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HomeMy WebLinkAbout08/05/1991, 1 - GENERAL PLAN UPDATE Issue: Traffic and Circulation Description A 1989 public opinion survey of city residents identified "traffic" as a major planning issue. High traffic levels can increase noise and reduce pedestrian and bicycle safety, cause congestion and travel delays, and increase air pollution. Increases in traffic also signal a change in the small-town or rural character of an area. Higher traffic levels can change community character even if roads are added or widened to allow free flow of the higher traffic volumes. Traffic increases are caused by: - More people and businesses in the city and county; - More trips due to each person or businesses, whether existing or new; - More trips due to people and businesses located outside the area, but passing through it to get to some other area. The Land Use Element defines the desired type, amount, and location of development, so it will have a substantial affect on traffic levels. Early in 1990, the city's transportation consultant identified the relative traffic impacts of three alternative land use approaches: - Maximum growth, which entails a 40 percent increase in dwellings and a 166 percent increase in non-residential floor area. The airport area would develop consistent with the "Airport Area Concept Plan;" the Dalidio area would develop as outlined in a privately proposed specific plan; the proposed Obispo Del Sur project would be carried out; and a business park proposed for the Froom Ranch would develop. Closer capacities, which aims for a closer balance between residential and non- residential capacities at buildout, by scaling back commercial and industrial development and making more land available for housing. Limited growth, which reduces both residential and nonresidential capacities in comparison with other alternatives, mainly by minimizing expansion of the city. Table 1 shows, for these three alternatives, the relative growth of trips having both origin and destination inside the city. Under all three alternatives, such traffic levels would significantly increase, though there is a substantial range in the amount of increase due to differing amounts of development. The trip volume of alternatives not specifically evaluated, such as airport area development consistent with the concept plan, but no Obispo del Sur or Froom Ranch projects, would fall between the closer-capacities and maximum-development alternatives. /-3 r Table 1 Comparison of Existing and Build-out Trip Generation Existing Maximum Closer Limited (1990) Development Capacities Development Total "Internal" trips 534,300 973,700 765,700 732,200 Percentage Increase — 82% 43% 37% Source: DKS Associates (June 1990) Trips having origins or destinations outside the city, plus pass-through trips, total about 125,000 in 1990 and about 202,000 at build-out under the Planning Commission's recommended land use approach (a 62 percent increase); the number of such "external" trips would vary due to different amounts of growth in other parts of the county and state, and somewhat with the city's growth alternatives. There would be relatively more external trips with the maximum development alternative, due to commuting. Pass- through trips, estimated to be about 40 percent of all "external trips" in 1990 and more in the future, would not differ due to city growth choices. Vehicle trip generation may be reduced by using alternative forms of transportation. Programs favoring such means as bicycles, transit, walking, and ride sharing, can be expanded to offset some of the growth in traffic levels. The draft Circulation Element under consideration by the Planning Commission addresses the issue of promoting alternative forms of transportation. Also, the draft 1991 Clean Air Plan prepared by the Air Pollution Control District recommends a county-wide trip reduction program focusing on reducing employment trips. The ability of local agencies to achieve a significant shift away from single-occupant trips in cars is largely unknown. However, even with optimistic projections of success for alternative transportation programs, increased population and business within the range under consideration will cause significant traffic increases. Growth in other parts of the county will affect city traffic levels; such growth is accounted for in traffic forecasts made by DKS Associates as part of the analysis of the city's street network. The consultants assumed that traffic on corridors connecting San Luis Obispo to other parts of the county would increase at the same rate as population increases in other parts of the county. An analysis of population and traffic growth over the past ten years shows that traffic from the north county has increased at a rate similar to population growth there. However, traffic on Highway 1 has increased at 2.5 times the rate of population increase in the north coast area, indicating a large contribution from traffic due to tourism or other factors. If this trend continues in the future, traffic on Highway 1 and Santa Rosa Street north of Highway 101 may increase more than estimated by DKS Associates. As part of the analysis of the land use and circulation elements, the EIR consultant will be asked to evaluate the effects of alternative regional traffic assumptions. 