection to Vachell Lane. Refer
also to Master Comment Response 8.
Comment Response DH-2: The EIR evaluates Project impacts and identifies impacts and
mitigations in accordance with transportation standards from the City of San Luis Obispo,
County of San Luis Obispo, and Caltrans. The combination of Applicant proposed road
and intersection improvements and the transportation improvement mitigation measures in
the EIR would generally serve to maintain or improve existing traffic flows.
Comment Response DH-3: Refer to Master Response 10 regarding your comments on
residential uses near the airport. For discussion of impacts relating to aesthetics and visual
resources, refer to Section 3.1. Aesthetics and Visual Resources. Please note that the Project
includes an open space buffer and landscaped berm along Buckley Road to provide a visual
buffer between the Project and adjacent agricultural lands.
DJ-1
8.0 RESPONSE TO COMMENTS
8-270 Avila Ranch Development Project
Final EIR
Commenter 65 – Debbie Jensen
Comment Response DJ-1: Regarding water availability, the Draft EIR discloses
environmental impacts of the proposed development, including those related to water
availability. See Master Comment Response 7 and Section 3.13, Utilities, Impact UT-3.
Regarding comments on Rolling Hills traffic, refer to Commenter 53, Comment Response
BF1-1.
DV-1
8.0 RESPONSE TO COMMENTS
8-272 Avila Ranch Development Project
Final EIR
Commenter 66 – Dennis Vavrek
Comment Response DV-1: Thank you, your comment has been noted. Growth inducing
impacts are addressed in Section 4.2, Other CEQA Sections. This section identifies and
discloses the potential for additional growth in the region, consistent with State CEQA
Guidelines 15126(d).
DA-1
8.0 RESPONSE TO COMMENTS
8-274 Avila Ranch Development Project
Final EIR
Commenter 67 – Denny d'Autremont
Comment Response DA-1: Please refer to Master Comment Response 1.
Hurd-1
Hurd-2
Hurd-3
Hurd-4
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-277
Final EIR
Commenter 68 – Dia Hurd, December 20th Letter
Comment Response Hurd1-1: Please see Section 3.2, Agricultural Resources, and
Section 3.8, Land Use, for a detailed discussion of policy consistency and viability of
agricultural land. Please also refer to Master Comment Response 2.
Comment Response Hurd1-2: Please see Master Comment Responses 6, 9 and 10
regarding airport safety and airport noise. Impact HAZ-3 in Section 3.6, Hazards and
Hazardous Materials, for a detailed discussion on airport safety issues. As described in this
section, impacts associated with airport safety are found to be less than significant. Please
see Section 3.3, Air Quality and Greenhouse Gas Emissions, for a detailed discussion on
air quality impacts.
Comment Response Hurd1-3: Please see Master Comment Response 8.
Comment Response Hurd1-4: Your opposition to the Project is acknowledged. Please
see Master Comment Response 6 regarding your concerns on airport safety. See Section
3.12, Transportation and Traffic, for a detailed discussion of traffic-related impacts.
Hurd-1
8.0 RESPONSE TO COMMENTS
8-280 Avila Ranch Development Project
Final EIR
Commenter 69 – Dia Hurd, December 14th Letter
Comment Response Hurd2-1: Please refer to Master Comment Response 1.
Hurd-1
8.0 RESPONSE TO COMMENTS
8-282 Avila Ranch Development Project
Final EIR
Commenter 70 – Dia Hurd, December 13th Letter
Comment Response Hurd3-1: Your opposition to the Project is acknowledged. Impacts
related to water availability, noise, traffic, and air quality emissions are addressed in the
EIR. See Sections 3.3, Air Quality and Greenhouse Gas Emissions, 3.9, Noise, 3.12,
Transportation and Traffic, and 3.13, Utilities.
DD-1
8.0 RESPONSE TO COMMENTS
8-284 Avila Ranch Development Project
Final EIR
Commenter 71 – Dorothy DeVries
Comment Response DD-1: Your opposition to the Project due to increased traffic is noted.
Please refer to Master Comment Response 8, and Section 3.12, Transportation and Traffic,
Impacts TRANS-4 through TRANS-8, for detailed discussion on traffic impacts to Buckley
Road, Vachell Lane, Higuera Street, and LOVR. Please also refer to Master Comment
Responses 6, 9, and 10 regarding concerns related to the airport.
DH
-1
DH
-2
DH
-3
8.0 RESPONSE TO COMMENTS
8-286 Avila Ranch Development Project
Final EIR
Commenter 72 – Doug C. Hoffman
Comment Response DCH-1: Thank you, your comment has been noted.
Comment Response DCH-2: The Project does not connect to Rolling Hills Road or
Caballeros Avenue, and would not add traffic to these roads. Project contributions to
increased traffic on SR 227 are addressed in Master Comment Response 8.
EN-1
8.0 RESPONSE TO COMMENTS
8-288 Avila Ranch Development Project
Final EIR
Commenter 73 – Eric Norrbom
Comment Response EN-1: Your opposition to the Project is acknowledged. Refer to
Master Comment Response 6.
EP-1
EP-2
EP-3
8.0 RESPONSE TO COMMENTS
8-290 Avila Ranch Development Project
Final EIR
Commenter 74 – Ernie Peterson
Comment Response EP-1: The EIR evaluates Project impacts at four intersections and
one segment along Buckley Road and applies transportation standards from the City of San
Luis Obispo, County of San Luis Obispo, and Caltrans. However, please see revisions to
Section 3.12, Transportation and Traffic, of the EIR which includes expanded discussions
of traffic capacity, operational and safety issues along Buckley Road. Please also see
Master Comment Response 8.
Comment Response EP-2: The EIR evaluates Project impacts at four intersections and
one segment along Buckley Road and applies transportation standards from the City of San
Luis Obispo, County of San Luis Obispo, and Caltrans. Mitigation Measure TRANS-5
requires a project contribution towards improvements at the Buckley Road/SR 227
intersection, to be accomplished by amending the AASP fee program to include this
improvement. See also Master Comment Response 8.
Comment Response EP-3: Refer to Master Comment Response 8.
EC-1
EC-2
EC-3
8.0 RESPONSE TO COMMENTS
8-292 Avila Ranch Development Project
Final EIR
Commenter 75 – Evan Chechopoulos
Comment Response EC-1: Please refer to Master Comment Response 8.
Comment Response EC-2: Cumulative land use and roadway network improvements
were evaluated consistent with the City's LUCE, based on existing conditions known at the
time of release of the NOP.
Comment Response EC-3: Please refer to Impact NO-3 in Section 3.9, Noise, for a
detailed analysis of operational noise impact associated within the increase in Project-
generated traffic trips along local roadways. As described in Impact NO-3, impacts would
be reduced to a less than significant level after implementation of Mitigation Measures
NO-3a (noise reduction building design features) and NO-3b (paving technology to reduce
noise levels for sensitive receptors near the roadway).
GRF1-1
8.0 RESPONSE TO COMMENTS
8-294 Avila Ranch Development Project
Final EIR
Commenter 76 – G.R. Flores, January 2nd Letter
Comment Response GRF1-1: Please refer to Master Comment Response 2 and Section
3.2, Agricultural Resources, and specifically to Impact AG-1, for a detailed discussion of
impacts to agricultural lands. As impacts to agricultural resources are identified as
significant and unavoidable, the City Council would be required to adopt a Statement of
Overriding Considerations to weigh the Project’s significant agricultural impacts against
the Project’s benefits if it were to approve the Project.
GRF2-1
8.0 RESPONSE TO COMMENTS
8-296 Avila Ranch Development Project
Final EIR
Commenter 77 – G.R. Flores, December 9th Letter
Comment Response GRF2-1: Thank you and we appreciate your comments on the EIR.
Please refer to Commenter 76, Comment Response GRF1-1 and Master Comment
Response 2. Project-related impacts to air quality are described in Section 3.3, Air Quality
and Greenhouse Gas Emissions. Project related impacts to water, sewer, and solid waste
are described in Section 3.13, Utilities. Project impacts to light and glare are described in
Section 3.1, Aesthetics and Visual Resources, specifically in Impact VIS-4. Project-related
impacts to water runoff are described in Section 3.7, Hydrology and Water Quality, under
Impact HYD-2.
GG-1
GG-2
GG-3
8.0 RESPONSE TO COMMENTS
8-298 Avila Ranch Development Project
Final EIR
Commenter 78 – Gale Garrison
Comment Response GG-1: An analysis of housing in the City of San Luis Obispo, which
considers the City’s large student population, is described in Section 3.10, Population and
Housing. Traffic trips generated by the population residing in the Project site are addressed
within Section 3.12, Transportation and Traffic.
Comment Response GG-2: Traffic impacts to Vachell Lane, South Higuera Street, Prado
Road, and LOVR are addressed in Section 3.12, Transportation and Traffic, and Appendix
P, Transportation Impact Study. Refer also to Master Comment Response 8.
Comment Response GG-3: Please refer Master Comment Response 7. Detailed
discussion of availability of City water supplies, Project water demand, and impacts
associated with implementation of the Project on these water supplies is provided in
Section 3.13, Utilities. Refer to Impacts UT-2 and UT-3. Impacts to water supplies were
found to be less than significant.
Chizek-1
Chizek-2
8.0 RESPONSE TO COMMENTS
8-300 Avila Ranch Development Project
Final EIR
Commenter 79 – Gaylord Chizek
Comment Response GC-1: Your comment is noted. Please see Section 3.12,
Transportation and Traffic, for a detailed analysis of Project-related traffic impacts.
Comment Response GC-2: Please refer to Master Comment Response 7.
GK
1-1
8.0 RESPONSE TO COMMENTS
8-302 Avila Ranch Development Project
Final EIR
Commenter 80 – Georgianne Kandler, January 16th Letter
Comment Response GK1-1: Thank you and we appreciate your comments on the EIR.
Your comment has been noted. Please refer to Commenter 53, Comment Responses BF1-
1 through BF1-4.
GK2-1
8.0 RESPONSE TO COMMENTS
8-304 Avila Ranch Development Project
Final EIR
Commenter 81 – Georgianne Kandler, January 18th Letter
Comment Response GK2-1: Refer to Commenter 78, Comment Responses GG-1 through
GG-3.
HSA-1
8.0 RESPONSE TO COMMENTS
8-306 Avila Ranch Development Project
Final EIR
Commenter 82 – Howard and Sandy Amborn
Comment Response HSA-1: Refer to Master Comment Response 1.
JKW-1
JKW-2
8.0 RESPONSE TO COMMENTS
8-308 Avila Ranch Development Project
Final EIR
Commenter 83 – J. K. Waldsmith
Comment Response JKW-1: Refer to Master Comment Response 8.
Comment Response JKW-2: Refer to Master Comment Response 5.
JB-1
8.0 RESPONSE TO COMMENTS
8-310 Avila Ranch Development Project
Final EIR
Commenter 84 – Jaleah Brynn
Comment Response JB-1: The Project does not connect to Rolling Hills Road or
Caballeros Avenue, and would not add traffic to these roads. Project contributions to
increased traffic on SR 227 are addressed in Master Comment Response 8.
JL-1
JL-2
JL-3
JL-4
JL-5
JL-6
JL-7
JL-8
JL-9
JL-10
JL-11
JL-12
JL-13
JL-14
JL-15
JL-15
Con.t
JL-16
JL-17
8.0 RESPONSE TO COMMENTS
8-316 Avila Ranch Development Project
Final EIR
Commenter 85 – James Lopes
Comment Response JL-1: The Project is required by LU Policy 8.1.6 to be implemented
either through a separate specific plan or an amendment of the AASP. The City has elected
to pursue the latter. The Project’s Development Plan will be used as the basis to update the
AASP, in fulfillment of the City’s Specific Plan requirement related to the Project. The
Office of Planning and Research states that a Specific Plan addresses the planning of
necessary infrastructure and facilities, as well as land uses and open space. This
Development Plan addresses these components, and goes into further detail, for example
providing information related to utility capacity, distribution of land uses in the Project
site, and transportation access throughout the site. Please also refer to Section 2.6.1,
Required Approvals, for a list of entitlements required for the Project. This includes a
Vesting Tract Map (VTM) to establish lot lines and architectural review. The draft VTM
is included in this EIR in Appendix C.
Comment Response JL-2: The mitigation measures in the Draft EIR are provided to
address and reduce impacts where feasible, as a result of implementation of this Project.
Per State CEQA Guidelines Section 15126.4(4)(b), “The mitigation measures must be
‘roughly proportional’ to the impacts of the Project. Dolan v City of Tigard, 512 U.S. 374
(1994)…” Hence, there must be an essential nexus between a mitigation measure and the
Project’s impact. Alternatives to the Project within Section 5.0, Alternatives, comply with
State CEQA Guidelines Section 15126.6, which states “…an EIR need not consider every
conceivable alternative to the Project. Rather, it must consider a reasonable range of
potentially feasible alternatives that will foster informed decision making and public
participation…”. The EIR therefore selects a reasonable range of alternatives that meet the
Project Objectives for analysis and would serve to reduce one or several impacts identified
under the Project. Those alternatives selected for analysis in this EIR were considered due
to their potential to meet most of, if not all of, the Project Objectives and would result in
less severe impacts to the human and biological environment.
Regarding the scope of the EIR, please refer to Section 1.5, Scope of the EIR. As described
in this section, the scope of the EIR includes the evaluation of potentially significant
environmental issues associated with the Project identified within the IS and issues raised
during scoping discussions after the release of the NOP. Further, this EIR tiers from the
environmental analysis of the 2014 LUCE Update EIR. Further discussion of impacts
associated with “community development” are described within this document.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-317
Final EIR
Comment Response JL-3: The scope of the Draft EIR is to analyze the impacts of the
currently proposed Project, not previous proposals. The Project’s consistency with other
local and regional plans is evaluated within Section 3.8.4, Consistency with Plans and
Policies.
Comment Response JL-4: Refer to Section 3.8, Land Use and Planning, for a detailed
discussion on consistency with the ALUP and the AASP. In December 2016, the ALUC
found that the Project is consistent with the ALUP (Appendix N). For further background
and analysis, please refer to the LUCE Update EIR (2014).
Comment Response JL-5: The scope of the Draft EIR is to analyze the impacts of the
proposed Project that we deemed complete in December 2015. Previous submittals were
pre-LUCE in May 2014, review applications in May and September of 2015, and a final
deemed-completed application for 720 units in December 2015. At no time was there an
application for 280 units as cited by the commenter. Refer to Section 3.8, Land Use and
Planning, Impact LU-2, for a detailed discussion on the Project’s consistency with the
ALUP. Please note that the EIR considers a Major Reduced Development Alternative in
Section 5.0, Alternatives; however, this alternative was discarded for further analysis as
would not meet the Project and LUCE objectives. See Section 5.4.1.3 for further detail.
Refer also to Master Comment Response 4.
Comment Response JL-6: The proposed Development Plan, Specific Plan Amendment
and related actions would allow for the development of the Avila Ranch area as identified
in the City’s General Plan as Special Focus Area SP-4. All components of the Project are
defined and described in detail in Section 2.0, Project Description. The Project is consistent
with the development parameters described in the recent LUCE update. For further detail
on specific review processes, see Section 2.6.1, Required Approvals.
Comment Response JL-7: Please refer to Section 2.0, Project Description, for a detailed
discussion on General Plan Land Use Element requirements. The proposed 720 residential
units exceeds 700 units as allowed in Section 8.1.6 of the Land Use Element due to account
for allowable density bonus units. The Project includes a 20-unit density bonus in
accordance with Chapters 17.16.010 and 17.28 of the City’s Zoning Ordinance for the
purpose of environmental analysis. See Table 2-3 in Section 2.0, Project Description, for
further detail. Further, clarifying language has been added to Section 2.6.3., Development
Plan. In addition, as stated within Section 2.0, the Project would require a General Plan
Amendment to implement LU 8.1.6.
