HomeMy WebLinkAbout7/5/2017 Item 12, Sullivan
Christian, Kevin
From:Michael Sullivan <mcsgday@yahoo.com>
Sent:Tuesday, July 04,
To:E-mail Council Website
Cc:Michael Sullivan
Subject:Comments sent to City of San Luis Obispo - for Council hearing of 05 July 2017 6 pm
- San Luis Ranch project - from Michael Sullivan
Attachments:2017-07-05
_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_a.doc;
2017-07-05
_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_
A.doc; 2017-07-05
_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_
B.doc
04 July 2017
To: City of San Luis Obispo
From: Michael Sullivan
The three documents attached are my comments (MS Word 2003 format) on the San Luis Ranch project, Council hearing of 05 July
2017 at 6 pm.
The documents include:
- Comments of Michael Sullivan
- ATTACHMENT A
- ATTACHMENT B
If you can, would you confirm receipt of the above 3 documents by e-mail to me at your earliest convenience (not later than 05 July
2017 at 10 am, if feasible.) Thank you.
Michael Sullivan
mcsgday@yahoo.com
1
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Monday - 03 July 2017
To:
City Council of City of San Luis Obispo, CA
emailcouncil@slocity.org
From:
Michael Sullivan, 9557 Coosa St., Ventura, CA 93004 Tel. 805-647-4101
REGARDING: San Luis Obispo City Council public hearing of
Wednesday 05 July 2017 - 6 pm - San Luis Ranch (Agenda item # 12)
(Consideration of Council regarding proposed approval of San Luis
Ranch project)
>>>>>
INTRODUCTION
My family owns a residential property very close to the proposed San Luis Ranch
project. I am concerned about the lack of a legally-adequate analysis of project
alternatives.
I request that the Council postpone any approval of the San Luis Ranch project
until such time as a revised “project Alternatives” analysis is prepared for the San
Luis Ranch project.
- The main reason for this request is that the City has not operated in conformance
with the California Environmental Quality Act (CEQA) or in conformance with
the CEQA Guidelines in the selection of appropriate project alternatives to be
included in the Final Environmental Impact Report (Final EIR) for this project.
- Another reason for this request is that it is possible to create a better project
through the use of available project alternatives which meet most project
objectives yet provide better benefits, for example, additional on-site open space,
better protection of existing trees and riparian corridor, and a lower level of traffic
and smog impacts based on a minor reduction in housing units which still allows
affordable housing.
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FAILURE OF CITY TO ABIDE BY California Environmental Quality
Act (CEQA) AND CEQA GUIDELINES
The following City actions were illegal and improper under CEQA and CEQA
Guidelines:
(1) Use of conclusory arguments to dismiss and reject project
alternatives suggested by the public in comments on the Draft EIR is not
allowed under CEQA and CEQA Guidelines. Proposed project
alternatives suggested as comments on the Draft EIR by Michael
Sullivan and various other persons were dismissed and rejected based
on conclusory logic, which violates CEQA Guidelines, 15088(c).)
The proposed "Alternative 3M” as proposed by Michael Sullivan in his comments on
the Draft EIR, and various other proposed project alternatives submitted by other
persons in comments on the Draft EIR, were dismissed and rejected using conclusory
arguments, i.e., the argument that only the four alternatives included in the Draft EIR
would be allowed, and no others would be added or considered, regardless of merit,
because the author of the EIR determined that the original 4 alternatives in the Draft
EIR were sufficient. (See also San Luis Ranch Final EIR, Vol. 2, Master Response 1,
Adequacy of Draft EIR Alternatives, at p. 8-2 - 8-3.)
The San Luis Ranch Final EIR (May 2017), Vol. 2, uses “Master Responses” to address
various issues raised by the public, such as suggested project Alternatives, etc. The
“Master Response to Alternatives” is used as a means to dismiss and reject any
proposed project alternatives other than the four original project alternatives adopted in
the Draft EIR, with the argument that those four project alternatives are sufficient under
CEQA or CEQA Guidelines and that no other suggested project alternatives need be
considered or adopted for inclusion in the Final EIR. This sort of conclusory response
is inconsistent with CEQA Guidelines 15088(c).
In assessing the merit of a proposed project Alternative, “major environmental issues
raised when the Lead Agency's position is at variance with recommendations and
objections raised in the comments must be addressed in detail giving reasons why
specific comments and suggestions were not accepted. There must be good faith,
reasoned analysis in response. Conclusory statements unsupported by factual
information will not suffice.” CEQA Guidelines 15088(c).
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(2) The City has not provided a reasonable range of project
Alternatives, because:
(a) The project Alternatives approved by the City and considered
by the City were infeasible because they do not satisfy city objectives
and/or project objectives. If the City presents four project alternatives,
each of which would not satisfy city objectives and/or project objectives, the
City has failed to meet the standards of CEQA Guidelines 15126.6(a) and
CEQA Guidelines 15126.6(c). (See discussion, below.) All four of the
original Draft EIR Alternatives are found by the City to be infeasible.
See, for example, Council staff report (San Luis Ranch council hearing
of 05 July 2017, Packet Pg 329-330).
(b) The City has refused to provide fair, objective, fact-based
reasons for rejecting a suitable, reasonable, project Alternative (called
“Alternative 3A”) which was proposed by Michael Sullivan in comments
on the San Luis Ranch Draft EIR). Similarly, project Alternatives
proposed by various other persons in comments on the Draft EIR were
also dismissed and rejected. (See information in section (3), below.)
CEQA and CEQA Guidelines mandate that “An EIR shall describe a range of
reasonable alternatives to the project, or to the location of the project, which would
feasibly attain most of the basic objectives of the project but would avoid or
substantially lessen any of the significant effects of the project, and evaluate the
comparative merits of the alternatives.” See CEQA Guidelines 15126.6(a).
As noted below, all four of the original Draft EIR Alternatives are found by the City to
be infeasible. See, for example, Council staff report (San Luis Ranch council hearing of
05 July 2017, Packet Pg 329-330). That analysis shows that Alternative 1 is infeasible
because it fails to meet the City’s objectives for the project area. That analysis shows
Alternatives 2, 3, and 4 are infeasible because they do not satisfy a majority of the key
project objectives.
