HomeMy WebLinkAboutItem 17 - MOU WITH CAL POLY REGARDING IMPLEMENTATION OF MITIGATION MEASURES IDENTIFIED IN THE CAL POLY MASTER PLAN ENVIRONMENTAL IMPACT REPORTItem 17
Council- • . Report
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Department Name: Community Development
Cost Center:
4001
For Agenda of:
March 17, 2020
Placement:
Business
Estimated Time:
90 Minutes
FROM: Michael Codron, Community Development Director
Prepared By: Brian Leveille, Senior Planner
SUBJECT: MEMORANDUM OF UNDERSTANDING (MOU) WITH CAL POLY
REGARDING IMPLEMENTATION OF MITIGATION MEASURES
IDENTIFIED IN THE CAL POLY MASTER PLAN ENVIRONMENTAL
IMPACT REPORT (EIR).
RECOMMENDATION
Authorize the City Manager to execute the proposed MOU (Attachment A) with Cal Poly and
direct staff to continue to engage in the Cal Poly Master Plan process to ensure that impacts on
City services and infrastructure associated with build -out of the Master Plan are properly
identified and mitigated.
REPORT -IN -BRIEF
On December 19, 2019, Cal Poly published the Draft EIR for its 2035 Master Plan. The 45-day
public review period ended on February 3, 2020, and the City submitted comments identifying
its concerns with the potential environmental effects associated with build -out of the Master Plan
(Attachment B). The City provides a wide range of services to the campus, including emergency
response, water and wastewater treatment, and transit to name a few. Therefore, City review of
the Master Plan and Draft EIR is important to ensure that service impacts associated with
development of the Master Plan are identified and that agreements are developed as may be
needed to address changes in the scope or level of service provided to campus.
While developing the Draft EIR for the Master Plan, Cal Poly engaged with City staff to discuss
key issues where the City would likely play some role in mitigating identified impacts. For
example, Cal Poly lacks sufficient potable and non -potable water supply to complete build -out of
the Master Plan. A Memorandum of Understanding (MOU) is now recommended to address
mitigation measures in the Draft EIR associated with Water and Wastewater, Transportation, and
Housing. Through the normal EIR review process, the City has provided comments on other
issue areas such as biological resources, air quality and greenhouse gas emissions, and public
services. City staff is seeking direction from the City Council to continue to engage with Cal
Poly on all of the issues related to development under the Master Plan to ensure that impacts to
the City are appropriately addressed.
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DISCUSSION
Background
On December 19, 2019, Cal Poly published the Draft EIR for Cal Poly's 2035 Master Plan. The
45-day public review period ended on February 3, 2020, and the City submitted comments
identifying its concerns with the potential environmental effects associated with build -out of the
Master Plan (Attachment B). The City's comments were based on direction previously provided
by the City Council in the form of "Guiding Principles" (see Attachment C, Council Resolution
10676, 2015 Series).
The City has been engaged in the effort of working with Cal Poly on the Master Plan, informed
by the Guiding Principles since 2015. The Draft EIR published this past December is the second
Draft EIR developed for the Master Plan. The first Draft EIR was published, but the comments
provided by the City, the public, and other agencies never received a response. Instead, Cal Poly
took the input received, modified its project description to avoid certain environmental impacts,
and published a new Draft EIR based on an updated project description.
Although not in the City "limits", the City of San Luis Obispo and Cal Poly are intertwined in
social, economic, environmental, and shared infrastructure and services. The City provides a
wide range of services to the campus, including emergency response, water and wastewater
treatment, and transit to name a few. For its part, Cal Poly is an important economic partner for
the City — it is one of the largest employers in the County, generating significant economic
activity and benefit for City residents and businesses alike. As Cal Poly is planning to increase
enrollment to 25,000 students from the 2019 enrollment figure of 21,242, it must work in concert
with the City to ensure the health and safety, and mobility, of its student body and its existing
and future staff and faculty.
While developing the Draft EIR for the Master Plan, Cal Poly engaged with City staff to discuss
key issues where City cooperation would have a role in mitigating identified impacts. Meetings
between City staff and Cal Poly staff have focused on the following topics:
1. Water and Wastewater
2. Transportation
3. Housing and Population
4. Public Safety
5. Public Facilities, including Parks and Recreation
Purpose of Proposed Memorandum of Understanding (MOU)
MOU's are intended to be an expression of a working relationship between two or more parties.
The proposed MOU is not a legally binding document. In short, the proposed MOU expresses
both organization's good faith understanding of how they can work together to accomplish
certain mitigation measures identified in the areas of Water and Wastewater, and Transportation.
To that end, the MOU contemplates a variety of future agreements and collaborations, which will
be necessary to the implementation of the Master Plan, as envisioned. All of these future
agreements and activities must be authorized by the City Council in the future; either directly
during a public hearing, or through the approval of departmental work programs. In no way does
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the MOU bind this or future City Council members to any particular decision as it relates to
future negotiated agreements with Cal Poly; it simply formally acknowledges the need for such
future efforts.
Why is the MOU Limited to Water and Wastewater, Transportation, and Housing?
Ultimately, it has been Cal Poly's assessment that City participation in the implementation of
mitigation measures is only required in the areas of Water and Wastewater, and Transportation.
Coordination in these areas would facilitate on campus housing production in the future. In
discussions with Cal Poly, City staff conveyed the City's desire to reach agreement to
accomplish the following, associated with increased enrollment:
1. Linking enrollment growth to the provision of housing on campus so that implementation of
the Master Plan does not contribute to the scarcity of housing opportunities in the City, which
drive up housing costs for everyone.
2. Fair share contributions to General Government, Public Safety, and Parks and Recreation
facilities that are impacted by increased population.
Linking Enrollment Growth and On -Campus Housing
Cal Poly has rebuffed attempts to come to agreement on the concept of linking enrollment
growth to the provision of housing on campus. In general, two reasons are provided for this.
First, that Cal Poly has been making steady progress in its efforts to house all first and second -
year students. The following chart is provided to illustrate this trend. Second, Cal Poly and the
State University system are unwilling to set a precedent that new housing has to be provided for
new students.
It should be noted that one of the near -term projects in the Master Plan is a major new student
housing project. The construction of up to 2,000 beds is anticipated in the North Campus area
adjacent to Brizzolara Creek. The project description for the Master Plan EIR indicates that these
beds could be available as soon as 2022. This one project would increase the percentage of all
students living on campus from 35% to 44% and would eclipse projected enrollment growth over
the same timeframe. As a result, staff s efforts have been focused on identifying constraints and
providing constructive feedback to Cal Poly staff regarding issues that could prevent plan
implementation.
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25,000
20,000
15, 000
10,000
5,000
0
Cal Poly Enrollment and Housing
Lf7 a Un a un a r' N M It Lf7 sA r- 00 M a r� N Cry It, un CD r- 00 M
f� 00 00 OS Q7 O O O O O O O O O O r-I r-I r-I r-I r-I r-I r-I r-I rl r-I
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� Cal Poly Total Enrollment
� Cal Poly Students Living On Campus
-Percent of Cal Poly Students Livi ng On Campus
40%
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25%
20°l
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0 JO
Source: Cal Poly University Housing
Fair Share Contributions for General Government, Public Safety, and Parks and Recreation
Facilities
In 2018 the City Council adopted a new Capital Facilities Financing Plan that identified
appropriate fees for General Government, Public Safety, and Parks and Recreation facilities that
would be assessed on new development. This "nexus study" is compliant with State law (AB
1600), which gives jurisdictions the ability to levy fees on new development that represent the
development's fair share of the costs needed to provide identified services. On several occasions,
City staff has discussed this issue with Cal Poly and provided its EIR consultants with a copy of
the nexus study. Staff believes that enrollment growth can cause an increase in population in the
City, which has costs. In 2017 when there was a spike in enrollment at Cal Poly, the City was
able to quantify and document those costs (Attachment B, 2017 letter from Katie Lichtig to
Jeffrey Armstrong, dated 9/11/2017). Although Cal Poly is not required to pay into the City's
impact fee programs, the program provides a method to mitigate the impacts of increased
population on City facilities. However, this is another area where Cal Poly disagrees that there is
an impact on City facilities that requires mitigation. Ultimately, the Master Plan provides for a
decrease in the number of students living off campus from 14,113 in 2020 to 9,988 students in
2035. The City staffs concern is that there is nothing in the Master Plan that links increased
enrollment to the provision of housing on campus for students or faculty, or commits Cal Poly to
accommodate increased enrollment to mitigate against anticipated impacts in the event that
enrollment growth does, in fact, outpace on campus housing production. Moreover, housing
production alone does not address other potential impacts in the City of on campus population
growth. Therefore, the potential is high for the City to experience increased demand for its
facilities along with associated costs.
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Highlights of the Proposed MOU Terms
Recitals in the Memorandum of Understanding are provided for context and in recognition of the
cooperative relationship that exists between the campus and the City on many issue fronts. City
Council direction to staff is to work with Cal Poly to ensure that the Master Plan EIR explores
the impacts of growth on campus on City services and facilities. Notably, the ability of the City
to come to agreement on MOU terms for two issue areas does not mean that the City is otherwise
in agreement with all provisions of the Master Plan and the impact analysis contained in the
Draft EIR. Significantly, staff will continue to follow up on and work with Cal Poly on all of the
issues commented on (Attachment B). It is important to note that the City's ability to effectively
implement MOU terms is dependent on Cal Poly's response to the City's EIR comment letter
and how issues raised are addressed in the Final EIR and Final 2035 Cal Poly Master Plan. Cal
Poly staff has indicated that the Master Plan and Final EIR will be presented to the California
State University, Board of Trustees, at their May 2020 meeting. The City will be closely
following that process and staff intends to attend the Trustees meeting and will be prepared to
address any outstanding issues concurrently through that process.
Water and Wastewater Impacts
The City provides water distribution and treatment and wastewater collection and treatment
services to the Cal Poly campus by agreement (Attachment D). The following impacts are
identified in the Draft EIR and will require Cal Poly to reach agreement with the City to
implement appropriate mitigation measures.
Impact 3.14-3; Have Insufficient Water Supplies Available to Serve the Project and
Reasonably Foreseeable Future Development during Normal, pry and Multiple Dry Years
Development of the 2035 Master Plan would result in increased population levels and development of new buildings,
which would increase demand for water supply. Campus water demand would be reduced through conservation
measures, transfer of water supply service from Cal Poly to the City, and a new non -potable source would be provided
through the development of the WRF_ Under the 2035 Master Plan, adequate water supplies would be available to meet
future demands if the first phase of the WRF is operational in 2022 and the second phase is operational in 2028_
Without the availability of reclaimed water from the WRF, there would not be adequate supplies beginning in 2025.
Because the design, timing, and other details of the WRF are not yet established, it cannot be determined with certainty
that water supplies would be available to meet increased demand from implementation of the 2035 Master Plan_ Thus,
the impact on water supply would be significant_
Source: Master Plan Draft EIR Page 3.14-16
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Impact 3.14-4: Result in Inadequate Wastewater Treatment Capacity
Under the 2035 Master Plan, Cal Poly development and operation of proposed buildings and increased campus
population levels would increase wastewater flows. Several conservation actions would reduce wastewater
generation, such as replacing toilets, urinals, faucets, and showerheads with Iow-flow alternatives. Cal Poly plans to
construct an on -campus WRF in two phases, each of which would have a treatment capacity of 190 afy (169,621 gpd),
for a total capacity of 380 afy (339,242 gpd). Phases 1 and 2 are expected to be operational in 2022 and 2028,
respectively. While general timing of WRF construction and operation are planned, specific timing and other details
are yet unknown. Planned water conservation actions would not be sufficient in and of themselves to reduce
wastewater generation such that capacity of the City's wastewater conveyance system could accommodate 2035
Master Plan development. Because the timing of adequate wastewater capacity is unknown and development of new
campus buildings and facilities could exceed available wastewater treatment capacity, the impact would be
potentially significant.
Source: Master Plan Draft EIR Page 3.14-19
Terms Proposed and Subsequent Agreements Necessary to Support Implementation of Related
Water and Wastewater Mitigation Measures
a) Develop mechanisms to confirm operational resiliency of Cal Poly's water supply.
b) Cal Poly to secure additional, temporary non -potable water supply and wastewater capacity,
if needed, to support the development of on -campus housing.1
c) Reach agreement on Cal Poly fair -share financial contribution to support required upgrades
of City's water treatment plant and distribution system.
d) Reach agreement on Cal Poly fair -share financial contribution towards required upgrades of
City's water resource recovery facility and wastewater collection system.
e) Cal Poly to regularly inform City of progress towards reducing municipal sewer inflow and
infiltration.
f) Establish protocol and objectives for annual partnership meeting to address items such as
anticipated facility upgrades and related fair share contributions, inflow and infiltration
reduction projects, smart meters installation to track water supply use/flow rates, adaptive
management of water supply storage and other related water and waste water matters.
Transportation Impacts
The City provides transit services to the campus through an existing contract. The City's ability
to help address the following environmental impacts relates directly to the success of current and
future negotiations between the City and Cal Poly to identify and provide appropriate levels of
transit service on campus to achieve shared goals.
1 The provision of a temporary non=potable water supply would require City Council approval of a General Plan
amendment. Temporary non -potable water from the City could offset Cal Poly's current use of its Whale Rock
water supply used for agriculture irrigation. However, as it would only be provided for a short-term, this would not
provide the permanent water source needed for planned enrollment growth and on -campus housing under the Master
Plan. Cal Poly would need to acquire a permanent water source to meet this demand.
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Impact 3.13-1: Result in Vehicle Miles Traveled That Exceed Regional Vehicle Miles
Traveled Targets
With implementation of the 2035 Master Plan, Cal Poly, as a whole, would exceed the countywide VMT per service
population target of 19.22 (15 percent below existing regional VMT per service population). Although implementation
of the 2035 Master Plan would reduce VMT per capita compared to existing conditions due to the location of all new
and a greater proportion of total student enrollment in on -campus housing, this impact would be significant.
Cal Poly Draft EIR Page 3.13-12
Impact 3.13-2: Conflict with a Program, Plan, Ord inance, or Policy Addressing Circulation
and Transit
Implementation of the 2035 Master Plan would increase demand for transit, which may require investments in additional
transit service and/or facilities to maintain the level and quality of service necessary to retain and expand ridership.
Failure to maintain quality service could lead to losses of ridership and Increases in travel by other modes (e.g.,
automobiles) that could result in environmental effects such as increased emissions. This impact would be significant.