8.0 RESPONSE TO COMMENTS
8-318 Avila Ranch Development Project
Final EIR
Comment Response JL-8: The LUCE requires that 50 percent of the Project site area shall
be provided in open space, allowing up to one-third of that space to be provided offsite.
This results in a minimum requirement that 50 acres of open space be provided on the
Project site. Total onsite open space (not including recreational park areas), totals 55.30
acres. Refer to Section 2.0, Project Description, for further detail.
Comment Response JL-9: The dashed line on Figure 1-1, Regional Location, represents
the boundary of the Airport Area Specific Plan (AASP). No flight paths are shown on this
figure.
Comment Response JL-10: Please refer to Section 4.2, Other CEQA Sections, for a
detailed discussion on growth-inducing impacts. This section identifies and discloses the
potential for additional growth in the region, consistent with State CEQA Guidelines
15126(d).
Comment Response JL-11: Please refer to Table 3.8-9 in Section 3.8, Land Use and
Planning, for a detailed discussion on the Project’s consistency with the AASP. Refer to
Table 3.8-7 in Section 3.8, Land Use and Planning, for a detailed discussion on the
Project’s consistency with the General Plan Land Use Element. Discussion of the Project’s
consistency with the General Plan is available in Impact LU-3.
Comment Response JL-12: The Project’s impacts to traffic are addressed in Section 3.12,
Transportation and Traffic. The Project’s impacts to air quality and GHGs are addressed
in Section 3.3, Air Quality and Greenhouse Gas Emissions. See Master Comment
Response 5 regarding issues related to affordable housing.
Comment Response JL-13: The Project’s impacts to housing and the jobs/housing
imbalance is addressed in Section 3.10, Population and Housing. As described in Impact
PH-2, the Project is found to have a beneficial impact to the jobs/housing imbalance (refer
to Impact PH-2). Section 3.10 also describes the Project’s cumulative contribution to
housing impacts in Section 3.10.4.4. Impacts related to General Plan buildout are addressed
in the LUCE Update EIR (2014). See Master Comment Response 8 regarding impacts to
SR 227.
Comment Response JL-14: Your comments on Project design are noted. The EIR
evaluates the Project as it is proposed, and the Project’s impacts to housing are addressed
in Section 3.10, Population and Housing. Impact PS-3 describes the Project’s impact to
affordable housing and identifies impacts as less than significant.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-319
Final EIR
Comment Response JL-15: Your comments on New Urbanism and Smart Growth are
acknowledged. The Project is located within the City limits and within the URL and
complies with the General Plan’s requirements to contain development within the URL.
Please note purpose of an EIR is not to modify the Project Objectives; rather, the purpose
of an EIR is to provide detailed information about the effect the proposed Project is likely
to have on the physical environment (State CEQA Guidelines Section 21061). Project
Objectives are under the control of the Project Applicant, with input from the City. Impacts
related to internal motor vehicle trips are addressed within Section 3.12, Transportation
and Traffic, and within the Transportation Impact Study in Appendix P. Please also note
the Project’s incorporation of infrastructure for alternative transportation, including the
provision of Class I and II bicycle lanes and bus stops (see Section 2.6.5, Circulation).
Comment Response JL-16: The intersection of South Higuera Street/Vachell Lane is
evaluated as study intersection 9 in the Draft EIR under all analysis scenarios. Detailed
discussion of Project impacts to this intersection and necessary mitigation measures are
provided in Section 3.12, Transportation and Traffic. See discussion of Impact TRANS-7
and Mitigation Measure TRANS-7d. Additionally, Figure 3.12-5 has been added to Section
3.12, Transportation and Traffic, which depicts improvements proposed as part of
Mitigation Measure TRANS-7d.
Comment Response JL-17: The Buckley Road Extension is proposed by the Project as a
part of Phase 2. The EIR concluded that the Buckley Road Extension was not needed prior
the Phase 2. The costs associated with this extension/improvement would be paid by the
Applicant. Refer to Section 3.12, Transportation and Traffic.
JR-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-321
Final EIR
Commenter 86 – James Ream
Comment Response JR-1: Your opposition to the Project is acknowledged. Please refer
to Master Comment Response 7 for a detailed response regarding water availability. Please
refer to Master Comment Response 8 for a detailed response regarding your traffic
concerns.
JW-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-323
Final EIR
Commenter 87 – James Walker
Comment Response JW-1: Thank you, your comment and support of the Project has been
noted.
JPS-1
JPS-2
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-325
Final EIR
Commenter 88 – Jean and Peter Smidth
Comment Response JPS-1: The Project does not connect to Rolling Hills Road or
Caballeros Avenue, and would not add traffic to these roads. Project contributions to
increased traffic on SR 227 are addressed in Master Comment Response 8.
Comment Response JPS-2: For discussion of local school capacity, and Project impacts
on school enrollment, refer to Master Comment Response 11 and Section 3.11, Public
Services, Impact PS-3.
JK-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-327
Final EIR
Commenter 89 – Jennifer Klay
Comment Response JK-1: The LOVR Bypass is evaluated in the Cumulative Conditions
section of Appendix P and Section 3.12.4.4 of Section 3.12, Transportation and Traffic, of
the EIR. See Impact TRANS-15.
JKR2-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-329
Final EIR
Commenter 90 – Jim and Kay Rizzoli, January 18th Letter
Comment Response JKR1-1: The EIR evaluated Project impacts to all of the locations
described in the comment, and identified mitigation measures where appropriate. The
Project would add fewer than 300 ADT to the Broad Street corridor north of Buckley Road,
which is approximately only 1 percent of the existing traffic volume. These added trips
would not substantially increase delays at side street intersections along Broad Street.
Comment Response JKR1-2: The Project would add fewer than ten peak hour trips to the
segment of SR 227 south of Buckley Road, which is less than one percent of the existing
traffic volume. Under cumulative conditions, the Project would add less than 30 peak hour
trips to the SR 227 corridor, which corresponds to less than one percent of the forecast
cumulative volume. These added trips would not substantially increase delays at the
intersection of the Crestmont Drive and SR 227. SLOCOG's SR 227 Operations Study
evaluates this corridor and recommends improvements. The Project would contribute to
the planned improvements at Buckley Road/SR 227 per Mitigation Measure TRANS-5.
JKR2-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-331
Final EIR
Commenter 91 – Jim and Kay Rizzoli, December 12th Letter
Comment Response JKR2-1: Your concerns regarding traffic are noted. Traffic and
transportation impacts are addressed in Section 3.12, Transportation and Traffic, and
appropriate mitigation measures are identified to reduce the severity of the impacts to less
than significant degree. In response to concerns regarding the duration and timing of the
public comment period, please refer to Master Comment Response 1.
JA-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-333
Final EIR
Commenter 92 – Joan Adams
Comment Response JA-1: Your opposition to the Project is acknowledged. Please refer
to Master Comment Response 8.
JSW-1
JSW-2
JSW-3
JSW-4
JSW-5
JSW-6
JSW-6
Cont.
JSW-7
JSW-8
8.0 RESPONSE TO COMMENTS
8-336 Avila Ranch Development Project
Final EIR
Commenter 93 – John and Susan Wimer
Comment Response JSW-1: For discussion of impacts resulting from development within
or adjacent to the Tank Farm Creek floodplain, refer to Master Comment Response 3 and
Section 3.7, Hydrology and Water Quality, Impacts HYD-2 and HYD-3. As discussed
under Impact HYD-2 in Section 3.7, Hydrology and Water Quality, runoff flowing onsite
from properties located to the east would be captured and retained in the wetland area
located in the northeast corner of the Project site. In order to address the potential for
flooding from runoff entering the site from the East, the EIR includes Mitigation Measure
HYD-2a, which requires a Master Drainage Plan that addresses regional drainage and
flooding. The Master Drainage Plan would demonstrate peak flows and ensure that onsite
detention facilities safely retain flood flows. In addition, the EIR includes Mitigation
Measure HYD-2c, which requires that offside drainage from the east be rerouted into
surface detention and treatment facilities. This would be included in the Master Drainage
Plan. Inclusion of drainage conveyances to direct runoff entering the site from the east
would ensure that impacts related to the removal of the East-West Channel are minimized.
Comment Response JSW-2: Post-Project flood conditions are based on those conditions
both existing and proposed at the time of preparation of the Draft EIR, and are modeled in
Appendix E. Based on known anticipated conditions, realignment of Tank Farm Creek
would occur in coordination with proposed remediation at the Chevron Tank Farm property
to the northeast.2 After completion of remediation within the Chevron Tank Farm property,
the Chevron Tank Farm property would retain larger quantities of water within the site,
thereby reducing peak flows entering the Project site. This would reduce the total flows
through Tank Farm Creek. As described in Impact HYD-2, projected peak flows were
estimated for Tank Farm Creek at the confluence with East Fork San Luis Obispo Creek
by adding the hydrograph for the upstream portion of the Tank Farm Creek watershed
(Chevron Tank Farm property remediation area) to the combined hydrograph for the area
downstream of the Chevron Tank Farm property remediation area (see Table 3.7-5). Based
on this analysis, flood flows in Tank Farm Creek would not increase by more than 5 percent
from the existing condition for the design storms, and 100-year peak flows in the Tank
Farm Creek watershed would be reduced by approximately 12.3 percent. Mitigation
Measure HYD-2a (Master Drainage Plan) would ensure coordination of drainage
improvements with the Chevron Tank Farm property to the north, and establish the
2 Please see also Master Response 3 regarding the uncertainty surrounding the pending Chevron Tank Farm
Project.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-337
Final EIR
schedule and timing of onsite improvements. As described in Impact HYD-3, the
approximate 200-foot segment of the Buckley Road Extension that would fall within the
100-year floodplain may be subject to occasional flooding; however, no structures are
proposed and no persons would be put at risk. This is considered an adverse but less than
significant impact after mitigation, including implementation of the Master Drainage Plan.
Comment Response JSW-3: For discussion of existing site drainage and impacts to onsite
drainage and runoff resulting from development of the Project, refer to Master Comment
Response 3 and Impacts HYD-2 and HYD-3 within Section 3.7, Hydrology and Water
Quality and Appendix E. As the commenter asserts, the increase in impervious surfaces
would result in runoff; however, the Project includes storm water conveyance
infrastructure including drainage culverts throughout the site installed beneath proposed
Project roadways, and a dual pocket park/bioretention basin, and a 12-foot swale at the
northern Project boundary to address flood flows. As described in Appendix E, the
bioswale proposed within the southwestern portion of the Project site would retain flood
flows and reduce flooding at the intersection of Buckley Road/Vachell Lane as well as
contribute to groundwater recharge.
Comment Response JSW-4: Refer to Comment Response JSW-2.
Comment Response JSW-5: Thank you and your comment is noted. This issue is
analyzed in Section 3.12, Transportation and Traffic, Impact TRANS-2.
Comment Response JSW-6: With regard to phasing of transportation improvements,
refer to Impact TRANS-2 within Section 3.12, Transportation and Traffic. The phasing of
transportation infrastructure was found to be less than significant after mitigation,
including implementation of a Transportation Improvement Phasing Plan.
Comment Response JSW-7: Refer to Master Comment Response 8.
Comment Response JSW-8: The Prado Road interchange is included in the Cumulative
scenario consistent with the City's Circulation Element. The City and Caltrans are currently
studying the interchange as a part of a separate process.
JV-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-339
Final EIR
Commenter 94 – Julie Vallejo
Comment Response JV-1: Thank you, your comments regarding Buckley Road and
Vachell Lane are noted. The extension of Buckley Road from Vachell Lane to South
Higuera Street is proposed under the Project during Phase 2. See Section 2.6.5, Circulation.
In addition, a left-turn restriction from Vachell Lane/South Higuera Street would be
required after construction of the Buckley Road Extension which would prohibit turns into
and out of Vachell Lane to address approach delays caused by high traffic volumes along
South Higuera Street that interfere with turning movements at this intersection.
KK1-3KK1-2KK1-1
KK1-7KK1-12KK1-11KK1-10KK1-9KK1-8KK1-6KK1-5KK1-4
KK1-22KK1-21KK1-20KK1-19KK1-18KK1-17KK1-16KK1-15KK1-14KK1-13
KK1-26KK1-25KK1-24KK1-23KK1-22 Cont.
KK1-28KK1-27
KK1-32KK1-31KK1-30KK1-29
KK1-32 Cont.
8.0 RESPONSE TO COMMENTS
8-356 Avila Ranch Development Project
Final EIR
Commenter 95 – Karen Krahl, January 11th and 12th Letters
(Note: the commenter submitted two largely duplicate letters both included below; the
January 12th letter appears to include updates in red to the January 11th letter).
Comment Response KK1-1: Regarding airport noise and its potential impacts to future
residents of the Avila Ranch Project are addressed in Impact NO-4, Section 3.9, Noise. See
also Master Comment Response 9. Also see Master Comment Response 6 and Section 3.6,
Hazards and Hazardous Materials, Impact HAZ-3, for a detailed discussion on airport
safety issues. In addition, all of the residential units are located outside of higher airport
noise areas. Please note that as part of the Project design, bedrooms, sleeping rooms, and
living rooms and other noise-sensitive parts of R-3 dwelling units would be located on the
side farthest from the noise source. Further, modern construction techniques reduce interior
noise levels by 25 decibels or more, limiting effects on future residents and potential for
complaints.
Comment Response KK1-2: The EIR analyzes impacts created by the Project regarding
both to air quality and to public infrastructure, and mitigation is required where necessary
to reduce impacts. The EIR addresses impacts to County agricultural lands (see Impact
AG-2 in Section 3.2, Agricultural Resources), air pollutant emissions (see Section 3.3, Air
Quality and Greenhouse Gas Emissions). The adequacy of traffic infrastructure is analyzed
within Section 3.12, Transportation and Traffic, and in Appendix P, Transportation Impact
Study. To the extent feasible, transportation infrastructure improvements are phased to be
in place prior to major Project increases in traffic and associated impacts.
Comment Response KK1-3: Impacts to traffic under the Project are analyzed in Section
3.12, Transportation and Traffic, as well as within the Transportation Impact Study in
Appendix P. This includes analysis of the intersections of Buckley Road/SR 227, Buckley
Road/Vachell Lane, Tank Farm Road/South Higuera Street, and segments of South
Higuera Street and the LOVR overpass. Where necessary, mitigation measures to reduce
traffic impacts would be required. In addition, as noted above, to the extent feasible,
infrastructure improvements are being phased to coincide with Project major increases in
Project generated traffic to ensure that Project development is consistent with City and
County standards. However, under State law, the Project alone cannot be required to repair
all existing transportation deficiencies.
Comment Response KK1-4: Increases in air emissions from the use of motor vehicles
under the Project are considered in the analysis of impacts to air quality in Section 3.3, Air
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-357
Final EIR
Quality and Greenhouse Gas Emissions, and detailed vehicle emissions calculations are
provided in Appendix H. Operation vehicle emissions estimates are accounted for with
Project operation air emissions, which assumes a limited amount of vehicle idling. Idling
of standard motor vehicles for short periods of time (e.g., less than a minute at an
intersection would not generally produce enough diesel particulate matter to be
carcinogenic or toxic.
Comment Response KK1-5: Cumulative land use and roadway network improvements
were evaluated consistent with the City's LUCE, based on existing conditions known at the
time of release of the NOP.
Comment Response KK1-6: The EIR provides discussion of existing intersection and
road segment operations along SR 227 (Broad Street). Refer to Segment and Intersection
Operations of Section 3.12.4.2 in Section 3.12, Transportation and Traffic.
