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.
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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.
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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,
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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.
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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.
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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.
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FIGURE 1 FORECAST EMISSIONS COUNTYWIDE
REACTIVE ORGANIC GASSES (ROG)
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FIGURE 2 IND1 __+TORS OF AIR QUALITY: _982 - 1989
COUNTYWIDE
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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.
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