Cal Poly Draft EIR Page 3.13-14
Impact 3.13-3: Conflict with a Program, Plan, Ordinance, or Policy Addressing Bicycle Facilities
Implementation of the 2035 Master Plan would not interfere with implementation of planned bicycle facilities in the
City and County of San Luis Obispo_ It would increase bicycle travel on campus, which could generate bicycle
volumes that physically disrupt the use of existing facilities. Implementation of the 2035 Master Plan would increase
automobile, transit, bicycle, and pedestrian trips to, from, and within campus, which would increase the competition
for physical space between the modes; thus, increasing the risk of collisions. This impact would be significant,
Cal Poly Draft EIR Page 3.13-16
Impact 3.13-4: Conflict with a Program, Plan, Ordinance, or Policy Addressing
Pedestrian Facilities
Implementation of the 2035 Master Plan would increase pedestrian travel on and off campus, which could generate
pedestrian volumes that physically disrupt the use of existing facilities. Implementation of the 2035 Master Plan would
increase automobile, transit, bicycle, and pedestrian trips to, from, and within campus, which would increase the
competition for physical space between the modes, which increases the risk of collisions_ This impact would be significant
Cal Poly Draft EIR Page 3.13-18
Terms Proposed and Subsequent Agreements Necessary to Support Implementation of Related
Transportation Mitigation Measures
a) Ensure the City and regional stakeholder agencies (County, RTA, SLOCOG, APCD) are
informed and consulted as Cal Poly develops and implements its Transportation Demand
Management Program (TDM).
b) Scale and optimize transit services available to the Cal Poly community in accordance with
changing population and utilization, with the objective of reducing Vehicle Miles Traveled
(VMT).
c) Consolidate and/or coordinate active transportation projects to optimize results and avoid
conflicts between vehicles, bicycles and pedestrians.
d) Collaborate on initiatives to improve mobility safety off campus.
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e) Develop procedures for determination of Cal Poly's fair -share financial contributions
towards required upgrades of City's transportation infrastructure.
f) Establish protocol and objectives for annual partnership meeting to address transportation
planning, TDM program evaluation issues, and potential transportation enhancement
projects, including trip monitoring, ongoing evaluation of VMT reduction, transit service
enhancements, and programs/projects to enhance active transportation and mobility safety.
Housing Impacts (Population and Housing)
The Draft EIR disclosed that it is likely enrollment increases will occur before new housing is
available on campus. This additional housing demand will drive down vacancy rates and
potentially increase the cost of housing in the City, however, this is not identified as an
environmental impact of the Master Plan. Throughout the DEIR impacts to other issue areas are
evaluated as less than significant since it is assumed additional housing on campus will have
mitigating effects in other issue areas - like Transportation and demand for public services and
facilities. As noted in the City letter to Cal Poly (Attachment B), staff is concerned that there will
be challenges for Cal Poly to make housing available in phase with enrollment increases due to a
variety of factors including needed additional environmental studies, resource agency permitting,
and additional water and wastewater capacity requirements. Although MOU terms for Housing
are not specific with respect to mitigation measures in the Draft EIR, the terms do highlight Cal
Poly and City agreement to remain engaged and work towards the expeditious development of
new on -campus housing supply.
Terms Proposed and Subsequent Agreements Necessary to avoid impacts to City Housing stock
and facilities
a) Continued active work by Cal Poly to construct the next student housing project which will
provide 1600-2000 new student beds.
b) Cal Poly will regularly inform the City of progress towards its construction of on campus
housing and provide information on capital projects, occupancy rates, and enrollment targets.
c) Establish protocol and objectives for partnership meetings to address issues related to
University and City growth and best accomplish transportation, public service and other
resource planning.
Other Environmental Impacts of Concern
As previously discussed, the City submitted a letter (Attachment B) detailing a variety of
concerns with the scope, analysis, and conclusions made in the Master Plan Draft EIR. The
following issue areas are covered in the letter.
1. Aesthetics — The Draft EIR identifies significant and unavoidable impacts as it relates to
development of the Grand/Slack site for faculty/staff housing. The City recommends that
Cal Poly incorporate standards for appropriate setbacks and height reductions on the edge
of campus to help address this issue.
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Air Ouality, Enemy Consumption and Greenhouse Gas (GHG) Emissions — The
City commends Cal Poly's commitment to using 100% on -site generated renewable
energy to support its growth. The renewable energy goal is identified as a requirement in
the GHG Analysis, Chapter 3.8, however, the associated mitigation measures do not
require all building to be powered by 100% renewable energy. In addition, the EIR does
not evaluate any large-scale energy projects that may be needed to actually achieve the
goal.
2. Biological Resources — The City expressed concern about the scope of the biological
resource evaluation, particularly as it relates to the North Campus housing site, planned
for a near -term student housing project. The lack of detailed analysis indicates that plans
for delivering new student housing on campus by 2022 will be difficult to achieve,
particularly if a habitat conservation plan is required to secure resource agency permits.
3. Hydrology and Water Duality — The Draft EIR does not evaluate impacts that could
occur due to flooding. The City and County both use the same standards found in the San
Luis Obispo Waterways Management Plan and Drainage Design Manual. If the Master
Plan identified compliance with these standards it would address City concerns that
future development on campus will be designed to accommodate flood waters
appropriately and not create downstream impacts.
4. Noise — Impacts on City residents related to noise from the Spanos Stadium Expansion
are not evaluated for considered in the Draft EIR. In addition, there is no analysis of noise
generated by construction activities, including construction traffic. It is important that Cal
Poly engage with the City to ensure that noise impacts are addressed and having
appropriate policies in the Master Plan and mitigation measures identified in the Final
EIR for noise is strongly encouraged by the City.
5. Public Services — The City highlights its concern about the impacts of growth on campus
to public facilities. As previously discussed, the City's Capital Facilities Fee Program
nexus study identifies the incremental cost of new residents on the public facilities. The
Draft EIR lacks a complete evaluation of these impacts on facilities. It should be noted
that public safety services are covered by existing agreements and contracts that do
adequately address the cost of services for emergency response, fire suppression, and law
enforcement.
Previous Council or Advisory Body Action
The City Council has conducted the following meetings with associated actions as it relates to
the Cal Poly 2035 Master Plan:
1. November 17, 2015 — City Council adopts Resolution 10676 (2015 Series) with guiding
principles for engagement in the Master Plan process and authorizes the Mayor to send a
letter to Cal Poly with associated information about City policies and guidance.
2. March 5, 2019 — City Council reviewed its policy for short-term water supply alternatives for
users outside of the City and directed staff to return with a General Plan amendment to
clarify that outside users may receive non -potable water and recycled water. A proposed
General Plan amendment is necessary for the City to have an agreement with Cal Poly to
provide it with a short-term, non -potable water supply. (Attachment D)
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Policy Context
Council Resolution 10676 (2015 Series) identifies the specific General Plan policies that support
City engagement in the Master Plan process across a wide variety of policy areas, including Land
Use, Circulation, Housing and Neighborhood Wellness, and Safety.
Public Engagement
City staff has corresponded with members of the public and regional agency staff on the matter
of the Cal Poly Master Plan Draft EIR. Staff has provided notification to interested parties of the
City Council meeting for this item.
CONCURRENCE
The recommendation was developed with concurrence from Utilities, Public Works, Police, Fire,
Parks and Recreation, and Administration.
ENVIRONMENTAL REVIEW
The California Environmental Quality Act does not apply to the recommended action in this
report by general rule, because the action does not constitute a "Project" (CEQA Guidelines
Section 15378). The proposed MOU is a non -binding document that describes issue areas that
the City and Cal Poly agree to work on for the purpose of implementing mitigation measures
identified in the Cal Poly 2035 Master Plan EIR. Any future projects carried out under the MOU
will need to be approved along with an environmental determination, however, assumptions
made at this time about future impacts would be speculative.
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FISCAL IMPACT
Budgeted: No
Funding Identified: No
Fiscal Analysis:
Budget Year: N/A
Funding Sources
Current FY Cost
Annualized
On -going Cost
Total Project
Cost
General Fund
N/A
State
Federal
Fees
Other: Water and
Sewer Funds
Total
*Note: Cal Poly pays the City for water and wastewater services by agreement, most recently updated in
2013. An update to the existing rate agreement is planned in 2020 to ensure the City collects adequate
revenue to the City's Water and Sewer Funds, including fair share contributions to infrastructure projects.
Increased enrollment on campus includes costs for the City. The cost of increased, unplanned
enrollment was evaluated in 2017 when Cal Poly experienced a spike in enrollment that resulted
in impacts to the transit system, emergency services, parking, code enforcement, housing
(Attachment B, Attachment C, Letter Dated 9/11/2017). City staff s analysis is that Cal Poly can
and should make fair -share contributions to the costs of City services and infrastructure needed
to serve it. The Draft EIR and Master Plan fail to take these costs into account. If costs to the
City are not adequately addressed, the fiscal impact could be significant, potentially resulting in
the delayed implementation of important infrastructure projects or unmitigated safety risks.
ALTERNATIVES
1. Continue Consideration of Draft MOU — The City Council could continue consideration of
the draft MOU for water and wastewater, and transportation items. Council should provide
staff with direction on changes or additional information needed to make a decision on this
item.
2. Do Not Authorize the MOU — The City Council could direct staff not to enter into the MOU
at this time. Direction should be provided if there are changes to the document that would be
sufficient to gain the support of a majority of Council Members.
Attachments:
a - Draft City -Cal Poly MOU
b - Letter on Cal Poly Master Plan Update DEIR with attachments
c - Council Resolution 10676 (2015 Series)
d - Council Reading File - 03-05-2019 Item 14 Cal Poly Regional Water Supply Alternatives
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MEMORANDUM OF UNDERSTANDING
BETWEEN
CALIFORNIA POLYTECHNIC STATE UNIVERSITY
AND
THE CITY OF SAN LUIS OBISPO
This Memorandum of Understanding ("MOU") is by and between California Polytechnic State
University ("Cal Poly") and the City of San Luis Obispo ("City").
I. Background
Cal Poly and the City of San Luis Obispo have a long and successful history of working together
to achieve shared objectives and solve problems. Evidence of this can be found in various
agreements including those addressing transit bus service, fire protection, water and wastewater, as
well as cooperative policing. Numerous other points of collaboration large and small are indicative
of a strong and growing "town -gown" relationship. In 2016, the City and Cal Poly received a
prestigious award for the shared effort of creating the San Luis Obispo Neighborhood
Wellness/Community Civility Effort (Civility Report). The Civility Report remains an important
guiding document that supports resident quality of life and student success.
The City and Cal Poly have been similarly engaged in a process to understand the impacts of the
Cal Poly 2035 Master Plan as identified in its Draft Environmental Impact Report, and the
infrastructure and service needs, including water, wastewater and transportation, for both Cal Poly
and the City. The parties understand that maintaining a high level of partnership will contribute to
more effective outcomes as Cal Poly and the City continue to grow. Recognizing the importance of
this overarching objective, the purpose of this MOU is limited to documenting certain key objectives
identified by the parties as critical to accommodating further development on campus.
II. Goals and Principles
a. The parties enter this MOU to promote cooperation, and further develop their growing
relationship.
b. The parties will endeavor to improve communication by sharing information consistently and
meeting regularly.
c. This MOU is a statement of broad policy objectives and interests of the parties that will inform
future discussions and negotiations between Cal Poly and the City and is not intended to create
any contractual commitments.
d. In the event the parties identify projects or services requiring legal and/or financial
commitments between each other, the parties will negotiate in good faith toward written
agreements.
III. Water and Wastewater
The parties have enjoyed a longstanding partnership around water as reflected in various
agreements including those addressing water and wastewater treatment as well as shared supply
(e.g., Whale Rock Commission). Over the past year, staff from both entities have collaborated
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closely to develop strategies to ensure the availability and reliability of Cal Poly's water supply and
wastewater capacity in support of development planned in the 2035 Master Plan. The following
objectives will be addressed via amendment of existing agreements or establishment of new
agreements:
a. Develop mechanisms to confirm operational resiliency of Cal Poly's water supply
b. Secure additional, temporary non -potable water supply and wastewater capacity for Cal Poly if
needed to support the development of on -campus housing
c. Reach agreement on Cal Poly fair -share financial contribution to support required upgrades of
City's water treatment plant and distribution system
d. Reach agreement on Cal Poly fair -share financial contribution towards required upgrades of
City's water resource recovery facility and wastewater collection system
e. Cal Poly to regularly inform City of progress towards reducing municipal sewer inflow and
infiltration
f. Establish protocol and objectives for annual partnership meeting to address items such as
anticipated facility upgrades and related fair share contributions, inflow and infiltration
reduction projects, smart meters installation to track water supply use/flow rates, adaptive
management of water supply storage and other related water and wastewater matters.
IV. Transportation
The City and Cal Poly recognize the opportunity to increase their level of partnership around
transportation planning and programs. Coordination of effort is essential to adapting and building
systems that are responsive to growing populations and evolving transportation trends.
The value of collaboration in this area has long been realized with respect to the City's transit
system, which provides excellent service to both the City and Cal Poly populations. Continued efforts to
evaluate and, where appropriate, expand transit service and Transportation Demand Management
(TDM) policies at the Cal Poly campus will play an essential role in supporting Cal Poly's robust TDM
program and in the City's overarching climate action and sustainability goals to reduce Vehicle Miles
Traveled (VMT) and greenhouse gas emissions. Cal Poly and City agree that continued cooperation is
essential to achieve these goals and are deeply engaged in discussions around an expanded form of
partnership with the shared objective of building a more dynamic, sustainable, and mutually beneficial
transportation program.
In addition to transit service, which is critical to the parties' transportation plans and objectives,
other specific areas that would benefit from intentional partnership include traffic safety (on and off
campus), regional transit, and increased support for active transportation projects and programs. For
example, City and Cal Poly recently initiated a collaborative effort to assess and procure a bike share
program to serve the entire community.
The parties have identified the following interests and actions for near -term implementation:
a. Ensure the City is informed and consulted as Cal Poly develops and implements its TDM Program
b. Scale and optimize transit services available to the Cal Poly community in accordance with
changing population and utilization, with the objective of reducing VMT
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c. Consolidate and/or coordinate active transportation projects to optimize results and avoid
conflicts between vehicles, bicycles and pedestrians
d. Collaborate on initiatives to improve mobility and safety off campus
e. Identify potential mechanisms for Cal Poly to participate financially towards implementation of
transportation safety and mobility improvements that directly benefit university students, staff
and visitors.
f. Collaborate on strategies to address concerns related to campus spillover parking within
adjacent residential neighborhoods
g. Establish protocols and objectives to address transportation planning, TDM program evaluation
issues, and potential transportation enhancement projects, including trip monitoring, ongoing
evaluation of VMT reduction, transit service enhancements, and programs/projects to enhance
active transportation and mobility safety.