Comment Response KK1-7: The EIR evaluates Project impacts at four intersections and
one segment along Buckley Road and applies transportation standards from the City of San
Luis Obispo, County of San Luis Obispo, and Caltrans. However, the Final EIR has been
updated to more fully address increases in traffic and side street intersection operations
along Buckley Road. Please see revisions to Section 3.12, Transportation and Traffic, of
the EIR which includes expanded discussions of traffic capacity, operational and safety
issues along Buckley Road. Please also see Master Comment Response 8.
Comment Response KK1-8: The EIR analyzes potential Project consistency with
applicable policies of the City General Plan, including policies relating to the protection of
biological and agricultural resources. For discussion of consistency with these policies,
refer to Section 3.4.4.3 of Section 3.4, Biological Resources, Section 3.2 Agricultural
Resources, and Section 3.8, Land Use and Planning.
Comment Response KK1-9: Refer to Master Comment Response 8.
Comment Response KK1-10: Refer to Master Comment Response 8.
Comment Response KK1-11: Please see revisions to Section 3.12, Transportation and
Traffic, of the EIR which includes expanded discussions of traffic capacity, operational
and safety issues along Buckley Road. Please also see Master Comment Response 8.
Comment Response KK1-12: The EIR provides a detailed analysis of potential impacts
to water supply, including those that could occur during the recent 5-year drought as well
as the adequacy of groundwater resources to support ongoing Project use of local
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Final EIR
groundwater for agricultural operations. It should also be noted that the Project includes
substantial water conservation and reuse measures. A detailed water supply assessment
(WSA) was prepared for the Project (see Appendix M) and was subject to peer review by
both the EIR preparers and City staff. As discussed in Section 3.13, Utilities,
implementation of the proposed Project may result in the relocation of an existing onsite
well only. For discussion of operations of this well and impacts to City water supply, refer
to Section 3.13, Utilities. Project impact to groundwater resources is discussed in Impact
HYD-6, Section 3.7, Hydrology and Water Quality. Based on this analysis, the EIR finds
that water supplies are adequate to serve the Project and that continued more limited use
of groundwater would not adversely impact local groundwater resources as such use would
be reduced from historic averages. Please also refer to Master Comment Response 7.
Comment Response KK1-13: Whether units are owner-occupied, occupied by students
or rented, the construction of additional housing would help to improve the City’s existing
jobs-to-housing imbalance. Further, the Project would provide affordable housing units to
meet the requirements of the City’s Inclusionary Housing Requirements program. All such
inclusionary affordable units are carefully monitored by the City to ensure that they are
purchased or rented by qualified individuals or families. Occupancy projections for units
and overall population estimates for the Project are based on citywide average figures,
which account for typical population characteristics, including student households. See
Section 3.10, Population and Housing, Impacts PH-2 and PH-3.
Comment Response KK1-14: The Project includes the development of a bicycle lane
network, including proposed bicycle lanes along Buckley Road. Class II bicycle lanes are
also proposed along the Earthwood Lane and Horizon Lane extensions to link future
Project residents to Suburban Road and commercial and employment uses to the north as
well as offsite improvements such as new bicycle lands along Vachell Road proposed as
part of the Project and/ or required as mitigation in the EIR. See Section 2.6.5.2, Class I
Paths and Class II Bicycle Lanes, and Pedestrian Circulation.
Comment Response KK1-15: Refer to Commenter 40, Comment Response
CALTRANS2-1.
Comment Response KK1-16: The EIR identifies both Project construction-related and
long-term operational emissions as significant and unavoidable and requires all possible
feasible mitigation measures to reduce or avoid such impacts. In addition, although the
Project would include many measures to reduce pollutant emissions and the EIR requires
extensive further mitigation, the City would be required to adopt a Statement of Overriding
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-359
Final EIR
Considerations to weigh the Project’s significant air quality impacts against the Project’s
benefits. Per CEQA Section 15093, “If the specific economic, legal, social, technological,
or other benefits, including region-wide or statewide environmental benefits, of a proposed
project outweighs the unavoidable adverse environmental effects, the adverse
environmental effects may be considered ‘acceptable’”.
Comment Response KK1-17: Amortization of construction emissions is based on detailed
air emissions modeling methodology, and is generally consistent with SLO APCD’s
methodology for modeling and reporting construction-related emissions. Although the
Project primarily involved residential development, the Project would develop commercial
retail and visitor serving uses to accommodate residents of the Project and surrounding
area. As such, the EIR employs a reasonable worst case estimate for the reporting of
construction related air pollutant emissions. Air pollutant emissions estimates and potential
for dispersion also account for local climatic conditions. Refer to Section 3.3, Air Quality
and Greenhouse Gas Emissions, for methodology and discussion of Project impacts.
Detailed air emissions calculations can be found in Appendix H of this EIR.
Comment Response KK1-18: Although the Project design and EIR mitigation measures
include a wide range of measures to promote and encourage biking and transit use, traffic
generation estimates and associated pollutant emission estimates employ conservative
assumptions regarding transit and bike use to ensure identification reasonable worst case
estimates for such emissions.
Comment Response KK1-19: The Project would provide a range of unit types and sizes
with a resultant mix of unit prices with a goal to provide “workforce” housing. While such
uncontrolled units would be or rented sold at market rates, a diversity of housing types and
sizes would provide a range of sale or rental prices for future residents.
Comment Response KK1-20: The impacts of airport noise on persons within the Project
site is analyzed within Impact NO-4 in Section 3.9, Noise. Airport safety and airport
operations are also analyzed within Impact HAZ-3, Section 3.6, Hazards and Hazardous
Materials. Please see also Comment Response KK1-1.
Comment Response KK1-21: The EIR thoroughly analyzes safety issues and the Project
would be subject to review and approval by the Airport Land Use Commission (ALUC).
Please also refer to Commenter 113, Comment Response MVL-5.
8.0 RESPONSE TO COMMENTS
8-360 Avila Ranch Development Project
Final EIR
Comment Response KK1-22: Water availability and Project water demand is analyzed in
Section 3.13, Utilities. Please also refer to Comment Response KK1-12 and Commenter
110, Comment Response MW/MB-18.
Comment Response KK1-23: The SLCUSD was contacted during the preparation of this
EIR and the detailed analysis of school enrollment impacts provided in Section 3.11, Public
Services reflects SLOUSD input. Please also refer to Master Comment Response 11.
Comment Response KK1-24: Impacts to fire services are discussed in detail in EIR
Section 3.11, Public Services. This analysis was prepared in close coordination with the
City Fire Department, including proposed use of an Interim Fire Station. The effects of
congestion on fire response times are not anticipated to be substantial; however, a brief
discussion of this issues have been added to Impact PS-2. Please also refer to Master
Comment Response 11.
Comment Response KK1-25: Refer to Commenter 48, Comment Response AC-2.
Comment Response KK1-26: Please note that although the Project would result in the
loss of approximately 94.6 acres of agricultural lanes, of which 68 acres is considered
prime soils onsite, the site has been designated for urban uses by the County since 2000
and by the City since 2008 when it annexed the property. As discussed throughout the EIR,
the proposed development lies within the City’s Urban Reserve Line. Please also refer to
Master Comment Response 2.
Comment Response KK1-27: The costs of increased fire protection services are being
addressed through a Development Agreement between the Project applicant and the City.
The proposed Project and future Avila Ranch residents will contribute funds to both
construction and operation of the proposed new fire station.
Comment Response KK1-28: The cumulative impacts of pending development projects
on agricultural land, including those associated with the Dalidio and Froom Ranch are
discussed in Section 3.2, Agricultural Resources (refer to Subsection 3.2.4.4). In addition,
the Project sets aside substantial open space areas to address airport safety and would be
subject to review and approval by the ALUC. See Master Comment Response 6.
Comment Response KK1-29: Please note that the State grant provided to the City for
preparation of the LUCE was intended to promote infill development.
Comment Response KK1-30: Notification of EIR availability met or exceeded state
requirements. Refer to Master Comment Response 1.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-361
Final EIR
Comment Response KK1-31: Comments in support of or opposition to the proposed
Project are best made directly to City decision-makers. With regards to transportation
mitigation measures, improvements such as the planned roundabout at the intersection of
Buckley Road and SR 227 and several planned turn lane extensions would reduce both
existing congestion and mitigate Project impacts are recommended by licensed traffic
engineers as the best methods to address this issue.
Comment Response KK1-32: Thank you and we appreciate your comments on the EIR.
However, this comment does not pertain to any inadequacies within the EIR and is not a
CEQA-related concern.
KK2-1
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Avila Ranch Development Project 8-363
Final EIR
Commenter 96 – Karen Krahl, December 12th Letter
Comment Response KK2-1: Please refer to Master Comment Response 1.
KD-1
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Avila Ranch Development Project 8-365
Final EIR
Commenter 97 – Kathleen Dente
Comment Response KD-1: Please refer to Section 3.12, Transportation and Traffic,
Section 3.13, Utilities, and Section 3.11, Public Services, for detailed discussions on your
concerns on traffic, water availability, schools. Also see Master Comment Response 7 for
a detailed response regarding water availability, and Master Comment Response 11 for a
detailed response regarding impacts to schools.
KB1-1
KB1-2
KB1-3
KB1-4
KB1-5
KB1-6
KB1-7
KB1-8
KB1-9
KB1-10
8.0 RESPONSE TO COMMENTS
8-368 Avila Ranch Development Project
Final EIR
Commenter 98 – Kathy Borland, January 11th Letter
Comment Response KB1-1: The purpose of an EIR is to identify, analyze, and disclose
potential impacts from a project. City decision-makers determine approval of a project after
their review of the environmental document. The commenter correctly identifies
significant impacts to agricultural resources and air quality. Because of the significant
unavoidable impacts identified within the EIR, the City would be required to adopt a
Statement of Overriding Considerations if it were to approve the Project. Per CEQA
Section 15093, “If the specific economic, legal, social, technological, or other benefits,
including region-wide or statewide environmental benefits, of a proposed project outweigh
the unavoidable adverse environmental effects, the adverse environmental effects may be
considered ‘acceptable’”.
Comment Response KB1-2: The EIR does identify significant and unavoidable impacts
to air quality and GHGs in Section 3.3, Air Quality and Greenhouse Gas Emissions. All
feasible mitigation measures have been included to reduce the severity of the impact. Refer
to Comment Response KB1-1.
Comment Response KB1-3: The EIR does identify significant and unavoidable impacts
to long-term air quality emissions in Section 3.3, Air Quality and Greenhouse Gas
Emissions. Refer to Comment Response KB1-1.
Comment Response KB1-4: The EIR does identify significant and unavoidable impacts
related to consistency with the 2001 Clean Air Plan in Section 3.3, Air Quality and
Greenhouse Gas Emissions. Refer to Comment Response KB1-1.
Comment Response KB1-5: Please refer to Impact NO-3 in Section 3.9, Noise, for a
detailed discussion on long-term noise impacts related to operation of the Project after
construction is completed. This includes an analysis of operational noise impact associated
within the increase in Project-generated traffic trips along local roadways. As described in
Impact NO-3, impacts would be reduced to a less than significant level after
implementation of Mitigation Measures NO-3a (noise reduction building design features)
and NO-3b (paving technology to reduce noise levels for sensitive receptors near the
roadway).
Comment Response KB1-6: Refer to Master Comment Response 2.
Comment Response KB1-7: The Project would not contribute "7,000+ cars a day on
Buckley Road". The Project would contribute varying levels of traffic to Buckley Road
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-369
Final EIR
over time due to the phased nature of roadway completion, with the total number of daily
cars from the Project on Buckley Road are estimated to reach 490 daily trips at buildout of
the Project. Please see revisions to Section 3.12, Transportation and Traffic, of the EIR
which includes expanded discussions of traffic capacity, operational and safety issues
along Buckley Road. Please also see Master Comment Response 8. The EIR also evaluates
Project impacts at four major intersections and one segment along Buckley Road and
applies transportation standards from the City of San Luis Obispo, County of San Luis
Obispo, and Caltrans. Mitigation Measure TRANS-5 requires a project contribution
towards improvements at the Buckley Road/SR 227 intersection. With regards to
recommended improvements to turn lanes (e.g., lengthening of turn lanes), the EIR
provides detailed analysis of levels of service and queuing at impacted intersections
consistent with City standards and finds that such improvements would reduce congestion
and fully mitigate Project and cumulative impacts at these locations.
Comment Response KB1-8: The EIR evaluates Project impacts at four intersections and
one segment along Buckley Road and applies transportation standards from the City of San
Luis Obispo, County of San Luis Obispo, and Caltrans. However, please see revisions to
Section 3.12, Transportation and Traffic, of the EIR which includes expanded discussions
of traffic capacity, operational and safety issues along Buckley Road. Please also see
Master Comment Response 8.
Comment Response KB1-9: Please refer to Master Comment Response 8.
Comment Response KB1-10: Please refer to Master Comment Response 8.
KB2-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-371
Final EIR
Commenter 99 – Kathy Borland, December 12th Letter
Comment Response KB2-1: Your opposition to the Project is noted. In response to public
concerns regarding the duration and timing of the public comment period, please refer to
Master Comment Response 1.
KL-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-373
Final EIR
Commenter 100 – Katie Longabach
Comment Response KL-1: Your opposition to the Project is noted. Please refer to Master
Comment Response 8.
KP-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-375
Final EIR
Commenter 101 – Kayla Plourde
Comment Response KP-1: Please refer to Master Comment Response 1.
Kienow-1
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Avila Ranch Development Project 8-377
Final EIR
Commenter 102 – Ken Kienow
Comment Response Kienow-1: Per your suggestions, and as described in Mitigation
Measure AQ-2b, 1) neighborhood electric vehicles/car share program would be provided
for the Project; 2) outdoor electrical outlets would be provided per City code and are
optional on all houses and electrical charging station for electric vehicles would be
provided at the Town Center; 3) 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; and 4) provide preferential
parking / no parking fee for alternative fueled vehicles or vanpools.
KMB-1
KMB-2
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Final EIR
Commenter 103 – Kristie and Matthew Barry
Comment Response KMB-1: Refer to Master Comment Response 8.
Comment Response KMB-2: Refer to Commenter 53, Comment Response BF1-1.
LJ-1
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8-382 Avila Ranch Development Project
Final EIR
Commenter 104 – Linda Jankay
Comment Response LJ-1: Your concerns regarding increased traffic are noted. Please
refer to Master Comment Response 8, Commenter 53, Comment Response BF1-1, and
Section 3.12, Transportation and Traffic, for a detailed discussion on the Project’s impact
on traffic and local roadways, including traffic along SR 227, Buckley Road, and Vachell
Lane. Please note that the Project proposes left turn restrictions at Vachell Lane/South
Higuera Street to address intersection operations. This modification of Vachell Lane is to
occur upon completion of the Buckley Road Extension. See Section 2.6.5, Circulation.
LS-1
LS-2
LS-3
LS
-4
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8-384 Avila Ranch Development Project
Final EIR
Commenter 105 – Lisa Sutherland
Comment Response LS-1: Please refer to Master Comment Response 8.
Comment Response LS-2: Please refer to Master Comment Response 8 and Section 3.12,
Transportation and Traffic, Impact TRANS-5.
Comment Response LS-3: Your opposition to the Project is noted. Please refer to Master
Comment Response 5 regarding housing affordability.
Comment Response LS-4: Please refer to Impact CR-3 in Section 3.5, Cultural
Resources, for a detailed discussion of issues related to the Project’s potential impacts to
cultural resources.
LM-1
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Final EIR
Commenter 106 – Lydia Mourenza
Comment Response LM-1: Please refer to Master Comment Response 1.