9 /.Y Traffic to and from the south county uses Highway 101 and Highway 227. Currently, most traffic uses Highway 101. However, traffic levels on Highway 227 have been increasing. As the capacity of Highway 101 is reached and peak-hour travel is delayed, a greater percentage of south county traffic will use Price Canyon Road and Broad Street (Highway 227). This pattern will be reinforced if the airport industrial area becomes a more significant destination and significant growth occurs east of Pismo Beach and Arroyo Grande. Growth elsewhere in county areas will tend to focus traffic on corridors that connect with job centers: Santa Rosa Street (Highway 1), Broad Street (Highway 227), Highway 101, and Los Osos Valley Road. Growth within the city is expected to have more dispersed traffic impacts throughout the community. Planning Commission recommendation The Planning Commission's recommended Land Use Element proposes overall development levels that are greater than the "Limited Growth" alternative but less than the "Closer Capacities" alternative. Therefore, the traffic growth associated with the Planning Commission's recommended Land Use Element lies between these two alternatives — somewhere between a 37% and 43% increase in trip ends, assuming trip generation rates about the same or slightly lower than currently occur. The Planning Commission recommended "rural industrial" development levels in the airport area in part to hold down traffic increases associated with that area's development. The commission's recommended Circulation Element, including trip reduction measures and street projects, will be presented soon. Environmental and economic questions Council and staff have not previously identified questions. The EIR for the land use and circulation elements will evaluate broad land-use alternatives for their relative traffic impacts. If the City Council wants specific alternatives to be tested, they should be identified now. The EIR will evaluate the impacts of projected traffic levels on neighborhoods, and on congestion levels in the downtown and along arterial streets. The ability of proposed Circulation Element projects and programs to mitigate these impacts will be evaluated and additional mitigation measures will be suggested, as necessary and appropriate. Future traffic growth will require expenditures for new roads, expanded transit service, bicycle programs and pedestrian facilities. New development can be required to pay for the capital costs of new facilities needed to serve it, but not more. The Public Works Department and consultants are preparing a program for City Council consideration, 3 /-S which would generate additional revenue for transportation programs, including streets, transit, and bicycle and pedestrian facilities. The County Air Pollution Control District (APCD) is proposing a county-wide trip reduction program. The cost of implementing the program would be born mostly by employers and employees, while administration costs would be born by APCD. Question for staff guidance Which one or combination of the following efforts should the city emphasize to deal with increasing automobile traffic? A. Slowing or preventing growth; B. Diverting travel demands to other modes: rail, regional and local busses or trolleys, walking, bicycles, car pooling; C. Street changes: widening, adding/changing signals; one-way streets; eliminating curbside parking. gmD:TRAFMr_WP Issue: Air quality & Clean Air Plan Description San Luis Obispo' s relatively clean air, highly valued by residents and visitors, is threatened by increasing population and activities which generate air pollution. The key question which the city faces in this: will our air be adequately protected by proposed measures which control pollution from each source, our should we limit the growth of sources below what has been projected for our area? There is also a dilemma: if other communities in the air basin accommodate growth displaced by San Luis Obispo, especially housing for those who work in the city, air pollution will not be minimized, and may be worse. As required by state law, the Air Pollution Control District (APCD) has prepared a Clean Air Plan ("CAP" --June 1991 draft) for the county. The Clean Air Plan aims to reduce emissions of reactive organic gasses and oxides of nitrogen so that ozone, a primary component of smog, can be brought within limits to protect health and welfare, which are now exceeded. The plan tries to achieve the. necessary reductions while the county as a whole grows as projected by the state. As shown in Figure 1 , the measures contained in the draft plan are not expected to achieve the required reductions for reactive organic gasses, which would exceed the state ' s mandated levels by about 25 percent in the year 2010. The reductions for oxides of nitrogen would fall within the limits. According to Figure 1, assuming that the recommended control measures and vehicle emission standards set by the state will be effective, future emissions for both pollutant categories will be lower in the future, even with projected growth. However, countywide data from 1982 through 1989 show upward trends in air pollution which will be hard to reverse (Figure 2 , attached) . The Clean Air Plan includes recommendations for land use and circulation (Appendix E) . Several features of the city' s draft update anticipated and reinforce the recommended measures: - Maintaining a compact community inside the urban reserve line, with open .space around it; - Allowing residential and commercial development that are relatively dense compared to other communities in the county, and close to each other; - Encouraging an intensely developed, mixed-use core area which is served by local and regional transit; - Trying to improve the job/housing balance. 1 l- 7 Planning Commission recommendation In addition to the broad land-use strategies noted above, the commission's recommended draft includes a section (policy 1. 