HomeMy WebLinkAbout8/14/2018 Item 2, GurneeT. Keith Gurnee
August 14, 2018
HAND DELIVERED
John Fowler, Chairman
Planning Commission
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Subject: The Anholm Bikeway
Dear Chairman Fowler:
As a resident of the historic Anholm neighborhood since 1972, my wife and I have been alarmed at what
the city has been trying to do to our neighborhood with its Anholm Bikeway plans. For the better part of
two years, the neighborhood has pulled together to develop some design ideas of its own as a counter
proposal to what the city is trying to do to the place where we live.
This letter and its attachments is a representation of the views of Anholm Neighbors United (ANU), an
affiliation of a number of neighborhood residents who have gotten together multiple times during this
process to brainstorm how to protect the livability and character of our neighborhood. As the
representative of this group, I hope that we might be given up to 10 minutes at tonight's Planning
Commission hearing to present our neighborhood -based design ideas for the streets that serve us.
Attached to this letter are the following documents:
• A narrative of our proposed ideas and recommendations,
• A set of graphics representing those ideas, and
• A report prepared by Douglas Wood and Associates on the flawed CEQA analysis associated with this
project and outlining a series of recommendations to bring the project into compliance with CEQA.
This is a project of profound importance, not only to our neighborhood but to our city as a whole. We look
forward to presenting our thoughts and recommendations in the hopes that the Planning Commission will do
the right thing by our neighborhood.
Sincerely,
a•� 6 IW
T. Keith Gurnee
CC: Jake Hudson
Anholm Neighbors United
August 14, 2018
Introduction: Anholm Neighbors United (ANU) is a work group comprised of 15 residents of the Anholm
Tract, one of the city's most desirable historic neighborhoods. It was formed well over a year ago out of
concern for what the city was proposing to do to our neighborhood with the Anholm Bikeway project.
Since that project has been in the works for over two years, ANU has met 6 times to consider the various
City proposals and to craft some ideas of its own as counter -proposals to the plans devised by the city.
While those of us who live in the Anholm neighborhood feel that Broad and Chorro have been successful
and safe as shared streets, it became clear to us that our city leadership is determined to do something
to our neighborhood. We concluded that we needed to come up with a "least worst" option that the
neighbors could live with as an alternative to the city's proposals.
As a result, ANU has offered a_ range of design ideas generated from within the neighborhood. Those
neighborhood ideas which have evolved over time have always been intended to:
• Improve public safety for all modes of travel
• Preserve as much on -street parking is possible in the neighborhood
• Retain Broad and Chorro as shared streets that have worked well for years, and
• Do no harm to our neighborhood.
The neighborhood's earlier design ideas received a strong positive response from the large audience
that attended a city -organized neighborhood meeting at the City/County Library earlier this year. Now
that city staff is presenting yet another alternative that has yet to be vetted with the community, so
do we have some new ideas we would like to present to you this evening.
Our Preferred Resolution: It is the consensus of our group that the best solution is to leave things as
they are. Why?
➢ The system of shared streets on Chorro and Broad has worked well for years. Bicycle ridership is
noticeably up, and there have been no car -on -bike or bike -on -car accidents recorded reported
by the Police Department in the last five years.
A The elimination of any on -street parking would create a severe hardship for residents living
along Broad and Chorro.
➢ The city should take the money it would spend on the Anholm Bikeway and devote those funds
to making public safety improvements for bike lanes on arterial streets like Foothill Boulevard
which is where the accidents and fatalities are occurring.
➢ Based on the staff report, the "No Project" alternative is the most "environmentally preferred
alternative" resulting in the least amount of traffic impacts on Chorro Street.
In other words, "if it ain't broke don't fix it!" It's a solution looking for a problem and a waste of public
funds.
The Staff -Recommended Alternative: The city remains determined to do something to our
neighborhood as evidenced by the latest staff recommended alternative being considered by the
Planning Commission this evening. This alternative, which the public is seeing for the first time tonight,
has yet to be vetted with the neighborhood and the greater community. This latest alternative is
consistent with the Council's direction provided at its meeting of April 20, 2018 to provide "diversion"
on Broad Street. While it has some features that our neighborhood could live with, there is only one
feature that is a nonstarter for our neighborhood: the diverter that calls for the full closure of Broad
Street between Ramona Street and Meineke that would allow through passage for bicycles only.