V. Housing
Since 2000, Cal Poly has tripled its student occupancy on campus, investing more than half a billion
dollars into student housing facilities without the use of any state funds. During that same period, Cal
Poly enrollment has grown by just over 4,300 students while the university has added more than 5,100
beds to its housing inventory. Cal Poly has provided additional housing capacity for all student
enrollment growth since 2000. Despite Cal Poly's enrollment increases, there were approximately 658
fewer students living off campus in the fall of 2019, as compared to the fall of 2000, because Cal Poly
increased the percentage of students living on campus from 17% to 37%.
The Cal Poly 2035 Master Plan sets an even more ambitious goal of housing on -campus more than
60% of anticipated enrollment. As part of the Master Plan, Cal Poly is preparing to provide for
California's critical higher education needs by increasing headcount enrollment by 4,056 students. As it
has done over the last two decades, Cal Poly plans to house all of its enrollment growth, as well as
significantly reduce the number of students living off campus. With Cal Poly's planned increase of 7,200
on -campus beds articulated in the 2035 Master Plan, the university is working to reduce the number of
students living off campus by more than 3,100 students.
Cal Poly has elasticity in its current on -campus bed capacity within residence halls. When necessary
and feasible, Cal Poly will evaluate whether increased bed density should be implemented to
accommodate enrollment growth.
The parties have identified the following interests and actions for near -term implementation:
1. The parties understand the importance of the university's next student housing project and
the related enabling projects (i.e. on -campus WRF to support water/wastewater capacity).
The University is actively working on the university's next student housing project to build
1600-2000 new student beds.
2. Cal Poly to regularly inform the City of progress towards constructing additional housing on
campus and share its five-year capital plan, housing occupancy rates, and enrollment
targets.
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3. Establish protocol and objectives for annual partnership meeting to address issues related
to university and city growth and best accomplish transportation, public service and other
resource planning.
City and Cal Poly leadership hereby commit to act in good faith in pursuit of these shared objectives.
CITY
Date
CAL POLY
Date
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ly
rftlo
Community Development
919 Palm Street, San Luis Obispo, CA 93401-3249
805.781.7170
slocibj.org
February 3, 2020
Jeffrey Dumars
Associate Director of Environmental & Space Planning
Facilities Management and Development
Cal Poly
1 Grand Avenue, San Luis Obispo, CA 93407
SUBJECT: Cal Poly 2035 Master Plan Draft EIR (SCH#2016101003)
Dear Mr. Dumars:
The City of San Luis Obispo provides this letter with attachments as its formal comments
on the Draft EIR for Cal Poly's 2035 Master Plan. We appreciate the opportunity to
comment, and the time and coordination that has occurred on the mitigation measures
that require City participation. Ultimately, the City asserts that the EIR has improved and
the purpose of these comments are intentionally put forward to strengthen the analysis of
the environmental impacts and fully disclose those impacts so that environmental impacts
can be fully mitigated to the extent reasonably feasible.
As you know, the City and Cal Poly have existing agreements that cover a wide range of
services where the campus and community support each other's mutual success. With
this in mind, we have used the Draft EIR as a tool to better understand how these
agreements will continue to serve the campus and community as the campus grows with
development under the 2035 Master Plan.
The comments provided herein are intended to be constructive to help ensure the City's
ability to support implementation of the Master Plan. In this regard, the Draft EIR and
Master Plan are tools that will help us identify Cal Poly's fair share of the costs of public
facilities and services needed to support growth on campus.
Attached to this comment letter is a 2015 communication authorized by the City Council
including "City Comments on the Cal Poly Master Plan Update," and "Guiding Principles
for Input on the Cal Poly Master Plan Update." The following comments are made with
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this guidance in mind, and in consideration of the City's current Major City Goals for
Housing and Climate Action.
Please don't hesitate to reach out should you have any questions about the information
contained in this letter.
Sincerely,
c;
Michael Codron
Community Development Director
Attachments: Draft EIR Comments
Letter from Mayor Marx to Jeffrey D. Armstrong (December 1, 2015)
Letter from Katie Lichtig to Jeffrey D. Armstrong (September 11, 2017)
CC: San Luis Obispo City Council
Ray Aronson, Executive Director of Facilities, Planning, and Capital Projects
Jessica Darin, Chief of Staff
Christine Dietrick, City Attorney
Juanita Holler, Associate Vice President for Facilities
Keith Humphrey, Vice President for Student Affairs
Derek Johnson, City Manager
Courtney Kienow, Director of Community Relations
Cindy Villa, Vice President for Administration and Finance
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Draft EIR Comments
Introduction/Project Description
The City is concerned about enrollment growth on campus to the extent that it is not
planned for and that it is not phased to occur subsequent to the provision of additional
housing on campus. A spike in enrollment that occurred in 2017 provided the City with an
opportunity to quantify costs associated with unplanned enrollment growth, which resulted
in unplanned costs to the City in the areas of emergency response and transit, for
example (Katie Lichtig; September 11, 2017, attached).
The project description assumes that enrollment will increase at a lower rate over the next
two decades than it has during the past two decades, but no evidence is cited to support
this assumption. In fact, the data identified in the DER of past enrollment growth supports
a growth rate of 280 students per year, not the 205 students per year used throughout
the DER. This is equivalent to a 26.8% decrease in historic enrollment growth. No
evidence has been cited or supplied to explain why it was assumed that such a significant
decrease will occur, nor does the DER include any assurances in the form of enforceable
project components or mitigation measures to ensure that the planned rate of enrollment
growth will actually occur.
The way to remedy this is through enforceable policies in the master plan and/or
mitigation measures in the Final EIR that would prevent increases in enrollment beyond
what is planned for, or that trigger additional measures to mitigate impacts should
increased enrollment occur. Phasing enrollment growth in alignment with the provision of
facilities on campus (e.g. water supply, active transportation projects, transit service,
housing, etc.) is recommended as a method to address the potential for unmitigated
impacts associated with unplanned enrollment growth.
Aesthetics
Slack and Grand Project
The Faculty and Staff Workforce Housing (Slack and Grand) project is identified as a near
term project in Table 2-12. The proposed development is up to five stories in height which
greatly exceeds that of the adjacent single-family residences along Slack Street.
Although the DER identifies this as a significant and unavoidable impact, Mitigation
Measure 3.1-1 relies only on landscaping to mitigate impacts and would not reduce
impacts to the maximum extent feasible. Feasible mitigation could also include detailed
architectural design to provide a more compatible transition to the surrounding
neighborhoods, consistent with the City's property development standards for Edge
Conditions (SLOMC 17.70.050). The City believes that compliance with its standards for
Edge Conditions would be feasible and effective mitigation for the project contemplated
on the Slack and Grand site.
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Air Quality, Energy Consumption and GHG Emissions
City comments on these three topic areas are combined to focus comments on specific
policy interests of the City with respect to GHG emissions reduction strategies. The City
of San Luis Obispo is pursuing a 2035 Carbon Neutral goal and has taken a leadership
role across the State and country with respect to programs and standards to help achieve
this outcome. Specifically, the City has adopted a policy preference for all -electric new
buildings and is pursuing adoption of a Clean Energy Choice Program to incentivize all -
electric new development. The City is developing a Carbon Offset Requirement and has
negotiated with new housing developers to eliminate the use of natural gas in major new
subdivisions.
Therefore, the City finds the commitment that all buildings constructed under the Master
Plan will be powered by 100% on site renewable energy commendable. The City notes
that this renewable energy goal is identified as a requirement in the GHG analysis in
Chapter 3.8. However, mitigation measures in Chapter 3.8 concerning GHG emissions
do not require that all buildings be powered by 100% renewable energy. For instance, will
the WRF be 100% powered by on -site renewable energy? If so, where will the renewable
energy be generated? The DEIR does not describe or evaluate any large-scale renewable
energy projects to indicate that the requirement can be achieved. Implementation of the
Master Plan goals on energy and GHG reduction would benefit greatly by a more detailed
discussion of how the on -site renewable energy goals can be feasibly accomplished.
The DEIR relies on the VMT model to supply estimates for the Master Plan's operational
GHG emissions. However, the VMT model excluded vehicle miles traveled by vendors
and visitors to the campus. As a result, a GHG analysis that relies on that VMT model
may not include the full scope of GHG emissions generated by this project.
The DEIR states that daily VMT estimates were "adjusted to annual VMT using a
conversion factor of 267 days per year, which accounts for Cal Poly's academic schedule,
holidays, and enrollment levels during summer and regular academic quarters." (DEIR,
p. 3.8-15.) Although VMT may be lower when school is not in session, the campus is still
in operation and people still visit it during those times (i.e. move in, orientation, summer
sessions, construction projects, etc.). As a result, GHG emissions still occur on the days
that the annual VMT estimate has excluded with no basis and thus is incomplete and
deprives the public from understanding the full GHG emissions of campus operations. By
basing its GHG emission estimates on a VMT model that excluded 98 emission producing
days per year, the GHG analysis is potentially underreporting the potential GHG impacts
associated with this project. In addition, Chapter 3.3 of the DEIR acknowledges that the
project will increase trip counts by 7,495 daily trips. The GHG analysis should likewise
take these trips into account and fully disclose and evaluate impacts to GHG.
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Biological Resources
Generally, the City is concerned that the EIR and Master Plan fail to provide a program
for evaluating impacts to biological resources to guide project designs and streamline
subsequent environmental review. The presence of special status plant and animal
species is identified, but there is no guidance through Master Plan policies or detailed
mitigation measures regarding the scope and scale of future biological studies needed to
avoid impacts and secure resource agency approval for projects contemplated in the
Master Plan. The need for certain resource agency approvals (an Incidental Take Permit
and a Habitat Conservation Plan are both noted as possible requirements) may
significantly delay housing and water projects that are relied upon in the DEIR to self -
mitigate impacts to housing, transportation, GHG emissions, noise and other issue areas
identified throughout the DEIR.
Plants
The analysis in this section relies on deferral of studies to identify and mitigate impacts at
some future point, however, no program for future studies is provided to guide future
investigations. Mitigation measure 3.5-1 a states surveys should be conducted prior to
approval of "specific projects under the 2035 Master Plan." This mitigation measure is
vague as to what projects would trigger this measure (i.e. projects that may otherwise
qualify for an infill exemption). The DEIR appears to base analysis of potential impacts to
protected plant species on one reconnaissance level survey that was completed in June
2019. As noted in Table 1, Appendix E, there are many protected plant species that may
be present on the site that do not flower in June. Mitigation Measure 3.5-1 b only provides
for avoidance of impacts to special status plants in the area outside of the footprint of
structures and site features. Proper evaluation in advance of the approval of building
footprints should inform their final location to potentially avoid or minimize impacts to the
greatest degree possible and avoid potential delays in Master Plan implementation.
Hydrology and Water Quality
The DEIR does not evaluate potential impacts that could result from flooding. One way to
address this would be for DEIR and Master Plan to include specific references to the
regional San Luis Obispo watershed Waterway Management Plan (WMP). The WMP has
been adopted by both the City and County as the agreed upon standard for the San Luis
Obispo watershed. The impact of not analyzing flooding is that the project may cause an
increase in the rate or amount of surface water that would result in flooding both on and
off -site, it may impede or redirect flood flows, or it may cause the release of pollutants
due to inundation that may occur within the flood plain. CEQA requires a full evaluation
of these impacts, as stated in CEQA Guidelines Appendix G. By not including this full
evaluation in the DEIR, the project creates potential unmitigated impacts that have not be
disclosed to the public or decision makers.
Slack and Grand project and Retirement Community
The DEIR does not evaluate impacts to City stormwater facilities and potential runoff from
the Slack and Grand site that will flow into the City's stormwater system and into San Luis
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Obispo Creek. Once water from on -site impervious areas enters the City right's -of -way,
Cal Poly would be subject to the City's stormwater permits. No analysis is provided
demonstrating how the project would comply with City permit requirements.
No analysis is provided on how the development of the retirement community may also
impact the City's stormwater system as drainage is likely to be directed to City
infrastructure. No evidence is provided of how these projects will comply with City permit
requirements or how San Luis Obispo Creek will not be impacted by development. A
requirement for WMP compliance would address the concern.
Flooding
The DEIR does not evaluate potential floodplain impacts. City and County Floodplain
Management Regulations should be disclosed and pre- versus post -development
impacts should be analyzed. The DEIR states that buildings will be located above the
floodplain but there is no analysis or clear mitigation to ensure that floodwaters will not be
displaced creating downstream impacts. These are significant issues that could create
hazardous conditions and property damage. In particular, the DEIR does not evaluate the
extent of construction within the Base Flood Elevation (BFE) and whether it is feasible to
locate new construction outside this zone. If flood flows are obstructed or capacity of the
floodplain is altered without appropriate mitigation, impacts will result.
Noise
Spanos Stadium
The Master Plan Update includes a 4,000 seat increase in capacity at Spanos Stadium
and there is no quantified analysis of existing or anticipated noise levels during events.
Absent a noise evaluation, the DEIR and Master Plan could include Mitigation Measures
or policies to ensure disclosure of future noise levels and that feasible mitigation is
applied. For example, the DEIR and/or Master Plan could provide direction regarding the
orientation of speakers away from sensitive receptors, acceptable volume levels,
restrictions on hours of events, and clear thresholds to guide the evaluation of future
stadium expansion projects.
Construction Noise
Implementation of the Master Plan Update would include construction of millions of
square feet of academic and support buildings, infrastructure improvements, a new
Wastewater Reclamation Facility (WRF), expansion of Spanos Stadium, and several
housing projects to be constructed over a period of 15 years. These activities will
introduce significant new noise sources to the areas surrounding the entrances to campus
and have the potential to create long term impacts to the surrounding areas. The DEIR
does not include disclosure of potential impacts associated with construction traffic under
3.10-1, Impact 3.1-2, or elsewhere in the DEIR. The DEIR appropriately references City
noise thresholds and it would also be appropriate to make use of standard City noise
reduction methods as outlined in the City General Plan Noise Element and Noise
Standards contained in its Municipal Code. Some of the standard noise reduction
measures include:
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• Limit the operating times of noise -producing activities and compliance with
City Municipal Code requirements for construction hours of operation.
• Rerouting traffic and construction truck trips onto streets that can maintain
desired levels of service and which do not adjoin noise -sensitive land
uses. The DEIR includes a measure for a materials haul routes, but the
City should be consulted on these routes since City residents and will be
affected and City streets will be used.