15) on air quality calling for: - Consultation with the APCD on all significant development; - Adoption of an updated, countywide air quality plan; - Use of a model to evaluate air quality impacts of adopted plans and proposed amendments; - Reduction of general-plan development capacities throughout the county if measures to control air pollution at each source prove to be inadequate to offset growth; - Various transportation measures; - A mitigation fee for new development. Alternatives to commission recommendation It is difficult to identify distinct alternatives to the commission' s overall recommendation since any approach will involve whatever Clean Air Plan is adopted by the county, which in turn will call for action by the city. The basic choice, which the city cannot make by itself, is how heavily we should rely on each of the two components to protecting air quality: (a) controlling overall growth of pollution sources and (b) controlling the production of pollution from each source through such means as location, transportation modes, and alternative fuels, materials, and emission-control hardware. For any given controls at the source, more people and economic activity will result in more air pollution. On the other hand, proposed source controls may allow the area to accommodate projected growth without significant harm to air quality. Environmental and economic questions Staff believes the basic questions have been answered by the draft Clean Air Plan or will be answered in the general plan update EIR (scope to be reviewed by the council August 6) . The council should identify any additional specific information needed to give direction on the Land Use Element update. gmD:AIRQ-CC.WP 2 Q -U FIGURE 1 FORECAST EMISSIONS COUNTYWIDE REACTIVE ORGANIC GASSES (ROG) ss so _......_.. ........__............. ........................._...___..........._...._. _._...... . ... ................. Tzs ........ .........._...................... ...... __...... . 0 n s 20 P e ........................................... ........ D ..................................................................... .......... . ............. 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EOC O �. ❑ coo � �cdrhcccl = O y. U Qr C Cd td 'O (y oD �. V U C: y T c � af� of IVU Z, o E .y c O Cd cdU ` � � O O •G CdU ¢ ¢ U 'a G O aux C4 nm. 0; u0 v , ww UUUUUW ;14 a. N d h L. d O C O Cd L c� CL, 1 1 0 IL)&C v p, C Cd H w o � U � C � O a c toa tu r. y X OD 7 7 �n CS 3 � O ON ['- \OOO\ I'd" 00 C p\ V1 4 w O\ O 00 O O\ \D M O\ O\ 0j CT C \0 \0 N Ln O .r O I�r M I", O\ �•. ..� 00 C r`00\OttOVj00r N t— p\ f3. c7t7NO\ \pN � \o , vn 00 4 r ..�t'7 00 c'n � r•i � . � 69 /1 V ci Cd C v pj Li •�,+ V CL 0 .0 cd a ca � � V X- u oj W • �°' c0 ° cuv' EW °� $ °.' o v c v r. � 'a od' CQ > OWE u ; z co y x MEETING AGENDA DATE JU- -21 ITEM# 7-27-91 Mr : Bill Roalman Councilman San Luis Obispo , Ca . Dear Bill : I am writing to you because I feel that you share some of my concerns about our city. It appears that the planning commission with its updated transportation element to the general plan is attempting to make some progress in repairing our deteriorating environment in San Luis Obispo . The concept of emphasizing alternate forms of transportation and deemphasizing the single passenger automobile in our city is a breath of fresh air so to speak . It is time to spend a greater percentage of our resources on mass transit and other forms of transportation such as bicycling and walking and less on making things more convenient or easier for the automobile user . People want to make changes and enjoy the results but they will not make them voluntarily. I beleive people are waiting to be told what to do in this regard and will be glad when they are. Unfortunately these things will never be accomplished on a national level but perhaps can be. accomplished on a county or city level if county/city government will take on the responsibility . Since at first it may not be politically popular it will take some courage but , in the long run, people will thank those who had the forsight to support such measures. Please let me know if or how I can be of assistance. Thank you, Lgers Dr . Walter 242 Marlene Dr . San Luis Obispo , Ca. 93405 546-7774 (W) 541-5363 (H) cc Ron Dunin COPIBTO: Peg Pinard 0Duoos clmFyl Penny Rappa PCILMERK/CORIG. �DDR Jerry Reiss ❑ M.DR❑ F11 DCl�F91CEIVED L ❑ Po1.lCECH. ❑ MCMT.TE46,S 13REC DSR AUG 2 X O � FILL ° F_ s xM C"a Ralsim Nll-rTING 8�AGENDA DATE � ITEM # R RM DESIGN GROUP ArcPilet-tic•Pln,nrin Er anrrrin;; fnrrr or;• Lnnd<nrpc Alchih•durr July 31, 1991 COMES-10: Honorable Ron Dunin ❑•DcnotcsActon ❑ RI Mayor, City of San Luis Obispo Z'Connd1 EZ/CDD MR. P. O. Box 8100 CAO ❑ FTN.DIR. ACAo El �,REC1 IEF San Luis Obispo, CA 93403-8100 L,/ATTORNEY p FAA Dom• L-,r CLF1:K/OR1G. 0 POLiCE0L ❑ MGMT.TEA1.1 D ?E-C Dir. ❑ r-READFILE ❑ UIILDIR. Re: Airport Area E" -r. r 2 Fr[L Dear Mr. Dunin and Members of the Council: As the City Council is now deeply immersed in its General Plan update, one of the major issues you will be examining is what should be done with the Airport Area. On behalf of the Airport Area Owner's Property Association, we wish to state our positions with respect as to the best approach to the area. For background purposes, you and the Council are well aware that the City, County, and the Airport Area Owner's Association endeavored back in 1983 to start preparation of a Specific Plan for the Airport area--the Airport Area Specific Plan. While the County has been the lead agency for this effort ever since it started, the planning process called for a close working relationship and involvement between the City, the County, and the Airport Area Property Owner's Association. As you no doubt know by now, this attempted planning effort has gone on far longer than anybody ever anticipated--it is now more than eight years since the effort was started. Nonetheless, it did yield the City Council's and Board of Supervisor's approval of a concept Land Use Plan for the airport area in 1989. After all the energy that has gone into planning the area, the City and County's joint approval of the concept plan is an accomplishment that should not be repudiated by the Council in its update process. The Airport Area Property Owner's Association now wants to go on record requesting that the Council reconfirm its 1989 decision approving the Airport Area Concept Plan and (1) Incorporate the Airport Area Concept Plan within the Land Use Plan as part of the City's Land Use Element Update; RECEIVED AUG -11991 3o_6 South Higuera Street,San Lui>Obispo,California 9;401 Sus/44¢-3714 CITY CLERK 1ov - nth Street, Modesto,California 953c4 209"544-1794 �.