HomeMy WebLinkAbout7/5/2017 Item 12, Cooper
To:SLO City Council
From:Allan Cooper, San Luis Obispo
Re:Review of the San Luis Ranch Project Including the
SpeciÐc Plan
Date:July 3, 2017
On July 5, 2017 you will be certifying a Statement of Overriding
Considerations for the San Luis Ranch SpeciÐc Plan. The Final EIR
states that this project will be inconsistent with the SLOAPCD 2001
Clean Air Plan because it would result in an increase in vehicle miles
traveled (VMT) that would exceed the rate of population growth. The
overriding consideration in response to this unavoidable
environmental risk is that the San Luis Ranch SpeciÐc Plan includes
workforce housing intended to balance jobs and housing and
signiÐcant entry-level housing that is speciÐcally Åaffordable by
designÆ.
This is an unacceptable overriding consideration because, in fact,
the San Luis Ranch project will not provide workforce or affordable
housing Åby designÆ.
You may think otherwise because this subdivision is comprised of
small houses on small lots. Yet the price of this housing will still hover
in the $500,000 range because:
1)each household will have to carry the exorbitant costs of a
ÅCommunity Facilities DistrictÆ;
2)each household will have to carry the developerÈs cost of
extending roads;
3)each household will have to carry the costs of installing new parks
and bikeways;
4)the selling prices of these so-called Ånet zeroÆ homes will have to
include the costs of solar panels, super-sealed building envelopes,
ductless mini-split heat pumps and highly insulated windows and
doors; and
5)by the time these houses are built, housing inÑation will have
already taken its toll.
Moreover, there is no certainty that any of the 30,000 workforce
currently commuting into SLO from outside communities will live here.
Why? Because they will be making a tradeoff between a larger home
on a larger lot in a quieter, outlying community to a smaller home on a
smaller lot under a noisy airport Ñight path. So who will buy these
homes? AfÑuent parents of Cal Poly students and wealthy retirees¼
not our workforce.
Irrespective of the cost of housing, I am proposing that you balance
jobs and housing by following the example set by the Avila Ranch
Project.
The Avila Ranch Project achieves the most trafÐc reduction for each
home by giving existing SLO workers Ðrst priority for their units. The
Avila Ranch developers have already identiÐed over 500 SLO
employees currently commuting into SLO who have expressed
interest in buying into their project.They will also limit the R-1 and
R-2 units for owner-occupants only during the initial 5 years of
occupancy to make sure that local SLO workers will not have to
compete with investors for these units.
Finally, I am urging you to reduce the number of units proposed for
this project (Alternative 3: Historical Resource Preservation) in such
manner to insure the preservation of the historic farm complex and,
perhaps more importantly, to insure the preservation of 244 mature
trees. Even though Mitigation Measure BIO-2(b) will replace impacted
riparian trees, it will require a prolonged period of time to nurture
these replacement trees and it is impossible to predict if these
replacements will survive climate change. Moreover, drought tolerant,
pest free trees such as eucalyptus are irreplaceable carbon
sequesters and invaluable habitats for butterÑies and egrets. All
mature native and non-native trees should be protected and
preserved.
1
I concur with the Ðndings in the EIR which state that air quality, cultural
resources (historic resources and cumulative historic resources), land use/
policy consistency (General Plan policy consistency), noise (construction
noise), and transportation (existing and near-term intersection operations,
existing and near-term lane capacities, existing and near-term segment
operations, cumulative intersection operations, cumulative lane capacities,
and cumulative segment operations) created by this project will be
signiÐcant and unavoidable. This project at the time of buildout will also
place unavoidable adverse impacts on the CityÈs current sewer, water,
school, law enforcement and Ðre protection capacities.
But more speciÐcally, the proposed tree replacements, particularly along
the riparian corridor, will result in not only signiÐcant but unavoidable
adverse impacts - not mitigable impacts as the EIR states. The mitigations
involving replacement in-kind minimum ratios, particularly with regards to
the proposed removal of the mature eucalyptus trees, will hardly mitigate
the permanent loss of the monarch overwintering grove and active great
blue heron nest habitat. Monarchs need tall trees(of at least 60 feet)
because they roost in the intermediate level of the canopy where wind
protection is greatest. Tall Eucalyptus trees are hugely important as habitat
trees as they provide cover and nest sites for Great Blue Herons as well as
for Double-Crested Cormorants, hawks and Great Horned Owls. The report
notes that one mitigation - creating new offsite nesting habitat for great blue
herons - is experimental and that the relocation techniques described in
Crouch et al. (2002) were used to relocate black-crowned night heron
(Nycticorax nycticorax), not great blue herons.
1
Often during the Spring, an area of high pressure will build at the surface over the western
United States and produce Santa Lucia (northeasterly) winds, also referred to as Åoffshore
windsÆ because they Ñow from the land out to sea especially during the night and morning
hours. Severe temperature differences in the vertical plane occur resulting in an . A
temperature occurs when a warmer, less dense air mass covers cooler, denser air at
the surface. The temperature changes are because of cool moisture-laden northwesterly
(onshore) winds from the PaciÐc Ocean blowing through Los Osos Valley while hot and dry
Santa Lucia northeasterly (offshore) winds move from the Santa Lucia Mountains through Avila
Valley.
As you know the relocation of the historic house and viewing stand should
not be done arbitrarily. Two questions should be asked: 1) Why is it
necessary to relocate these properties? and 2) Is the City ÅapprovingÆ the
RRM-designed ÅIllustrative Agriculture Heritage CenterÆ site plan? The
layout of these relocated buildings - in a circle - is non-historic. There
should have been an attempt to lay these structures out relative to one
another in a more traditional manner assuming that they have to be
relocated in the Ðrst place.
Finally, the California Government Code - Gov Title 7. Planning And Land
Use \[65000 - 66499.58\]) żrecognizes that premature and unnecessary
development of agricultural lands for urban uses continues to have adverse
effects on the availability of those lands for food and Ðber production and
on the economy of the state. Furthermore, it is the policy of the state that
development should be guided away from prime agricultural lands¼Æ This
project involves conversion of 68 acres of prime soils to urban
development.
In the Ðnal analysis, your review of this SpeciÐc Plan should note that this
project is Åinconsistent with State Planning LawÆ.
Thank you for your time and consideration.