However, ‘The range of potential alternatives to the proposed project shall include those
that could feasibly accomplish most of the basic objectives of the project and could
avoid or substantially lessen one or more of the significant effects.’ (See CEQA
Guidelines 15126.6(c). Selection of range of reasonable alternatives.) If the City
presents project alternatives, each of which would not satisfy city objectives and/or
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project objectives, the City has failed to meet the standards of CEQA Guidelines
15126(c).
Because the City has found the original 4 project Alternatives to be deficient in attaining
important project objectives (and therefore infeasible) and because the City has refused
to consider Michael Sullivan’s “Alternative 3A” or other Alternatives suggested by
other persons, the City has failed to provide a reasonable range of project alternatives.
(3) “Alternative 3A” as proposed by Michael Sullivan in comments on
the San Luis Ranch Draft EIR is one example of a suitable project
alternative. Various other proposed alternatives also have merit.
There is no logical reason to dismiss or reject “Alternative 3A” as proposed by Michael
Sullivan. “Alternative 3A” fits the requirements of CEQA Guidelines 15126.6(a). It
was designed to feasibly attain most of the basic objectives of the project. In fact,
“Alternative 3A” as proposed was identical to the project as proposed in the Specific
Plan, with the single exception of a minor reduction in the number of housing units from
580 to 530. Under this scenario using “Alternative 3A” the attainment of a reasonable
number of affordable housing units would still be possible. “Alternative 3A” also has
notable benefits, such as: (a) probable reduction in the Class I impacts to traffic and air
pollution, in proportion to the reduction in the number of housing units; (b) more on-
site open space available; (c) better opportunity for protection of sensitive habitats near
the eucalyptus grove and along Prefumo Creek.
The City has allowed use of a Final EIR in which “Master Responses” to various public
concerns have been presented. (See San Luis Ranch Final EIR (May 2017), Volume 2).
By use of the “Master Response” to proposed Alternatives that were proposed by
various by persons who commented on the Draft EIR, the Final EIR employs a standard
response (“Master Response” to Alternatives, or to other issues) with the conclusory
answer that the four original project Alternatives in the Draft EIR are sufficient and
therefore additional proposed Alternatives or substituted Alternatives will not be
allowed. This is sort of conclusory response is illegal under CEQA and CEQA
Guidelines, as discussed above.
>>>>>>>
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Furthermore, the City should also re-examine some of the proposed
project Alternative ideas other than the one I proposed.
Example 1 - James Lopes (letter sent to Council for Council hearing of 05 July 2017)
suggests several ideas for alternative concepts for the project, such as
(a) smaller quantities of residential units
(b) smaller allowable commercial-use total floor areas
(c) postponement of the project approval until we can organize some workshops to
discuss combinations of alternatives
Example 2 - Allan Cooper (letter sent to Council for Council hearing of 05 July 2017)
suggests:
(a) preservation of 244 mature trees in the riparian area (Prefumo Creek) or nearby
(b) reduce the number of housing units to help achieve (a) (This is similar to the
“Alternative 3A” proposed by Michael Sullivan)
(c) re-think the definition of “affordable work-force housing” in terms of more
restrictive regulations about who qualifies for such housing
Example 3 - Letter 8 and Letter 9 (comments on the San Luis Ranch Draft EIR)
discusses concerns about removal of too much topsoil in the agricultural section of the
project. One suggestion (in Letter 8) is to use alternative areas (not the project site) for
fill dirt. Why is that concept rejected? Other concerns in Letter 10 are also rejected.
(4) The responses in the EIR misinterpret and/or misunderstand CEQA
and/or CEQA Guidelines.
The Rincon consultant(s) who prepared the San Luis Ranch draft EIR and Final EIR
also evidently misunderstands the requirements of CEQA and CEQA Guidelines. In the
"Master Response 1 - Adequacy of Draft EIR Alternatives," it is stated that an
Alternative with fewer housing units, for example with 350 housing units, "would not
reduce any identified significant environmental impacts to a less than significant level.
Therefore, this potential alternative was not considered further in the Draft EIR."
However, under CEQA and CEQA Guidelines, when Class I impacts exist (e.g., traffic
congestion and air pollution), the criterion for selection of Alternatives does not limit
such Alternatives to ones that "reduce any significant environmental impacts to a less
than significant level." Rather, "The range of potential alternatives to the proposed
project shall include those that could feasibly accomplish most of the basic
objectives of the project and could avoid or substantially lessen one or more of the
significant effects." CEQA Guidelines 15126.6(c).
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It is logical to assume that if the number of housing units is related to the amount of
traffic congestion or air pollution, then a reduction in the number of housing units would
be expected to incrementally reduce those impacts. Indeed, the traffic models used in
such predictions follow such logic. Therefore, it would be reasonable to look at
“Alternative 3A” or similar concepts which have different levels of reduction in housing
units, and then use the traffic models and air pollution models to quantify the reduction
in those impacts for a range of quantities of proposed housing units.
(5) The purpose of project Alternatives in the EIR is to avoid or lessen
severe environmental impacts. The analysis in this San Luis Ranch
project has been to maximize both the commercial and residential uses
to the most intense and most environmentally damaging level
permissible. For example, the General Plan envisions that the number
of housing units would be from 350 to 580. The current plan allows up
to 580, the maximum.
This approach is inconsistent with CEQA Guidelines 15126.6(b):
CEQA Guidelines 15126.6(b) - “Purpose. Because an EIR must identify ways to
mitigate or avoid the significant effects that a project may have on the environment
(Public Resources Code Section 21002.1), the discussion of alternatives shall focus on
alternatives to the project or its location which are capable of avoiding or
substantially lessening any significant effects of the project, even if these
alternatives would impede to some degree the attainment of the project objectives,
or would be more costly.” CEQA Guidelines 15126.6(b).
An example of the failure to limit severe impacts is in the “air quality” assessment.
The project has a Class I impact on air quality. This smog problem will be especially
severe for any older residents. For example, the Los Angeles Times reported (30 June
2017) that Harvard University scientists found that “Smog may be lethal at any level”
and is linked to premature death in seniors. (Please see ATTACHMENT B.)
Why then does this project permit the highest level of residential and commercial use,
which directly affects vehicle trips, which is related directly to the smog problem at this
project site and nearby?
