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HomeMy WebLinkAboutExtended Open Space Public Comment, CooperChristian, Kevin From: Hill, Robert Sent: Monday, January 08, 2018 1:45 PM To: Christian, Kevin Subject: FW: Initial Study/Mitigated Negative Declaration for Evening Use at Cerro San Luis Natural Reserve Attachments: 112_29_17... initialstudy.pdf Public comment. Thank you! From: Allan Cooper [ Sent: Friday, December 29, 2017 8:02 PM To: Hill, Robert <rhill@slocity.org> Subject: Initial Study/Mitigated Negative Declaration for Evening Use at Cerro San Luis Natural Reserve Dear Mr. Hill - I am forwarding you via attachment my comments regarding the Initial Study/Mitigated Negative Declaration for Evening Use at Cerro San Luis Natural Reserve. Thank you! - Allan To: Robert Hill, SLO Natural Resources Manager Re: Notice of Intent to Adopt Re -Circulation of a Mitigated Negative Declaration Pilot Program for Extended Open Space Hours of Use During Winter Months, Cerro San Luis Natural Reserve From: Allan Cooper, San Luis Obispo Date: December 29, 2017 Dear Mr. Hill - I am forwarding you below my concerns and comments related to the several specific passages which I excerpted below from the "Initial Study/Mitigated Negative Declaration for Evening Use at Cerro San Luis Natural Reserve" (see: ftttI/www.gi1oqfty.org[/­Hor'g/ ShowDocument?id=1763 . I would appreciate it if you would enter my comments into the public record. I would also be most grateful if you could find the time to respond to my comments. In any event, I wish you a Happy 2018! - Allan "There are no designated scenic highways near the project area. Therefore, there would be no impact to scenic resources visible from a scenic highway." According to Figure 11 "Scenic Roadways and Vistas" (see:ttp l/www.slocity.or / horns/ h ! document?id= 1) in the SLO Conservation and Open Space Element, Highway 101 as it runs past this portion of the Cerro San Luis Natural Reserve is designated "moderate scenic value". "According to the San Luis Obispo Open Space Survey (Riggs et. al, 2015), use of the Reserve averaged approximately 800 visitors per day during the period between December of 2014 and March 2015, and average daily use between the hours of 6:00 PM and 9:00 PM was 65 individuals, despite the City's existing Open Space Regulations provision that Open Space is closed one hour after sunset. Therefore, existing average daily baseline use during the proposed evening hours from one hour after sunset until 8:30 PM is 65 individuals." How could one surmise that when it is no longer illegal to access the Cerro San Luis Natural Reserve after sunset, the number of users will remain at 65? "Given that passive recreational trail use represents a small proportion of the overall project area, that there is nothing associated with the project that would physically block or impede wildlife movement, that the increased seasonal hours of use are proportionally small compared to overall annual use, and that evening use is existing at present, the proposed project does not represent a substantial change to the environment effecting wildlife movement or corridors." Again, one cannot assume that "existing evening use" will remain the same once this new pilot program is enacted. "... however, the Cerro San Luis Natural Reserve is not identified as containing either a wildlife corridor or potential wildlife corridor." This is contradicted by Figure 3 (see ht p /dwwvW slocity.ora/home/showdo ummentw? id=4104) "Wildlife Corridors" in the SLO Conservation and Open Space Element showing three wildlife corridors entering the Cerro San Luis Natural Reserve, one from Los Osos Valley road and the other two from North Broad Street. "Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?": Less Than Significant Impact with Mitigation Incorporated There is no mention here of the Miles' Milk -vetch which is located within the Cerro San Luis Natural Reserve per Figure 2 "Species of Local Cancern" (see: http: wwvgrfgit.Jarrlhz?cumei?idb) in the SLO Conservation and Open Space Element and how this biological resource will be protected. "The Cerro San Luis Natural Reserve does not contain any significant riparian habitat." According to Figure 9 "Creeks and Wetlands" (see:C x�,,Mytg!kt 1 ment.Zi :4j 1-0) in the SLO Conservation and Open Space Element, there is within the Cerro San Luis Natural Reserve and within the SLO City limits an `intermittent creek and a good riparian corridor' which terminates on North Broad Street and abuts the south end of the Mission Lane cul-de-sac. There is also another "perennial creek with a degraded corridor but able to be restored or repaired" which again terminates on North Broad Street immediately north of Mission Lane. Significantly, the good riparian corridor which runs immediately south of the Mission Lane cul-de-sac aligns with the northernmost extension of the Lemon Grove Loop trail. "COSE policy 8.5.5 regarding passive recreation states, `The City will consider allowing passive recreation where it will not degrade or significantly impact open space resources... in accordance with an approved open space conservation plan. Passive recreation activities may include: hiking, nature study, bicycle use, rock climbing, horseback riding or other passive recreational activities as permitted and regulated in the Open Space Ordinance."' According to the Western Reserve Land Conservancy, horseback riding and bicycling are conditionally permissible passive recreation activities. Passive recreation may be defined as a non -motorized activity that is compatible with other passive recreation uses. COSE includes "bicycle use" under the list of "passive recreation activities" but this is likely referring to mountain biking only during the daylight hours. It is clear to me (and it should be to others) that night-time mountain biking is not compatible with other passive recreation single trail uses such as night-time hiking. "The proposed project site is served by the City of San Luis Obispo Fire Department and Police Department. It is possible that expanded hours of use during the evening as proposed by the project could result in increased calls for service. However, with only 1-2 calls per month for emergency services under existing circumstances, it is very unlikely that the proposed project would result in the need to the construct new fire or police facilities; therefore this impact would be less than significant." It is more than likely that by increasing the hours of use for night biking and night hiking during the winter months with all of their attendant hazards, there will be far more calls for service beyond the current 1-2 calls per month.