This suggested diverter would destroy the connectivity and functionality of our neighborhood by closing
off access from both Broad and Chorro to our neighborhood grocery store. Traffic to that store from
Broad would be diverted onto Meineke to Chorro, then north onto the Foothill/Chorro interchange
which will be heavily impacted by the 22 Chorro and the 790 Foothill projects. Should 790 Foothill be
approved by the city, the Broad/Chorro/Foothill intersections will be a nightmare to navigate.
The staff's recommended alternative will result in increased traffic volumes on Chorro to the point
where the Circulation Element would have to be amended to reclassify Meineke, Chorro, and Lincoln as
streets meeting irto carry higher levels of traffic than they are currently designed to carry under the
LUCE. In other words, the city. is proposing a project that is inconsistent with its General Plan.
Hence, we have endeavored to come up with an alternative solution that we feel could meet the city's
goals with minimum impacts to our neighborhood.
The Neighborhood Alternative: The ideas generated by the neighborhood would keep Broad and
Chorro as shared streets. Our ideas are intended to slow traffic speeds and hopefully traffic volumes on
Broad, Chorro, Meineke, and Lincoln while maintaining ease of access to our neighborhood shopping
center, retaining the maximum amount of on -street parking, and improving public safety. The latest
ideas derived from our group also need to be thoroughly analyzed and vetted with the greater
neighborhood and community.
We would like to see an alternative that would include many of the features suggested by staff while
modifying others. In addition to the traffic calming measures suggested by staff i.e. bulb -outs, speed
bumps, and speed pillows, etc., these would be the features of the Neighborhood Alternative that would
include two (2) diverters:
➢ The Ramona/Broad Diverter: We recommend a diverter design that would close only the
southbound lane on Broad while leaving the northbound lane open to Foothill Boulevard. The
design of this diverter would also reduce traffic volumes on Meinecke and Chorro and possibly
obviate the need to amend the General Plan. We have shown two design options for this
diverter:
1. The Northern Ramona/Broad Diverter: This option would close the southbound lane on
Broad Street from Ramona to the first driveway entrance to the shopping center. The street
closure could be devoted to a mini parklet with seating areas and a bioswale. This would
allow residents of the Anholm neighborhood to freely access the shopping center using
Broad Street and returning to their residences using Ramona to Broad. The advantage of this
option is that there would have to be no circuitous movements to gain access to and from
the shopping center without having to use Foothill Boulevard.
2. A Southern Ramona/Broad Diverter: This option would involve closing the southbound lane
of Broad Street between Ramona and Meineke while leaving the northbound lane of Broad
open. This diverter would also contain a bioswale while incorporating a southbound
protected Class I bike Lane between Ramona and Meineke. While this option would allow
free northbound access to both the shopping center and Foothill Boulevard, traffic from
those locations back to the Anholm neighborhood would be more circuitous and require the
use of side streets.
➢ The Mountain View/Broad Street Diverter: This would involve placing a small diverter to block
northbound traffic from the 101 freeway on Broad at its intersection with Mountain View St.
The design of this diverter would force northbound traffic on to Mountain View over to Chorro.
It would also be designed to allow traffic on the southern stretch of Mountain View to take that
connection to Chorro.
➢ Extension of the Murray Street median: This concept would extend the existing landscape
medians on Murray into the Chorro Street intersection while providing gaps for emergency
vehicles, other vehicles, and bikes. The travel lanes on Chorro would be narrowed to a width of
11 feet in each direction separated by a raised grouted rock island. The pedestrian paths on both
medians would be connected to each other and remain ADA accessible. The southbound lane on
Chorro would have a speed pillow that would not interfere with responding emergency vehicles
but would slow other traffic. The northbound lane could either be configured the same way as
the southbound lane or it could be equipped with speed bumps connecting the grouted rock
feature to the median island. This configuration would allow for lower speed traffic and perhaps
lower traffic volumes on Chorro.