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(6) How does the public know for sure that mitigation measures funded
by terms of the Development Agreement will be sufficient and will be
practical, and enforceable, and will not impose a future tax on citizens in
the City of San Luis Obispo? The Development Agreement is not yet in
place and we do not know when it will be in place and what it says and
what it promises for mitigation contributions. I have a concern that this
dilemma may also be incompatible with CEQA and CEQA Guidelines
because the needed environmental impact mitigations are not assured at
the time of project approval.
>>>>>>>>>>
Respectfully,
Michael Sullivan
LIST OF ATTACHMENTS
ATTACHMENT A - Proposed “Alternative “3A” of Michael Sullivan sent via e-mail on 30 Jan 2017
to City of San Luis Obispo on 30 Jan 2017 as a comment on the San Luis Ranch Draft EIR.
NOTE: See the responses to these comments in the San Luis Ranch Final EIR (May 2017), Vol. 2, at
p. 8-68 through 8-82.)
ATTACHMENT B - News story - Los Angeles Times. 30 June 2017. “Smog may be lethal at any
level.” (Transcription)
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
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28 Jan 2017
Sent on 30 Jan 2017 via e-mail to the following persons:
To:
City of San Luis Obispo, Calif.
c/o Brian Leveille, Community Development Dept.
bleveille@slocity.org (805-781-7166
c/o City Clerk - Carrie Gallagher
cgallagher@slocity.org (805) 781-7102
From:
Michael C. Sullivan
Mailing address: 9557 Coosa St., Ventura, CA 93004
Property address in San Luis Obispo: 1127 Seaward St., San Luis Obispo, CA 93405
(Property at 1127 Seaward St. is owned by the Walter E. Sullivan and Louise F. Sullivan Trust,
Michael C. Sullivan, Trustee)
Phone: 805-441-6981 (cell / text);
Phone: 805-647-4101 (home message machine)
E-mail: mcsgday@yahoo.com
COMMENTS OF MICHAEL C. SULLIVAN
REGARDING DRAFT EIR - SAN LUIS RANCH PROJECT AND ANNEXATION TO THE CITY OF
SAN LUIS OBISPO
Abbreviations commonly used
CEQA- California Environmental Quality Act
DEIR - Draft Environmental Impact Report
EIR - Environmental Impact Report
SLO - San Luis Obispo
SP - Specific Plan (for San Luis Ranch annexation)
Summary of issues
1. Alternatives as presented in DEIR are not adequate for purposes of CEQA.
REF: DEIR part 1 (Executive summary); DEIR part 2 (Project description); DEIR part
25 (Alternatives).
The DEIR examines 4 alternatives:
• Alternative 1: No Project, No Development
• Alternative 2: No Project, Measure J Entitlements
• Alternative 3: Historical Resource Preservation
• Alternative 4: 50% On-Site Agriculture/Open Space
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The number of viable alternatives is insufficient, because according to the DEIR, at least two of them
(ALTERNATIVE 1 and ALTERNATIVE 2) do not fit the City’s General Plan and therefore are
infeasible. ALTERNATIVE 3 is the environmentally superior alternative. ALTERNATIVE 4 would
result in less residential and commercial development than the Specific Plan, and therefore it is likely
that the City’s decision-makers would reject ALTERNATIVE 4 because it is not close enough to the
goals and objectives of the Specific Plan currently adopted. Therefore, only one alternative,
Alternative 3, remains feasible. This improperly limits the discussion of a broad enough range of
feasible alternatives.
I have proposed ALTERNATIVE 3A, which is discussed below. It should be reviewed and evaluated
by the city, so that a reasonable number of feasible alternatives is considered and evaluated in
comparison with the proposed Specific Plan.
ISSUE # 1
1. Alternatives are not adequate for purposes of CEQA
As required by Section 15126(d) of the State CEQA Guidelines, this EIR examines a range of
reasonable alternatives to the project that could feasibly achieve similar objectives. The
alternatives offered in the Draft EIR (DEIR) are insufficient.
ALTERNATIVE 1‐ No project / No Development
“Based on the comparison provided in Table 6‐1, the No Project/No Development Alternative
(Alternative 1) would result in the fewest adverse environmental effects. However, since this is the “No
Project” alternative, CEQA requires that a separate alternative also be identified as the Environmentally
Superior Alternative.”
(DEIR at p. 6‐22 through 6‐23.)
Comments on Alternative 1
The City of San Luis Obispo General Plan anticipates that this particular project site shall be developed
under a Specific Plan as a regional mixed-use commercial center. Alternative 1 does not achieve that
objective. Listing of this alternative does nothing to provide some alternative which could meet the
City of San Luis Obispo General Plan goals for this project site as a mixed-use development.
- “The alternatives shall be limited to ones that would avoid or substantially lessen any of the
significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones
that the Lead Agency determines could feasibly attain most of the basic objectives of the Project
(Section 15126.6).” DEIR, at p. 6-1, Alternatives.
- “In defining feasibility of alternatives, the CEQA Guidelines state that “among the factors that
may be taken into account when addressing the feasibility of alternatives are site suitability,
economic viability, availability of infrastructure, general plan consistency, other plans or
regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably
acquire, control or otherwise have access to the alternative site” (Section 15126.6).” DEIR at p. 6-1,
Alternatives.
Because the No Project Alternative (Alternative 1) provides no economic viability for the project
proponent, and because it does not attain the basic objectives of the project as envisioned by the
proponent and the City, this alternative (Alternative 1) serves no useful purpose.
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ALTERNATIVE 2 ‐ No Project, Measure J Entitlements
6.4.2 Alternative 2: No Project, Measure J Entitlements
Description
“This alternative assumes that the San Luis Ranch Specific Plan is not adopted and that none of
the proposed entitlements are implemented, including annexation to the City. Therefore, this
alternative represents a project that would be processed by San Luis Obispo County, and
considers what would be reasonably expected to occur in the foreseeable future based on
current plans and consistency with available infrastructure and community services. There are
existing entitlements on the project site for development in the County from the voter‐approved
initiative known as “Measure J,” which was passed in 2006 and upheld in 2009. The Measure J
entitlements include 60 multi‐family dwelling units, 560,000 square feet of regional commercial
and outdoor sales areas, 198,000 square feet of office space, and a 150‐room hotel and ancillary
facilities. Because the Measure J entitlements would leave the project site under the jurisdiction
of the County, but surrounded entirely by the City limit, these entitlements would also require
the use of private water from onsite wells and an onsite wastewater treatment facility. Figure 6‐
1 depicts the Measure J site plan and approximate development area of this alternative.”