�' QS OBI;;_EOa IQ ......r„„. Honorable Ron Dunin Page 2 July 31, 1991 (2) Incorporate an urban reserve line in the Land Use Plan that would bring the entire area shown in the Airport Area Concept Plan into the City's Urban Reserve; (3) Give the Airport Area Property Owner's Association a definitive idea as to when the airport area might be annexed to and served by the City as a part of the General Plan; (4) Commit to energetically seek those resources necessary to bring the Airport Area into the City and provide the area with full city services. In considering this request, you should be aware that the County of San Luis Obispo is currently working on their General Plan Update and will be incorporating the City and County approved Airport Area Concept Plan within their update. If the City cannot give the Airport Area Property Owner's Association a clear expectation of when they could be annexed to and served by the City, the Association will have no choice but to proceed as necessary to find the resources necessary to sustain the City and County approved conceptual land use plan. Should you have any questions or comments regarding these requests and positions, please don't hesitate to give us a call. Sincerely, RRM DE GROUP Victor M ome Chie ecutiv ffice cc Airp rt Ara Tec ical Advisory Committee Lee E. H aier, RRM e/vm-dunin.ltr MEEviNG AGENDA MPA DATE 8-ITEM #._ MERRIAM PLANNING 30 July 1991 REG•t:1-u��, Members City Council of San Luis Obispo SSOCIATES do Arnold Jonas, Community Development Director JUL 31 1991 City of San Luis Obispo � r or sis oc s RE: Phasing of commercial development Dear Council Members: Just a brief note to express some of my concerns regarding commercial development. 1. Regarding commercial growth management: For example, the Dalidio annexation area has the potential for(and the market demand) for up to 40 acres of shopping center commercial phased in over some time. However, each of the major anchor stores requires between 100,000 and 120,000 square feet of gross leasable area, and the infill shops another 60,000 square feet. Obviously limiting commercial growth to the proposed 20,000 square feet a year in the City (0.75?/o of existing commercial uses)will be incompatible with a regional shopping center concept. Worse if half of the allocation were to go to the center(10,000 square feet a year),it will take 25 to 30 years to even get the first phase of the regional center built. This is a certain way to make these stores go elsewhere and insure that there will be more driving to Santa Maria with the attendant need for extra highway lanes and added air pollution etc.. There is also the additional problem that such a stretched out project timeframe cannot fund such major improvements as the widening of Madonna Road or the addition of a new interchange at Highway 101 and Prado Road. This type of activity requires major front end capital commitments for improvements which do not lend them selves to phasing. The alternative if for the City to fund the projects itself, but from what funds? In conclusion, the commercial phasing concept as proposed is not compatible with development of large commercial facilities, and must be altered if the Council wishes to gain significant retail and the related sales tax income. 2. 3% affordable housing tax on commercial development: While the Council can impose this type of condition, I hope it will not do so inflexibly. Already we have two non performing projects downtown(Court Street and French)which could not stand the imposition of this additional burden. The primary role of retail commercial, in terms of city benefit, is to provide sale tax income, not housing. The San Francisco example is not really relevant. The primary income there is from headquarters office highrise complexes which are often replacing housing. These offices must be in San Francisco to function. Commercial shopping in Our area can be in any number of communities on the Central Coast. I am afraid that this tax becomes one more means of pricing SLO out of the market and we will lose the sale tax income which allows us to subsidize such items as the bus system and other public services. FrCLERK/7 ctzonSincerely, CDD DIR.❑ FIN.DIR.(31 ❑ ME CHIEF❑ FW DIR.Andrew G.Merriam, AIA, AICP ic. ❑ I7oucEcs-I. Principal ❑ MCMI:TEAM ❑ FEC Dir, ,(](/CTRFr11D FIL£ ❑ =D[P�. 1350 Marsh Street San Luis Obispo. California 9340 ��— An-tres. G. Merriam. AIA, AICP MEETING AGENDA : 96_ITEM 0=_ July 30, 1991 Dear Mayor Dunin and Council Members, This letter is in response to an article regarding affordable housing that appeared in the Telegram Tribune on July 27, 1991 . There is in this country, arising a very disagreeable notion that there are "rights" to health care and affordable housing, and that it is the duty of our government to provide these things. I must say that I am incredulous and ashamed that my city council is jumping on this bandwagon. According to the article, my wife and I are low income. We are dead set against any such proposals for they amount to "taxing the rich" in the name of fairness to bring up the standard of living for us, the less fortunate. In reality what happens .when our government taxes us more, (in this case requiring developers to dedicate a percentage of the value to affordable housing) , the standard of living for everybody is lowered. I know that our representatives to our government rarely represent us but I would urge you to consider what the U.S.S.R. is currently experiencing. The people in that country are Aonging for what we have in the U.S.A. and yet our leaders seem bent on throwing our beloved market economy away, not because "the people" want to but because the people in government need to make work for themselves and therefore keep their jobs. We are also concerned with what sounds like a proposal to move all of the automobile dealers to one section of town. This would be fine if that is what the businesses wish to do but I suspect the bureaucratic mind at work instead. What do you propose to do with the four or five vacant lots that you would create? Why not move the auto parts dealers too? What about repair garages and gas stations? Any business that has anything to do with automobiles, including those that people drive to for work or shopping, should all be moved to Los Osos Valley Road. I believe that if you were to look at the deep and serious ramifications of these proposals