➢ Other Public Safety Improvements: We feel that the neighborhood could use some
enhancement of some public safety features such as bold painted crosswalks at side street
intersections along both Broad and Chorro, enhanced street lighting, and ADA accessible ramps
to sidewalks at crosswalk locations.
Evaluating the Alternatives: The City Alternative and the Neighborhood Alternative both need to be
fully vetted with the greater Anholm Neighborhood and the community at large. Before that, they also
need to be thoroughly evaluated based on traffic impacts on the Anholm neighborhood and the traffic
impacts associated with the full buildout and occupancy of the projects being considered and Foothill
and Chorro. A detailed cost analysis should also be provided for both alternatives.
Complying with CEQA: Local CEQA professional Douglas Wood of Douglas Wood and Associates has
worked with ANU to ensure that the city is fully complying with the California Environmental Quality Act
in its evaluation of this project. He has prepared a detailed report that has been attached to this
document outlining his and our concerns with how the city has failed to comply with CEQA, including a
set- of recommendations for the city to fully comply with CEQA.
In exhausting our legal and administrative remedies, Mr. Wood as outlined a series of deficiencies in the
city's CEQA analysis, and the last page of his report contains a series of recommendations to bring the
city into full compliance with CEQA. Mr. Wood will be presenting his findings contained in his report at
this hearing.
In Conclusion: ANU respectfully requests that the Planning Commission take the following actions on
the proposed Anholm Bikeway project and make the following recommendations to the City Council:
1. That the Council direct staff to continue this item to allow for a full traffic and fiscal analysis of
both the City Alternative and the Neighborhood Alternative and to conduct a thorough vetting
of both alternatives with the greater Anholm Neighborhood and the community at large.
Z After obtaining further public feedback from that thorough vetting, recommend that the
Council direct staff to complete a fully compliant CEQA analysis as recommended by Doug
wood of the recommended alternative derived from that public process.
ANHOLM
BIKEWAY • ,
CEQA
ANALYSIS
Douglas Wood & Associates, Inc.
1461 H guera Street, Suite A
San Luis Obispo, CA 93401.
August 7, 2 018
SECTION 2
RELEVENT CEQA GUIDELINES
Issue 1- General Concepts and Policies
SECTION 15002 GENERAL CONCEPTS
(g) Significant Effect on the Environment. A significant effect on the environment is
defined as a substantial adverse change in the physical conditions which exist in the
area affected by the proposed project. Further, when an EIR identifies a significant
effect, the government agency approving the project must make findings on whether
the adverse environmental effects have been substantially reduced or if not, why not
SECTION 15003 POLICIES.
(b) The EIR serves not only to protect the environment but also to demonstrate to
the public that it is being protected.
(c) The EIR is to inform other governmental agencies and the public generally of the
environmental impact of a proposed project.
(d) The EIR is to demonstrate to an apprehensive citizenry that the agency has, in
fact, analyzed and considered the ecological implications of its action.
(g) The purpose of CEQA is not to generate paper, but to compel government at all
levels to make decisions with environmental consequences in mind.
(h) The lead agency must consider the whole of an action, not simply its constituent
parts, when determining whether it will have a significant environmental effect.
(i) CEQA does not require technical perfection in an EIR but rather adequacy,,
completeness, and a good -faith effort at full disclosure. A court does not pass upon
the correctness of an EIR's environmental conclusions, but only determines if the
EIR is sufficient as an informational document
(j) CEQA requires that decisions be informed and balanced.
SECTION 15004 TIME OF PREPARATION
(b) Choosing the precise time for CEQA compliance involves a balancing of
competing factors. EIRs and negative declarations should be prepared as early as
feasible in the planning process to enable environmental considerations to influence
project program and design and yet late enough to provide meaningful information
for environmental assessment.