• Lowering traffic speeds through street or intersection design methods.
• Conduct focused noise studies to supplement overall programmatic noise
analysis to determine specific measures to avoid or minimize noise
impacts.
• Best Management Practices (BMP's) should be established which include
measures such as use of sound blankets, mufflers, temporary sound
barriers, locating stationary equipment away from residences,
neighboring property owner notification and a process to address
construction noise complaints.
• Lastly, City Streets will be impacted from construction trips and the
University should implement a pavement index evaluation before and after
construction and cover the incremental costs for impacts related to the
degradation of city roads.
Population and Housing
The City appreciates and supports the Master Plan's efforts to plan for and provide a
significant amount of student housing. The housing goals stated in the Master Plan, if
reached, will benefit Cal Poly's students and, importantly, the surrounding community as
well, returning needed housing stock to non -students and decreasing neighborhood
compatibility issues. However, the DEIR relies on the housing goals stated in the Master
Plan without providing assurances that the housing will actually be built or that it will be
built in time to mitigate the impacts of increased enrollment. If the on -campus housing
contemplated under the Master Plan is not timely built, impacts to transportation, air
quality, noise, and housing will be more significant than evaluated in the DEIR.
Table 2-9 sets forth a helpful yearly estimate of enrollment and on -campus housing
through the planning horizon of the Master Plan. However, the estimates are based on
two assumptions that lack substantial evidence: (1) enrollment will increase at a steady
yearly rate of only 205 students; and (2) new housing will actually be constructed
consistent with stated goals, with no enforceable accountability measures or mitigations
required if goals are not actually met. Because enrollment increases may occur at rates
and in amounts that are much greater than have been estimated in the DEIR, and
because housing may not be built on campus consistent with the Master Plan's stated
goals, the DEIR's assumptions lack substantial evidence as a basis for its conclusions
about environmental impacts.
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Affordable Housing
The DEIR does not include an analysis regarding potential housing impacts associated
with the increased faculty, staff, vendors, and construction personnel necessary to
complete the Master Plan and support the increase in enrollment. The 380 units proposed
for the Slack and Grand project will not accommodate the 787 new employees anticipated
under the Master Plan (when compared to 2015 levels), nor will it address housing needs
generated by the 15-year construction period or the additional employees anticipated to
use the expanded Technology Park. (See DEIR, p. 2-18.) The DEIR also does not
evaluate impacts to housing that will result from the new employees required to support
the staff at the new retirement community. If sufficient affordable housing is not available
in the City, these employees will be required to commute to the campus and to the
retirement community from outside of the area. The DEIR lacks sufficient evidence to
show that these constraints were taken into account in the VMT analysis, the estimate of
transportation impacts, or in the analysis of impacts on housing contained in this chapter.
As the DEIR admits, the City is a high -cost housing market. (DEIR, p. 3.11-15.) Yet the
DEIR does not contain any analysis of the potential impacts associated with the increased
demand for affordable housing to support the new employees associated with the Master
Plan. Both the City and County have Inclusionary Housing policies and ordinances to
ensure that new development that creates a demand for affordable housing either directly
or indirectly contributes to the construction of affordable housing units. The lack of
analysis in the DEIR could be addressed through compliance with City or County
inclusionary housing requirements.
Off -Campus Housing
The DEIR says that enrollment increases are likely to occur before new housing is
constructed on -campus, which will require more students to seek housing in the City and
County than are already living off -campus. (DEIR, p. 3.11-20.) The DEIR then dismisses
impacts to housing in the City and County by arguing that vacancy rates would
accommodate this influx of new residents. This conclusion is not supported by substantial
evidence. First, vacancy rates in the City are less than 4%, not 6.3% as reported in the
DEIR. According to the Census ACS Survey, the rental vacancy rate in 2017 was 3.63%.
Moreover, the DEIR does not cite to evidence that a 6.3% vacancy rate equates to enough
housing to accommodate at least 416 additional students (the number of additional
enrolled students anticipated in the DEIR for the years 2020 and 2021). Nor does the
DEIR provide any evidence or analysis of what will occur if new on -campus housing is
not constructed by the year 2022, however, delays could occur and there are no
mechanisms in the DEIR or Master Plan that link enrollment growth to the provision of
new housing supply on campus. Therefore, the DEIR should have evaluated impacts to
housing resulting from delays in construction of housing on -campus. The failure to do so
results in underreported and unevaluated potentially significant impacts to housing.
Public Services
In April 2018, the City of San Luis Obispo published a Capital Facilities Development
Impact Fee Nexus Study (EPS; April 16, 2018). The Nexus Study provided the City with
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the necessary technical documentation to adopt updated fee programs to ensure that
new development covers its fair share of the costs of infrastructure and public facilities
that benefit the new development. Although the City's fee programs do not apply to
development on campus, the Nexus Study provides a sound methodology under CEQA
for the analysis of impacts to public facilities. The City encourages Cal Poly to use this
Nexus Study as a basis to determine fair share contributions associated with the
provisions of new residential uses on campus (other than student housing), such as the
Grand/Slack workforce housing project and the retirement community project located
west of Highway 1, near Stenner Creek Road. The City has available mitigation either via
agreement or using impact fee methodology in the Nexus Study for each of the following
issue areas.
Emergency Response
The DEIR evaluates potential impacts on fire service based on per capita calls for service
to the campus in the year 2017 as well as off -campus calls for service made by students.
(DEIR, p. 3.12-15.) These projections do not include any per capita analysis of calls for
service to the new residents at the workforce housing (Slack and Grand) project or the
retirement community project. In fact, there is no discussion of how fire and police
services will be provided to these new communities, which are outside of the core area
covered by the current emergency services agreement. In addition, the future population
and planned uses at the retirement community are very different from the population and
uses planned for the remainder of the campus. Therefore, the student -related calls used
to estimate a rate of per capita calls for service cannot be relied upon to estimate impacts
to public services associated with these projects. As a result, the DEIR should identify the
need to update the current Emergency Services Agreement (July 1, 2018) prior to
development and occupancy of either project.
Law Enforcement
The DEIR does not take into consideration additional demands on SLOPD services that
will be generated by the retirement community and Slack and Grand projects. These
projects are likely to require SLOPD services as non -student residents seek help from the
San Luis Obispo police department in addition to University PD. Moreover, the retirement
community's separation from the main campus makes it even more likely that calls for
service will be answered by the Sheriff's Department as the site is located outside of City
limits and across Highway 1 from the main campus. The DEIR does not disclose or
evaluate how police services will be provided to these new communities nor how impacts
to SLOPD and the Sheriff's Department will be addressed.
Parks and Recreation
The DEIR analyzes potential impacts to recreational and park facilities using an estimated
total campus population of 28,935 to determine the total acres of recreational facilities
needed to serve the population. This estimate excludes the proposed retirement
community population, and possibly the Slack and Grand project population as well,
which together may add another 1,025 residents and 60 employees to the Master Plan's
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total population. As a result, the DER potentially underestimates the recreational needs
and impacts of the increase in population contemplated under the Master Plan.
Transportation
Facility Expansion
The Master Plan project description includes expansion of existing sport and special event
facilities on campus, including a 4,000-seat expansion of Alex Spanos Stadium. Trip
generation from these expansions would generate thousands of additional trips in
relatively short time periods and there are no policies or programs that would limit the use
of these facilities. While level of service (LOS) or other measures of auto capacity may no
longer be required as applicable thresholds of significance for analysis of transportation
impacts under CEQA, the magnitude of additional trip generation (auto, bikes, peds,
transit) from these expansions should be quantified to guide system planning and traffic
handling plans and programs. The DEIR's transportation analysis should be updated to
include an evaluation of the venues and events proposed in the Master Plan and the
adequacy of the existing circulation system to accommodate these increased demands.
In addition, the Master Plan should be updated with policies and programs that govern the
use of these facilities.
Enrollment and Housing Linkage
The Master Plan provides estimates or forecasts for student enrollment levels and on -
campus housing production through a phased development program through 2035. The
transportation impact analysis provided in the DER considers the increased production of
on -campus housing as a significant contributor towards reducing campus -generated VMT
by providing opportunities for students to live in a location where most of their daily travel
is possible via short trips by foot, bicycle or transit. However, the Master Plan does not
include any formal policies, programs or mitigation mechanisms that govern actual
enrollment levels or require the timely production of on -campus housing in tandem with,
or in advance of, increases in on -campus enrollment or traffic -generating development. To
address this, the Master Plan and DER should include policies or programs to govern
actual enrollment and development to a level that is on pace with actual production of on -
campus housing and informed by the actual effectiveness of the proposed Transportation
Demand Management (TDM) programs as evaluated by regular trip/VMT monitoring
activities.
Multimodal Transportation Demand
It is understood that auto level of service (LOS) and other measures of traffic congestion
were not included to determine transportation impacts under CEQA pursuant to SIB 743. In
turn, the EIR Transportation section includes no quantitative estimates of auto traffic
generation associated with buildout of the Master Plan. While the DER may not be
required to evaluate auto traffic generation with respect to LOS or other capacity -related
significance criteria to determine transportation impacts, complete omission of this
information from the Transportation chapter presents significant challenges for entities
such as the City with respect to system planning for streets and intersections that provide
direct access to the Cal Poly Campus. For purposes of full disclosure, the City request that
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the Final EIR include the estimated number of net new daily, AM and PM peak hour vehicle
trips expected to be added to City streets within the vicinity of the campus. This information
was provided in Appendix G for bicycle and pedestrian trips and should be replicated for
auto trips.
VMT Impacts and Mitigation
The DER identifies a potentially significant impact (Impact 3.13-1) due to project -
generated VMT that exceeds regional VMT thresholds. The corresponding mitigation
measure (Mitigation 3.13-1) requires development and implementation of a
Transportation Demand Management (TDM) plan and concludes that this impact would
be reduced to a "less -than -significant" level. The adequacy of this mitigation approach is
questionable for several reasons.
The EIR concludes that the TDM measures outlined in Mitigation Measure 3.13-1 would
reduce campus -wide VMT to the level required to mitigate the identified impact —a net
reduction of 5.04 VMT per service population (about 21 % below the baseline Existing
plus Project VTM estimates). However, the document provides no supporting analysis or
documentation to verify whether this level of reduction is feasible or whether similar
results have been achieved at comparable university campuses. Studies show that the
ultimate efficacy of a TDM program can vary significantly from project to project. While
there is available data and planning -level models that can be used for estimating TDM
reductions —such as the CAPCOA model referenced in the CSU Transportation Impact
Study Manual —the DER provides no supporting analysis or documentation to support
the claims presented.
The CSU CEQA Handbook recommends caution regarding use of mitigation measures
that could be interpreted as "deferred mitigation." On pg. 84-85, the Handbook
states: The CSU CEQA Handbook recommends caution regarding use of mitigation
measures that could be interpreted as "deferred mitigation". On pg. 84-85, the Handbook
states:
"Mitigation measures cannot defer to future studies, consultations, or future
undefined time. Such measures are called "deferred mitigation" and are easy
points for legal challenge. In some situations, it is not known whether there
will be an impact without doing additional surveys or studies, especially for
large and long-term projects or programs for which a Program EIR is
prepared. To avoid improper "deferred mitigation" you must clearly identify
what you will do if any future studies identify that there could be an impact.
Alternatively, if such information is not yet available, you need to incorporate
performance standards or criteria into the measure to ensure that the
strategies ultimately selected in fact will reduce the impact as reported in the
CEQA document."
The Handbook continues with the following guidance:
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"Remember. If some doubt exists as to whether a mitigation measure will fully
mitigate the impact, it is good practice to indicate that the impact will remain
significant and unavoidable even with the incorporation of mitigation."
As currently presented, the strategies identified under Mitigation Measure 3.13-1 appear
to be deferred mitigation. The DER recommends development of a TDM plan and
identifies potential strategies that could be implemented to reduce vehicle trip generation,
including a biennial monitoring program to track the efficacy of the TDM plan.
Of particular concern is the fact that this mitigation measure does not describe how VMT
will be measured as part of this monitoring program, what performance criteria will be
used to evaluate progress towards achieving the targeted VMT reduction, or what specific
actions will be taken if monitoring results reveal that TDM strategies have not been
sufficiently effective. The City has relayed on several occasions that this was a minimum
measure that must be met and its absence is noticeable and does not provide the level
of confidence that TDM or monitoring will be an integral part of achieving the University's
projected mode shifts.
Furthermore, this mitigation strategy does not require any measurable level of TDM
implementation or VMT reduction prior to implementation of potential VMT-increasing
activities, such as increases to student enrollment and on -campus employment without
corresponding production of on -campus housing, allowing impacts to occur before
mitigation would be implemented. This strategy relies on monitoring every two years to
verify if required VMT reductions have been achieved, which potentially defers necessary
mitigation until after an impact has materialized. Monitoring should be conducted
annually, and mitigation measures should be taken immediately if VMT is higher than
projected.
It should be noted that a primary component of the TDM plan includes expansion
of local and regional public transit services to the campus through coordination and
fair -share contributions towards increasing SLO Transit and SLORTA bus services.
However, because these transit services are not operated by Cal Poly, the university
cannot ensure that these services are expanded as needed to meet the required VMT
reduction targets. If VTM increases are not closely monitored and needed fair -share
contributions are not provided prior to impacts occurring and/or if the amount of fair -
share contributions is inadequate, the City would be put in a position of having to fund
the gap to provide the increased service, or the City may not be able to shoulder the
increased financial burden depending on the budget priorities at the time. The City of
San Luis Obispo is agreeable to negotiating an MOU with the campus for the purpose
of implementing this mitigation measure that broadly seeks to bring Cal Poly
contributions in line with current and future operational needs.
Within the Master Plan, Implementation Program 20 states that "Cal Poly should partner
with the City to help develop off -campus bicycle improvements as prescribed in the City's
bike plan and that improve connections between the campus and community." Further,
DER Mitigation Measure 3.13-1 outlines a TDM program that includes a general
recommendation to "support active transportation projects on and near campus through
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infrastructure improvements to enhance safety and efficiency of these travel modes." The
City of San Luis Obispo is agreeable to negotiating an MOU with the campus for the
purpose of implementing this mitigation measure.
However, the DEIR should identify more specific recommendations or mechanisms for
contributing towards active transportation infrastructure improvements within the vicinity
of the campus. Potential mechanisms for proportionate contribution may include
participation in the City's Transportation Impact Fee program, which funds citywide
bicycle and pedestrian infrastructure improvements, or direct participation in projects near
campus, such as the addition of separated/protected bicycle facilities, installation of
accessible pedestrian curb ramps, additional street lighting, and intersection crossing
enhancements.