MFS
-1
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Final EIR
Commenter 107 – M. Farid Shahid
Comment Response MFS-1: Thank you, your comment and support of the Project has
been noted.
Brinton-1
Brinton-2
Brinton-3
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8-390 Avila Ranch Development Project
Final EIR
Commenter 108 – Mac Brinton
Comment Response Brinton-1: Refer to Master Comment Responses 8.
Comment Response Brinton-2: Refer to Master Comment Responses 8.
Comment Response Brinton-3: Refer to Master Comment Responses 8.
MB-1
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Final EIR
Commenter 109 – Margaret Baker
Comment Response MB-1: Please refer to Master Comment Response 8 for a detailed
response regarding traffic at SR 227. Section 3.12, Transportation and Traffic, Impacts
TRANS-4 through TRANS-8 contain a detailed discussion on impacts to surrounding
roadways including Buckley Road, South Higuera Street, Tank Farm Road, and LOVR.
MW/MB-1
MW/MB-2
MW/MB-3
MW/MB-4
MW/MB-5
MW/MB-6
MW/MB-7
MW/MB-8
MW/MB-9
MW/MB-10
MW/MB-11
MW/MB-12
MW/MB-13
MW/MB-14
MW/MB-15
MW/MB-16
MW/MB-17
MW/MB-18
MW/MB-19
MW/MB-20
MW/MB-20
Cont.
MW/MB-21
MW/MB-22
MW/MB-23
MW/MB-24
MW/MB-25
MW/MB-26
MW/MB-27
MW/MB-28
MW/MB-29
MW/MB-30
MW/MB-31
MW/MB-32
MW/MB-33
MW/MB-33
Cont.
MW/MB-34
MW/MB-35
8.0 RESPONSE TO COMMENTS
8-398 Avila Ranch Development Project
Final EIR
Commenter 110 – Mark Wheeler and Marge Barinka
Comment Response MW/MB-1: Thank you and we appreciate your comments. However,
this comment does not pertain to any inadequacies within the EIR and is not a CEQA-
related concern, so no EIR-related response is possible.
Comment Response MW/MB-2: Discussion of impacts to agricultural resources resulting
from implementation of the Project, including the loss of prime agricultural land, is
provided in Section 3.2, Agricultural Resources, Impact AG-1. Please refer also to Master
Response 2.
Comment Response MW/MB-3: As discussed in Comment Response MW/MB-2, the
EIR discloses and describes impacts relating to conversion or the loss of agricultural lands
and prime farmland soils in Section 3.2, Agricultural Resources. However, the benefit of
having agricultural land within a City’s sphere of influence is not related to direct or
indirect Project impacts and is a policy consideration and is best directed to City decision-
makers.
Comment Response MW/MB-4: Vehicle emissions and greenhouse gas emissions are
addressed in Section 3.3, Air Quality and Greenhouse Gas Emissions.
Comment Response MW/MB-5: Thank you and we appreciate your comments. However,
this comment does not pertain to any inadequacies within the EIR and is not a CEQA-
related concern.
Comment Response MW/MB-6: As discussed in Section 3.13.2.1 of Section 3.13,
Utilities, the City is currently upgrading the existing Water Resources Reclamation Facility
(WRRF) to increase its operational capacity to 5.4 MGD, which will handle the full build-
out dry-weather wastewater flows of the City, as predicted in the LUCE Update EIR. The
WRRF upgrade program is expected to be completed in 2020, approximately 10-years prior
to operational build-out of the Project. Operational wastewater demand of the Project
would be met by the upgraded capacity of this facility, and it is not anticipated that the
Project’s increase in wastewater demands would result in exceedance of any wastewater
treatment air emission thresholds or the violation of WRRF permits.
Comment Response MW/MB-7: Impacts to biological resources resulting from
implementation of the proposed Project are provided in Section 3.4, Biological Resources.
No fairy shrimp were identified within the Project site. See Appendix I for the Biological
Report, listing species surveyed within the Project site.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-399
Final EIR
Comment Response MW/MB-8: Impacts to biological resources resulting from
implementation of the proposed Project, including creek realignment, are provided in
Section 3.4, Biological Resources.
Comment Response MW/MB-9: Impacts to cultural and archaeological resources are
analyzed in Section 3.5, Cultural Resources.
Comment Response MW/MB-10: With respect to development of the Project within a
delineated flood-hazard area, associated impacts and mitigation measures designed to
reduce such impacts are provided in Section 3.7, Hydrology and Water Quality. See also
Master Comment Response 3.
Comment Response MW/MB-11: Refer to Comment Response MW/MB-10.
Comment Response MW/MB-12: Refer to Comment Response MW/MB-10.
Comment Response MW/MB-13: Impacts related to creek realignment are analyzed in
Section 3.7, Hydrology and Water Quality. Also, see Appendix E for more information on
Project drainage.
Comment Response MW/MB-14: Discussion of the additional runoff resulting from
development of the Project is provided in Section 3.7, Hydrology and Water Quality.
Specifically, Impact HYD-2 and HYD-3 discusses the Project’s anticipated impacts with
regard to drainage of the site and the Project’s effect on runoff.
Comment Response MW/MB-15: Refer to Comment Response MW/MB-10.
Comment Response MW/MB-16: Refer to Comment Response MW/MB-10.
Comment Response MW/MB-17: As discussed under Impact HYD-2 in Section 3.7,
Hydrology and Water Quality, runoff flowing onsite from properties located to the east
would be captured and retained in the wetland area located in the northeast corner of the
Project site. With respect to impacts resulting from this runoff, refer to Impact HYD-2.
Comment Response MW/MB-18: Detailed discussion of availability of City water
supplies, Project water demand, and impacts associated with implementation of the Project
on these water supplies is provided in Section 3.13, Utilities. Refer to Impact UT-2. Also
see Master Comment Response 7.
Comment Response MW/MB-19: This comment does not pertain to any inadequacies
within the EIR and is not a CEQA-related concern.
8.0 RESPONSE TO COMMENTS
8-400 Avila Ranch Development Project
Final EIR
Comment Response MW/MB-20: The EIR provides detailed discussion of the existing
noise environmental and impacts associated with noise volumes resulting from
implementation of the Project in Section 3.9, Noise. The Sound Level Assessment for the
Avila Ranch Project prepared by Acoustics Consulting, provided in Appendix O, was
prepared using appropriate industry standards and methodology. The Sound Level
Assessment measured noise levels from 6 noise stations located around the Project site to
capture a representation of the existing noise environment. Station 4 was located next to
the northwest boundary of the property, adjacent to the current AirVol Block
manufacturing facility with loading and staging areas, and a potential 24-hour daily
operation. Station 6 was located in the northeast corner of the site to capture operational
noise levels from the San Luis Obispo County Regional Airport.
Comment Response MW/MB-21: Thank you and we appreciate your comments.
However, this comment does not pertain to any inadequacies within the EIR and is not a
CEQA-related concern.
Comment Response MW/MB-22: Thank you and we appreciate your comments.
However, this comment does not pertain to any inadequacies within the EIR and is not a
CEQA-related concern. The construction phasing schedule is described in Section 2.7,
Project Construction.
Comment Response MW/MB-23: While there are no requirements for the number of
persons per household, the Draft EIR uses the 2015 City Housing Element average
household size of 2.29 persons per unit in the City of San Luis Obispo to estimate the
population generated by the proposed Project.
Comment Response MW/MB-24: Potential conflicts related to adjacent agricultural
operations is analyzed in Impact AG-2 within Section 3.2, Agricultural Resources.
Comment Response MW/MB-25: Thank you and we appreciate your comments.
However, this comment does not pertain to any inadequacies within the EIR and is not a
CEQA-related concern.
Comment Response MW/MB-26: Discussion of the provision of emergency services to
the Project site, and any impacts associated with deficiencies in these services, is provided
in Section 3.11, Public Services.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-401
Final EIR
Comment Response MW/MB-27: Section 3.12, Transportation and Traffic, provides
detailed discussion of the existing transportation network, including operations of
roadways and intersections, and known system deficiencies.
Comment Response MW/MB-28: Traffic impacts and proposed mitigation measures are
based on a detailed Transportation Impact Study prepared by Central Coast Transportation
Consulting. Through implementation of proposed mitigation measures, anticipated impacts
at several intersections and along local roadway segments could be mitigated to a less than
significant level through utilization of common industry standards for transportation
improvements, such as turning-movement improvements, intersection signalization, lane
realignment, widening of road segments, etc. However, some transportation impacts could
not feasibly be mitigated to a less than significant level, and come impacts resulting from
Project implementation are considered significant an unavoidable. For detailed discussion
of these impacts and mitigation measures, refer to Section 3.12, Transportation and Traffic.
Comment Response MW/MB-29: Refer to Comment Response MW/MB-28.
Comment Response MW/MB-30: All of the noted intersections are evaluated in the EIR,
and mitigations are presented in accordance with City policies where the Project would
result in or contribute towards impacts to these transportation facilities. Refer to discussion
of impacts and mitigation measures in Section 3.12, Transportation and Traffic. See Impact
TRANS-7 and Mitigation Measures TRANS-7a through TRANS-7d.
Comment Response MW/MB-31: The analysis of Project impacts on the U.S. Highway
101 northbound and southbound on- and off-ramps at LOVR consider existing traffic
conditions in the analysis of Project construction and operational impacts. Detailed
discussion of impacts to these freeway facilities are included under Impact TRANS-8 of
Section 3.12, Transportation and Traffic. As noted in this discussion, existing conditions
of these facilities were determined prior to completion of the LOVR interchange project,
which has improved conditions of these facilities beyond that which was identified in the
Transportation Impact Study.
Comment Response MW/MB-32: As discussed in Section 3.12, Transportation and
Traffic, under Impact TRANS-2, the Project would construct the Buckley Road extension
prior to occupancy of Phase 2 and would not add traffic to Vachell Lane in Phase 1.
Comment Response MW/MB-33: Please see revisions to Section 3.12, Transportation
and Traffic, of the EIR, which includes expanded discussions of traffic capacity,
8.0 RESPONSE TO COMMENTS
8-402 Avila Ranch Development Project
Final EIR
operational and safety issues along Buckley Road. Please also see Master Comment
Response 8.
Comment Response MW/MB-34: The Prado Road interchange is included in the
Cumulative scenario consistent with the City's Circulation element. The City and Caltrans
are currently studying the interchange as a part of a separate process.
Comment Response MW/MB-35: With regard to discussion of existing City water
supply, and Project demand for water services, refer to Comment Response MW/MB-18
and Master Comment Response 7. With regard to discussion of capacity of WRRF, refer
to Comment Response MW/MB-6. In addition, a Water Supply Assessment (WSA) was
prepared for the Project and included in Appendix M of the EIR. Discussed of the findings
of the WSA is provided under Impact UT-3 of Section 3.13, Utilities.
MM-1
MM-2
MM-
3
8.0 RESPONSE TO COMMENTS
8-404 Avila Ranch Development Project
Final EIR
Commenter 111 – Melanie Mattina
Comment Response MM-1: Please note as stated in Section 2.0, Project Description, only
a portion of the 720 units would be affordable units. The Applicant would be required to
provide affordable housing to meet the City’s Inclusionary Housing Requirements. See
also Master Comment Response 5.
Comment Response MM-2: Please refer to Master Comment Response 11 and Section
3.11, Public Services, Impact PS-3 for a discussion on the Project’s impact to schools.
Please see Section 3.12, Transportation and Traffic, Impact TRANS-2 for detailed
information on the Project’s impact to road infrastructure. Please see Master Comment
Response 7 for a discussion on impacts to water availability.
Comment Response MM-3: For discussion of water supply and availability, refer to
Master Comment Response 7 and Section 3.13, Utilities, Impact UT-3. As described in
Section 3.13, Utilities, analysis of water availability for the Project is based upon the City’s
2015 Urban Water Management Plan. The City’s projected water demand within the Urban
Water Management Plan is based on the 10-year average of per capita water usage, which
accounts for cyclic water factors including years of drought, wet years, and normal years.
While the City has been in a drought state, water usage varies depending on the water cycle,
and the EIR assesses average usage over a 10-year period. Regarding groundwater
resources, the City will continue to use groundwater for domestic purposes when available,
but will not consider groundwater a source of supply as part of its water resource planning
or water supply availability, and apart from the replacement of an onsite well that would
continue to be used only for agricultural purposes, domestic water supply would be
provided primarily by existing reservoirs (Whale Rock, Nacimiento, and Salinas) and City
recycled water facilities. Refer to Section 3.13, Utilities, for further discussion of existing
and future water supplies. For further discussion of impacts to local groundwater, refer to
Section 3.7, Hydrology and Water Quality, Impact HYD-6.
MN-1MN-2
8.0 RESPONSE TO COMMENTS
8-406 Avila Ranch Development Project
Final EIR
Commenter 112 – Melissa Cummins (Newman)
Comment Response MN-1: The Project does not connect to Rolling Hills Road or
Caballeros Avenue, and would not add traffic to these roads. Project contributions to
increased traffic on SR 227 are addressed in Master Comment Response 8.
Comment Response MN-2: The Project would add fewer than ten peak hour trips to the
segment of SR 227 south of Buckley Road, which is less than one percent of the existing
traffic volume. Under Cumulative conditions, the Project would add less than thirty peak
hour trips to the SR 227 corridor, which corresponds to less than one percent of the forecast
Cumulative volume. These added trips would not substantially increase delays at the
intersection of the Crestmont Drive and SR 227. To further address Project contributions
to traffic at this intersection, Mitigation Measure TRANS-5 requires a project contribution
towards improvements at the Buckley Road/SR 227 intersection to ensure adequate
operation of this facility.
MVL-1
MVL-2
MVL-3
MVL-4
MVL-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-411
Final EIR
Commenter 113 – Mila Vujovich-La Barre
Comment Response MVL-1: Operational vehicle emissions estimates are accounted for
with Project operation air emissions as modeled by CalEEMod within Appendix H, which
includes emissions for a limited amount of vehicle idling time per vehicle trip. Idling of
standard motor vehicles for short periods of time at an intersection (e.g., less than a minute
at an intersection) would not generally produce enough diesel particulate matter to be
carcinogenic or toxic. Detailed operational vehicle emissions based on estimated VMT data
can be located in Section 4.0, Operational Data – Mobile, in Appendix H. Further,
Mitigation Measure AQ-1a limits idling time for construction vehicles.
Comment Response MVL-2: The impact analysis provided in this EIR assesses the
impacts associated with implementation of the proposed Project and does not analyze
separate impacts associated with a Prado Road overpass project independent from the
Project. Per CEQA Section 15130, “[a]n EIR shall discuss cumulative impacts of a project
when the project’s incremental effect is cumulatively considerable, as defined in section
15065 (a)(3).” Section 3.12.4.4 of the EIR provides discussion of the Project’s near-term
and long-term cumulative effect on transportation and circulation systems with respect to
other pending, approved, or ongoing projects within the vicinity. The Project’s cumulative
impacts associated with the Prado Road overpass and other pending or planned projects is
described in Impacts TRANS-13 through TRANS-15 in Section 3.12, Transportation and
Traffic. The EIR addresses cumulative traffic impacts to the Prado Road/South Higuera
Street intersection and identifies these impacts as cumulatively considerable. The City
would therefore be required to adopt a Statement of Overriding Considerations to weigh
the Project’s significant cumulative impacts against the Project’s benefits. Per CEQA
Section 15093, “If the specific economic, legal, social, technological, or other benefits,
including region-wide or statewide environmental benefits, of a proposed project outweigh
the unavoidable adverse environmental effects, the adverse environmental effects may be
considered ‘acceptable’”.