SECTION 15021. DUTY TO MINIMIZE ENVIRONMENTAL DAMAGE AND BALANCE
COMPETING PUBLIC OBJECTIVES
(a) CEQA establishes a duty for public agencies to avoid or minimize environmental
damage where feasible. (1) In regulating public or private activities, agencies are
required to give major consideration to preventing environmental damage. (2) A
public agency should not approve a project as proposed if there are feasible
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alternatives or mitigation measures available that would substantially lessen any
significant effects that the project would have on the environment.
(b) In deciding whether changes in aproject are feasible, an agency may consider
specific economic, environmental, legal, social, and technological factors.
(c) The duty to prevent or minimize environmental damage is implemented through
the findings required in CEQA.
(d) CEQA recognizes that in determining whether and how a project should be
approved, a public agency has an obligation to balance a variety of public objectives,
including economic, environmental, and social factors.
SECTION 15064. DETERMINING THE SIGNIFICANCE OF THE ENVIRONMENTAL
EFFECTS CAUSED BY A PROJECT
(a) Determining whether a project may have a significant effect plays a critical role
in the CEQA process. (1) If there is substantial evidence, in light of the whole record
before a lead agency, that a project may have a significant effect on the environment,
the agency shall prepare a draft EIR. (2) When a final EIR identifies one or more
significant effects, the Lead Agency and each Responsible Agency shall make a
finding under Section 15091 for each significant effect and may need to make a
statement of overriding considerations under Section 15093 for the project.
(b) The determination of whether a project may have a significant effect on the
environment calls for careful judgment on the part of the public. agency involved,
based to the extent possible on scientific and factual data. An ironclad definition of
significant effect is not always possible because the significance of an activity maX
vaU with the setting. For example, an activity which may not be significant in an
urban area may be significant in a rural area.
(c) In determining whether an effect will be adverse or beneficial the Lead Agency
shall consider the views held by members of the public in all areas affected as
expressed in the whole record before the lead agenc. Before requiring the
preparation of an EIR, the Lead Agency must still determine whether environmental
change itself might be substantial.
(d) In evaluating the significance of the environmental effect of a project the Lead
Agency shall consider direct physical changes in the environment which may be
caused by the project and reasonably foreseeable indirect physical changes in the
_environment which may be caused by the project
(e) Economic and social changes resulting from a project shall not be treated as
significant effects on the environment. Economic or social changes may be used,
however, to determine that a physical change shall be regarded as a significant
effect on the environment. Where a physical change is caused by economic or social
effects of a project, the physical change may be regarded as a significant effect in the
same manner as any other physical change resulting from the project. Alternatively,
economic and social effects of a physical change may be used to determine that the
physical change is a significant effect on the environment. If the physical change
causes adverse economic or social effects on people, those adverse effects may be
used as a factor in determining whether the physical change is significant. For
example, if a project would cause overcrowding of a public facility and the
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overcrowding causes an adverse effect on people, the overcrowding would be
regarded as a significant effect.
(f) The decision as to whether a project may have one or more significant effects
shall be based on substantial evidence in the record of the lead agency. (1) If the
lead agency determines there is substantial evidence in the record that the project
may have a significant effect on the environment, the lead agency shall prepare an
EIR (Friends of B Street v. City of Hayward (1980) 106 Cal.App.3d 988). Said
another way, if a lead agency is presented with a fair argument that a project may
have a significant effect on the environment. the lead agency shall prepare an EIR
even though it may also be presented with other substantial evidence that the
project will not have a significant effect.
CEQA COMPLIANCE: The City of San Luis Obispo is required by the California
Environmental Quality Act to follow the policies and guidelines noted above
when considering any project or development proposal submitted to the City.
These policies and guidelines include the following:
1. Proceed with production and certification of a thorough analysis of
potentially significant adverse impacts which leads to an informed and
balanced decision.
Z. Production of a complete environmental analysis based upon a good faith
effort at full disclosure.
3. Preparation of environmental documents as early as possible in the
planning process in order to enable environmental considerations to
influence the proposed project and its design.
4. Selection of a project design that avoids or minimizes environmental
damage.
S. Consideration of specific economic, environmental, legal, social and
technological factors in their decisions.