Traffic Safety
The Environmental Setting section of the EIR Transportation Chapter provides a brief
summary of existing collision trends for streets within the vicinity of the campus, as
referenced from recent editions of the City's Annual Traffic Safety Report. However, the
Impacts and Mitigation Measures section includes virtually no discussion or analysis of
potential traffic safety issues outside of the campus boundaries with implementation of
the Master Plan.
Per the DEIR, build -out of the Master Plan is projected to add approximately 930 new
bicycle trips, 850 new pedestrian trips, and 133,000 net new VMT per day to City
transportation facilities within the vicinity of the campus. There is no discussion of
whether these increases in multimodal traffic demand can be accommodated by
existing off -campus infrastructure, or whether this demand has potential to exacerbate
existing traffic safety issues within the campus vicinity. Additional analysis of potential
traffic safety considerations should be provided as follows:
A. Evaluate potential for additional traffic (auto, bike & pedestrian) generated by
the campus to increase collision rates at the following high -collision rate
locations as identified in recent City Traffic Safety Reports:
• California/Taft
• California/Monterey
• California/US 101 NB Ramps
• Grand/Loomis
• California/Mill
• Foothill/Santa Rosa
• Foothill/Casa
• Santa Rosa/Boysen
• Foothill Boulevard (Tassajara to California)
B. While auto traffic capacity analysis may no longer be required to determine impacts
to transportation, vehicle queuing analysis should be provided for the
abovementioned intersections for the purposes of evaluating potential safety
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impacts related to turn pocket queue spillback, or sight distance impacts as a result
of project traffic.
Parking
The project does not include sufficient parking improvements to accommodate the
increase in on -campus population contemplated in the Master Plan. It is also unclear if
this is a formal aspect of the proposed TDM program. Even if first and second -year
students are precluded from parking cars on -campus, the addition of only 174 new
parking spaces will not be sufficient for the new faculty, support staff, and employees who
will be working on campus, nor has evidence been presented that sufficient parking will
be available for vendors, temporary employees, or event attendees, including attendees
at the planned expansion of Spanos Stadium and the Technology Park expansion.
Moreover, the project description indicates that Cal Poly intends to limit parking for certain
students, however, these limitations are stated as intentions and not enforceable
restrictions and the DEIR provides no evidence that the lack of parking on campus will
actually persuade new students, employees, and visitors to not drive personal
automobiles to campus. As the on -campus population increases, it is reasonable to
assume that more cars will come with their owners. The DEIR does not describe how Cal
Poly intends to ensure that students who live on or off campus do not bring cars to the
area and park them off campus. This lack of planning for parking will perpetuate and
increase impacts on the neighborhoods surrounding the campus where employees and
visitors will be forced to search for parking. This, in turn, will create additional impacts to
noise, roadway maintenance, and air quality in these areas. These impacts have not been
evaluated properly in the DEIR. The City believes that coordination of specific mitigation
measures on the matter of parking is important to ensure that any impacts created by a
lack of parking on -campus do not simply spill over to City neighborhoods off -campus.
Utilities and Service Systems Utilities
Water Supply Resiliency
The DEIR is required to evaluate water resiliency to ensure that sufficient water supplies
will exist to serve buildout under the Master Plan. The DEIR includes no evidence or
information regarding how Cal Poly is planning for water resiliency during times when
Whale Rock dam, spillway, pump stations, or pipeline are unavailable due to maintenance
needs or construction. Cal Poly worked with the City to identify potential water supply
alternatives to improve its water resiliency; however, Cal Poly did not provide this
information in the DEIR. The 2007 Memorandum of Understanding (2007 MOU) between
City and the University regarding capacity interest in City water and wastewater facilities
does not address water supply resiliency.
Water Storage/Reservoir Expansion
The DEIR does not include an analysis of the impacts associated with the expansion of
Cal Poly's existing reservoir system for recycled water storage necessary to support Cal
Poly's proposed Water Reclamation Facility (WRF) and future water needs contemplated
under the Master Plan. Appendix H, page 24, explains that Cal Poly's "proposed WRF
would also require expansion of the existing reservoir system to a maximum (total) of 100
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AF. If the existing reservoir system cannot be expanded then the University may
potentially construct two additional reservoirs for recycled water storage from the WRF. "
Water storage is also generally described on Project Description on page 2-40 and page
2-47. This expansion, or new construction of additional reservoirs, is not included in the
impact analysis. One hundred acre-feet of water storage is nearly 32.6 million gallons - a
substantial amount of water. The Master Plan EIR does not identify where this storage
will be located, nor does the DER analyze the environmental impacts associated with
construction and maintenance of these significant new facilities. It is also unclear whether
the storage will be sized and under the jurisdiction of the Division of Safety of Dams. If
so, the Division of Safety of Dams should be identified as a responsible agency and
should be consulted regarding the adequacy, design, and permitting of the storage
facilities. Because this information is not provided int the DER, impacts associated with
providing the water and wastewater services necessary to support buildout of the Master
Plan may be understated.
The DER does not include analysis of daily and monthly non -potable water demands to
support its water supply impact analysis. The daily and monthly demand pattern for
agricultural and landscape irrigation is relevant to determining whether Cal Poly's
proposed WRF will generate a sufficient and reliable water supply. Based on 2015 and
2019 data, Cal Poly's non -potable demand was over 850,000 gallons per day in July,
when average daily wastewater generation was—38,000 gallons in 2015 and—75,000
gallons in 2019 for the entire existing campus.
The DER does not include information regarding the existing non -potable water storage
capacity on -campus, the extent to which existing daily agricultural water demand will be
feasibly supplied with water from the WRF, and the availability of sufficient storage to
ensure delivery of enough water to meet agricultural demand. In other words, existing
daily agricultural water demand is not estimated in the DER to support the concept that
this demand will be offset with non -potable water from the proposed WRF. This
information is necessary to inform the sizing of the needed storage and to illustrate that
the planned water sources required to support buildout of the Master Plan are feasible.
As a result, the DER does not include the information necessary to support its
conclusions regarding impacts to agricultural uses and to water demands resulting from
buildout of the Master Plan.
The DER acknowledges that "some adjustments to the system, such as increased
pumping to reservoirs or storage tanks may be necessary," however, no analysis was
provided regarding the environmental impacts associated with the siting, construction,
and maintenance of these new reservoirs and storage tanks. (DEIR, p. 3.14-14) In fact,
neither the DER nor the Master Plan identify how many of these storage facilities are
needed, where they will be located, or whether it is feasible to locate them in places that
will not impact biological, cultural, hydrologic, and other resources. Instead, it is likely that
the amount of storage that will be necessary to serve the new development contemplated
in the Master Plan will be significant, which will likewise create significant impacts to
sensitive resources. As a result, the DER fails to identify potentially significant impacts
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associated with the infrastructure necessary to provide sufficient water to campus under
the Master Plan. The DEIR's conclusion that the Master Plan will not require or result in
the relocation or construction of new or expanded water infrastructure is not consistent
with what is proposed by Cal Poly in the Master Plan (100 acre-feet of storage). This is a
significant problem for the DER, as well as the Master Plan, as new housing and other
amenities will not be able to be completed until these necessary improvements are
completed and thus potentially creates a cascade of unmitigated impacts if campus
population increases through increases in enrollment that does not include concomitant
housing.
Short -Term Non -Potable Water Supplies
Mitigation Measure 3.14-3 relies on the possibility that the City may provide short-term
non -potable water supplies to Cal Poly in the event that the WRF is not completed and
capable of providing sufficient water supplies for near term projects. A number of
important actions by the City would be required in order to enable this to occur. The City's
General Plan will need to be amended to enable it to provide non -potable water to Cal
Poly on a short term -basis', and an analysis must be completed to ensure that providing
this water would not interfere with the City's existing entitlements and permits. A contract
will also be required, which has not been negotiated between the City and Cal Poly. The
City is open to discussing this arrangement, but additional time, resources, and City
Council action is necessary, which the DER should acknowledge. Additionally, this
measure defers an analysis of whether the provision of such non -potable water by the
City would create its own negative environmental impacts.
A provision should be added to Measure 3.14-3 to allow reliance on such temporary non -
potable sources only if no negative environmental impacts would occur as a result and
for the sole purpose of delivering on campus housing. Finally, this measure does not
include specific requirements for measuring and monitoring water demand in conjunction
with any arrangement for short-term water supplies from the City and expected
completion of the WRF. The measure should be amended to require measuring and
monitoring of water demand and supplies in sufficient intervals and using realistic and
supported projections of future supply and demand to ensure that enough potable water
will truly be available to serve new construction and non -potable water will be available
to continue to serve Cal Poly's existing agricultural uses.
The DER concludes that the Master Plan will have sufficient water supplies available to
serve the project and reasonably foreseeable future development during normal, dry and
multiple dry years due to implementation of Measure 3.14-3. However, this measure does
not account for the possibility that new housing and other water -dependent construction
1 General Plan Policy 1.13.2. Recycled Water. Provision of recycled water outside of City limits may only
be considered in compliance with Water and Wastewater Element Policy A 7.3.4 and the following findings:
A. Non-potable/recycled water is necessary to support continued agricultural operations. B. Provision of
non-potable/recycled water will not be used to increase development potential of property being served. C.
Non-potable/recycled water will not be further treated to make it potable. D. Prior to provision of non-
potable/recycled water, the property to be served will record a conservation, open space, Williamson Act,
or other easement instrument to maintain the area being served in agriculture and open space while
recycled water is being provided.
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may be built under the Master Plan before the WRF and associated expansion of existing
water storage reservoirs, or construction of new water storage reservoirs, are completed
or capable of providing sufficient water to offset demand and that short-term non -potable
water supplies may be available for some period of time but become unavailable before
the WRF is completed. In this event, the new housing and other buildings would be
occupied but Cal Poly would not have sufficient potable water available through its Whale
Rock entitlement, or through a temporary non -potable supply from the City, to supply all
of its demand. It is also possible that problems will occur during the design, construction,
and permitting of the WRF and associated expansion of existing water storage reservoirs,
or construction of new water storage reservoirs, such that it becomes significantly delayed
or rendered infeasible altogether. Because the design of the WRF is not complete and
there is currently no plan for sufficient storage capacity, it is questionable that reliance on
the WRF is feasible to mitigate the Master Plan's future water demand.
It is highly unlikely that the WRF and associated water storage will be constructed and
operational by the year 2022. Design, construction, and permitting of new water
reclamation and water storage facilities take significant amounts of time and resources.
As a result, it is likely that Cal Poly will require alternative water sources to supply new
development under the Master Plan, as contemplated in Mitigation Measure 3.14-3, and
additional capacity within the City's WRRF to accommodate growth until Cal Poly's WRF
is operational. To the extent that a delay in completion of the WRF also delays completion
of new on -campus housing to defray housing, transportation, air quality, and GHG
impacts caused by increased enrollment, these would be new or substantially increased
impacts of the Master Plan that are not evaluated or disclosed in the DEIR.
Impacts to the City's Water Resource Recovery Facility (WRRF)
Table 3.14-8 summarizes projected wastewater flows under full buildout of the Master
Plan. However, the table does not include an estimate of flows occurring during the years
2015-2020. From 2015 to 2019, flows have increased from 197,557 gallons per day (gpd)
in 2015 to 274,795 gpd in 2019, an increase in the annual average 79,480 gpd. The 2007
MOU identifies Cal Poly's capacity interest as "daily dry weather flow calculated on a
monthly average of .471 million gallons daily." Cal Poly's monthly average dry weather
flow has increased from 302,595 gpd in 2015 to 384,627 gpd in 2019, an increase in
82,032 gpd. By not including the increased flows that have occurred since the year 2015,
the DEIR underestimates the total amount of wastewater that will be generated under the
Master Plan. This underestimation impacts Cal Poly's ability to rely on its proposed WRF
and the City's wastewater services to meet total Master Plan demand.
The baseline wastewater flows identified in Table 3.14-10 do not identify appropriate flows
to accurately measure impacts associated with increased wastewater generated under
the Master Plan. Table 3.14-10 identifies an "average annual flow" in 2015. However, as
described above, the 2007 MOU for wastewater treatment services uses daily dry
weather flow calculated on a monthly average, which is higher. Using Cal Poly's
wastewater flow for 2019 leaves less than an additional 100,000 gpd available for the
year 2020. If projected flow increases are correct for the year 2025 as identified in Table
3.14-10 (114,433 gpd), Cal Poly does not have sufficient capacity under the 2007 MOU
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regarding capacity interest in City facilities to support Master Plan development planned
to be online in 2025. This is a potentially significant impact that is not disclosed, evaluated,
or mitigated in the DEIR.
Given the likelihood of delays in completion, permitting, and operation of the new WRF,
it will be likely that Cal Poly will rely on increased wastewater treatment services the City
to support the Master Plan. Mitigation Measure 3.14-4a would preclude operation of new
facilities under the Master Plan until the WRF is completed or sufficient wastewater
services are available from the City. However, as stated above, based on the trend from
2015 to 2019, Cal Poly is expected to exceed existing capacity at the City's WRRF in the
year 2025 under the 2007 MOU. As a result, it is likely that new on -campus housing
projects will be delayed even though enrollment is expected to increase. This will result
in new and increased impacts to housing, transportation, air quality, and GHG that have
not been analyzed in the DEIR.
Impacts to the City's Wastewater Collection System
The DEIR acknowledges that Cal Poly's existing peak wet weather wastewater flows
exceed the 1.2 mgd limitation included in the 2007 MOU between the City and Cal Poly,
that flows exceeded the limit in the year 2015, and that even implementation of the WRF
and other conservation measures will not adequately address these exceedances.
Mitigation Measure 3.14-4b addresses this issue by requiring Cal Poly to implement inflow
and infiltration reduction projects to reduce peak wet weather flows, which the City
appreciates. However, the measure requires that the inflow and infiltration reduction
projects reduce flows to 2018/2019 levels, not to the 1.2 mgd limitation stated in the 2007
MOU which is not adequate mitigation nor consistent with its commitment to the City of
San Luis Obispo.
The DEIR does not evaluate the environmental effects of peak wet weather flows caused
by inflow and infiltration into Cal Poly's sewer pipes. These peak flows utilize capacity
reserved for future development in the City and can lead to sanitary sewer overflows in
the City's wastewater collection system. Sanitary sewer overflows are a public health risk
and can result in NPDES (National Pollutant Discharge Elimination System) Permit
violations, fines from the Central Coast Water Board, beach closures by the San Luis
Obispo County Public Health Department, Clean Water Act third party lawsuits, or a long-
term enforcement agreement referred to as a consent decree. Environmental impacts
from Cal Poly's peak wet weather flows must be disclosed and evaluated in the DEIR.