DEIR, p. 6‐6 to 6‐7.
“Alternative 2 would fail to meet most of the project‐specific objectives. As shown in Table 6‐1,
Alternative 2 would result in increased physical environmental impacts when compared to the project
and would not achieve many of the planning goals included in the City’s General Plan as they apply to the
San Luis Ranch Specific Plan area. “ DEIR at p. 6‐22.
Comments on Alternative 2.
For the reasons below, Alternative 2 is not a reasonable alternative.
- A part of the project description states, “The project is intended to be consistent with the
development parameters described in the City’s Land Use and Circulation Element (LUE) (adopted in
December 2014).” DEIR, Executive Summary, p. ES-1. Alternative 2 is not at all consistent with the
development parameters described in the City’s LUE. The DEIR states, “Alternative 2 would fail to
meet most of the project‐specific objectives. As shown in Table 6‐1, Alternative 2 would result in
increased physical environmental impacts when compared to the project and would not achieve many of
the planning goals included in the City’s General Plan as they apply to the San Luis Ranch Specific Plan
area.” DEIR, p. 6‐22.
- The Alternative section of the DEIR states, “Since this alternative (Alternative 2) assumes that the
project site would be developed under an existing entitlement, this alternative would not require
environmental review under CEQA.” That is not necessarily true or valid. It has been 7 years since
Measure J entitlements were approved by voters. In the interim, there have been significant changes with
baseline conditions, such as traffic, housing, new developments, etc.
‐ Furthermore, Measure J as it stands remains inconsistent with the General Plan of the County of San Luis
Obispo, because Measure J exempts itself from the normal constraints of the County’s General Plan. As far
as I know, this particular legal point has not yet faced scrutiny in the courts.
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‐ It also remains uncertain whether the Local Agency formation Commission would allow such a project
as described by Measure J, for example, because of the uncertainty of water supply and sewage treatment
and traffic mitigation.
- Alternative 2 is not feasible at all, because it is inconsistent with the existing General Plan Land
Use Element of the City of San Luis Obispo in various ways. Such an alternative would leave the
project site entirely in County jurisdiction, surrounded by the City of San Luis Obispo. This would be
inconsistent with the intention of the City of San Luis Obispo that this “island” should be annexed to
the City, which is rationale for the San Luis Ranch project.
Examples of inconsistencies of Alternative 2 with City of SLO General Plan:
SLO City Land Use Element: (LUE)
Approach to Planning (LUE at 1‐19)
San Luis Obispo should:
1. Choose its future, rather than let it happen. San Luis Obispo should be proactive in implementing its
vision of the future, and should work with other agencies and institutions to create our desired mutual
future.
Inconsistency: Adoption of Alternative 2 interferes directly with the City implementing its own vision of
the future. Instead, it would require adoption of a much different plan, proposed 7 years ago as a County
initiative.
Society and economy (LUE at p. 1‐20)
34. Where appropriate, create compact, mixed‐use neighborhoods that locate housing, jobs, recreation,
and other daily needs in close proximity to one another, while protecting the quality of life in established
neighborhoods.
Inconsistency: Measure J does not provide the housing, open space, and mixed‐use quality of the project
site which is envisioned by the General Plan.
Land‐use Map. (LUE Map at p. 1‐23) The existing Dalidio project site is already designated by the City
as a Specific Plan area. See Sec. 8.1, below.
Inconsistency: Alternative 2, if implemented, would permanently remove the possibility of a City‐
approved Specific Plan for this site.
1.1.2. Development Capacity and Services (LUE at p. 1‐34)
The City shall not designate more land for urban uses than its resources can be expected to support.
Inconsistency: Because various characteristics of the Measure J proposal (e.g. traffic problems, growth‐
inducing impact, etc.) are not known (because no Initial Study, or Negative Declaration, or EIR has been
prepared for that project), it is unknown if Alternative 2 can be handled within city constraints on
development capacity and services.
1.5. Jobs/Housing Relationship (LUE at p. 1‐34)
The gap between housing demand (due to more jobs and college enrollment) and supply should not
increase.
Inconsistency: Apparently the City‐proposed Specific Plan provides more housing than the Measure J
plan. The Measure J plan would not satisfy the goal of improving the amount of housing as compared with
the Specific Plan.
1.9.1. Agricultural Protection (LUE at p. 1‐36)
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The City shall support preservation of economically viable agricultural operations and land within the
urban reserve and city limits. The City should provide for the continuation of farming through steps such
as provision of appropriate general plan designations and zoning.
Inconsistency: Alternative 2 protects less agricultural land than the City‐approved San Luis Ranch plan.
8.1. Specific Plan Areas (LUE at p. 1‐82 and Figure 10 at p. 1‐83)
8.1.1. Specific Plan / General Plan Amendment
The City shall require the completion and approval of a specific plan and associated General Plan
Amendment prior to annexation (if applicable) and development of land within an area designated as a
Specific Plan Area on Figure 10. The required General Plan Amendment will modify the General Plan Land
Use Diagram to reflect the land use diagram from the approved specific plan, based on the land uses listed
under “Performance Standards” for each site.
Inconsistency: Alternative 2, if implemented, would permanently remove the possibility of a City‐
approved Specific Plan for this site which meets the unique standards of the City’s General Plan.
12. Implementation policies (LUE at p. 1‐102)
Inconsistency: If Alternative 2 is adopted, the City cannot fulfill certain critical implementation policies,
such as Zoning Regulations, Subdivision Regulations, Community Design Guidelines, Public Planning,
Environmental Review, etc.
CONCLUSION: Because of these various constraints, above, and because of
various inconsistencies of Alternative 2 with the City of San Luis Obispo
General Plan, Alternative 2 is not a feasible or proper or legal or reasonable
alternative, and so Alternative 2 must be discarded.
ALTERNATIVE 3 ‐ Historical Resource Preservation (See DEIR at p. 6‐12, Fig.