6. Consideration of significant effects based upon the actual project setting
rather than generalized conditions.
7. If there is substantial evidence that a project may have a significant impact
on the environment, an EIR will be prepared.
8. If the City is presented with a fair argument that a project may have a
significant impact on the environment, the City will prepare an EIR.
9. Consideration of the views held by members of the public particularly those
members of the public directly impacted by the proposed project.
R
Issue 2 - Consideration of ProjectAlternatives
SECTION 15126.6. CONSIDERATION AND DISCUSSION OF ALTERNATIVES TO THE
PROPOSED PROJECT
(a) Alternatives to the Proposed Project. 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. An EIR need not consider every conceivable alternative to
a project. Rather it must consider a reasonable range of potentially feasible
alternatives that will foster informed decision making and public participation.
(b) Purpose. Because an EIR must identify ways to mitigate or avoid the significant
effects that a project may have on the environment, 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-roject even if these
alternatives would impede to some degree the attainment of the project objectives
or would be more costly. Association of Environmental Professionals 2018 CEQA
Guidelines 178
(c) Selection of a range of reasonable alternatives. 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. The EIR should briefly
describe the rationale for selecting the alternatives to be discussed. The EIR should
also identify any alternatives that were considered by the lead agency but were
rejected as infeasible during the scoping process and briefly explain the reasons
underlying the lead agency's determination.
CEQA COMPLIANCE: The City of San Luis Obispo, as Lead Agency, is obligated
to consider a reasonable range of alternatives which are capable of avoiding
or substantially reducing any significant impacts of a proposed project.
Project alternatives should still be considered even though it may impede the
_attainment of other project objectives or would be more costly. Each of the
three Anholm Bikeway alternatives appear to meet these criteria and should
therefore be considered by the City in their selection of a future bikeway
design.
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Issue 3 -Use of Categorical Exemptions
Sections 15300 through 15332 of the State CEQA Guidelines provides a general list
of various types of projects which may not to have a significant effect on the
environment and are therefore exempt from the provisions of CEQA. This list of
exemptions includes 33 different classes or categories of exemptions, two of which
were used by the City to justify their Categorical Exemption finding for the first
phase of their bikeway alternative.
The City staff indicated in their report to the City Council that the Anholm Bike Plan
is categorically exempt from CEQA based on two classes or categories of exemption,
those being Class 1, Existing Facilities and Class 4, Minor Alterations to Land as
further discussed below. City staff is currently preparing construction documents
for these Phase I facilities with construction tentatively scheduled for the fourth
quarter of 2018. City Staff indicated that this portion of the project was categorically
exempt from any CEQA evaluation.
SECTION 15301. EXISTING FACILITIES
Class 1 consists of the operation, repair, maintenance, permitting, leasing, licensing,
or minor alteration of existing public or private structures, facilities, mechanical
equipment, or topographical features, involving negligible or no expansion of use
beyond that existing at the time of the lead agency's determination. The types of
"existing facilities" itemized below are not intended to be all inclusive of the types of
projects which might fall within Class 1. The key consideration is whether the
project involves negligible or no expansion of an existing use Examples include but
are not limited to (c) existing highways and streets, sidewalks, gutters, bicycle and
pedestrian trails and similar facilities.
15304. MINOR ALTERATIONS TO LAND
Class 4 consists of minor public or private alterations in the condition of land, water,
and/or vegetation which do not involve removal of healthy, mature, scenic trees
except for forestry or agricultural purposes. Examples include, but are not limited to
(h) the creation of bicycle lanes on existing rights-of-way.
SECTION 15300.2. EXCEPTIONS
(a) Location. Categorical Exemptions are qualified by consideration of where the
project is to be located. A project that is ordinarily insignificant in its impact on the
environment may in a particularly sensitive environment be significant. Therefore,
these classes are considered to apply all instances, except where the project may
impact on an environmental resource of hazardous or critical concern where
designated, precisely mapped, and officially adopted pursuant to law by federal,
state, or local agencies.
(b) Cumulative Impact. All exemptions for these classes are inapplicable when the
cumulative impact of successive projects of the same type in the same place, over
time is significant.