Impacts to the City's Water Treatment Plant and Water Distribution System
The Water Supply Assessment, included in DEIR Appendix H, assumes that the portion
of Cal Poly's Whale Rock supply currently used for agricultural uses will be replaced with
non -potable water from Cal Poly's proposed WRF, freeing up all of Cal Poly's Whale Rock
water for potable use to serve new residents, students, and employees on campus.
(DEIR, p. 3.14-12.) This will require the City to treat more water than it is currently treating
for Cal Poly. Although the DEIR acknowledges that the 2007 MOU provides Cal Poly up
to 1,000 AFY of water treatment services (1.44 mgd), peak day projections provided in
Table 15 exceed 1.44 mgd. This impact is not identified in Impact 3.14.1.
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Additionally, the impact analysis in section 3.14.1 references the Water Supply
Assessment which includes numerous assumptions related to the operation of the City's
water distribution system that are not identified in the 2007 MOU and were not validated
by the City prior to inclusion in the DEIR. Without a detailed review and understanding of
the modeling assumptions, the City does not agree with the conclusion under Impact
3.14.1, on page 3.14-14 that "Modeling indicates that there is adequate conveyance
capacity to accommodate anticipated development associated with the 2035 Master Plan
under average day demand, peak daily demand, and peak hourly demand." Also, due to
these assumptions, the City does not agree with the determination provided in Section
1.4 (3) that "There is adequate City potable water conveyance capacity under ADD, PDD,
PHD, and PDD + City FF for all Cal Poly flow conditions modeled.", Both Section 3.14
and Appendix H refer to a Cal Poly Utility Master Plan with an anticipated completion date
in early 2020. This document has not been made available for City review and may also
include invalid assumptions related to the operation of the City's water distribution system.
A modification to the MOU between Cal Poly and the City is needed to clarify assumptions
related to peaking factors, fire flow, storage, and conveyance capacity to determine
whether significant capital improvements are necessary to Cal Poly's or the City's water
distribution systems for buildout of the Master Plan.
Water and Wastewater Service to the Proposed Retirement Community
The DEIR does not disclose impacts associated with connecting the planned retirement
community located west of Highway 1 from the rest of campus and may rely on the City's
water distribution system for its water service (including fire flow and storage) and/or the
City's wastewater collection system. It is unclear whether any planning or environmental
analysis has been conducted to determine that water and wastewater services to these
areas is available and can be feasibly provided, or if Cal Poly is intending to rely on the
City to provide domestic water, fire flow, and water storage and treat wastewater from this
facilities. As identified in the City's General Plan, the City's wastewater collection system
is capacity constrained during peak wet weather in the service area adjacent to Cal Poly's
proposed retirement community. Average wastewater flow is estimated at 21,129 gpd in
Appendix I, Table 1, in 2030. If Cal Poly is proposing to connect to the City for wastewater
collection service, mitigation would be required to achieve an adequate, measurable
offset of wet weather wastewater flows.
"ADD" is average day demand; "PDD" is peak daily demand; "PHD' is peak hourly demand; City FF is
City fire flow.
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Office of the City Council
990 Palm Street, San Luis Obispo. GA 93401-3249
807 781 7114
'J
December 1, 2015
Jeffrey D. Armstrong
President
Office of the President
Cal Poly State University
San Luis Obispo, CA
SUBJECT: City Comments on the Cal Poly Master Plan Update
Dear President Armstrong:
Please consider the attached City comments on land use concepts under consideration for
the Cal Poly Master Plan update. The comments were endorsed by the City Council on
November 17, 2015. Final City comments are based on the "Guiding Principles for Input on
the Cal Poly Master Plan Update," which were adopted by the City Council on September
15, 2015. The "Guiding Principles" were informed by General Plan policies relevant to the
update covering topics such as: Neighborhood Wellness, Economic Health, Housing, Multi -
modal transportation, Protection of Agriculture and Open Space Resources, Diversity, and
Public Services.
On behalf of the City Council, I'd like to express our appreciation for the efforts Cal Poly has
put forth to reach out to the community and collaborate with the City of San Luis Obispo as
a key stakeholder. It is in this spirit that you will see many of the City comments include
continued and enhanced communication and collaboration between Cal Poly and the City
of San Luis Obispo.
Thank you for your consideration of the City of San Luis Obispo's comments on the Cal
Poly Master Plan Update.
Sincerely,
— Mo�o
J n Marx
ayor
City of San Luis Obispo
Attachments: City Comments on Cal Poly Master Plan Update
Guiding Principles for Input on the Cal Poly Master Plan Update
CC: San Luis Obispo City Council
Katie Lichtig, City Manager
Michael Codron, Community Development Director
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City Input on Cal Poly Master Plan Update Land Use Concepts
1) Explore implementation of programs and incentives for faculty and staff to live
within existing neighborhoods (not on campus) to stabilize neighborhoods close to
campus.
2) Master Plan policies/principles should address neighborhood compatibility in terms
of scale, density, character of development and residential neighborhoods should
be limited and only be designated for staff, faculty and family housing.
Neighborhood Sensitivity zones should also be added to the residential
neighborhood area west of Highway 1 that is adjacent to existing City
neighborhoods.
3) The Master Plan update should include recommendations of the Neighborhood
Wellness/Community Civility Report where applicable.
4) Proposed Residential Neighborhood Development should be sited and developed
in order to avoid or minimize impacts to scenic view sheds and environmental
resource impacts (riparian, creek, agriculture).
5) New development in the Poly Canyon area and on land adjacent to City Open
Space should consider regional trail connections and coordinated with City and US
Forest Service Staff.
5} Large events resulting from new facilities and expansion of existing facilities (e.g.
Arena, Agriculture Events Center, Mott Gym, Spanos Stadium, etc.) that have the
potential to affect the City transportation system should include advance notification
and coordination with City staff to minimize impacts; and any potential cumulative
impacts on the City's infrastructure, including but not limited to the transportation,
streets, and bikes systems associated with large events at those facilities should be
fully evaluated and mitigated in the Campus Master Plan Update EIR.
7) Impacts to City emergency services and Police mutual aid response should be
evaluated and mitigated since the expansion of these facilities have the potential to
result in increased calls for fire, rescue, and medical service during large events.
8) Further evaluation of the wastewater facility west of California Boulevard should
assess potential impacts on existing uses in the vicinity and consider relocation of
the facility to a location with greater separation from existing residential
neighborhoods and City boundaries.
9) Master Plan and EIR should explore the impact of growth on City services,
including but not limited to recycled water, wastewater, police, fire, and
neighborhood wellness.
1 0] Coordinate future development plans for review and cooperation in planning with
City Departments (Transportation, Police, Fire, Utilities, Natural Resources,
Planning).
11) Fiscal Impact Analysis. In order to accurately evaluate potential service impacts the
University should prepare a Fiscal Impact Analysis.
12) The final Refined Master Plan Update should consider the City's Guiding Principles
for the Master Plan Update and relevant City General Plan policies for which they
are based.
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CITY'S GUIDING PRINCIPLES FOR CAL POLY MASTER PLAN UPDATE
The following principles are not prioritized, and are each supported by a few, exemplary goals or
policy statements from the City's General Plan (see Appendix that follows).
l . Neighborhood Wellness — The Master Plan should support efforts to provide a safe and
positive living environment for all residents in City neighborhoods. The
recommendations found in the Neighborhood Wellness/Community Civility report
should be implemented wherever possible. The Master Plan should include buffers
between areas of campus activities and adjoining residential neighborhoods; protect
neighborhoods from light, noise, and glare from campus development; pull more
intensive uses to the interior of campus; and provide suitable locations for parties and
Greek life housing and activities on campus.
2. Economic Health — The Master Plan should support the economic health of the City, and
negative fiscal impacts created by Plan implementation should be mitigated by the
University. The Master Plan should support consideration of a hotellconference facility
within the City limits.
3. Housing — The Master Plan should continue to push to house all undergraduate students
on campus. In the interim, future increase in enrollment should be linked to prior
provision of on -campus housing. Programs should be included to encourage housing for
faculty and staff within existing neighborhoods (not on campus) to both stabilize
neighborhoods close to campus and encourage residents to rely on active transportation
and transit to get to and from campus..
4. Multi -Modal Transportation — The Master Plan should support City goals for modal -
split, encourage walking, cycling, and the use of transit by students and employees, and
discourage single -occupant vehicle trips from the University into the City. Programs
should support continued contribution to City transit; provision of an internal campus
shuttle system; improved hub for a transit center; and restriction of parking passes for
residents living within one (1) mile of campus.
5. Protection of Open Space and Agricultural Resources — Land planning for future
growth should take into account impacts on natural resources, preserve agricultural land
to the greatest extent feasible, and identify opportunities preserve important open space
resources while making important connections to other public open space lands adjacent
to the University. The Master Plan should include provisions for conservation easements
on open space lands.
C. Diversity — The Master Plan should support a diverse population and contribute
positively to a larger community that welcomes and respects all people.
Public Services —The Master Plan and EIR should fully explore the impact of growth on
City services: recycled water, wastewater, police, fire, and code enforcement and should
include a fiscal impact analysis for City services to ensure that future growth of the
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City Guiding Principles — Cal Poly Master Plan Update
University contributes its fair share to support city services, so that existing levels of
service to the community are not eroded as the University enrollment continues to grow.
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City Guiding Principles — Cal Poly Master Plan Update
POLICY SUPPORT FOR GUIDING PRINCIPLES
NEIGHBORHOOD WELLNESS
Land Use EIement (L UE) L UE 2.1. Neighborhood Focus. The City shall preserve, protect and
enhance the City's neighborhoods and strive to preserve and enhance their identity and promote
a higher quality of life within each neighborhood.
LUE 2.3.11. Residential Project Objectives_ Residential projects should provide:
A. Privacy, for occupants and neighbors of the project;
B. Adequate usable outdoor area, sheltered from noise and prevailing winds, and
oriented to receive light and sunshine
C. Use of natural ventilation, sunlight, and shade to make indoor and outdoor spaces
comfortable with minimum mechanical support.
D. Pleasant views from and toward the project;
E. Security and safety.
F. Bicycle facilities consistent with the City's Bicycle Plan;
G. Adequate parking and storage space;
H. Noise and visual separation from adjacent roads and commercial uses. (Barrier walls,
isolating a project, are not desirable. Noise mitigation walls may be used only when there
is no practicable alternative. Where walls are used, they should help create an attractive
pedestrian, residential setting through features such as setbacks, changes in alignment,
detail and texture, places for people to walk through them at regular intervals, and
planting.)
I. Design elements that facilitate neighborhood interaction, such as front porches, front
yards along streets, and entryways facing public walkways.
J. Buffers from hazardous materials transport routes, as recommended by the City Fire
Department.
L U 2.2. b Neighborhood Characteristics
The City shall promote livability, quiet enjoyment, and safety for all residents.
Characteristics of quality neighborhoods vary from neighborhood to neighborhood, but
often include one or more of the following characteristics:
A mix of housing type styles, density, and affordability.
Design and circulation features that create and maintain a pedestrian scale.
Nearby services and facilities including schools, parks, retail (e.g., grocery store, drug
store), restaurants and cafes, and community centers or other public facilities.
A tree canopy and well -maintained landscaping.
A sense of personal safety (e.g., low crime rate, short police and emergency response
times).
Convenient access to public transportation.
Well -maintained housing and public facilities.
L U 2. 6. S Fraternities & Sororities
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The City shall work with Cal Poly to develop a proposal to locate fraternities and
sororities on campus for consideration by the CSU Board. If locations on campus cannot
be provided, fraternities and sororities should be limited to medium -high and high -
density residential areas near the campus.
Housing Element (HE) HE 8.18 Jointly develop and implement a student housing plan and
continue to support "good neighbor programs" with Cal Poly State University, Cuesta
College and City residents. The programs should continue to improve communication
and cooperation between the City and the schools, set on- campus student housing
objectives and establish clear, effective standards for student housing in residential
neighborhoods.
ECONOMIC HEALTH
LUE San Luis Obispo should•
14. Retain existing businesses and agencies, and accommodate expansion of existing businesses,
consistent with other goals.
15. Emphasize more productive use of existing commercial buildings and land areas already
committed to urban development.
16 Provide an adequate revenue base for local government and public schools.
17. Provide high quality public services, ensuring that demands do not exceed resources and that
adequate facilities and services can be provided in pace with development.
18. Cooperate with other agencies in the county to assure that increases in the numbers of
workers and college and university students in the San Luis Obispo area do not outpace housing
availability.
24. Provide a resilient economic base, able to tolerate changes in its parls without causing
overall harm to the community.
25. Have developments bear the costs of resources and services needed to serve them, except
where the community deliberately chooses to help pay in order to achieve other community
goals.
27. Serve as the county's hub for: county and state government; education; transportation;
visitor information; entertainment, cultural, professional, medical and social services;
community organizations; retail trade.
HOUSING
L UE Goal 18. Cooperate with other agencies in the county to assure that increases in the
numbers of workers and college and university students in the San Luis Obispo area do not
outpace housing availability.
L UE 2.6.1 Cal Poly
The City shall encourage Cal Poly to build housing on campus for all of its students, to the
extent feasible. On -campus housing should be expanded at least as fast as enrollment increases.
Consideration shall be given far housingfor faculty and staff as student enrollment increases.
4
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Item 17
City Guiding Principles — Cal Poly Master Plan Update
LUE 2.6.4 Location
The City shall encourage the development of housing likely to attract faculty, staff, and students
to locate close to Cal Poly. The City shall work with Cal Poly to facilitate faculty and staff
owning or renting housing in adjacent neighborhoods.
HE 8.4 Encourage Cal Poly University to continue to develop on -campus student housing to
meet existing and future needs and to lessen pressure on City housing supply and transportation
systems.
HE 8.5 Strengthen the role of on -campus housing by encouraging Cal Poly University to
require freshmen and sophomore students to live on campus.
HE 8.6 Locate fraternities and sororities on the Cal Poly University campus. Until that is
possible, they should be located in Medium -High and High Density residential zones near the
campus.
HE 8.7 Encourage Cal Poly University to develop and maintain faculty and staff`' housing,
consistent with the General Plan.
MULTI MODAL
Circulation Element (CE) CE 1.6.1. Transportation Goals
1. Maintain accessibility and protect the environment throughout San Luis Obispo while
reducing dependence on single -occupant use of motor vehicles, with the goal of achieving
State and Federal health standards for air quality.
2. Reduce people's use of their cars by supporting and promoting alternatives such as
walking riding buses and bicycles, and using car pools.