6.2)
“As described in DEIR Section 6.4.3, Alternative 3 would preserve the San Luis Ranch Complex, thereby
avoiding the significant and unavoidable impact to historic resources identified for the project. This
alternative would also reduce other potential environmental effects due to the preservation of the
eucalyptus grove in the northwest portion of the project site along Madonna Road, and due to the reduced
overall development footprint. As shown in Table 6‐1, Alternative 3 would also result in reduced impacts
to air quality, GHG emissions, noise, biological resources, land use/policy consistency, and hydrology and
water quality, while resulting in slightly increased impacts to transportation (due to the loss of the
proposed San Luis Ranch Way access route).”
“Alternative 3 would also achieve the basic objectives of the project. This alternative would provide infill
growth for the City, and would be generally consistent with the General Plan with the existing historic
structures on the project site. A variety of housing opportunities would be available, including affordable
housing opportunities. The multimodal transportation network would continue to provide accessibility
via automobile, bicycle, and pedestrian amenities, including the Bob Jones Regional Trail. The alternative
would be similar to the project in its adherence to sustainable development practices and design features.
Therefore, Alternative 3 is
identified as the environmentally superior alternative over other alternatives, as shown in Table
6‐1.”
Comments on Alternative 3.
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The City of SLO should look at the feasibility of a variant of Alternative 3, in which more of the
land adjacent to Prefumo Creek and more of the eucalyptus grove in the northwest portion of the
project site is protected by being undeveloped. My proposal, which I call ALTERNATIVE 3A,
would eliminate a moderate amount of housing (50 units total), but otherwise the project would
be nearly the same as it is in the Specific Plan. Such a new alternative (“Alternative 3A”) is
proposed by me and discussed below under “OTHER FEASIBLE ALTERNATIVES.”
Alternative 4: 50% On-Site Agriculture/Open Space (See Fig. 6-3)
The DEIR states: Alternative 4 would retain 50 percent of the net site acreage as on‐site agricultural and
open space uses to be consistent on‐site with the City’s General Plan Land Use Element Policy 8.1.4.f.
This alternative would retain the portion of land designated for commercial uses (NC) southeast of Froom
Ranch Way and southwest of Prado Road in agriculture. This alternative would reduce the portion of the
site available for residential and commercial development on the project site.
Comments on Alternative 4:
It is likely that the City of SLO would consider Alternative 4 infeasible, because it does not include the
same land use plan as envisioned for the Specific Plan. Therefore Alternative is not a viable alternative
for purposes of CEQA.
OTHER FEASIBLE ALTERNATIVES
Additional “Alternative 3A” - Proposed herein by Michael Sullivan in
response to this Draft EIR for San Luis Ranch
Alternative 3 A as proposed by me would be nearly identical to the Specific Plan, but would remove
50 housing units, as shown in the table below, “TABLE 01 - Compare “ALTERNATIVE 3A” with
Specific Plan as proposed in DEIR, Table 2-1.” Extra open space could be added to the Specific Plan,
as a result of this reduction in housing. I propose that this extra open space (additional 2.6 acres,
yielding 6.0 acres total of open space) could be used in a widening of the parkway along the east bank
of Prefumo Creek, from Madonna Road to Froom Ranch Road, to include a widening of some of the
open space area within the eucalyptus grove and habitat area, as envisioned in DEIR part 25, Fig. Fig.
6-1 (Measure J plan).
TABLE 01 ‐ Compare “ALTERNATIVE 3A” with Specific Plan as proposed in DEIR, Table
2‐1
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
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LAND USE
TYPE
(See DEIR,
Fig. 2‐4, Fig.
2‐5, Fig. 2‐6,
and Table 2‐
1)
Specifi
c Plan
>>>>>
Specifi
c Plan
ZONE
Specifi
c Plan
>>>>>
UNITS
Specific
Plan
>>>>>
ACREAGE
ALT.
PLAN
3A
Specific
Plan
ZONE
ALT.
PLAN 3A
UNITS
ALT. PLAN
3A
APPROX.
ACREAGE
REQUIRED
Net
gain of
usable
acreage
Low‐
medium
density
residential
(Medium
density
SFR, as in
Fig. 2‐6)
NG‐10 200 16.0 acres
Density =
0.08 Acres /
unit) = 3484
sq ft / unit
NG‐10 170
13.6
acres
16.0 ‐
13.6. =
2.4
acres
for
NG‐10
Medium‐
density
residential
(Medium‐
high
density
SFR, as in
Fig. 2‐6)
NG‐23 100 6.8 acres
Density =
0.068 acres /
unit = 2962
sq ft / unit
NG‐23 100 6.8 acres
High‐
density
residential
(MFR, and
High
Density
MFR, as in
Fig. 2‐6)
NG‐30 200 10.4 acres
Density =
0.052 acres /
unit = 2265
sq ft / unit
NG‐30 180
Pertains to
MFR land,
adjacent to
Madonna
Road and
Prefumo
Creek )
9.36
acres
10.4 ‐
9.36 =
+1.0
acre
for
NG‐30
Affordable
housing
density
bonus
80 n/a 80
Commercia
l (NC)
NC up to
150,00
0 SF
9.7 acres NC up to
150,000
SF
9.7 acres
Office NC up to
150,00
0 SF
3.9 acres NC up to
150,000
SF
3.9 acres
Hotel and
conference
center
NC 200
rooms
3.6 acres NC 200
rooms
3.6 acres
Public
parks
3.4 acres 6.0 +2.6
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
Page 8 of 13
TABLE 01 ‐ Compare “ALTERNATIVE 3A” with Specific Plan as proposed in DEIR, Table
2‐1
LAND USE
TYPE
(See DEIR,
Fig. 2‐4, Fig.
2‐5, Fig. 2‐6,
and Table 2‐
1)
Specifi
c Plan
>>>>>
Specifi
c Plan
ZONE
Specifi
c Plan
>>>>>
UNITS
Specific
Plan
>>>>>
ACREAGE
ALT.
PLAN
3A
Specific
Plan
ZONE
ALT.
PLAN 3A
UNITS
ALT. PLAN
3A
APPROX.
ACREAGE
REQUIRED
Net
gain of
usable
acreage
acres acres
Regional
and local
roads
8.1 acres 8.1 acres
Local roads 9.4 acres 9.4 acres
Agriculture and
open space
Agriculture A 52.7 acres 52.7 acres
Internal
open
spaces
P/OS 7.4 acres P / OS 7.4 + 3.4 =
10.0
acres
Total
3.4
add’l.
acres
for
P / OS
Advantages of “ALTERNATIVE 3A”
1. ALTERNATIVE 3A retains all the features of the proposed Specific Plan except for a
modest reduction of 50 housing units.