Comment Response MVL-3: Thank you, your comment has been noted. Refer to Master
Comment Response 5. As described in Section 2.6.3.2, Project Inclusionary Housing, a
portion of the Projects 720 units would meet the City’s Inclusionary Housing Requirements
program. These units would be subject to resale and rental restrictions to meet the needs
for low and moderate income households. See also Impact PH-3 in Section 3.10,
Population and Housing for a detailed discussion on Project impacts to affordable housing.
Comment Response MVL-4: Please refer to Master Comment Response 6.
8.0 RESPONSE TO COMMENTS
8-412 Avila Ranch Development Project
Final EIR
Comment Response MVL-5: As discussed in Commenter 46, Comment Response PPD-
73, the ALUC held a hearing on December 21, 2016, to review the Project and its
alternatives and their conformance with the ALUP. The ALUC concluded that the proposed
Project and the MPA are in conformance with the ALUP, and a statement regarding their
decision has been included in Section 3.8, Land Use, and Section 5.0, Alternatives. Please
refer to Master Comment Response 13.
Comment Response MVL-6: For questions regarding the availability of water supplies
and Project water demand, refer to Section 3.13, Utilities, and Master Comment Response
7.
Comment Response MVL-7: Discussion of existing school facilities, enrollment
capacities, and the Project’s demand for public school services are provided in Section
3.11, Public Services, Impact PS-3. Refer also to Master Comment Response 11.
Comment Response MVL-8: Discussion of existing emergency services, service
capabilities, and Project impacts on emergency services are provided in Section 3.11,
Public Services. As described in Section 2.6.6.4, Fire Protection Services, the Project
would provide an Interim Fire Station to provide adequate service to the Project site and
would remain operational until the City’s proposed fifth fire station is constructed and fully
operational; the City’s fifth fire station would provide fire protection services for the new
residential units and surrounding population near the City’s southern edge. Impact PS-2 in
Section 3.11 analyzes the adequacy of fire protection and determines the Project’s impact
to be significant but mitigable after payment of a fair share contribution to fire protection
facilities.
Comment Response MVL-9: The site is not currently zoned for agriculture (as referenced
by the quoted statute) but is instead zoned Business Park (BP) and Conservation/Open
Space (C/OS), is in the URL and City, and is designated and mapped for development
under the Avila Ranch Specific Plan under the Land Use Element of the City LUCE.
Development of the property for agriculture would be inconsistent with the City’s recently
adopted LUCE. Refer to Commenter 48, Comment Response AC-2.
Comment Response MVL-10: Please note that Class I bicycle paths, parking, solar
panels, and sustainable construction are incorporated into the Project design. See Section
2.6.4, Project Design for more detail. The Project incorporates multi-modal transportation
elements into the Project design, including approximately 3 miles of new off-road Class I
bicycle paths and on-road Class II bicycle lanes, as well as pedestrian walkways and
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-413
Final EIR
improved transit service to the site. Although located in the southern area of the City, the
site is within walking distance of a large full service shopping center with a market, retail
and service outlets and restaurants as well as several light industrial and office park
employment centers. The Project, as well as required mitigation measures in the EIR,
would include substantial offsite improvements to pedestrian facilities and bicycle lanes to
provide linkages to these nearby uses, further enabling future Project residents to walk or
bike to such destinations. Regarding the use of solar panels, the Development Plan
specifies that at least 50 percent of units in the development shall have photovoltaic solar
panels, equating to at least 360 dwelling units and the commercial units. The current City
standard is about 120 units (30 percent of R-1 and R-2 units, while multi-family and
commercial are exempt from the Conservation and Open Space policy). However, through
the planning review process, additional solar capabilities and energy conservation features
may be proposed and incorporated as part of the final Project design. The Project would
include sustainable development design in compliance with the U.S. Green Building
Council’s LEED-ND “silver” certification, as well as San Luis Obispo County’s Green
Build “emerald” certification rating. To the extent feasible, building orientation would
follow the County’s Green Build Passive Solar guidelines.
NS-1NS-2
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-415
Final EIR
Commenter 114 – Nathan Stong
Comment Response NS-1: To address Project impacts to these road segments, the EIR
provides Mitigation Measures TRANS-8a and TRANS-13, which discuss this issue and its
residual impacts. Adding a second westbound through lane would decrease vehicle density,
thereby increasing gaps and reducing delay to side street approaches.
Comment Response NS-2: The study locations were identified and evaluated consistent
with the City's Transportation Impact Study guidelines. The Draft EIR evaluates the
roadway segment adjacent to the Los Verdes development and the adjacent signalized
intersections. Driveways are evaluated under the scope of segment level of service, this
location was analyzed in the study and mitigation measures were developed accordingly.
Smidth-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-417
Final EIR
Commenter 115 – Niels Smidth
Comment Response Smidth-1: Refer to Master Comment Response 8.
OD
-1
OD
-2
OD
-3
OD
-4
OD
-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-419
Final EIR
Commenter 116 – Orin Davis
Comment Response OD-1: Please refer to Master Comment Responses 8, and also
Section 3.12, Transportation and Traffic, for a detailed discussion on your traffic concerns.
Comment Response OD-2: Please refer to Master Comment Response 2 for a detailed
response to your concerns regarding prime agricultural land.
Comment Response OD-3: Please refer to Master Comment Response 7 for a detailed
discussion of issues related to water availability.
Comment Response OD-4: Please refer to Master Comment Response 6 for a detailed
discussion of issues related to airport safety.
Comment Response OD-5: Please refer to Master Comment Response 1.
PK-1
PK-2
PK-3
PK-4
PK-5
PK-5
Cont.
PK-6
PK-7
PK-8
PK-9
PK-10
PK-11
PK-12
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-423
Final EIR
Commenter 117 – Pamela Krahl
Comment Response PK-1: The proposed Project is within the jurisdiction of the City and
is not subject to policies or requirements of the County General Plan. Refer to Master
Comment Response 2.
Comment Response PK-2: The proposed Project is located within the City of San Luis
Obispo. As such, the Lead Agency overseeing preparation of this EIR is the City of San
Luis Obispo Community Development Department Planning Division. As the Project is
not under the jurisdiction of the County, and the City does not have individual CEQA
guidelines, this EIR was prepared in conformance with the 2016 CEQA Statues and
Guidelines.
Comment Response PK-3: The Project was analyzed using thresholds listed in the City
of San Luis Obispo General Plan Circulation Element and is addressed in Section 3.12,
Transportation and Traffic, Impacts TRANS-4, TRANS-11 and TRANS-12. The EIR
found these impacts to be less than significant after the implementation of mitigation
measures, including an improvement plan for Horizon Lane, Earthwood Lane, and
Suburban Road, construction of bicycle bridges along Buckley Road, and coordination
with SLO Transit. The Project was analyzed for consistency with the Circulation Element
in Section 3.8.4, Consistency with Plans and Policies, and addressed in Impact LU-3 in
Section 3.8, Land Use and Planning, and the Project was found to be consistent with the
goals and policies of this regulatory document after the implementation of transportation
mitigation measures listed in Section 3.12, Transportation and Traffic.
Comment Response PK-4: An analysis of the Project’s consistency to General Plan
elements including those relating to land use, circulation, conservation and open space,
noise, safety, parks and recreation, and water and wastewater is provided in Section 3.8.4,
Consistency with Plans and Policies. Refer to Section 3.8, Land Use and Planning. Where
appropriate, the EIR uses thresholds identified within the General Plan to identify impacts,
including those for transportation and traffic, agricultural lands, and noise. Where a
significant impact is identified, the EIR requires mitigation measures to reduce impacts,
including those related to traffic and congestion. See Section 3.12, Transportation and
Traffic for a complete list of transportation mitigation measures. Impact AQ-2 in Section
3.3, Air Quality and Greenhouse Gas Emissions addresses Project impacts related to
vehicle emissions. Refer to Master Comment Response 2 regarding impacts to agricultural
resources.
8.0 RESPONSE TO COMMENTS
8-424 Avila Ranch Development Project
Final EIR
Comment Response PK-5: Refer to Master Comment Response 7. Section 3.13, Utilities,
provides detailed discussion of existing City water supplies, availability of these supplies,
and anticipated Project demand. Please see Master Comment Response 3 regarding
flooding within the Project site. For discussion of impacts to hydrologic resources and
water quality within Tank Farm Creek, refer to Section 3.7, Hydrology and Water Quality,
Impact HYD-5. Impacts to creek water quality was found to be less than significant after
the implementation of Mitigation Measures HYD-2a (Master Drainage Plan), and HYD-5
(Development Maintenance Manual).
Comment Response PK-6: As part of the Project review process, the City and Applicant
submitted a Project pre-application to the ALUC to determine consistency with the AASP
and ALUC policies and regulations. In a meeting held on December 21, 2016, the ALUC
determined that the Project was consistent with these plans and policies. Discussion of
ALUC hearing decision has been included in Section 3.8, Land Use and Planning. Please
also refer to Master Comment Response 6.
Comment Response PK-7: For discussion of impacts relating to the development of
residential units in close proximity to airport activities, refer to Impact NO-4 in Section
3.9, Noise. Please also refer to Master Comment Response 6.
Comment Response PK-8: The EIR evaluates traffic flows and congestion during the AM
and PM peaks hours as that is when roads and intersections are potentially most congested.
Although there may be other peaks that occur (e.g., construction trade traffic, school
traffic), these peak hours represent the time when potential Project traffic impacts may be
at their greatest. Therefore, any impacts that occur during other lesser peaks would be les
substantial and are addressed in the analysis of the primary peak hours. Construction traffic
is discussed in detail under Impact and Mitigation Measure TRANS-1 in Section 3.12,
Transportation and Traffic. With implementation of Mitigation Measure TRANS-1, the
Applicant would implement a Construction Transportation Management Plan for all
phases, which would minimize construction impacts on the surrounding road network. The
peak hours of analysis used to determine construction traffic impacts were identified
consistent with City policies.
Comment Response PK-9: The study evaluated eight intersections on South Higuera
Street and four intersections on Buckley Road. Where the Project would result in impacts
to these facilities, appropriate mitigation measures have been identified which would serve
to alleviate queue times, traffic congestion, and ensure safe conditions for drivers,
pedestrians, and bicyclists. The widening of Tank Farm Road is analyzed in cumulative
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-425
Final EIR
Impact TRANS-15 and requires implementation of Mitigation Measure TRANS-15b. This
improvement would require the installation of a pork chop island to improve safety and
assist pedestrian crossings and widening of the south side of Tank Farm Road from Higuera
to the existing bus stop.
Comment Response PK-10: Mitigation Measure TRANS-7a provided in Section 3.12,
Transportation and Traffic, describes how the Project would contribute towards this
improvement, the timing of the improvement, and residual impacts. Further, Figure 3.12-4
has been included in Section 3.12, depicting the proposed lane improvements. Impact
TRANS-15 includes a discussion of this improvement and discloses that this impact could
be significant and unavoidable if the City is not able to obtain additional right-of-way.
Comment Response PK-11: The EIR evaluates Project impacts at four intersections and
one segment along Buckley Road and applies transportation standards from the City of San
Luis Obispo, County of San Luis Obispo, and Caltrans. The roadway design of Buckley
Road is currently capable of safety conveying existing and Project traffic, and widening of
this roadway is not necessary. Other improvements to the local transportation network,
such as the extension of Buckley Road and connection of road segments to the site from
Suburban Road, would serve to provide alternative access to the Project site, therefore
reducing reliance of Buckley Road to access the Project site and reducing the Projects
impacts to safety and travel along Buckley Road. See Master Comment Response 8.
Comment Response PK-12: Thank you, your comment has been noted.
Santos-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-427
Final EIR
Commenter 118 – Patience Santos
Comment Response Santos-1: Your opposition to the Project is acknowledged. Please
refer to Master Comment Response 7 for a detailed response regarding your concerns about
water supply. Project related impacts to air quality, housing, traffic, and water are
addressed in Sections 3.3, Air Quality and Greenhouse Gas Emissions, 3.10, Population
and Housing, 3.12, Transportation and Traffic, and 3.13, Utilities, of this EIR.
PDR
-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-429
Final EIR
Commenter 119 – Patty and Dean Rupprecht
Comment Response PDR-1: Please refer to Master Comment Response 7 and Impact UT-
3 in Section 3.13, Utilities, for a detailed discussion of water supply issues. Please refer to
Section 3.12, Transportation and Traffic, for a detailed discussion of Project-related traffic
impacts.
PS1-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-431
Final EIR
Commenter 120 – Patty Smith, December 12th Letter
Comment Response PS1-1: Your opposition to the Project is noted. In response to public
concerns regarding the duration and timing of the public comment period, please refer to
Master Comment Response 1.
PS
2-3
PS
2-4
PS
2-5
PS
2-6
PS
2-7
PS
2-1
PS
2-2
8.0 RESPONSE TO COMMENTS
8-434 Avila Ranch Development Project
Final EIR
Commenter 121 – Patty Smith, January 16th Letter
Comment Response PS2-1: Thank you, your comment has been noted. Section 3.1,
Aesthetics and Visual Resources, Impacts VIS-1 and VIS-2 address the Project’s impacts
to visual character and aesthetics. The EIR found impacts to aesthetics to be adverse but
less than significant due to provision of open space buffers and vegetation design which
would screen views of the Project site from areas of high viewing exposure, as well as
Project compliance with development and landscape design guidelines of the City’s LUCE
Update and the City’s Community Design Guidelines.
Comment Response PS2-2: Cumulative traffic impacts are discussed in Section 3.12,
Transportation and Traffic, Impacts TRANS-13 through TRANS-15. Please note that
TRANS-15 is identified as a significant impact in the EIR. Impact AG-2, Section 3.2,
Agricultural Resources, discloses potential land use conflicts with surrounding lands and
found impacts to be less than significant. See also Master Comment Response 2.
Comment Response PS2-3: Please refer to Master Comment Response 8.
Comment Response PS2-4: Please refer to Master Comment Response 8.
Comment Response PS2-5: The analysis of cumulative impacts is based upon the list of
pending, approved, or reasonably foreseeable development projects anticipated to occur
through 2035 and known at the time of issuance of the NOP. As such, projects which have
been recently proposed or approved were not included in this analysis. For list of those
projects included in the cumulative analysis of this EIR, see Table 3.0-1 in Section 3.0,
Environmental Impact Analysis and Mitigation Measures.
Comment Response PS2-6: Detailed discussion of availability of City water supplies,
Project water demand, and impacts associated with implementation of the Project on these
water supplies is provided in Section 3.13, Utilities. Refer to Impact UT-3. Please also see
Master Comment Response 7.
Comment Response PS2-7: Please refer to Master Comment Responses 6, 9 and 10. For
discussion of impacts relating to the development of residential units in close proximity to
airport activities, refer to Impact NO-4 in Section 3.9, Noise and Impact HAZ-3 in Section
3.6, Hazards and Hazardous Materials.
PSA-1
8.0 RESPONSE TO COMMENTS
8-436 Avila Ranch Development Project
Final EIR
Commenter 122 – Pete and Sandy Agalos
Comment Response PSA-1: Thank you and we appreciate your comments. Your
opposition to the Project is noted and will be directed towards City decision makers.
PB-1
8.0 RESPONSE TO COMMENTS
8-438 Avila Ranch Development Project
Final EIR
Commenter 123 – Peter Brazil
Comment Response PB-1: Your opposition to the Project is acknowledged. As described
in Section 2.0, Project Description, the Project would include construction of an Interim
Fire Station at the intersection of Earthwood Lane/Venture Drive. This station would
support two firefighters or emergency responders after 50 percent buildout of the Project
site (approximately 360 units), as required by the Fire Master Plan. The Interim Fire Station
would provide coverage to the Project site and surrounding areas until the City’s fifth fire
station is constructed and operational. These improvements have been prescribed based on
the guidance of the City’s Fire Department. Please see Section 3.11, Public Services, for a
detailed discussion on impacts to emergency services. Section 3.12, Transportation and
Traffic, Impacts TRANS-4 through TRANS-8 describe Project-related traffic impacts,
including those to Buckley Road, Vachell Lane, South Street, South Higuera Street, and
LOVR.