of affordable housing and the perfect little community, you would see how contrary to common sense they really are and drop them like hot potatoes. The more that government tries to create Utopia, the worse off the people who are the "benefactors " of the programs become. I suggest that you leave your hands off of these ridiculous ideas and do not try to fix something that already works fairly well. I appreciate that you have taken the time to read this and I hope that you will respond. COPMSTO: Sincerely, ❑ FYI Action � 0 El FIN.DR ,/� FIRE �7/l�; ihxu ❑ EIV -i ° FW DR 7 O I 1y;11 CLE,K/ORIG. ❑ POUCECI-L ❑ MCMT.1F,4h( ❑ PECpu` C COUNCIL READFIU Q/{�� i $A I.S OBISPO,CA i� [✓� A E IN ENDA q AG 1281 17th Street Los Osos, CA 93402 July 29, 1991 Mr. Bill Roalman San Luis Obispo City Council San Luis Obispo, CA 93401 Dear Mr Roalman: As I'm sure you know, the Air Pollution Control District's Clean Air Plan is in the public comment phase at this time. If adopted, the plan will require cooperation and specific actions from the City Council, as well as the County Supervisors and other local governments. As a technical person, with some background in atmospheric physics, I wrote a rather detailed response to the draft plan. I have enclosed a copy for your information. I want to stress that my purpose is to strengthen the APCD plan, which I find too weak in a number of areas. I'd be happy to answer any questions that you might have about this. You can reach me at Cal Poly at 756-2205 or at home at 528-6933. Sincerely, Randall Kni Professor of Physics Cal Poly COPii'STO: ❑•Nnot s Ad im Fri d/Cttu�7 mD DIP - 0❑ FIN.DIR. CAO ❑ FIRECHIEF Od/AITOSL'JEY ❑ FW DUL Ili CLERK/ORIG. ❑ POLICECH. ❑ mrmT.TEAb1 ❑ PEC.DIR. RECEIVED CDFILEQUnLDIIL Z. F/ JUL 311991 cm CLERK .w..ps OBISPO&;44 RESPONSE TO DRAFT CLEAN AIR PLAN SAN LUIS OBISPO COUNTY AUGUST 1, 1991 RANDALL D. [NIGHT DEPARTMENT OF PHYSICS CAL POLY INTRODUCTION AND SUMMARY Introduction Air quality is one of the many things that we usually take for granted in SLO County. Ninety-five percent of the time, or more, the air here is crystal clear. Few give any thought as to whether our air will stay that way in the future. Fewer yet realize the extent to which our air is already becoming filled with pollutants, such as ozone, that are not visible to the unaided eye. Unfortunately, the air quality in SIA County is demonstrably growing worse, as documented by the ACPD data. It will continue to worsen in the future, as the county grows, unless steps are taken to control and reduce the emission of pollutants and their precursors. The topography of SIA county is not substan- tially different that that of Los Angeles - a coastal plain, where the majority of the population lives, backed up against steep mountains that tend to trap pollutants. Granted, the mountains here are not as high as those surrounding the LA basin, and so don't provide quite as large a barrier to dispersal, but the summertime inversion level is still generally less than the 2500-3000 foot elevations of the Santa Lucia range. Preventing air quality from deteriorating is m=h easier than trying to "fix it after it's broken." The LA experience shows all too clearly the nearly impossible difficulties of waiting until it gets bad before taking action. Even with the growth control measures already in place, the county's population will double to 400,000 by about the year 2020. Air quality will be seriously worse then if actions aren't taken now - including emission controls, land use plan- ning, and transporation decisions. Decisions which are difficult to make today may well be impossible to make in twenty years. The political process has never been known for looking much beyond the next election, but resource preservation is an issue that calls for public officials and the public to put the general welfare ahead of private agendas. Maintaining our air quality will be costly - to businesses and to individuals. But inaction is just as costly, if not more so, in terms of health issues and damage to crops and landscapes. Criticism that "it will cost too much" is simply not justified - the history of environmental regulation is that business continues just fine and that, in many cases, unexpected savings from more efficient operations more than offset the costs. We can pay up front to main- tain the central coast's air quality as a precious resource, or we can pay even more later to repair the damage. Citizens will then ask that inevitable questions, "Why didn't we do something while we could?' There's still time to take the necessary actions. The challenge is to work pro-actively to pre- serve our air quality rather than re-actively trying to fix it after it's broken. 1 Summ The ACPD plan is generally on target at identifying issues and proposing needed actions. While the second section of this response does critique and take ex- ception to some specific issues, such criticism should not in any way be inter- preted as trying to weaken the APCD plan. My intention in providing this re- sponse is to offer suggestions as to ways in which the plan can and should be further strengthened. I will here summarize my suggestions, for the benefit of those not interested in the details, and then in the second section I'll substantiate the basis for these suggestions. 