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HomeMy WebLinkAbout02-28-2018 Item 2 - Cooper To:Scott Lee, Parking Manager & Tim Bochum, Deputy Director Transportation Re: Comments on the Palm/Nipomo Parking Structure Project DEIR From:Allan Cooper, San Luis Obispo Date:February 16, 2018 I believe that the DEIR should have identiÐed the Åenvironmentally superior alternativeÆ to be Alternative 1: No Project because this garage will not meet the Åproject objectivesÆ which are Åto ameliorate the current high demand for parkingÆ (see below). However, if the Council decides to move ahead with the construction of a garage at this location then I would urge them to select the DEIRÈs other environmentally superior alternative, Alternative 4: Historic Resource Preservation, which would include the parking structure and 5,000 square feet of commercial space, but retain the two houses at 610 and 614 Monterey Street. The theater would not be included as part of this alternative. After all, why is the City favoring the SLO Repertory Theatre when there are numerous other non-proÐts that could beneÐt from such a facility? A decision was made by Council on April 4, 2017 to build the parking structure Ðrst while other components, such as the Repertory Theatre, could be built later when funding is in place. The CityÈs January 19, 2006 MOA with the Repertory Theatre is no longer binding. We are encouraging Council to hold off on pursuing a new MOA with the Repertory Theatre. However, I would prefer that Alternative 4 be modiÐed by replacing the 5,000 square feet of commercial space with ofÐces at the Ðrst level and residential on the second story along this stretch of Nipomo Street because the commercial development proposed to be located along Nipomo Street is inappropriate. It will be isolated from the main shopping areas in the downtown core. What is missing in this DEIR is a trafÐc analysis taking into account that the Broad Street ÅdoglegÆ may be partially or totally closed (now formally part of the Downtown Concept Plan), that Broad Street may become a bicycle boulevard and that the Highway 101 off- and on-ramps accessing Broad Street may someday be closed. The DEIR states: ÅThe City of San Luis Obispo is in the process of updating the Mission Plaza Concept Plan, which may result in changes to the Broad Street Çdog legÈ. The cumulative forecasts were developed assuming no changes to vehicle access near Mission Plaza. The modiÐcations under consideration as part of the Mission Plaza Concept Plan would not substantially change the Ðndings of this transportation analysis (CCTC 2017). No other roadway network changes affecting the study locations were assumed to be in place under cumulative conditions.Æ How can one assume that no cumulative changes would result from the closure of the Ådog legÆ or that other Åroadway network changesÆ (i.e., closure of the Broad Street on/off ramps and a proposed bicycle boulevard)? The DEIR further states: ÅConsistent with the CityÈs Multimodal Transportation Impact Study Guidelines, a neighborhood trafÐc analysis that evaluates ADT on roadways classiÐed as Local Residential is not included in this section because the study area roadways are classiÐed as Local Commercial roadways.Æ This project is surrounded with residential development and two schools. I believe that, before this project goes any further, there should be a neighborhood trafÐc analysis. Moreover, such an analysis could help determine the best location for a 4th parking garage. The noise analysis is surprising in that there is no prediction of increased decibel levels along Broad between Highway 101 and the proposed garage. See below: ÅThe addition of project generated trafÐc would increase noise levels along the projectÈs studied roadway segments. As shown in Table 17, residences along Palm Street would experience a roadway noise level increase of approximately 1.0 dBA, which would result in an ambient noise level of approximately 60.4 Ldn. Residences along Nipomo Street would experience an increase in roadway noise levels of 0.7 dBA, resulting in an ambient noise level of 63.5 Ldn. Both Broad Street and Monterey Street would not exhibit changes in ambient noise levels, based on the number of trips generated by the project, therefore, noise impacts along these roadways would be less than signiÐcant.Æ WouldnÈt one surmise that there would be increased usage of the Broad Street/Highway 101 on- and off-ramps once the garage is installed? In conclusion, the DEIR states that Alternative 1: No Project/No Development could also be considered environmentally superior to the proposed project because the site would remain as is and it would not result in any signiÐcant environmental impacts; however, it would not meet the project objectives. However, there is no demonstrable need at this time for this project in that there is little demand for parking at this end of town. In 2015, Walker Parking Consultants stated ÅThe location of the planned Palm/Nipomo parking structure is not ideal to ameliorate the current high demand for parking experienced on streets and in some surface lots Downtown.Æ The demand exists, instead, in the major growth areas east of Santa Rosa. The 2014 Walker Parking Consultant demand study projected that occupancy would be at 60%. Over 1/3 of the parking spaces will remain unoccupied. Private and public development projected to take place here in this part of town will take years to develop. We should also recognize that back when the Ðrst demand study was written in 2009 the size and scale of both the Garden Street Terraces and Chinatown projects were signiÐcantly greater than now. If the Palm/Nipomo parking structure will not ameliorate the current high demand for parking, then does this garage at this location meet Åthe project objectivesÆ? Moreover, the construction cost projection ($23,600,000) may be too low (at $53,034 per space for a 445 space facility) and it is Ðscally irresponsible to prepare an EIR that will cost $1.65 million without any proof that this project is needed. The Walker report warns that any exclusive use of the parking structure will likely mean that Åany Ðnancing will not be funded through tax exempt bonds and would likely increase Ðnancing costsÆ. This exclusive use refers to the demand for parking for Monterey Place (65 spaces) and SLO Museum of Art (39 spaces). This additional Ðnancing cost will only further burden a City that has let it's unfunded liabilities build up over the years This money (were it to be available) would be better spent on alternative transportation systems. The City should look at decentralized solutions to the parking problem taking into account emerging technologies and changes to driving and parking dynamics. Thank you!