PF
-1
PF
-2
PF
-3
PF
-4
PF
-5
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-441
Final EIR
Commenter 124 – Phil Farber
Comment Response PF-1: Refer to Master Comment Response 8.
Comment Response PF-2: Please refer to Master Comment Response 7 for a detailed
discussion on your water availability concern.
Comment Response PF-3: Please refer to Master Comment Response 2 for a detailed
discussion on agricultural land related to the Project.
Comment Response PF-4: Please refer to Master Comment Response 12 for a detailed
discussion on airport noise impacts.
Comment Response PF-5: Cumulative land use and roadway network improvements
were evaluated consistent with the City's LUCE, based on existing conditions known at the
time of release of the NOP.
PM
-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-443
Final EIR
Commenter 125 – Phyllis Martinelli
Comment Response PM-1: Thank you and we appreciate your comments. Your
opposition to the Project is noted. Airport noise related impacts are addressed in Master
Comment Response 9. Refer to Master Comment Response 8 regarding traffic on SR 227.
Steiger-1
Steiger-2
Stegier-3
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-447
Final EIR
Commenter 126 – Rachelle Steiger and Hansen Steiger
Comment Response Steiger-1: Refer to Master Comment Response 8.
Comment Response Steiger-2: Refer to Master Comment Response 8.
Comment Response Steiger-3: For discussion of impacts on public schools, refer to
Master Comment Response 11 and Section 3.11, Public Services, Impact PS-3. Impacts to
schools and school enrollment are found to be less than significant.
RS-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-449
Final EIR
Commenter 127 – Richard Schmidt
Comment Response RS-1: Please refer to Master Comment Response 1.
RR-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-451
Final EIR
Commenter 128 – Rochelle Reed Smith
Comment Response RR-1: Please refer to Master Comment Response 1.
RKE-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-453
Final EIR
Commenter 129 – Roger and Kathleen Eberhardt
Comment Response RKE-1: Your opposition to the Project is noted. Project impacts on
traffic are addressed in Section 3.12, Transportation and Traffic. Project impacts to water
resources are addressed in Section 3.13, Utilities. Project impacts to air quality are
addressed in Section 3.3, Air Quality and Greenhouse Gas Emissions. Impacts related to
airport safety are addressed in Section 3.6, Hazards and Hazardous Materials. Please also
refer to Master Comment Response 3 for a detailed response regarding flooding within the
Project area. Please refer to Master Comment Response 6 for a detailed response regarding
the Project’s proximity to the airport.
RAS-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-455
Final EIR
Commenter 130 – Roland and Anita Smith
Comment Response RAS-1: Please refer to Master Comment Response 8.
RM-1
RM-2
RM-3
RM-4
RM-5
RM-6
RM-7
RM-8
RM-9
RM-10
RM-11
RM-12
RM-13
RM-14
RM-15
RM-16
RM-17
RM-18
8.0 RESPONSE TO COMMENTS
8-458 Avila Ranch Development Project
Final EIR
Commenter 131 – Ronald Malak, City of San Luis Obispo Planning Commissioner
Comment Response RM-1: Comment refers to a short (roughly 1,000 feet) segment of
South Higuera Street with a single northbound lane. The segments of South Higuera Street
both north and south of this segment both provide two northbound lanes. This segment is
outside of study area and the Project would contribute only roughly 118 ADT to this
segment, a less than one percent increase in traffic. This segment is planned to be widened
to four lanes as a City Capital Project and these improvements ae assumed to be completed
under Near Term and Cumulative Conditions.
Comment Response RM-2: Impacts to R-2 and R-4 units proposed as part of the Project
that arise from proximity to existing commercial and industrial development located within
the Project vicinity could include views of existing commercial-industrial uses (e.g., heavy
equipment storage, light and glare) emissions from existing uses (e.g., idling trucks, dust),
operational noise (e.g., idling trucks) and intermingling of new residential trips with
commercial-industrial traffic such as heavy trucks. While the EIR does not identify
potentially significant impacts related to the visual, air quality, traffic, and noise effects of
these existing uses on proposed R-2 and R-4 units, appropriate sections of the EIR have
been revised to include this discussion. Such impacts, along with additional recommended
mitigation measures to improve land use compatibility and improve consistency with
adopted City policy are discussed in detail in Section 3.1, Aesthetics and Visual Resources,
Section 3.3, Air Quality and Greenhouse Gas Emissions, Section 3.8, Land Use and
Planning, Section 3.9, Noise, and Section 3.12, Transportation and Traffic.
Comment Response RM-3: The Development Plan specifies that at least 50 percent of
units in the development shall have photovoltaic solar panels (i.e., roughly 360 units),
designed to meet 50 percent of total Project energy demand. This would exceed City
standards which would require that about 120 units (30 percent of R-1 and R-2 units) are
developed to include solar panels. It should be noted that multi-family and commercial
uses are exempt from this policy requirement. In addition, the Project would be compliant
with the most recently adopted version of the California Building Code, per Title 15 of the
City of San Luis Obispo Municipal Code and as discussed in Appendix D, the Project is
designed in anticipation of complying with revisions in the 2019 California Building Code.
However, in order to further reduce Project unavoidable and significant impacts to air
quality, Mitigation Measure AQ-2a has been updated to require provision of additional
solar or other alternative energy facilities (e.g., solar panels on commercial buildings; solar
canopies over commercial parking areas).
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-459
Final EIR
Comment Response RM-4: Please see Comment Response RM-3.
Comment Response RM-5: Your comment has been noted. As described in Section 3.12,
Transportation and Traffic, since the proposed Project is not within a transit priority area
and Office of Planning Research has not yet adopted new CEQA Guidelines for
replacement criteria to LOS thresholds, the Project is not subject to VMT impact
thresholds.
Comment Response RM-6: The new north/south connector road between Prado Road and
Tank Farm Road was assumed in the analysis of cumulative impacts, as this improvement
was proposed as part of the Chevron Tank Farm Remediation and Development Project.
Comment Response RM-7: Due to the impracticability of accurately forecasting phasing
of cumulative projects, a precise date in which cumulative traffic impacts would occur
cannot be approximated. In addition, such forecasting of precise dates is not required under
CEQA. Cumulative Project impacts are considered on a near-term or long-term schedule,
based on currently known project proposals, schedules, and funding.
Comment Response RM-8: Mitigation Measure AG-1 would require the Applicant to
“…identify and purchase or place in a conservation easement a parcel of land of at least 71
acres of equal quality farmland, or provide in-lieu feeds to allow the City to complete such
an acquisition.” The location of this parcel or parcels of farmland have not yet been
identified, and would be obtained by the Applicant as part of each final map phase of
development, subject to review and approval by the City. Based on City policy, the priority
for acquisition of such farmland would be within the City’s URL or Greenbelt area. .
Please refer also to Master Response 2.
Comment Response RM-9: As described in Section 5.3, Summary of Significant and
Unavoidable Impacts¸ the level of significance of short-term and long-term impacts, as
well as impacts resulting from inconsistency with the Clean Air Plan, are considered
significant and unavoidable. Short-term construction emissions would exceed adopted Tier
1 thresholds of significance for ozone precursors (ROG + NOx) and diesel particulate
matter (DPM) and long term operational emissions would exceed adopted Tier 1 thresholds
for ozone precursors, PM10, and DPM. Project-related impacts are summarized in Table
ES-1 of the Executive Summary.
Comment Response RM-10: The selection of alternatives is governed by those that
generally both are capable of reducing project impacts and which meet Project Objectives.
The lower end of the LUCE range of development of 500 units was not included as a full
8.0 RESPONSE TO COMMENTS
8-460 Avila Ranch Development Project
Final EIR
alternative as initial screening determined it would not materially contribute to avoiding or
substantially reducing potentially significant Project impacts. Further, it would also reduce
provision of affordable housing by almost 30 percent and substantially increase per unit
costs of funding extensive required on and offsite infrastructure improvements, potentially
requiring a shift toward larger and more expensive market rate units, potentially further
reducing overall housing affordability. A Reduced Project Alternative of 360 units was
considered and discarded from full analysis in the EIR as while it reduced environmental
impacts, it did not meet key Project Objectives or LUCE goals for the provision of housing,
particularly affordable housing or substantially contributing to an improved City jobs-
housing balance. In order to more fully address this question, a discussion of a Reduced
Project Alternative of 500 Units has been added to the alternatives considered and
discarded section of the EIR. See Section 5.0, Alternatives. Under this alternative, more R-
1 development would be constructed, similar to the Applicant’s plan proposed during the
LUCE update. As noted in the EIR, this alternative does not reduce the severity of any of
the significant impacts, since traffic generation would not substantially change, and
agricultural impacts would be similar. Please see also Master Comment Response 4.
The three alternatives considered in this EIR include the No Project Alternative, the
Mitigated Project Alternative, and the Residential Plus Business Park Land Use
Alternative. The No Project Alternative is required under CEQA. The Mitigated Project
Alternative was crafted to reduce or eliminate as many potentially significant Project
impacts as possible while still providing substantial amounts of housing to meet both
LUCE goals and Project Objectives. The Residential Plus Business Park Land Use
Alternative was created to continue to at least partially meet housing goals and objectives,
while address long-standing land use designations and early concerns of the San Luis
Obispo Regional Airport over safety. Refer to Section 5.4.1.3, Major Reduced Project
Alternative.
Comment Response RM-11: Thank you, your comment has been noted. As listed in Table
5-4, footnote 2 references mitigation measures for improvements to Suburban Road
between Earthwood Lane and South Higuera Street, and the intersections of South Street
with Higuera Street, South Higuera Street with Prado Road and Tank Farm Road with
South Higuera Street that would be implemented through reimbursement agreements.
Comment Response RM-12: Table 5-17 on page 68 of Section 5.4.2.2, Mitigated Project
Alternative, describes the estimated number of vehicle trips (Daily, AM Peak, and PM Peak
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-461
Final EIR
hour trips) associated with residential and commercial development proposed under the
Mitigated Project Alternative (MPA).
Comment Response RM-13: Page 5-79 of Section 5.0, Alternatives addresses the mix of
residential unit types proposed under the Residential Plus Business Park Land Use
Alternative and compares changes in the numbers and acreages of each unit type to the
proposed Project, but does not specifically address the number of affordable units.
However, as stated in Section 5.4.2.2, Mitigated Project Alternative, the exact number and
distribution of affordable units would be determined during consideration and approval of
the alternative by City decision-makers.
Comment Response RM-14: The discussion of air quality and GHG emissions provided
on page 5-81 of Section 5.0, Alternatives, concerns development under the Residential Plus
Business Park Land Use Alternative, not the MPA. This alternative would result in greater
levels of buildout than under the proposed Project, and associated air emissions would be
substantially greater than under the proposed Project, resulting in significant and
unavoidable impacts. Air quality impacts of the MPA are discussed on pages 5-44 through
5-50; MPA air quality impacts would be similar to, but is some cases reduced when
compared to the proposed Project.
Comment Response RM-15: Electric vehicle charging stations would be included as part
of the Project under Mitigation Measure AQ-2b. These stations are not proposed to be
provided at units, but in the R-3 and R-4 common parking areas, and garages would be pre-
wired for EV charging stations. However, Mitigation Measure AQ-2b has been adjusted to
give the City authority to determine the final number and location of electric vehicle
charging stations for R-3 and R-4 units. In addition, the garages of R-1 and R-2 units would
be pre-wired to be able to support EV charging connections. Further, onsite car sharing
would also be provided at an initial rate of one vehicle per 50 dwelling units, with at least
50 percent of the fleet being electric vehicles. Mitigation Measure AQ-2b has been updated
to clarify that the City would have authority over the number, type of, and management
practices for, vehicles proposed for car sharing.
Comment Response RM-16: 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 project feasibility study
and eventual provision of funding. However, for the purpose of the Cumulative Impact
analysis, the Traffic Study and impact analysis provided in the Section 3.12,
8.0 RESPONSE TO COMMENTS
8-462 Avila Ranch Development Project
Final EIR
Transportation and Traffic assumes the LOVR bypass to be in place under Cumulative
Conditions, or that the LOVR would be widened to four lanes, consistent with the LUCE.
Comment Response RM-17: As discussed under Impact PH-3 in Section 3.10.4.3, Project
Impacts and Mitigation Measures, the Applicant currently proposes to provide affordable
inclusionary units consistent with City policy requirements which stipulate that 15 percent
of all units shall be affordable for this particular Project. Provision of 15 percent of all units
as inclusionary affordable housing would result in provision of 105 affordable units. Please
see Section 2.6.3.2 and Section 3.10, Population and Housing, Impact PH-3 and Master
Response Comment 5.
Comment Response RM-18: Cars for hire currently exist and are reflected in existing
traffic condition and trip generation rates. The trip generation rates are based on the 9th
Edition of the Trip Generation Manual published by the Institute of Transportation
Engineers (ITE). The Manual is the most widely used industry resource for this type of
data, and provides an objective basis for estimating trips generated by a proposed
development. Autonomous vehicles may reduce congestion in two ways 1) by reducing
collisions, which are responsible for a substantial portion of non-recurring congestion, and
2) by reducing following distances and increasing travel speeds. However, autonomous
vehicles may increase congestion by making travel easier, lower cost, and carrying portions
of the population that can't drive their own vehicle. The impacts of autonomous vehicles
are therefore not known with certainty, and it would be speculative to specify a timeline
for full adoption and evaluate impacts with these technologies in place.
RG-1
RG-3
RG-4
RG-5
RG-2
RG-5
Cont.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-465
Final EIR
Commenter 132 – Russ Gordon
Comment Response RG-1: Refer to Commenter 98, Comment Response KB1-7.
Comment Response RG-2: The proposed Project would generate a net increase of roughly
5,900 new trips, not 7,000 as referred to by some commenters. The Near Term and
Cumulative scenarios include planned land use development in the City and Region. The
analysis includes the projects noted by the commenter. Forecasted increases in traffic
volumes on Sough Higuera Street north of Tank Farm Road would total approximately 118
new ADT, within the capacity of this roadway under City standards. The EIR requires
several intersection turn lane improvements along South Higuera Street to maintain traffic
flows.
Comment Response RG-3: As detailed in Section 3.10, Population and Housing, the
Project’s impacts to population and housing, including impacts to the jobs/housing
imbalance were identified as less than significant. In regards to increased demand on public
services including schools, police, and fire protection, the Project’s impacts are analyzed
in Section 3.11, Public Services and are found to be less than significant after the
implementation of mitigation measures. Please refer to Master Comment Response 11 for
a more detailed response on the Project’s impact to schools.
Comment Response RG-4: Thank you and we appreciate your comments on the EIR.
Please refer to Master Comment Response 2. The loss of agricultural lands is addressed in
Section 3.2, Agricultural Resources, specifically under Impact AG-1. Mitigation Measure
AG-1 would require the Applicant to establish an offsite agricultural conservation
easement to offset the loss of agricultural lands under the Project. The Project would
comply with GP standards for agricultural mitigation.
Comment Response RG-5: Thank you and we appreciate your comments. However, this
comment does not pertain to any inadequacies within the EIR and is not a CEQA-related
concern. Other feasible alternatives to the Project are described and analyzed in Section
5.0, Alternatives. Note that per State CEQA Guidelines Section 15126.6 “an EIR need not
consider every conceivable alternative to the project. Rather, it must consider a reasonable
range of potentially feasible alternatives that will foster informed decision making and
public participation.”