(c) Significant Effect. A categorical exemption shall not be used for an activity where
there is a reasonable possibility that the activity will have a significant effect on the
environment due to unusual circumstances.
SECTION 15382. SIGNIFICANT EFFECT ON THE ENVIRONMENT
"Significant effect on the environment" means a substantial, or potentiallX
substantial, adverse change in any of the physical conditions within the area
affected by the project, including, but not limited to, land, air, water, minerals, flora,
fauna, ambient noise, and objects of historic or aesthetic significance. An economic
or social change by itself shall not be considered a significant effect on the
environment. A social or economic change related to a physical change may be
considered in determining whether the physical change is significant.
CEQA COMPLIANCE: According to the State CEQA Guidelines, certain classes of
projects may be exempt from CEQA analysis if they have no significant impacts
upon the environment. The City of San Luis Obispo has already issued a
categorical exemption for the first phase of the City's bikeway alternative.
Their decision was based upon the Class 1 and Class 4 categorical exemptions
noted above. In both categories, an exempt project is described as "bicycle
and pedestrian trails" (Class 1 exemption) and "the creation of bicycle lanes
on existing rights-of-way." (Class 4 exemption). Each of the Anholm Bikeway
Alternatives involve several elements in addition to the creation of bicycle
lanes. Each of three bikeway alternatives contain some or all of the following
elements: provision of traffic diverters, the permanent closure of roadways,
the provision of pedestrian sidewalks, installation of a median island and
speed pillows, installation of speed bumps in addition to the existing speed
bumps on Broad Street, the loss of existing on -street parking and the
provision of protected bike lanes through the use of barriers to separate
bicyclists from automobile traffic. Given the nature and extent of these
additional facilities, it is apparent that all of the proposed bikeway
..alternatives involve more than merely the provision of bicycle lanes within
existing rights-of-way. As such, the use of Categorical Exemptions for any of
the proposed bikeway alternatives in order to avoid further environmental
analysis is contrary to the letter and intent of the State CEQA Guidelines.
Any Categorical Exemption which avoids further environmental review can be
rescinded if there is a "reasonable possibility that the activity will have a
significant effect on the environment due to unusual circumstances." As noted
in Section S of this analysis, there are several potentially significant adverse
impacts associated with some or all of the Anholm Bikeway Alternatives
which, without further analysis, could invalidate the City's Categorical
Exemption finding. These potentially significant impacts include, but may not
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be limited to: transportation/traffic, air quality, noise, population and housing
and public services (see Section 5, Environmental Checklist Form).
[U7
Issue 4 - Segmented Approvals or "Piece-Mealing"
The State CEQA Guidelines explicitly state in several locations that the Lead Agency,
that being the City of San Luis Obispo, must consider the entirety of the proposed
action. In this case, the entirety of the proposed action includes all of the proposed
bikeways, circulation changes, roadway closures, traffic diversions, etc. As noted
below, the Guidelines re -state this requirement in relation to the various processing
steps required for adequate public review.
SECTION 15063. INITIAL STUDY
(a) Following preliminary review, the Lead Agency shall conduct an Initial Study to
determine if the project may have a significant effect on the environment. (1) All
phases of project planning implementation and operation must be considered in
the Initial Study of the project.
SECTION 15126. CONSIDERATION AND DISCUSSION OF ENVIRONMENTAL
IMPACTS
All phases of a project must be considered when evaluating its impact on the
environment: planning acquisition development and operation
SECTION 15378. PROJECT
(a) "Project" means the whole of an action which has a potential for resulting in
either a direct physical change in the environment or a reasonably foreseeable
indirect physical change in the environment.
CEQA COMPLIANCE: As noted above, The City of San Luis Obispo has already
prepared and issued a Categorical Exemption for the first phase of the City's
proposed bikeway alternative. This action is considered to be contrary to the
CEQA Guidelines noted above. The State CEQA Guidelines state that "all phases
of a project" (i.e. "the whole of the action") must be considered when in
evaluating its impact on the environment." CEQA does not allow a Lead
Agency to divide a large project into smaller pieces for their environmental
assessments. The use of multiple and separate Categorical Exemptions to
cover an entire project (known as "piece-mealing"), is contrary to the
requirement to prepare a complete document at the outset of consideration of
an entire project. As such, the use of a Categorical Exemption for first phase
of the City's proposed bikeway alternative in order to avoid further
environmental analysis is contrary to the letter and intent of the State CEQA
Guidelines.