2. Larger corridor of available space (a net gain of 2.6 acres) for protection of park / open
space. This extra land could be used for
‐ Better protection of biological resources / habitat / wildlife corridor along the eastern
bank of Prefumo Creek and extending into the eucalyptus grove nearby which is in need of
protection for bird nesting sites, wildlife corridor, etc.
‐ A larger area for human recreation uses or open spaces uses such as strolling, sitting,
bird‐watching, etc.
‐ More area available for on‐site flood detention
‐ Alternative 3A would provide about 6.0 acres of park land, ant that meets the standards
of the General Plan. See: Land Use Element Policy 8.1.4. (SP‐2, San Luis Ranch (Dalidio) Specific
Plan Area).
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3. ALTERNATIVE 3A has environmental advantages similar to those in ALTERNATIVE 3:
Alternative 3A would reduce other potential environmental effects because a reduction in
the footprint of Multi‐family Residential use in the northwest corner of the project site
(i.e. adjacent to Madonna Road and Prefumo Creek) would allow more preservation of the
eucalyptus grove in the northwest portion of the project site along Madonna Road, and
reduced overall development footprint. Because of a reduced number of residential units,
Alternative 3A would likely have benefits similar to those of Alternative 3, i.e. reduced
impacts to air quality, GHG emissions, noise, biological resources, land use/policy
consistency, and hydrology and water quality. In Alternative 3A, San Luis Ranch Way
access route would remain. In Alternative 3A, as in the approved Specific Plan, some of
the historic Dalidio ranch buildings would be moved to the other site near the agriculture
use area.
“..... Alternative 3 would provide the same amount of parkland as the project – 3.4 acres– which is lower
than the minimum of 5.8 acres required by the performance standards described in Land Use Element
Policy 8.1.4. (SP‐2, San Luis Ranch (Dalidio) Specific Plan Area). As a result, Alternative 3 would be
similarly inconsistent with this policy in the City’s General Plan.” DEIR at p. 6‐13. In contrast, proposed
ALTERNATIVE 3A would provide about 6.0 acres of on‐site public park area, which meets the
performance standards of minimum parks area of Land Use Element Policy 8.1.4. (SP‐2, San Luis Ranch
(Dalidio) Specific Plan Area).
Overall, Alternative 3A could result in fewer General Plan policy inconsistencies when compared to the
project.
As discussed below, Alternative 3A could have somewhat smaller environmental problems compared to
the Specific Plan.
Alternative 3A could provide potential decrease in severity of certain
impacts such as:
‐ Improved Air quality (because of the reduction in number of housing units by 50 total units)
‐ Better conformance with General Plan Land Use element part 1.10.4. Design Standards
(because of preservation of more of the land adjacent to Prefumo Creek and land in the existing
eucalyptus grove near there):
“The City shall require cluster development to:
A. Be screened from public views by land forms or vegetation...
C. Prohibit building sites and roads within stream corridors and other wetlands, on ridge lines,
rock outcrops, or visually prominent or steep hillsides, or other sensitive habitats or unique
resources as defined in the Conservation and Open Space Element.” LUE 1.10.4.
‐ Better conformance with General Plan Land Use Element requirements for internal open space
(because ALTERNATIVE 3A provides an additional 3.4 acres for P/OS (parks / open space), i.e.
total of 10.0 acres for P/O (parks/open space) which could be applied to widen the strip of P/OS
land adjacent to the east side of Prefumo Creek from Madonna Road to Froom Ranch Way.
ALTERNATIVE 3A would have an open space plan similar to that in Figure 6‐1 (DEIR at p. 6‐8)
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
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shows the open space / park plan in the strip of land adjacent to the east side of Prefumo Creek,
with added open space land within the eucalyptus grove.
The San Luis Ranch Draft EIR states,
“the project includes a commitment to procure an off‐site agricultural conservation
easement/deed restriction such that one half of total land on‐site is preserved for agricultural
and open space use. In addition, the project would provide restored and enhanced wildlife
habitat areas.” DEIR at p. 4.9‐11, Table 4.9‐1.
‐ If the additional on‐site 3.4 acres of P/OS (parks/open space) land of ALTERNATIVE 3A were
available, less dedication of off‐site land would be needed.
>>>>>>
Problems in the Project Design
1. Insufficient parks/open space (P/OS) area (7.4 acres total). Public parks: 3.4 acres
within P/OS areas.
As shown on Figure 2‐6, the proposed open space would be located on the northwestern
portion of the project site along Prefumo Creek, as well as along Cerro San Luis Channel, which
is a permanent surface drainage that traverses the property from east to west. The open space
areas would also include a link in the Bob Jones Regional Trail. (Where is that Bob Jones Trail
link shown on Figure 2.6? Is it the strip of green at the northeast side of the commercial area in
the north part of the site?)
DEIR Figure 2‐4 shows proposed types of land use at the project site. The largest NC area (north part of
the site) shows a P/OS strip of land (about 40 or 50 feet wide, based on Fig. 2‐9, northeast of that NC area,
adjacent to Dalidio Drive. That strip of land should not be counted as P/OS (park / open space)_area
because it is merely a very narrow strip squeezed between a busy street and the commercial use. It is
actually more of a landscaped frontage and not a true park / open space. It should remain landscaped,
but it should not be counted as P/OS area. That is deceptive. Instead, the P/OS strip adjacent to Prefumo
Creek / Oceanaire Drive should be widened to better provide P/OS area that serves several important
functions:
(a) Preservation of a wider buffer between the existing residences (Oceanaire Drive) and the residential
NG‐30 and NG‐10 uses.
A wider buffer of P/OS adjacent to Prefumo Creek / Oceanaire residences can provide:
(a) larger wildlife corridor and habitat area,
(b) less intrusion of development on bird nesting areas in the eucalyptus forest area,
(c) larger area for pedestrian uses e.g. sitting, strolling, enjoying the creek, for people living in the
various residential use areas on the project site as well as for people living in nearby residential
neighborhoods outside of the project site,
(d) a more pleasing visual border, and more feeling of open‐ness,
(e) a wider creek floodplain area, yielding better flood control protection of adjacent on‐site residences
2. No P/OS buffer between residential use (medium high‐density SFR) and commercial use. (DEIR,
Fig. 2‐6).