3. Provide a system of streets that are well -maintained and safe for all forms of
transportation.
4. Widen and extend streets only when there is a demonstrated need and when the projects
will cause no significant, long-term environmental problems.
5. (Omitted)
6. Promote the safe operation of all modes of transportation.
7. Coordinate the planning of transportation with other affected agencies such as San Luis
Obispo County, Cal Trans, and Cal Poly.
8. Reduce the need for travel by private vehicle through land use strategies, telecommuting,
creative transportation demand management and compact work weeks.
9. Support the development and maintenance of a circulation system that balances the needs
of all circulation modes.
CE 7.7.1. Encourage Better Transportation Habits
Increase the use of alternative farms of transportation (as shown on Table 1) and depend less
on the single -occupant use of vehicles.
5
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Item 17
City Guiding Principles — Cal Poly Master Plan Update
L UE 2.2.3 Neighborhood Traffic
Neighborhoods should be protected from intrusive traffic. All neighborhood street and
circulation improvements should favor pedestrians, bicyclists, and local traffic. Vehicle
traffic on residential streets should be slow. To foster suitable traffic speed, street design
should include measures such as narrow lanes, landscaped parkways, traffic circles, textured
crosswalks, and, if necessary, stop signs, speed humps, bollards, and on -street parking and
sidewalks.
L UE 2.2.4 Neighborhood Connections 0-4
The City shall provide all areas with a pattern of streets, pedestrian network, and bicycle
facilities that promote neighborhood and community cohesiveness. There should be
continuous sidewalks or paths of adequate width, connecting neighborhoods with each
other and with public and commercial services and public open space to provide
continuous pedestrian paths throughout the city. Connectivity to nearby community
facilities (such as parks and schools), open space, and supporting commercial areas shall
also be enhanced, but shall not be done in a method that would increase cut -through
traffic. (See also the Circulation Element.)
PROTECTION OF OPEN SPACE AND AGRICULTURAL RESOURCES
L UE Goal 4. Protect, sustain, and where it has been degraded, enhance wildlife habitat on
land surrounding the city, at Laguna Lake, along creeks and other wetlands, and on open
hills and ridges within the city, so that diverse, native plants, fish, and animals can continue
to live within the area.
L UE Goal 6. Recognize the importance of farming to the economy of the planning area and
the county, protect agriculture from development and from incompatible uses, and protect
remaining undeveloped prime agricultural soils.
Conservation and Open Space Element (COSE) LOSE 8.1 Greenbelt. Open space outside
the urban area
Secure and maintain a healthy and attractive Greenbelt around the urban area, comprised of
diverse and connected natural habitats, and productive agricultural land that reflects the
Citys watershed and topographic boundaries.
COSE 8.2.1 Open space preserved.
Packet Page 280
Item 17
City Guiding Principles --- Cal Poly Master Plan Update
The City will preserve as open space or agriculture the undeveloped and agricultural land
outside the urban reserve line, including the designated Greenbelt as shown in Figure 5, and
will encourage individuals, organizations and other agencies to do likewise.
DIVERSITY
HE Goal 4. Preserve and accommodate existing and new mixed -income neighborhoods and seek
to prevent neighborhoods or housing types that are segregated by economic status.
LUE Goal Society and Economy. San Luis Obispo should be a well balanced community.
Environmental, social, and economic factors must be taken into account in important decisions
about San Luis Obispo's future. A healthy economy depends on a healthy environment. The
social fabric of the community for both residents and visitors must also be part oj'that balance.
LUE Goal San Luis Obispo should.
23. Enrich community cultural and social
backgrounds, talents, occupations, and interests.
PUBLIC SERVICES
life by accommodating people with various
LUE Goal 17. Provide high quality public services, ensuring that demands do not exceed
resources and that adequate facilities and services can be provided in pace with development.
LUE Goal 25. Have developments hear the costs of resources and services needed to serve them,
except where the community deliberately chooses to help pay in order to achieve other
community goals.
LUE Goal 42. San Luis Obispo should. Be a safe place to live.
Water and Wastewater Element (WWE) WWE B2.2.3 Wastewater Service for New
Development
New development shall pay its proportionate or `fair share" of expanded treatment and
collection system capacity and upgrades. New development will only be permitted if adequate
capacity is available within the wastewater collection system and/or Water Reclamation Facility.
Safety Element (SE) SE 3.0 Adequate Fire Service
Development shall be approved only when adequate fire suppression services and facilities are
available or will be made available concurrent with development, considering the setting, type,
intensity, and form of the proposed development.
T
Packet Page 281
Item 17
t Office of the City Manager
990 Palm Street, San Luis Obispo, CA 93401-3249
805.781 7114
sluL.iiy ui g
September 11, 2017
Dr. Jeffrey D. Armstrong
President, California Polytechnic State University
Administration Building
San Luis Obispo, CA 93407
Dear Dr. Armstrong,
I am writing to provide you with the City of San Luis Obispo's assessment of the impacts associated
with the increased enrollment expected on campus for Fall 2017. On August 15, 2017, Keith
Humphrey presented the specifics to our City Council, indicating that 1,000-1,200 additional students
are expected to be enrolled in classes this Fall.
During his presentation, Keith was very clear that this was a surprise. In fact, the University has
consistently messaged to City leaders and the community that enrollment would be kept at a "steady
state" until a variety of changes occurred on campus, including increased housing to accommodate
any increase to the student body.
The news that enrollment would not be held at a steady state — and would actually increase by a
significant percentage — is not welcome because increased enrollment will increase the cost of
services provided by the City to the campus and community and these costs have not been planned
for or budgeted.
The City and Cal Poly have a mutually beneficial relationship and a variety of partnerships and
agreements that benefit both City residents and the campus. These include law enforcement,
emergency response, water and sewer service, transit service, neighborhood wellness initiatives,
and information technology infrastructure. Both the City and the University embrace sustainability as
a guiding principle for future decision -making.
Given our close relationship and the goal of moving forward to a productive and sustainable future
together, we are hopeful that the University will give careful consideration to the following
assessment of impacts and the associated request for resources to mitigate the impacts that the City
expects to realize with increased enrollment.
In some cases, our agreements are somewhat formulaic (water and sewer service) and the
increased enrollment can be translated into a direct cost in line with existing methodology. In the
case of transit, impacts are anticipated that go beyond the scope of our existing agreements, but.
those costs can be fairly easily predicted based on our extensive experience serving campus based
on our review of empirical data. With respect to law enforcement, emergency response, and code
enforcement, the City has identified the impacts expected from the increased enrollment and has
identified ways that these impacts can be mitigated through the assignment of additional resources,
the costs of which should be borne by Cal Poly.
Packet Page 282
2017-18 Enrollment Impacts
lterrbage 2
Emergency Response (Fire and Medical Services)
The Fire Department has invested significantly in partnering with the University to improve decision
making of incoming students with a goal of increasing student safety by decreasing overconsumption
of alcohol, thus decreasing the need for emergency medical services. Alcohol -influenced decision
making is a primary factor in calls for service related to the University student population.
The Fire Department routinely tracks all emergency medical responses based on location and patient
demographics, including all calls to the University campus and all calls involving University students.
On a daily basis beginning during the Week of Welcome (WOW), the Fire Chief and his staff will
evaluate system -wide emergency response coverage related to University impacts. If the increase
in enrollment is attributed to an anomalous increase in fire and/or medical calls for service, the Fire
Department will need to increase staffing to ensure the availability of sufficient resources to serve
the campus and the City.
If this is the case, the most likely scenario would result in putting into service a two -person medical
response unit to address emergency call volume trends. The cost for this increased service
(equipment and personnel) is $112 per hour. If, for example, this staffing adjustment was necessary
for 12-hour periods on Thursday, Friday, and Saturday, the weekly cost of this scenario will be
$4,032. The authority to exercise staffing adjustments resides with the Fire Chief, who will consult
with the University Police Chief prior to implementing any planned staffing increases. The length of
this enhanced staffing model would also be based on emergency response trends related to
providing service to the University.
Law Enforcement
In consideration of the projected increase of 1,000 to 1,200 students for the 2017/18 Cal Poly school
year, the San Luis Obispo Police Department believes there will be increases in certain student
related call types. Call types that significantly involve students are alcohol related, noise, DUI and
parking/abandoned vehicles.
Noise, nuisance and alcohol:
Considering the majority of the student population increase is within the freshman class, we
anticipate there will be a significant impact on neighborhood wellness. This will include students
attending house parties, under -aged drinking, open containers and added foot traffic within the
neighborhoods that also leads to nuisance related activity.
Some of the anticipated impacts can be handled by our SNAP (Student Neighborhood Assistant
Program) employees. SNAP employees are current Cuesta and Cal Poly students. SLOPD believes
an increase of 2 SNAP employees, for 36 weeks, each at 20 hours per week, would address these
impacts. At the current salary rate for SNAP employees ($12.96) this would be an added cost of
$18,662 a year to SLOPD's budget.
This will not address any increases in criminal activity, property crime, or second response/long term
noise impacts that cannot be addressed by SNAP. However, SLOPD and UPD are currently in an
MOU that allows UPD to enforce municipal code violations within a 1-mile radius of the Cal Poly
campus. This MOU was established to help address neighborhood wellness issues involving
Packet Page 283
2017-18 Enrollment Impacts Ite Page 3
students within the neighborhoods surrounding Cal Poly, and can now be utilized to further address
the impacts associated with increased enrollment.
In order to further address anticipated impacts, SLOPD is asking that Cal Poly PD increase staffing
on San Luis Obispo's busiest days and times. The additional staffing would be assigned to the
neighborhoods surrounding Cal Poly to help enforce municipal code violations related to the potential
increased in student related violations. Our busiest days while Cal Poly is in session is Thursday
night to early Sunday morning between 8:00 p.m. and 2:00 a.m.
SLOPD will be tracking student related (CP, Cuesta and other) calls for service during the 2017/18
school year. Currently there is no definitive data to project the impacts related to the increase in the
student population. SLOPD will evaluate the statistical impacts throughout the year to further
determine the impacts related to the increased number of students added in the 2017/18 school
year.
Parking
Cal Poly has implemented a policy, which does not allow incoming freshman to park their vehicles
on campus. It is our belief there will still be a percentage who bring their vehicles to San Luis Obispo
and potentially park in neighborhoods. If only 15% bring a vehicle to San Luis Obispo, there will be
an additional 150 vehicles on SLO streets without a corresponding residence. Many of the
neighborhoods surrounding Cal Poly have parking restrictions that will require stepped up
enforcement to reduce negative impacts. With limited parking near campus, many will have to park
their vehicle further away from campus and may legally park their vehicles for no more than 72 hours
in one location. This will likely create an increase in the number of calls regarding abandoned
vehicles in addition to additional calls for vehicles violating other parking regulations. Vehicles
reported as abandoned must be marked and tagged with a 72-hour notice and rechecked at the
conclusion of the 72-hour period. The additional staff costs for increased enforcement and monitoring
are calculated at $10,130 during the school year, based on hourly rates for enforcement staff that
would be assigned the work.
Transit
As a direct result of increased enrollment and the prohibition of Freshman bringing cars on campus,
additional and unbudgeted transit services will need to be deployed to meet increased passenger
loads and maintain the reliable service area residents depend on. Based on prior years'
assessments (e.g. Closure of Grand Ave Parking Lot, Farmers Market nights, extra late evening
service and associated fuel expenses, etc.), no less than $26,000 in unbudgeted services would
need to be deployed. This value is directly tied to additional services SLO Transit has provided for
the direct benefit of the University and does not account for the loss in revenues from the riding
General Public who complained of "being crowded out" of public transit by the increased transit use
by students, faculty, and staff.
• Additional Tripper Service - $14,000
• Additional Farmers Market Service - $5000
• Additional Late Evening Service - $5000
• Associated Fuel - $2,000
Packet Page 284
2017-18 Enrollment Impacts
Iten�aJ74
Neighborhood Services and Code Enforcement
The Community Development Department is active in the neighborhoods around campus performing
pro -active code enforcement to implement the City's Neighborhood Enhancement Ordinance. In
addition, traditional code enforcement addresses complaints related to construction without permits,
such as garage conversions. The area around the Cal Poly campus experiences a greater incidence
of activities that require code enforcement resources than other neighborhoods in the City. Increased
enrollment is expected to exasperate this effect, particularly until the new dorms open in Fall 2018,
which may temporarily reduce this pressure.
Over the past few years, progress has been made in the area of neighborhood wellness. The
neighborhoods around Cal Poly campus have been closely monitored by City Code Enforcement
Technicians who routinely make contact with residents. New regulations regarding property
maintenance, storage of refuse containers, outdoor furniture, and maintenance of weeds/lawns has
had a beneficial impact and raised expectations for all City residents. For students living in
neighborhoods - often living alone for the first time - this program has had a demonstrably positive
impact. The improvements have been noted during recent neighborhood walk-abouts with Cal Poly
and City officials.
A Code Enforcement Technician I position that normally helps patrol the neighborhoods is currently
filled by a contract employee. That contract is set to expire on November 29, 2017, which would
leave one technician to patrol all property within the city limits. If this resource is eliminated during a
time of increased enrollment, much progress in the area of neighborhood wellness around campus
could be lost.
As a result, the City is requesting that Cal Poly fund the contract of a Code Enforcement Technician
I between November 29, 2017 and June 27, 2018 at a cost of $37,500. Maintaining this resource
during a time of increased enrollment will help maintain neighborhood wellness prior to the availability
of new on -campus housing.
Summary of Impacts
The following table summarizes the costs associated with increased services required by over -
enrollment that the City would expect to realize. The total dollar value the City is requesting to
address the impacts of increased enrollment is $92,292 during the 2017-18 academic year.
In addition, as previously discussed in this letter, if the increase in enrollment is attributed to an
anomalous increase in fire and/or medical calls for service, the Fire Department will need to increase
staffing to ensure the availability of sufficient resources to serve the campus and the City. The costs
associated with this additional resource would be $4,032 per week.
Finally, in order to further address anticipated impacts, SLOPD is asking that Cal Poly PD increase
staffing on San Luis Obispo's busiest days and times. The additional staffing would be assigned to
the neighborhoods surrounding Cal Poly to help enforce municipal code violations related to the
potential increased in student related violations. Our busiest days while Cal Poly is in session is
Thursday night to early Sunday morning between 8:00 p.m. and 2:00 a.m.
Packet Page 285
2017-18 Enrollment Impacts
lten�a17 5
It is our request that Cal Poly evaluate this information carefully and agree to cover the costs
identified to ensure that the services provided by the City may be continued in a manner that does
not impact the quality of life on campus or within the City.