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Issue 5 -The Environmental Checklist Form
The Environmental Checklist Form contained in Appendix G of the State CEQA
Guidelines is used to identify potentially significant impacts associated with a
proposed project. meet the requirements for an initial study when the criteria set
forth in CEQA Guidelines have been met. The questions in this form are intended to
encourage detailed assessment of potential impacts and their associated thresholds
of significance. Lead Agencies typically address the questions from this checklist
that are relevant to a project's environmental effects in order to determine the
nature and extent of required environmental documentation. No Initial Study was
prepared and no Environmental Checklist Form was completed by the City prior to
their approval of Phase 1 of the City's version of the Anholm Bicycle Plan
The following environmental factors are from the Environmental Checklist Form.
Several of these factors, when applied to the proposed Anholm Bikeway
Alternatives, could result in a finding of "Potentially Significant Impact". Among the
eighteen environmental factors contained in the Environmental Checklist Form,
there are five potential impact areas that are of particular relevance to the
consideration of the proposed Anholm Bikeway Alternatives. These factors include,
but may not be limited to, Air Quality, Noise, Population and Housing, Public
Services and Transportation/Traffic as noted below.
III. AIR QUALITY. Where available, the significance criteria established by the
applicable air quality management or air pollution control district may be relied
upon to make the following determinations. Would the project b) violate any air
quality standard or contribute substantially to an existing or projected air quality
violation?
XII. NOISE -- Would the project result in: a) exposure of persons to or generation of
noise levels in excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies? or b) exposure of persons to
or generation of excessive groundborne vibration or groundborne noise levels? or c)
a substantial permanent increase in ambient noise levels in the project vicinity_
above levels existing without the project? d) a substantial temporary or periodic
.increase in ambient noise levels in the project vicinity above levels existing without
the project?
XIII. POPULATION AND HOUSING. Would the project: a) induce substantial
population growth in an area, either directly (for example, by proposing new homes
and businesses) or indirectly (for example, through extension of roads or other
infrastructure)?
XIV. PUBLIC SERVICES. a) would the project result in substantial adverse physical
impacts associated with the provision of new or physically altered governmental
facilities, need for new or physically altered governmental facilities, the construction
of which could cause significant environmental impacts in order to maintain
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acceptable service ratios, response times or other performance objectives for any of
the public services: Fire protection? Police protection?
XVI. TRANSPORTATION/TRAFFIC. Would the project: a) conflict with an applicable
plan, ordinance or policy establishing measures of effectiveness for the performance
of the circulation system, taking into account all modes of transportation including
mass transit and non -motorized travel and relevant components of the circulation
system, including but not limited to intersections, streets, highways and freeways,
pedestrian and bicycle paths, and mass transit or b) conflict with an applicable
congestion management program, including, but not limited to level of service
standards and travel demand measures, or other standards.
CEQA COMPLIANCE: As discussed in Section 3, Use of Categorical Exemptions
of this analysis, a Categorical Exemption finding should be invalidated if there
is a potentially significant adverse impact associated with any or all of the
Anholm Bikeway Alternatives. According to Section 15300.2 of the State CEQA
Guidelines, any Categorical Exemption which avoids further environmental
review can be rescinded if there is a "reasonable possibility that the activity
will have a significant effect on the environment due to unusual
circumstances." The "unusual circumstances" of the Anholm Bikeway
Alternatives related to the five environmental factors noted above include, but
may not be limited to:
Transportation/Traffic: the redirection of existing traffic patterns will result
in vehicle traffic being added onto several roadways in the area, two of which
already experience traffic levels which exceed their General Plan capacities.