A P/OS buffer between these uses, even if relatively narrow, greatly enhances the living experiences for
the residential use.
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
Page 11 of 13
>>>>>
Alternative 3A would enhance the achievement of the following parts of the Land
Use Element of the General Plan:
SLO City Gen Plan - Land Use element
6.6. Creeks Wetlands, and Flooding Policies
San Luis Obispo's aquatic ecosystems consist of creeks, Laguna Lake, floodplains, marshes, wetlands,
serpentine seeps, and springs. These aquatic ecosystems provide habitat, recreation, water purification,
groundwater recharge, and soil production as well as natural flood protection by reducing the force of
floodwaters as they spread and decelerate over floodplains. Creeks, which are the most obvious of these
systems because they flow under and through the City, provide wildlife habitat, backyard retreats, and
viewing and hiking pleasures, in addition to carrying storm water runoff. When some creeks overflow during
major storms, they flood wide areas beyond their channels (Figure 8). San Luis Obispo wants to avoid injury
or substantial property losses from flooding, while keeping or improving the creeks' natural character, scenic
appearance, recreational value, and fish and wildlife habitat.
6.6.1. Creek and Wetlands Management Objectives
The City shall manage its lake, creeks, wetlands, floodplains, and associated wetlands to achieve the multiple
objectives of:
A. Maintaining and restoring natural conditions and fish and wildlife habitat;
B. Preventing loss of life and minimizing property damage from flooding;
C. Providing recreational opportunities which are compatible with fish and wildlife habitat, flood protection,
and use of adjacent private properties.
D. Recognizing and distinguishing between those sections of creeks and Laguna Lake which are in urbanized
areas, such as the Downtown core, and sections which are in largely natural areas. Those sections
already heavily impacted by urban development and activity may be appropriate for multiple use
whereas creeks and lakeshore in a more natural state shall be managed for maximized ecological value.
6.6.2. Citywide Network
The City shall include the lake, creeks, and wetlands as part of a citywide and regional network of open space,
parks, and – where appropriate – trails, all fostering understanding, enjoyment, and protection of the natural
landscape and wildlife.
6.6.6. Development Requirements
The City shall require project designs that minimize drainage concentrations and impervious coverage.
Floodplain areas should be avoided and, where feasible, any channelization shall be designed to provide the
appearance of a natural water course.
>>>>>>>>>>>>>>>>>>
2. The Specific Plan lacks a connection from the project site to Laguna Lake park
that is safe for pedestrians and bicyclists.
Two key intersections on Madonna Road (at Oceanaire Dr. and at Dalidio Dr.) provide access from the
SP project site to the Laguna Lake park. However, both of these intersections will be heavily impacted
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
Page 12 of 13
with traffic because of the project. These very busy intersections would likely have long wait times for
pedestrian crossing (at the signals). And, there is a danger to bicyclists at these two intersections,
especially at dusk and night time and during rush hours (7 am - 8:30 am and 4:30 pm - 6:30 pm).
The population size of residents living at San Luis Ranch SP are will be significant. People living
there will want more outdoor recreational opportunities than those provided on-site. Many of these
people will wish to use Laguna Lake park for various activities, e.g. hiking (in the park and beyond the
park in the hills), walking the dog, canoeing, fishing, using the par course, playing outdoor games, bar-
b-que, picnics, larger group activities, etc. Many of these activities are not possible within the Specific
Plan site, so there will be a significant need for access to Laguna Lake park from the SP site.
The City should consider the option of a pedestrian bridge, either at Oceanaire Dr., or at Dalidio Dr.,
crossing Madonna Road. The city should provide information about the probable cost of such a bridge
and funding mechanisms, and who would be responsible for paying for it.
>>>>>>>>>>>>>>
3. The Specific Plan does not consider the whole-city bicycle plan. What are the
standards for bicycle paths from the Prado Road / US 101 intersection to Broad
Street (via the Santa Margarita area and Damon Garcia Sports Fields?)
As the Margarita Area and Airport Area planning areas are developed, there will be more of a need for
bicycle connection between those areas and the San Luis Ranch residences and commercial areas.
Damon Garcia Sports Fields also are an attraction for residents of San Luis Ranch. The best possible
solution would be class 1 bike paths along the whole length of Prado Road, between Prado Rd. / US
101 intersection and Prado Rd. / Broad St. intersection. Is that being considered by the City? Would
such a scheme be incorporated as part of conditions of approval of San Luis Ranch Specific Plan, or
otherwise incorporated into the General Plan of SLO City?
>>>>>>>
4. The housing plan of the Specific Plan is not optimized for several issues:
(a) Parking - For example, as discussed below, some of the single-family residential units have
difficult series parking (2 cars parked head to tail) rather than parallel parking (2 cars parked parallel to
each other. This makes it difficult to park.
(b) Screening / buffers - Buffers and/or screening between certain residential uses and commercial
uses are inadequate. For example, the single-family housing area adjacent to the commercial areas is
directly adjacent. It could have at least a narrow strip of vegetation and/or fencing.
(c) Amount of area for internal parks within the site. This is addressed in Alternative 3A, below.
(d) Insufficient storage. Do the housing units with carports instead of garages have sufficient storage?
Probably not.
>>>>>
5. San Luis Ranch Specific Plan (including land use plan) is probably inconsistent
with General Plan of City of San Luis Obispo for various reasons.
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_A
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A. Amount of required open space / agricultural land for Specific Plan is probably inconsistent with
General Plan.
The General Plan requires approximately 50 % open space / agricultural use for the San Luis Ranch Specific
Plan site. It is my understanding that the original intent of the General Plan was that this 50% requirement
applies to the whole site area (131 acres total) and not to a reduced area remaining after accounting for
roadways, on-ramps, off-ramps, etc. This means about 65.5 acres would be required for agriculture / open space
use at San Luis Ranch Specific Plan site. Therefore, apparently the amount of agriculture / open space in that
plan is insufficient.
If the proper standard for amount of agriculture / open space is not 65.5 acres (50% of the total 131 acres site
area), but rather some smaller acreage based on a smaller computed net site acreage, what is the documentation
for such an interpretation? Was such an interpretation officially approved by City Council action? Please
explain.