ST-1
ST-2
ST-3
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-467
Final EIR
Commenter 133 – Scott Thorsov
Comment Response ST-1: Refer to Master Comment Response 2 and Section 3.2,
Agricultural Resources, specifically Impact AG-1, which addresses the Project’s impact to
agricultural lands. Mitigation Measure AG-1 would require the Applicant to establish an
offsite agricultural conservation easement to offset the loss of agricultural lands under the
Project.
Comment Response ST-2: Refer to Master Comment Response 8. Please note that after
construction of the Buckley Road Extension during Phase 2 of the Project, left-turn
restrictions would be installed at the Vachell Lane/South Higuera Street intersection,
improving intersection operations. See Section 2.6.5, Circulation for further detail.
Comment Response ST-3: The Project’s contribution towards pollution and air emissions
from motor vehicles is addressed in Section 3.3, Air Quality and Greenhouse Gas
Emissions, specifically Impact AQ-2. Mitigation Measure AQ-2 identifies measures to
reduce or offset motor vehicle emissions; however, the EIR conservatively assumes a
significant impact. Please refer to Master Comment Response 10 regarding the phasing of
transportation infrastructure.
SP-
1
SP
-2
SP-
3
SP-
4
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-469
Final EIR
Commenter 134 – Sharie Porter
Comment Response SP-1: Please refer to Master Comment Response 8 for a detailed
discussion on your traffic concerns.
Comment Response SP-2: Please refer to Master Comment Response 7 for a detailed
discussion on your water availability concern.
Comment Response SP-3: Please refer to Master Comment Response 9 for a detailed
discussion on airport noise impacts.
Comment Response SP-4: Your opposition to the Project is noted and will be directed
towards City decision makers. Cumulative land use and roadway network improvements
were evaluated consistent with the City's LUCE in the EIR, based on existing conditions
known at the time of release of the NOP.
SH-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-471
Final EIR
Commenter 135 – Stefanie Hilstein
Comment Response SH-1: Please refer to Master Comment Responses 7 and 8.
Hicks-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-473
Final EIR
Commenter 136 – Stephanie Hicks
Comment Response Hicks-1: Please refer to Master Comment Response 1.
TT-1
8.0 RESPONSE TO COMMENTS
8-476 Avila Ranch Development Project
Final EIR
Commenter 137 – Teri Thulin
Comment Response TT-1: Please see Master Comment Responses 8. Cumulative land
use and roadway network improvements were evaluated consistent with the City's LUCE
in the EIR, based on existing conditions known at the time of release of the NOP.
TM-1
TM-2
TM-3
TM-4
TM-4
Cont.
TM-5
TM-6
8.0 RESPONSE TO COMMENTS
8-484 Avila Ranch Development Project
Final EIR
Commenter 138 – Terry Marshall
Comment Response TM-1: For a depiction of the location of noise measurement stations,
refer to Appendix O, Figure 1 within the Sound Level Assessment.
Comment Response TM-2: Text within Section 3.9, Noise, has been revised to include
and consider the distance of the AirVol Block boundary from the Project site within the
analysis.
Comment Response TM-3: Thank you, your comment has been noted. Please see
Appendix O for the methodology for the Sound Level Assessment. As described in
Appendix O, although there were peak noise measurements up to 75 dBA associated with
industrial operations, the CNEL over a 24-hour period was measured at 56 dBA. As shown
in Figure 3.9-1, existing noise levels modeled approximately 200 linear feet from the
northwestern corner of the Project site are approximately 52 dB CNEL. As described in
the MPA and the revised Development Plan, the MPA would include special noise
compatibility design features above and beyond those included in the Project.
Comment Response TM-4: Figure 3.9-1 of Section 3.9, Noise, has been revised to depict
the location of noise measurement stations used during the Sound Level Assessment for
the Project.
Comment Response TM-5: Your comment has been noted. The Sound Level Assessment
found this region to have an existing noise level of approximately 52 dB CNEL, which is
well below the exterior noise threshold of 60 dB CNEL. As such, additional noise
monitoring at this location is not required.
Comment Response TM-6: Please note that while peak noise levels of 75 dB were
recorded at Station 4, the 24-hour average CNEL noise level was 56 dB, below the 60 dB
CNEL threshold. Regarding development of high-density residential units in the northwest
corner of the Project site, discussion of Impact NO-3 describes that “[t]he sleeping and
living portions of the R-4 units would be oriented away from the eastern and northern
Project boundaries, and carports, garages, and drives would be located along these
boundaries to act as noise buffers to adjacent non-residential land uses.” To further address
potential noise-related impacts on R-4 units, the EIR provides Mitigation Measure NO-3a,
which would include noise reduction building design features to ensure impacts to these
residents are reduce to a less than significant level. No additional mitigation measures are
required.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-485
Final EIR
As suggested by the commenter, 1) sound walls would be built on the north and east
property lines of the Project in Phase 3 that adjoin the Suburban Industrial Park. The barrier
would consist of mortared masonry. Further carports with solar canopies would be installed
around the western and northern perimeter of the R-4, and the units will be setback a
minimum of 100 feet from the property line. 2) Balconies would be orient balconies away
from the northwest property line. 3) R-4 units would be required to demonstrate that the
interior noise levels = meets or exceeds the City's interior noise standard.
TW-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-487
Final EIR
Commenter 139 – Terry Whitney
Comment Response TW-1: Please refer to Master Comment Responses 8 for a detailed
discussion of your traffic concerns.
TMS-1
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-489
Final EIR
Commenter 140 – Tom and Maria Soles
Comment Response TMS-1: The Project would add fewer than ten peak hour trips to the
segment of SR 227 south of Buckley Road, which is less than one percent of the existing
traffic volume. Under Cumulative conditions, the Project would add less than thirty peak
hour trips to the SR 227 corridor, which corresponds to less than one percent of the forecast
Cumulative volume. These added trips would not substantially increase delays at the
intersection of the Crestmont Drive and SR 227. To further address Project contributions
to traffic at this intersection, Mitigation Measure TRANS-5 requires a project contribution
towards improvements at the Buckley Road/SR 227 intersection to ensure adequate
operation of this facility.
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Wayne
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8.0 RESPONSE TO COMMENTS
8-492 Avila Ranch Development Project
Final EIR
Commenter 141 – Wayne Peterson, January 11th Letter
Comment Response Wayne P.1-1: Project trip distribution is described within Appendix
P, Transportation Impact Study and depicted within Figure 3.12-2. The EIR included
discussion of Project-related impacts to transportation on as described in Impact TRANS-
4, and requires implementation of mitigation measures to address such impacts. However,
due to uncertainty of timing of improvements and requirement for interagency
coordination, some impacts cannot be reduced below a level of significance. Refer to
Section 3.12, Transportation and Traffic and the Transportation Impact Study in Appendix
P. Impact TRANS-1 describes construction traffic impacts and requires implementation of
a Construction Management Transportation Plan to mitigate construction traffic impacts.
Implementation of this mitigation was found to reduce impacts to less than significant.
Also refer to Master Comment Response 8.
Comment Response Wayne P.1-2: The posted speed for Buckley Road is 55 mph.
Appropriate sections of the text have been revised, but this change does not affect the
analysis or mitigation included in the document. Note that the Project proposes Class II
bicycle lanes along the Buckley Road frontage. See Section 2.6.5, Circulation and Figure
2-5. Impacts to cyclists and the bicycle network are addressed in Impact TRANS-11,
Section 3.12, Transportation and Traffic and were found to be less than significant after
the implementation of mitigation measures.
Comment Response Wayne P.1-3: Discussion of the existing hydrologic setting
surrounding the Project site is provided in Section 3.7, Hydrology and Water Quality. Refer
to Master Comment Response 3.
Comment Response Wayne P.1-4: Refer to Master Comment Response 3. Mitigation
Measures HYD-3a and HYD-3b are required to address hydrological impacts, including
increased runoff and flooding of Tank Farm Creek. Plans for bridge, culvert, drainage
outfall, and other hydrological modifications will require approval by appropriate
authorities to ensure the adequacy of these improvements and/or modifications prior to
Project approval.
Comment Response Wayne P.1-5: The Project proposes over 3 miles of Class I paths
and Class II bicycle lanes. These include a Class I path on the north side of Buckley Road
along the Project frontage, and almost one mile of Class II bike lanes on Buckley Road to
South Higuera Street along the Project frontage. For a short segment along the north side
of Buckley Road, westbound cyclists would be directed onto a Class I facility for 4,000
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-493
Final EIR
feet. This diversion is intended to avoid the environmentally damaging effects of widening
of Buckley Road that would be required to support a continuous westbound Class II Bike
Lane. Widening of Buckley Road to accommodate this Class II Bike Lane could result in
direct impacts to Tank Farm Creek, leading to potential removal of environmentally
sensitive riparian vegetation and possible impacts to sensitive biological species such as
the southwestern pond turtle, and potentially even the California red legged frog and
steelhead trout.
Comment Response Wayne P.1-6: The commenter is correct that under Phase 1 of
construction, the Project would not connect to Vachell Lane. Refer also to Master
Comment Response 8.
Comment Response Wayne P.1-7: Refer to Master Comment Response 8.
Comment Response Wayne P.1-8: Refer to Master Comment Response 8.
Comment Response Wayne P.1-9: The EIR evaluates Project impacts at four
intersections and one segment along Buckley Road and applies transportation standards
from the City of San Luis Obispo, County of San Luis Obispo, and Caltrans. Construction
traffic is discussed in detail under Impact and Mitigation Measure TRANS-1. The Project
proposes to improve Buckley Road and Vachell Lane along the Project frontages as the
adjacent phases develop. These improvements would conform to City and County
engineering standards as appropriate. In addition, the City's Pavement Management Plan
includes repaving Vachell Lane from South Higuera Street to the City limits in 2020.
Buckley Road is included in the County’s 2015 Pavement Management Plan for
resurfacing within five years. Buckley Road's Pavement Condition Index from Jespersen
to Thread is rated as 'Good', and from Thread to SR 227 is rated as 'Fair'.
Wayne
P.2-1
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8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-497
Final EIR
Commenter 142 – Wayne Peterson, January 17th Letter
Comment Response Wayne P.2-1: Refer to Commenter 141, Comment Response Wayne
P.1-1.
Comment Response Wayne P.2-2: Refer to Master Comment Response 8.
Comment Response Wayne P.2-3: Refer to Master Comment Response 8.
Comment Response Wayne P.2-4: Refer to Commenter 141, Comment Response Wayne
P.1-3 and Master Comment Response 3.
Comment Response Wayne P.2-5: Refer to Commenter 141, Comment Response Wayne
P.1-4 and Master Comment Response 3.
Comment Response Wayne P.2-6: Refer to Commenter 141, Comment Response Wayne
P.1-5.
Comment Response Wayne P.2-7: Refer to Master Comment Response 8.
Comment Response Wayne P.2-8: Refer to Master Comment Response 8.
Comment Response Wayne P.2-9: Refer to Commenter 141, Comment Response Wayne
P.1-9.
Avila Ranch Draft EIR (DEIR) comments
Attention: John Rickenback/Tyler Corey
City of San Luis Obispo
Community Development Dept.
919 Palm Street
San Luis Obispo, CA 93401-3210
JFRickenbach@aol.com and tcorey@slocity.org
Re: Avila Ranch Development Project Draft Eir
Dear Board Members,
Please address the following concerns I have regarding the Draft EIR for the Avila Ranch Development
Project:
Fi rst, Traffic, water, and City Services Impacts: The Righetti Ranch and Jones Ranch Projects on
Tank Farm and Orcutt have broken ground and will add 370 residences; 161 homes have been built near
Prado Road in “Toscano Homes”.In addition, the City of San Luis Obispo is reviewing Draft EIRS on both
the Avila Ranch and San Luis Ranch concurrently. I have heard there is also a proposal for a Senior
housing development on the property adjacent to Home Depot. All of these projects impact the same
traffic areas and rely on the same public services such as fire, police, and schools.
I request that the DEIR for the Avila Ranch project include the aggregate impacts of all of the projects
listed above on the traffic, air quality, water and sewer, plus the aggregate impacts on each city service,
fire, police and schools.
Second, regarding the flood plain the Avila Ranch is proposed to be built on: I live on Esperanza
Lane and our property shares a property line along the east side of this proposed development. Our
house is considerably higher in elevation than much of the Avila Ranch Property and yet we were
required to purchase Flood Insurance when we purchased the property in 1985. Over the years we have
seen Esperanza Lane washed over completely, one year, by flood waters. In addition, the NE corner of
the Avila Ranch property floods regularly to the extent that on at least 2 occasions there was enough
water there for H ooded Mergansers (a small diving
duck that only visits the area in winter) to hang out on
for a couple of days. This year’s rain has caused
flooding on at least three occasions, in each of the 2 - 3
inch events at our location.
January 2017 from parcel 076-361-007, looking west
WC-1
February 2005 - from parcel 076-361-007, looking west
I am requesting that the DEIR address three specific areas regarding flooding.
1) Does the inflow model used in the Avila Ranch DEIR take into account the considerable water
that flows off of parcels 076-361-009, 076-361-006, 076-361-012, 076-361-007, 076-361-008, the 5
parcels on the end of Esperanza Lane, onto the Avila Ranch Project. I can see on one map that a
channel is planned from approximately our NW property corner over to Tank Farm Creek. However, other
maps do not show this necessary channel. In addition, some of the maps show High Density residences
very close to, if not overlapping this historically flooded area.
2) Does the outflow model used take into account that the stream southwest of the property hits
an area of very congested stream that flooded completely over the two bridges on the dirt section of
Vachell Lane, in this year’s rains.The backup during flood situations is not caused so much on the Avila
Ranch property itself, but further downstream.
January 2017 looking north along Vachell from
intersection with Buckley. The intersection was closed in both directions due to flooding (many people
ignore roadblocks).
WC-2
WC-3
January 2017 SW corner of Avila Ranch Property
at Vachell and Buckley. Note water covering road
on north side. This is after it had receded
overnight.
January 2017 SW corner of intersection at Vachell and Buckley
January 2017 View along Buckley Road at bridge, next to intersection with Vachell, with evidence of water having
flowed across road.
January 2017 - sw corner of Vachell and Buckley - evidence of heavy
flooding across Vachell beyond intersection. View of heavy riparian growth along creek.
January 2017 South side of bridge on Buckley, at Vachell, after flood waters receded.
January 2017 North side of bridge on Buckley, at Vachell, after flood waters receded. Note oil/gas line along
bottom edge of bridge.
Please check the outflow route for in the DEIR to be sure it is adequate during rains like this
year’s, as well as those during 50 and 100 year floods, which I am sure this is not one. The creek is
heavily overgrown downstream from Vachell, preventing adequate outflow from the Avila Ranch property.
3) I am unclear to what extent the elevation along the eastern property line of the Avila Ranch
project will be changed. What is the current elevation along our shared property lines and what will the
finished elevation be. I am concerned that the historic runoff from our property will have nowhere to go if
the elevation is increased, thereby creating extensive flooding on our properties.
WC-4
WC-5
January 2017, flooding on NE corner January 2017, historic flow of water
Of proposed Avila Ranch Project from the east onto proposed Avila
Ranch project.
Feel free to contact me if you have questions.
Respectfully,
Wendi Craig
Wlcraig1@juno.com
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-505
Final EIR
Commenter 143 – Wendi Craig
Comment Response WC-1: Discussion and analysis of Near Term and Cumulative
impacts are based on those projects that were approved, pending, or in progress at the time
of release of the NOP for Near Term, and LUCE buildout for Cumulative, respectively.