1. The primary need is for further efforts to reduce the emission of reactive organic gases (ROG). By APCD's own estimates, the current plan will fall short of the goal of 40% reduction. There are scientific reasons for believing that even more than 40% reductions may be necessary to achieve compliance with state standards. According to APCD estimates, sixteen sources in the county are responsible for over 90% of ROG emissions. Yet nine of those six- teen are not scheduled for any reductions in the current plan_ In fact, five of these sources are estimated to have increases in emissions of 50% or more by 2010- This is simply not acceptable when other businesses and individuals are being asked to make significant financial committments and lifestyle changes for the public welfare. The burden of keeping our air clean must be shared equitably by all. Consequently, these are the primary sources that need further attention in this plan. 2. Specific recommendations for sources that need regulation or control, in a rough priority order, are as follows: Priority Source 1 Agricultural pesticides 2 Off-road vehicles 3 Further efforts on architectural coatings 4 Agricultural burning 5 Mobile equipment (e.g. construction equipment) 6 Industrial solvents 7 Consumer products 8 Oil and gas production 9 Heavy diesel trucks 10 Asphalt paving The ROG emissions of this group of sources need to be reduced about 30%. That is not an unreasonable goal for any of them. 3. Energy conservation and energy efficiency measures need to be emphasized more in this plan. Regulatory approaches to pollution control will only be temporary appeasements if we don't bring our energy use under control. 4. Indirect Source Review measures must be included as part of the current plan, not deferred for further study. This is partly an equity issue and partly a recommendation based on the assertation that the plan's transportation measures won't stand a chance unless we begin immediately to plan alternative transporation modes for new developments. 2 5. There must be a stronger emphasis on the need for city/county governments to include air quality issues in their land use planning and transportation plans. In particular, many of the transporation measures of this plan will have to be enacted by local governments. Citizen involvement is essential in planning for "user friendly" alternative modes of transportation. 6. Several measures of the plan need further clarification before the plan can be accepted. In particular: issues about enforcement, and issues surround- ing New Source Review and the proposed emission credit system. 7. The APCD's Technical Advisory Committee must be restructured to remove a likely biased source of technical information about control strategies. This committee is composed almost exclusively of representatives of oil companies and electric utilities, precisely those companies most affected by this plan. Further, two of the companies represented on the Technical Advisory Committee have been fined in recent weeks for violation of environmental regulations. It's not acceptable that these are the very companies providing advice on how to improve our air quality. 3 DETAILED COMMENTS AND SUGGESTIONS 1. I first want to commend the APCD for their substantial efforts and for the thoroughness of this report. A particularly strong point is the realization and emphasis that emission reductions are not simply a technical matter for industries, but that successful reductions will involve land use planning, transportation measures, and a variety of other measures involving the general public. The comprehensive list of recommendations reflects this awareness. Also to be noted are the APCD's positive attitude toward the use of its Citi- zen's Advisory Committee and toward the public workshops and hearings. Public awareness and support of this plan are essential ingredients for its ultimate success. 2. My primary criticism of the APCD plan is that the methodology and scien- tific validity are rather weak. This is not the direct fault of APCD, but it reflects the lack of sufficient monitoring data and modeling. The primary gas that this plan is concerned with is ozone. The monitoring of ozone has been sufficient to document that SLO County is in violation of state standards and that a reduction of around 40% is needed to achieve full compliance. Further, the report uses the monitoring data to infer an average ozone growth rate of 5-10% a year. Although the graphs of Figure 3-6 are suggestive of an increasing trend, a simple linear regression analysis is not at all justified. A statistician could make a good case that the data shown are simply year-to- year fluctuations with no trend at all. Neither is it justified to restrict the data to only eight years for those stations having a longer record. If there really is a trend, to show it you need the longest string of data avail- able, not a mere eight years. And what about 1990? Surely a report issued in June of 1991 could have data from 1990. 1990 data will help clarify the question of how much, if any, trend there is. The more serious issue, though, is the assumption that a 40% reduction in ozone will be brought about through a 40% reduction of the precursor gases ROG (re- active organic gases - i.e. hydrocarbons) and NOx (nitrogen oxides). This ` assumption is not warranted. The photochemical process leading to ozone for- mation is very complex and nonlinear, and there's no simple rule of thumb giving the relation between precusor gas reductions and ozone reductions. It is, in fact, possible that a reduction of NOx can lead to an increase in ozone. That is not likely to be the case here, since this situation is gen- erally restricted to urban cores where the ROG/NOx ratio is very low, but it does point out the dangers of making simple assumptions about the connection between precursor reduction and ozone reduction. Further, no one has any idea what the 1= emissions of ROG are, and only very limited knowledge of the true NOx emissions. Hydrocarbons simply aren't monitored at all, and NOx monitoring has been very spotty. The emissions inventory and the planning inventory (Tables 4-1 and 4-2) are simply estimates of emissions, and it's likely that many of the numbers in the tables are sig- nificantly in error. This is nowhere stated in the the report, which would lead the reader to think that the emission sources in the county are well known and characterized. The NOx characterization is probably not bad, since there's one dominant source, but the ROG characterization is merely an educated guess. 