B. Housing affordability for “workforce” people - Is such housing as proposed truly affordable for
workforce people?
- How is “workforce” defined? What is their median and average income per person and per household
assumed to be? How is this determined?
- What are the assumptions of current (January 2017) housing costs for all types of housing in the SLO area, for
comparison? Is there also comparison of housing costs in other nearby communities for comparison, e.g. Los
Osos, Santa Margarita, Grover City, Oceano, etc.?
- For condominium or other types of multi-family housing, or for single family housing areas: What
Homeowner Association (HOA) Fees are anticipated? How is the Homeowners Association governed? What
are the approximate anticipated monthly fees for HOA fees when the first units are completed?
Is there any mechanism to regulate how rapidly the HOA fees may be increased from year to year?
- What about “workforce” people who at the lowest end of the range of monthly gross income? Is there any
chance they will also qualify for the affordable housing units?
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_B
Page 1 of 2
(Transcript)
Los Angeles Times (Los Angeles, California) - Friday, June 30, 2017 A9
_____
Air pollution, even in amounts below the legal limit, is linked to premature death in seniors, analysis
finds.
_____
By Tony Barboza
At a time when the Trump administration is moving to delay and dismantle air quality
regulations, a new study suggests that air pollution continues to cut Americans’ lives short, even at levels
well below the legal limits set by the U.S. Environmental Protection Agency.
The nationwide study of more than 60 million senior citizens linked long-term exposure to two main
smog components-- ozone and fine particulate matter--- to an increased risk of premature death.
The analysis found no sign of a “safe” level of pollution, below which the risk of dying early
tapered off.
Harvard University scientists who conducted the study calculated that reducing fine particle
pollution by 1 microgram per cubic meter nationwide would save about 12,000 lives each year. An
additional 1,900 lives would be saved annually by lowering ozone pollution by 1 part per billion, they
found.
The study appears in Thursday’s edition of the New England Journal of Medicine.
Fine particulate matter is composed of tiny health-damaging specks of pollution that can lodge
deep in the lungs and are linked to cardiovascular disease. Ozone, the lung-searing gas in warm-weather
smog, triggers asthma and other respiratory illnesses. Both pollutants build up in the air largely as a
result of emissions from vehicles, power plants and other major combustion sources.
For the analysis, researchers developed a new computer model that uses on-the-ground air-
monitoring data and satellite-based measurements to estimate pollution levels across the continental U.S.,
breaking the country up into 1-square-kilometer zones.
They paired that information with health date contained in Medicare claims records from 2000 to
2012 for all beneficiaries in the 48 contiguous states, a group that represents about 97% of the population
ages 65 or older.
The high-resolution date allowed scientists to estimate the health effects of air pollution at levels
far below the federal limits. For fine particulate matter, which has a legal limit of 12 micrograms per
cubic meter, the lowest amount they measured.
For ozone, which has an EPA limit of 70 parts per billion, they detected increased mortality levels
as low as 30 parts per billion, also the smallest concentration they measured.
The researchers calculated that when the concentration of particulate matter rose by 10
micrograms per cubic meter, the chances that a senior citizen would die during the study period rose by
7.3%. And when the ozone concentration rose by 10 parts per billion, the chances of early death rose by
1.1%. In both cases, the researchers controlled for factors such as smoking behavior, weight and income,
which are also likely to affect a senior’s risk of premature death.
The findings suggest that even though federal limits on the nation’s most widespread air
pollutants are updated periodically based on scientific reviews required under the Clean Air Act, they are
not strong enough to fully protect the public.
Critics may claim that stronger standards would offer diminishing returns, but the study results
provide new evidence than they would actually increase health benefits, with fewer people getting sick
and dying from dirty air, said Francesca Dominici, a data scientist at the Harvard T.H. Chan School of
Public Health and the study’s principal investigator.
“We are seeing that the air that we are breathing right now is harmful, it’s toxic,” Dominici said.
An editorial that accompanies the study said the findings “stress the need for tighter regulation of
air pollutant levels” and stricter limits on fine particulate matter.
“Despite compelling data, the Trump administration is moving headlong in the opposite
direction,” the editorial said, citing the president’s recent steps to dismantle emission-cutting rules,
2017-07-05_SLO_City_Council_San_Luis_Ranch_hearing_Comments_of_M_Sullivan_ATTACHMENT_B
Page 2 of 2
withdraw from the Paris climate accord and slash the EPA’s budget. “The increased air pollution that
would result from loosening current restrictions would have devastating effects on public health.”
The findings have important implications for California, where millions of people breathe the
nation’s highest levels of ozone and fine particulate matter.
Despite decades of improvement, the air in Southern California and the San Joaquin Valley
remains far from meeting federal health standards.
The new study adds to a robust body of research going back to the early 1990s associating fine-
particle pollution with shortened lives. But most of those studies were limited to populations in wealthier
and well-monitored urban areas, the researchers said.
The enormous sample size-- encompassing nearly all Americans over 65-- allowed scientists to
examine air-quality differences across all parts of the country, including small cities and rural areas, and
among various ethnic and socioeconomic groups.
The researchers found that men, blacks, Asians, Latinos and lower-income seniors all faced
higher risks of premature death from fine particulate matter. Black seniors were three times as likely as
seniors overall to die prematurely.
Under the Clean Air Act, the EPA must review national air quality standards for six major
pollutants every five years and adjust them if necessary to reflect the latest science.
The 12-micrograms-per-cubic-meter standard for fine particulate matter was last updated in 2012.
The federal standard for ozone was last strengthened in 2015 and is now being re-examined by the Trump
administration.
This month, EPA administrator Scott Pruitt announced a one-year delay in implementing the
federal ozone standard, citing “increased regulatory burdens, restrictions on infrastructure investment, and
increased costs to businesses.”
The decision allows California and other states with ozone levels above the current standard to
postpone the adoption of emissions-cutting measures.
Pruitt, who in his previous job as attorney general of Oklahoma made a career of suing to block
federal EPA regulations, is also moving to reshape the agency’s science advisory boards. These include
the committee that makes recommendations on federal air quality standards.
Environmentalists and health advocates fear Pruitt will replace academic experts with
representatives of regulated industries.
__________
tony.barboza@latimes.com
Twitter: @tonybarboza
>>> END >>>