Air Quality: the generation of additional vehicle miles traveled due to the
rerouting of established traffic patterns could contribute to increased levels of
pollutants and possible air quality violations.
Noise: the rerouting of established traffic patterns may result in the
permanent increase in ambient noise levels on several roadways above those
without the project, thereby affecting existing residential uses.
Population and Housing: elimination of on -street parking could directly
impact the ability of existing residents on Broad and Chorro Streets to have
direct access to their homes.
Public Services: the provision of traffic diverters, median islands and speed
bumps as well as the permanent closure of roadways could directly impact
fire and emergency vehicle access to the project area. This concerns gains
significance when considering the location of the Villages retirement
community on Broad Street.
13
Any of these environmental factors noted above could represent potentially
significant adverse impacts unless or until further analysis is conducted and
mitigation measures identified.
Based upon the State CEQA Guidelines, the City of San Luis Obispo should
proceed with preparation of an Initial Study that will include preparation of
the CEQA Environmental Checklist Form as described above. In so doing, the
City will be able to make an informed and legally defensible decision as to the
nature and extent of required environmental documentation associated with
the proposed Anholm Bikeway Alternatives. The most logical and legally
defensible approach in assessing the potentially significant impacts of any of
the Anholm Bikeway Alternatives would be through the preparation and
public circulation of a Program EIR rather than the preparation of a
Categorical Exemption or a Mitigated Negative Declaration (MND). A
Mitigated Negative Declaration is prepared when all potentially significant
impacts of the project have been mitigated to a level of insignificance. If any or
all of the five environmental factors noted above result in a finding of
potentially significant impact which is likely the case, an EIR is required
rather than a Mitigated Negative Declaration. As indicated in Section 15168
PROGRAM EIR of the State CEQA Guidelines, a Program EIR is prepared when a
proposed project involves "a series of actions" (or phases) "that can be
characterized as one large project." Use of a Program EIR has "several
advantages including: provision of "a more exhaustive consideration of effects
and alternatives than would be practical in an EIR on an individual action",
"ensure consideration of cumulative impacts that might be slighted in a case-
by-case analysis", "avoid duplicative reconsideration of basic policy
considerations", "allow the Lead Agency" (the City) "to consider broad policy
alternatives and program wide mitigation measures at an early time when
there is greater flexibility to deal with basic problems or cumulative impacts"
and a reduction in paperwork. A Program EIR also can be used as a base
document for any other future project activities that were not examined in the
original Program EIR. the preparation and a full public circulation of a
Program EIR provides a far greater degree of public information and
involvement than that provided by a Mitigated Negative Declaration.
14
SECTION 3
RECOMMENDATIONS
Based upon the above analysis, the following recommendations are provided
in order to ensure the City's full and complete compliance with the State CEQA
Guidelines:
1. The City of San Luis Obispo should proceed with the preparation and
certification of a complete environmental analysis for all phases of the
Anholm Bikeway Project. Preparation of this environmental analysis should
proceed immediately in order to enable environmental considerations to
influence the proposed project in its design.
2. This environmental analysis should be based upon a project design .that
avoids or minimizes environmental damage and considers specific economic,
legal and social factors in their decision. The views held by members of the
public, particularly those members of the public directly impacted by the
proposed Anholm Bikeway Project, should be considered.
3. The City's selection of a project design should reflect the consideration of
the range of alternatives that have been prepared. The future design of this
project should avoid or substantially reduce any significant impacts
associated with the proposed project.
4. The City should rescind the Categorical Exemption applied to Phase 1 of the
City's version of the Anholm Bikeway Project and include this phase within the
environmental analysis as recommended above.
S. The City Council should direct City Staff to prepare an Initial Study,
complete an Environmental Checklist Form and prepare a Program EIR
(rather than a Mitigated Negative Declaration) which covers all project phases
and addresses all potentially significant impacts of the Anholm Bikeway
Project. This Program EIR shall then be circulated for public review and
comment prior to any final decision made by the City Council on the in-home
bikeway project
15
GENP- 1719-2018 Anholin Bikeway Plan
Planning Commission Report — August 141, 2018
Page 4
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