5 Now I raise these issues not to invalidate the report's conclusions, but to make the case that the proposed actions need to be st -n r ned. It's clear that ozone needs to be reduced 40%. It's not at all clear if 40% reductions of ROG and NOx will meet this goal. Consequently, I feel that a conservative approach is to plan for significantly more than 40% reduction of the precur- sors. This is particularly true for ROG, where there are a variety of natural sources to content with. The report does not include these in the inventory on the basis that they are uncontrollable. While this is true, the proper conclusion should be that anthropogenic sources of ROG will have to to reduced more than 40% in order to affect a net reduction of 40%. If good fortune should find that ozone reductions are proceeding faster than expected, it's always easier to loosen regulations in the future than to have to tighten them if reductions are less than expected. 3. The plan's own projections indicate that 40% reduction of ROG will not be achieved by the proposed measures. I think, because of the issues noted in Comment 2. , that a significant further effort must be made to reduce ROG. Further reductions in NOx would be desirable, and can likely be acheived with- out much further effort, but these aren't as critical and so my focus is mainly on how to improve the ROG situation. As I noted, the figures in the planning inventory (Table 4-2) have large un- certainties associated with them. Nonetheless, they're the best estimates available of emissions, and so we must work with them. Some quick calculations using the Table 4-2 numbers indicate that the top eight NOx emitters are re- sponsible for 92.6% of emissions. NOx emissions are concentrated in a few pro- lific sources. ROG emissions, on the other hand, are smaller and more widely dispersed. It takes the top 16 sources to get up to 91.6% of emissions. A wise strategy is to focus on this top group of sources. Sources beyond these contribute so little that even a 100% reduction would have. little overall impact. Smaller sources should receive only minimal regulation, and even then only when reductions are highly cost effective. Going after small sources only engenders public anger that will jeapordize the entire plan. On the other hand, cost effectiveness should be a minor concern for the top group. These are the sources that must be reduced for the plan to work. I list below the top emission sources, by category and percentage emissions. Those sources indicated by * have NO PLANNED REDUCTIONS. This is over half of the sources in both categories with no planned reductions. Admittedly, a few of these (e.g. trains) cannot be regulated at all at the local level. Others (e.g. heavy trucks) are expected to have some reductions from actions taken at the state level, but these are projected to be small. Most of these * sources, however, have significant potential for reduction by local initia- tive that is not being addressed. 6 ROG NOX Bank Source Percent Source Percent 1 Light duty cars 23.4 Electric utilities 31.6 2 Light duty trucks 12.5 Light duty cars 15.0 3 Petroleum marketing 9.7 *Mobile equipment 14.7 4 *Pesticides 6.4 *Heavy diesel trucks 12.7 5 Other surface coating 5.4 Light duty trucks 8.1 6 *Domestic solvents 5.2 *Oil/gas production 5.2 7 *Mobile equipment 4.7 *Heavy gas trucks 2.8 8 Architectural coating 4.6 *Trains 2.5 9 *Off road vehicles 4.6 92.6 10 Oil/gas extraction 3.3 11 *Agricultural burning 2.6 12 Degreasing solvents 2.3 13 *Heavy diesel trucks 2.3 14 *Heavy gas trucks 1.9 * No reductions under the 15 *Industrial solvents 1.5 current plan. 16 *Asphalt paving 1�2 91.6 Further, quite a number of these * sources are projected to have major in- creases in emissions from the 1987 base level. Source Percent INCREASE urolected for 1987-2010 Industrial solvents 120% Off road vehicles 77 Pesticides 56 Agricultural burning 54 Asphalt paving 52 Domestic solvents 43 Increases of this magnitude are simply not acceptable when other businesses and individuals are being asked to make significant financial commlittments and lifestyle changes for the public welfare. Consequently, these are the primary sources that need further attention. 4. Here are ten specific emission sources that must be considered for reduc- tions. I've listed them in a rough priority order, and indicated whether their reduction affects primarily ROG, NOx, or both. Priority Source ROG NOx 1 Agricultural pesticides X 2 Off-road vehicles X X 3 Further efforts on architect. coatings X 4 Agricultural burning X 5 Mobile equipment (e.g. construction equip. ) X X 6 Industrial solvents X 7 Consumer products X 8 Oil and gas production X 9 Heavy diesel trucks X X 10 Asphalt paving X If these sources reduced ROG emissions by an average of 30% each, it would reduce the 2010 ROG .emissions by a further 4.8 tons/day. This is just about 7 exactly what is needed to achieve a 40% reduction from the 1987 base level. An average 20% reductions of these NOx sources would build in a margin of safety, as well as remove some apparent inequities of the current plan as to to who has to make reductions and who doesn't. I don't think that 30% reductions here are unreasonable, even allowing for restrictions at the state level. For example, statewide initiatives may pro- hibit tighter regulations on ag burning, but that doesn't preclude local in- itiatives to work with the agricultural extension and farm advisors to provide farmers with aJrna .'v a to burning. Such efforts would not be significantly different than working with employers to find alternatives to single occupancy automobile commuting. Diesel truck emission standards may be set at the state level, but that doesn't preclude local efforts at controlling when and where trucks are used (particularly local uses) in order to minimize emissions during the peak ozone forming hours. But most of the above sources can, and must, be subject to emission regulations at the local level. Industrial solvents, off-road vehicles, construction equipment, and pesticides are all major emission sources that can and should be reduced by local actions. 