This list includes Righetti Ranch, Toscano Homes, San Luis Ranch. For the list of projects
considered in the analysis of cumulative impacts, see Table 3.0-1 and Figure 3.0-1 in
Section 3.0, Environmental Impact Analysis and Mitigation Measures. Cumulative impacts
are addressed and identified within each resource section of the EIR, including those for
traffic (Section 3.12.4.4), water and sewer (Section 3.13.4.4), air quality (Section 3.3.4.4),
and public services (Section 3.11.4.4).
Comment Response WC-2: Refer to Master Comment Response 3 regarding your
concerns about flooding. See Appendix E, Avila Ranch Drainage Report for more
information regarding the inflow of water used for the hydrological model. As described
in Appendix E, discharges from neighboring properties were assigned as inflows into the
model. As described in Section 2.0, the North-South Creek Segment would be realigned
within the Project site. See Figure 2-2 regarding the location of the realigned portion of the
Creek and location of the R-3 housing units. Please note that as part of Mitigation Measure
BIO-2a, there would be a creek setback of at least 20 feet along either side of the Creek.
As discussed under Impact HYD-2 in Section 3.7, Hydrology and Water Quality, runoff
flowing onsite from properties located to the east would be captured and retained in the
wetland area located in the northeast corner of the Project site. With respect to impacts
resulting from this runoff, refer to Impact HYD-2.
Comment Response WC-3: Please refer to Master Comment Response 3. Appendix E
models post Project conditions outflow including peak flow conditions at the confluence
of the San Luis Obispo Creek and Tank Farm Creek southwest of the Project site. The
resulting peak flows are summarized in Table 7 of Appendix E. As provided in Section
3.7, Hydrology and Water Quality, MM HYD-3b requires that all bridges, culverts,
outfalls, and modifications to the existing creek channels must be designed and constructed
in compliance with the City’s Drainage Design Manual and approved by the City Engineer,
USACE, CDFW, and Central Coast RWQCB, and must meet City standards and policies.
These agencies shall ensure that structures and modifications can adequately handle flows
in the event of a 50- or 100-year storm.
Comment Response WC-4: Refer to Comment Response WC-3 and Master Comment
Response 3.
8.0 RESPONSE TO COMMENTS
8-506 Avila Ranch Development Project
Final EIR
Comment Response WC-5: The VTM in Appendix C shows the approximate finished
grade of the Project. Regarding flows entering the site from the east, please refer to Master
Comment Response 3.
WP-1
8.0 RESPONSE TO COMMENTS
8-508 Avila Ranch Development Project
Final EIR
Commenter 144 – William Palmer
Comment Response WP-1: Please refer to Master Comment Response 1.
8.0 RESPONSE TO COMMENTS
Avila Ranch Development Project 8-509
Final EIR
8.5 INDEX OF COMMENTS RECEIVED ON THE RECIRCULATED DRAFT EIR SECTIONS
Table 8-2 lists all agencies, organizations, companies, and individuals that provided written
and oral comments on the Recirculated Draft EIR Sections. As described above in Section
8.1, each comment letter was assigned a unique nomenclature based on commenter name
or organization, and each comment was assigned a number. In accordance with 2017
CEQA Statute and Guidelines, this section provides a written response to comments that
pertain to the recirculated sections, as described in Section 8.1.
Table 8-2. Index of Comment Received on the Recirculated Draft EIR Sections
Commenter
Number Name of Commenter Comment and Response
to Comment Location
Organizations
145. Gayle Totton (2) – Native American Heritage Commission N/A
146. Leah Brooks (3) – Bike SLO County N/A
147. Sarah Flickinger (2) – Los Verdes Parks 1&2 Homeowner’s
Association
N/A
Individuals
148. Debbie Hoffman (2) 8-522
149. Jennifer Klay (2) 8-524
8.6 RESPONSE TO COMMENTS RECEIVED ON THE RECIRCULATED DRAFT EIR
SECTIONS
The following pages contain copies of the comment letters received for the Recirculated
Draft EIR. Comments or letters not pertaining specifically to the recirculated Energy
Resources section have been entered into the public hearing record, but are not responded
to herein or as part of the EIR. As noted in the Notice of Availability for the recirculated
portions of the EIR “The City will respond to new comments related to the Recirculated
Portions submitted prior to April 7, 2017. New comments that do not relate to the material
that has been included in this recirculated document will not receive a response. (See
CEQA Guidelines, section 15088.5(f).” Commenters 145 through 147 submitted
comments that do not pertain to the recirculated sections and therefore no response is
offered on these comment letters. Presented first is a copy of the comment letter with
vertical lines indicating the extent of specific numbered comments, and on the subsequent
pages are the corresponding numbered responses to individual comments. Each comment
that addresses the recirculated section is either responded to directly, or provided a
reference to a master comment response or another comment response, and/or a reference
to changes in the EIR text to address the comment.
8.0 RESPONSE TO COMMENTS
8-510 Avila Ranch Development Project
Final EIR
8.6.1 Organizations
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City of San Luis Obispo
Community Development Department
Attn: Tyler Corey, Principal Planner
919 Palm Street
San Luis Obispo CA 93401-3218
tcorey@slocity.org
Dear Mr. Corey:
Re: Avila Ranch Draft Environmental Impact Report, Recirculated Portions
April 7, 2017
Bike SLO County appreciates the opportunity to comment on the Recirculated Portions
of the Avila Ranch Draft Environmental Impact Report (DEIR) relating to energy
impacts. We applaud the City for determining that additional analysis related to 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 bicycling saves
energy by reducing fuel consumption, and also reduces air pollution and traffic
congestion and improves public health.
We reiterate our comment that the Avila Ranch Draft Environmental Impact Report is
not acceptable because the Mitigated Project Alternative would increase demand for
bicycle facilities in an underserved area and potentially conflict with the City’s Bicycle
Transportation Plan regulations and General Plan thresholds.
City Policy supports:
-Pedestrian- and bicycle-friendly facilities located and designed to promote travel by
pedestrians and bicyclists.
-A transportation and circulation system that fosters travel by modes other than motor
vehicles, including walking, bicycles and public transit.
-A network of bicycle lanes and paths, sidewalks and pedestrian paths within existing
developed parts of the city by 2035, and extending the system to serve new growth
-Efforts of the County Air Pollution Control District to implement traffic reduction
programs.
We support the proposed mitigation measures with secondary energy conservation
effects:
-MM TRANS-2d: Construction of Class II Bicycle Lanes: Reduce personal vehicle use
and fuel consumption by providing connecting the Project site to the existing bicycle
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network, ensuring a safe and continuous bicycle route, and encouraging the use of
multi-modal options.
-MM TRANS-11: Construction of New Bicycle Bridges: Reduce vehicle fuel
consumption by providing a safe and continuous bicycle route and encouraging the use
of multi-modal options.
Although Avila Ranch proposes excellent bicycle facilities onsite and crucial
connections proposed to the bicycle transportation network, there are no guarantees
that the connections the applicant isn’t funding fully or in part as mitigations will be
constructed in the near future, especially in the unincorporated area. Unless these
connections are made at the same time the project is occupied, we are concerned that
trips by bike will be largely limited to the project site and immediate adjacent
destinations.
For example, the existing gap in the bicycle transportation network on Buckley Road will
be exacerbated by Avila Ranch as currently proposed. While Avila Ranch proposes
Class II bike lanes along its frontage, the abrupt end of the bikes lanes in the
unincorporated area leaves an approximate one-mile gap to the airport and growing
number of job sites and Los Ranchos Elementary School at the east end of Orcutt Road
and vicinity. Increases in motor vehicle traffic when Buckley Road is extended to
Higuera Street, combined with project-generated vehicle traffic, will make riding a
bicycle on Buckley Road without continuous Class II bike lanes perilous. Without
consistent Class II bike lanes on Buckley Road between Higuera Street and Highway
227, people will drive, resulting in more energy use.
The significant increase in project-generated vehicle traffic on South Higuera Street, Los
Osos Valley Road, Tank Farm Road, Buckley Road, Broad Street and other roadways
without adding buffers and other safety enhancements for people on bicycles, and the
DEIR’s proposed mitigations to address traffic congestion by adding multiple turn lanes
in intersections to increase capacity for motor vehicles will likely reduce the number of
people currently riding bicycles and prevent others from trying out of fear of being hit by
motorists. Again, more people driving will increase energy use.
In conclusion a major shift in emphasis from motor-vehicle dependency to multi-modal
choice is required to reduce energy use.Additional mitigations to reduce personal
vehicle trips are needed to achieve the 20 percent trips-by-bike goals in the Land Use
and Circulation Elements (LUCE) and Climate Action Plan and the 20 percent mode
share objective in the Bicycle Transportation Plan. According to HEAL SLO, San Luis
Obispo County’s obesity prevention coalition, Avila Ranch is projected to produce one-
third more driving miles per household (72 per day) than the City average (54),
especially drive-alone automobile traffic, because it is at the edge of City limits and far
from most services and all schools.
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Sincerely,
Mike
Mike Bennett, Executive Director
Bike SLO County
mike@bikeslocounty.org
Lea
Lea Brooks, Board Member
Bike SLO County
lea@bikeslocounty.org
Sarah Flickinger
On Behalf of the Los Verdes Parks 1 & 2 Homeowners’ Associations
c/o Attn: Sarah Flickinger, Los Verdes Homeowners’ Association, Inc.
92 Los Verdes Drive
San Luis Obispo, CA 93401
Re: Recirculated Portions of the Avila Ranch DEIR
April 7, 2017
To the City of San Luis Obispo, City Planning Commission and Developers of Avila Ranch:
In reviewing the recirculated portions of the Avila Ranch DEIR, our neighborhoods have concerns with the findings with
regard to energy and other impacts, mitigations outlined therein.
The report within the attachment appears to have some errors/omissions. For instance, there are areas where a section
is available for listing mitigations, but no mitigations are listed in the appendix, but they are outlined within the
summary. See in example mitigation measures for Waste.
There are also measures such as Low VOC Paint and Low VOC Cleaning Supplies being listed as offset mitigations, though
the developer has no ability to guarantee continued use of these materials within the homes, parcels, landscapes and
other areas beyond the initial construction. These are short term single point mitigation that does not encompass
operational aspects of the development. To use these measures as part of the calculations for ongoing balancing of
environmental impacts presents a flaw in the long-term viewpoint.
Air Quality Impacts can be mitigated to some degree over the long-term with urban forestry planning with the use of
diverse female, monoecious and/or evergreen native trees. Some requirement or provision for maintaining any
agricultural barriers and urban forest mitigations in perpetuity should be included to ensure the long-term benefits are
attained. During the development plan phase, specification for larger mature trees at the time of development can help
expedite the benefits.
It was disappointing to see no grey water usage integrated into the commercial or residential portions of the
development. While reclaimed water has benefits, the use of gray water can add an additional depth to water
preservation and its inclusion in new developments offers benefits to restoring the water cycle.
It was also disappointing to see standard building requirements such as solar commercial buildings and low-flow toilets
being used as energy offsets. These must be included; they are not optional mitigations. Including them as such
effectively double-counts their benefits to the environment and is misleading. Alternative measures that provide better
mitigation in addition to building code requirements would be limiting the amount of uninterrupted paved areas with
shade producing plantings to offset the heat island effect, use of permeable pavements or integration of living roofs on a
certain percentage of buildings and facilities.
We would like to express concern at the lack of water use during construction and grading, as presented in this
document. What was an agricultural percolation field is slated to be graded and barren throughout early construction
phases, and, in some cases according to the phasing herein, throughout the 10-year duration of the project. This will
have a negative impact on air quality in the vicinity for 10 years, with increased particulate matter. It will also have a
negative impact on surface temperatures (“heat island effect”) due to loss of vegetation. It could present challenges for
neighboring areas with regard to storm runoff as well, and, without water or cover plants, the ground will become
hardened and less penetrable until such time that a percolation area is added to the site. Additionally, there is a chance
that some of the soil on this site may have been exposed to contamination, and to let contaminated soil become
airborne for 10 years presents an additional health hazard to neighboring residences, cyclists and workers. Storm water
retention measures should be integrated into the construction and design of the neighborhood as a mitigation measure
to ensure long term sustainability.
Once complete, disturbed ground areas on and offsite not subject to development should be required to be replanted
with native plantings to ensure reestablishment in the near term, which improves drainage, reduces runoff and creates a
positive contribution to air quality and water cycle restoration. No such mitigation is currently included in the
documents. This can create hazards for vehicles, pedestrians and cyclists in the form of dust and gravel spilling into
sidewalks, bike lanes and streets.
The additional fuel consumption for neighboring residential and commercial users due to construction impacts as well as
future traffic impacts is also not included in this model. For instance, the addition of project traffic creates a failure for
multimodal transport at the intersection of Los Verdes Drive and Los Osos Valley Road. The DEIR’s mitigation is that
cyclists utilize a portion of the Bob Jones Trail that has yet to be built to access neighborhood commercial. For my
personal household alone this would account for 8-12 vehicle trips per day no longer being taken by bicycle. As short-
cycle neighborhood trips consume more fuel than freeway trips, this problem quickly compounds. Without signalization
at Los Verdes Drive, it is unsafe to cycle and therefore fuel consumption for additional car trips to and from the nearly
200 homes in the Los Verdes Parks should be modeled as part of the energy impacts of this development, as well as the
same for the neighboring Las Pradreras neighborhood, among others. As the Bob Jones Trail is the proposed mitigation
measure (though it is not being built as part of the development), the energy consumed in the trail’s development
should also be taken into consideration in order to achieve a full and accurate assessment of the energy impacts of this
development.
There are also additional vehicle miles travelled that should be calculated based on the proposed temporary closure and
future limited access to Buckley Road via Vachell. Many vehicles use this route daily. The additional distance to travel to
Tank Farm Road and back via S. Higuera and 227 for all of these vehicles for 10 years (and beyond in some cases) should
be calculated, considered and reported in a clear way.
We feel strongly that this document underestimates the short and long-term energy impacts of this development with
its currently proposed mitigations.
Lastly, noise impacts remain unaddressed in the recirculated portions of this document, as do air quality impacts to
neighboring residential areas. These need to be identified and addressed in a subsequent recirculation prior to
publication of the final EIR.
Sincerely,
Los Verdes Park 1 Homeowners’ Association, Inc.
Special Board Member
Representing the Los Verdes Parks 1 & 2 HOAs
Sarah Flickinger
8.0 RESPONSE TO COMMENTS
8-520 Avila Ranch Development Project
Final EIR
8.6.2 Individuals
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8.0 RESPONSE TO COMMENTS
8-522 Avila Ranch Development Project
Final EIR
Commenter 148 – Debbie Hoffman
Comment Response DH2-1: As discussed in Section 3.12, Transportation and Traffic,
implementation of required mitigation measures to address the Project’s impacts to the
transportation network would ensure that buildout of the Project does not substantially
increase traffic congestion or trip durations. As such, buildout of the Project is not
anticipated to substantially affect average vehicle fuel economy and additional analysis of
Project operational fuel consumption with regard to future traffic congestion is not
required.
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Below is the final public comment received on the Avila Ranch DEIR recirculated energy section. Thanks, Tyler
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8.0 RESPONSE TO COMMENTS
8-524 Avila Ranch Development Project
Final EIR
Commenter 149 – Jennifer Klay
Comment Response JK2-1: The analysis of impacts resulting from increased demand for
energy resources has been based on accepted methodologies for energy impact reporting
in accordance with CEQA Appendix F that have been established by the California Air
Resources Board (CARB), the local Air Pollution Control District (APCD), and the State
Office of Planning and Research. This analysis provides a detailed estimate of the Project’s
demand for electricity, natural gas, and transportation fuel based on average energy
consumption factors for similar uses, and detailed CalEEMod energy demand calculations
provided in Appendix H, and anticipated Project VMT provided in Appendix H and
Appendix Q.