Service Area
Scope of Additional Service
Cost Estimate
Emergency Response
Two -Person Medical Response, 36-
$4,032/week if
Hour total, Thursday -Sunday
warranted by calls for
service
Law Enforcement
UPD up -staff Thursday PM to early
(Cal Poly cost)
Sunday AM
Known Direct Costs to City
Law Enforcement
Two additional SNAP employees, 20-
$18,662
hours/week for 36 weeks
Parking Services
Stepped up parking enforcement in
$10,130
neighborhoods
Transit Service
Additional services to meet demand
$26,000
Neighborhood Wellness
One Code Enforcement Technician 1
$37,500
11 /30/17-6/27/18
TOTAL 2017-18
$92,292
Thank you for your attention to this important matter, and to ongoing collaborations between campus
and city leadership that help ensure and maintain a high level of service for residents and community
members on and off campus.
Sincerely,
Ka ie Lichtig
City Manager
Cc: Cynthia Vizcaino Villa, Vice President for Administration and Finance
Dr. Keith Humphrey, Vice President for Student Affairs
Jessica Darin, President's Office Chief of Staff
Mayor and City Council
Derek Johnson, Assistant City Manager
Michael Codron, Community Development Director
Deanna Cantrell, Police Chief
Garret Olson, Fire Chief
Daryl Grigsby, Public Works Director
Packet Page 286
Item 17
RESOLUTION NO. 10676 (2015 Series)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, PROVIDING CITY INPUT TO CAL POLY FOR
CONSIDERATION IN THEIR MASTER PLAN UPDATE PROCESS
(GENP-2088-2015)
WHEREAS, the City Council of the City of San Luis Obispo has established Guiding
Principles based on General Plan Policies which the Planning Commission has used as a basis to
provide recommendations on the Cal Poly Master Plan; and,
WHEREAS, the Planning Commission of the City of San Luis Obispo conducted a
public meeting in the Council Chamber of City Hall, 990 Palm Street, San Luis Obispo,
California, on October 28, 2015, for the purpose of reviewing draft land use concepts under
consideration by Cal Poly for the Campus Master Plan Update and provide recommendations to
the Council based on Guiding Principles supported by General Plan policy; and
WHEREAS, the City Council of the City of San Luis Obispo conducted a public
meeting in the Council Chamber of City Hall, 990 Palm Street, San Luis Obispo, California, on
November 17, 2015, for the purpose of considering Planning Commission recommended input
on land use concepts being considered for final inclusion in the Cal Poly Master Plan Update;
and
WHEREAS, the City Council has duly considered all evidence, including the testimony
of the public and interested parties, recommendations of the Planning Commission, the
evaluation and recommendations by staff, and refined land use concepts provided by Cal Poly,
and presented at said hearing.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis
Obispo as follows:
SECTION 1. Based upon all the evidence, the Council makes the following findings:
1. City comments to Cal Poly are based on City Land Use Element Policy for
Neighborhood Wellness goals to preserve and enhance the quality of life within
each neighborhood (LUE 2.1 Neighborhood Focus, LUE 2.3.11 Residential
Project Objectives) and provide high quality public services ensuring that
demands do not exceed resources (LUE Goal #17).
2. City comments to Cal Poly are consistent with Land Use and Housing Element
policies to facilitate faculty and staff housing in neighborhoods adjacent to Cal
Poly and to locate fraternities and sororities on the Cal Poly campus (LUE 2.6.4 &
HE 8.4 through 8.7).
Packet Page 287
Resolution No. 10676 (2015 Series)
Item 17
Page 2
3. City comments to Cal Poly are consistent with Circulation Element Policy to
coordinate planning of Transportation with other affected agencies such as Cal
Poly and support the development of a circulation system that balances the needs
of all circulation modes (CE 1.6.1).
4. City comments to Cal Poly are consistent with Land Use Element Goals and
Conservation and Open Space Element Policy to preserve protect scenic vistas,
preserve agricultural land, and enhance wildlife habitat on land surrounding the
City. (LUE Goals 4 & 6 and COSE 8.1).
5. City comments to Cal Poly consistent with Safety Element policy to ensure
adequate fire services are available concurrent with development (SE 3.0) and
Wastewater Element policy and new development pay its proportionate "fair
share" of expanded collection system capacity and upgrades.
SECTION 2. Environmental. City of San Luis Obispo input on land use concepts under
consideration by Cal Poly (agency with jurisdiction) for further development in the Master flan
update process is not an action which is subject to CEQA.
SECTION 3. Recommendation. The City Council of San Luis Obispo does hereby
approve the following input to Cal Poly for consideration in their Master Plan update process:
1) Explore implementation of programs and incentives for faculty and staff to live
within existing neighborhoods (not on campus) to stabilize neighborhoods close
to campus.
2) Master Plan policieslprinciples should address neighborhood compatibility in
terms of scale, density, character of development and residential neighborhoods
should be limited and only be designated far staff, faculty and family housing.
Neighborhood Sensitivity zones should also be added to the residential
neighborhood area west of Highway I that is adjacent to existing City
neighborhoods_
3) The Master Plan update should include recommendations of the Neighborhood
Wellness/Community Civility Report where applicable.
4) Proposed Residential Neighborhood Development should be sited and developed
in order to avoid or minimize impacts to scenic view sheds and environmental
resource impacts (riparian, creek, agriculture).
5) New development in the Poly Canyon area and on land adjacent to City Open
Space should consider regional trail connections and coordinated with City and
US Forest Service Staff.
R 10676
Packet Page 288
Resolution No. 10676 (2015 Series)
Item 17
Page 3
6) Large events resulting from new facilities and expansion of existing facilities (e.g.
Arena, Agriculture Events Center, Mott Gym, Spanos Stadium, etc.) that have the
potential to affect the City transportation system should include advance
notification and coordination with City staff to minimize impacts; and any
potential cumulative impacts on the City's infrastructure, including but not
limited to the transportation, streets, and bikes systems associated with large
events at those facilities should be fully evaluated and mitigated in the Campus
Master Plan Update EIR.
7) Impacts to City emergency services and Police mutual aid response should be
evaluated and mitigated since the expansion of these facilities have the potential
to result in increased calls for fire, rescue, and medical service during large
events.
8) Further evaluation of the wastewater facility west of California Boulevard should
assess potential impacts on existing uses in the vicinity and consider relocation of
the facility to a location with greater separation from existing residential
neighborhoods and City boundaries.
9) Master Plan and EIR should explore the impact of growth on City services,
including but not limited to recycled water, wastewater, police, fire, and
neighborhood wellness_
10) Coordinate future development plans for review and cooperation in planning with
City Departments (Transportation, Police, Fire, Utilities, Natural Resources,
Planning).
11) Fiscal Impact Analysis. In order to accurately evaluate potential service impacts
the University should prepare a Fiscal Impact Analysis.
12) The final Refined Master Plan Update should consider the City s Guiding
Principles for the Master Plan Update and relevant City General Plan policies
for which they are based.
Upon motion of Council Member Carpenter, seconded by Council Member Christianson,
and on the following roll call vote:
AYES: Council Members Carpenter, Christianson, and Rivoire, and Mayor Marx
NOES: Vice Mayor Ashbaugh
ABSENT:
R 10676
Packet Page 289
Resolution No. 10676 (2015 Series)
Item 17
Page 4
The foregoing resolution was adopted this 17`h day of November 2015.
rZI, 1��
Ma or Ja Marx
ATTEST:
Jon solabehere
[nt City Clerk
APPROVED AS TO FORM:
f rhristine Di
City Attorney
IN WITNESS WHEREOF, 1 have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, this tj day of Ft 1
A-so[abehere
m City Clerk
R 10676
Packet Page 290
CAL POLY
CAMPUS iMASTER PLAN
inlUNE 2 019
Memorandum of Understanding
(MOU) with Cal Poly Regarding
Implementation of Mitigation
Measures Identified in the Cal
Poly Master Plan
Environmental Impact Report
(EIR)
March 17, 2020
Recommendation
Authorize the City Manager to execute the proposed
MOU with Cal Poly and direct staff to continue to
engage in the Cal Poly Master Plan process to
ensure that impacts on City services and
infrastructure associated with build -out of the Master
Plan are properly identified and mitigated. (MOU —
Attachment A, packet page 239)
Cal Poly Master Plan
TABLE T1.1: CAL POLY POPULATION, HOUSING, AND FACILITY CAPACITY
Baseline
Master
Net
Fall 2015
Plan 2035
Change
Student Headcount
20,944
25,000
4,056
Faculty
1,166
1,522
356
Staff and Administrators*
1.982
2.413
4311
Total Campus Population
24,092
28,935
4,843
Student Housing (beds)
6,239
New beds In yak'XtyLtyu and minor ad]ustments to
1.519
Inventory
Revised Baseline (2018)**
7,758*
14,958
7,200
�500
Master Plan Instructional Capacity
17,500
5,000
(Full time Equivalent Students or net FTES)
'includes ASI and Caf Poly Corporation
FIGURE F1-2 EXISTING AND PROPOSED DEVELOPMENT
a
LIrT rrr .� •
i a
' ♦ _ ash i., Ct*' e... . , a _ 0-
At .
IN«Ni7�M► -[tom .r/
\ l
- Purposed &,ildngs OG >� J�
Draft EIR
Key Issue Areas
■ Water and Wastewater
■ Transportation
■ Housing and Population
■ Public safety
■ Public Facilities Including Parks
and Rec
❑raft Environmental Impact Report fort he
2035 Master Plan
CAL POLY
0—.ber 2019
Purpose of MOU
• Shared understanding of areas of cooperation
• Framework for future agreements and collaboration
• Formal acknowledgement of future efforts —
nonbinding
Mitigation Measure collaboration includes issue areas
focused on Water, Wastewater, and Transportation
MOU also includes Housing and Population
Water and Wastewater
Impact 3.14-3: Have Insufficient Water Supplies available to Serve the Project and
Reasonably Foreseeable Future Development during Normal. Dry and Multiple Dry Years
Development of the 2035 Master Plan would result in increased population levels and development of new buildings,
which would increase demand for water supply Campus water demand would be reduced through conservation
measures, transfer of water supply service from Cal Poly to the City, and a new non -potable source would be provided
through the development of the WRF. Under the 203S Master Plan, adequate water supplies would be available to meet
future demands if the first phase of the WRF is operational in 2022 and the second phase is operational in 2028.
Without the availability of reclaimed water from the WRF, there would not be adequate supplies beginning in 2025.
Because the design, timing, and other details of the WRF are not yet established, it cannot be determined with certainty
that water supplies would be available to meet increased demand from implementation of the 2035 Master Plan_ Thus,
the impact on water supply would be significant
Source: Master Plan Draft EIR Page 3.14-16
Impact 3.14-4: Result in Inadequate Wastewater Treatment Capacity
Under the 2035 Master Plan, Cal Poly development and operation of proposed buildings and increased campus
population levels would increase wastewater flows. Several conservation actions would reduce wastewater
generation, such as replacing toilets, urinals, faucets, and showerheads with low -flow alternatives. Cal Poly plans to
construct an on -campus WRF in two phases, each of which would have a treatment capacity of 190 afy (169,621 gpd),
for a total capacity of 380 afy (339,242 gpd). Phases 1 and 2 are expected to be operational in 2022 and 2028,
respectively. While general timing of WRF construction and operation are planned, specific timing and other details
are yet unknown. Planned water conservation actions would not be sufficient in and of themselves to reduce
wastewater generation such that capacity of the City's wastewater conveyance system could accommodate 2035
Master Plan development. Because the timing of adequate wastewater capacity is unknown and development of new
campus buildings and facilities could exceed available wastewater treatment capacity, the impact would be
potentially significant.
Source: Master Plan Draft EIR Page 3.14-19
Water and Wastewater — Mitigation Support
■ Confirm operational resiliency of Cal Poly's water supply
■ CP to obtain additional non potable water supply and wastewater capacity
■ Agreement on fair share towards upgrades of City water treatment plant and
distribution
■ Agreement for fair share towards WRRF and wastewater collection system
■ CP to inform City of progress towards reducing Inflow and Infiltration (I&I)
■ Annual meetings — facility upgrades, fair share contributions, I&I reduction, smart
meter installation, etc.
Transportation
Impact 3.13-1: Result in Vehicle Miles Traveled That Exceed Regional Vehicle Miles
Traveled Targets
Impact 3.13-2: Conflict with a Program, Plan, Ordinance, or Policy Addressing Circulation
and Transit
Impact 3.13-3: Conflict with a Program, Plan, Ordinance, or Policy Addressing Bicycte Facilities
Impact 3.13-4: Conflict with a Program, Plan, Ordinance, or Policy Addressing
Pedestrian Facilities
Transportation — Mitigation Support
■ Inform and consult City and stakeholder agencies on TDM programs
■ Scale and optimize transit services based on population and utilization
■ Consolidate and/or coordinate active transportation projects
■ Collaborate on initiatives to improve mobility safety off campus
■ Develop procedures for determining Cal Poly fair share towards
infrastructure
■ Annual meetings to address transportation planning:
- TDM evaluation
- potential enhancement projects
- trip monitoring and VMT reduction evaluation
- transit enhancements
- programs and projects to enhance active transportation and mobility
safety
Housing and Population
25,000
20,000
15, 000
10,000
5,000
0
Cal Poly Enrollment and Housing
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� Cal Poly Total Enrollment
� Cal Poly Students Living an Campus
- Perce nt of Cal Poly Students Living On Campus
40°/d
35%
30D/
2 5%
20%
15%
10°1
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Source: Cal Poly University Housing
Housing and Population — Terms proposed
■ Continued active work to construct the next student housing project
which provides 1600-2000 new student beds.
■ Cal Poly to regularly inform the City of progress towards construction of
on campus housing and provide information on capital projects,
occupancy rates, and enrollment targets.
■ Partnership meetings to address issues related to University and City
growth and best accomplish transportation, public service and resource
planning.
Other Draft E I R Issue Areas
■ Air Quality, Energy Consumption and Greenhouse Gas Emissions
(GHG)
■ Biological Resources
■ Hydrology and Water Quality
■ Noise
■ Public Services
Environmental Review
CEQA does not apply to the action since the MOU is not a "project" under
CEQA (CEQA Section 15378)
Recommendation
Authorize the City Manager to execute the proposed
MOU with Cal Poly and direct staff to continue to
engage in the Cal Poly Master Plan process to
ensure that impacts on City services and
infrastructure associated with build -out of the Master
Plan are properly identified and mitigated. (MOU —
Attachment A, packet page 239)