5. Energy conservations and energy efficiency should receive substantially more emphasis in this plan. Energy use affects not only our air quality, but also water quality, road congestion, issues such as whether there will be oil drilling off the SIA coast, and a host of other local concerns. Regulatory approaches to these problems will only be temporary appeasements if we don't, in the long run, bring our energy use under control. True, energy efficiency cannot simply be decreed through an APCD regulation. But the APCD plan can emphasize and encourage city/county government actions as well as make energy efficiency a central theme of public education efforts. The APCD can also take specific steps, such as providing incentives to en- courage local. governments and large companies to reduce energy use or to adopt more efficient alternatives as means of achieving emissions reductions. For example, it was suggested at the first public workshop that local governments and utilities introduce electric vehicles into their fleets. Current techno- logy is appropriate for the short, moderate speed trips that are the mainstay of these fleets, and increased use will help propel the technology forward to more widespread capabilities. It would take a bit of study to see that the reduced vehicle emissions weren't simply being displaced to increased power plant emissions as the batteries are recharged, but I think that this is exact- ly the type of solutions that APCD should be actively suggesting and promoting. 6. Indirect Source Review measures must be proposed and adopted now, not deferred for further study. To be effective, such measures must be adopted in conjunction with city/county governments. Developers profit handsomly from new housing tracts and centers of commercial activity, yet the historical record is that existing residents and local governments are left to clean up the side effects of traffic congestion, pollution, etc. If efforts to reduce the emissions from automobile traffic are to ever have a chance, we must im- mediately begin to require new developments to plan up front for alternative transportation - through bike paths, shuttle buses, and other appropriate mea- sures. Developments above a certain size should also fall under the "no net new emissions" guidelines and be required to mitigate or to purchase credits under the emission credit system. 8 7. There should be stronger emphasis of the need for city/county governments to include air quality issues as part of their land use planning and general plans. In particular, many of the transportation measures will have to be decided and implemented at the local level. The development of alternative -transportation modes will be essential for the success of this plan, but those alternatives will have to be "user friendly." Decisions imposed by elected officials or government agencies have little chance of winning public accept- ance. It will be vital to have public involvement from the beginning in the formulation of transporation plans. Equally vital, since long distance com- muting is so prevalent in the county, will be cooperation between the various cities and the county. Moving away from a culturally entrenched attachment to the private automobile will be slow and difficult, but this plan should push harder in that direction. 8. This plan should address, in some detail, the issue of enforcement. If adopted, the plan will lead to a wide variety of new regulations. For a few of the largest sources, such as the PG&E power plant, determining compliance will be straightforward. But many proposed regulations deal with smaller, widely dispersed sources. Lack of .effective enforcement will likely lead to widespread non-compliance, and a plan which looks good on paper will prove to be singularly ineffective at reaching its goals. For the foreseeable future, the budget situation will not be conducive to the hiring of a large, new en- forcement division. Consequently, this plan needs to consider at the outset how compliance is to be achieved. 9. New Source Review and the emission credit system, whereby new developments can purchase credits from businesses that have exceeded required reductions, are very vague. Public statements from the APCD staff suggest that this is viewed as a major component of the plan. If so, it certainly needs to be described much better, with more specific details as to how it would work, and given more prominance in the report. 10. The APCD is to be commended for forming and actually utilizing its Com- munity Advisory Committee, through which it has received input from a wide variety of viewpoints. Unfortunately, the same cannot be said for its Tech- nical Advisory Committee, which consists almost exclusively of representives from oil companies and utilities. These are exactly the businesses and in- dustries that are the largest emission sources in the county and will have to make the largest efforts to meet new regulations. Their advice as to what is or is not technically feasible cannot possibly be viewed as unbiased informa- tion. We have one of the state's preeminent engineering and science univer- sities right here, Cal Poly, yet there's not a single faculty member on the Technical Advisory Committee. Nor is there any individual who could be said to represent environmental interests. Further, two of the companies represented on this committee have, in recent weeks, been fined for violating environmental regulations: J. B. Dewar, Inc. for issues involving waste solvents, and Unocal for gaseous emissions from its Nipomo refinery. It's simply not acceptable that these are the very com- panies providing advice on how to improve air quality. To redress these issues, it is essential that the Technical Advisory Committee be restructured to provide a more balanced viewpoint, with reasonable repre- 9 sentation from environmental groups and from local technical people without interest in maintaining the status quo. SUMMARY I thank the APCD staff for accepting public input and reading long responses, such as this one. As I indicated at the outset, my criticisms and suggestions are intended to strengthen, not weaken, the APCD plan. There are both techni- cal and poltical reasons for doing so. I hope that this response proves to be useful as the APCD staff prepares the final report and moves into the phase of drafting specific regulations. 10