To: Pam Ricci,
Cc: Doug Davidson, Derek Johnson
Subject: Comments on the Johnson Ave. Housing Project Draft EIR
From: Eric Meyer
Date: Feb 10, 2014
In the Archival Records search and Phase One Archaeological Surface Survey of the property in question, prepared for Oasis Associates by Gibson’s Archaeological Consulting there is NO MENTION of the La Vina (aka La Vena) rancho property or the La Loma Adobe. Nor is it mentioned in the EIR.
The main structure of the La Vina was the Rancho La Loma de Nopalera Adobe. Also known as the La Loma… or sometimes as the Bowden Adobe. This building is the oldest known home in San Luis Obispo County and is owned by the City of San Luis Obispo… and is also located directly next to the school district site, approx. 500 feet east of the project site . The La Loma Adobe rancho site dates from 1782 and was built “by the indian servants of a Spanish Supervisor” according to records on file with the Community Development Dept of the City of San Luis Obispo.
It is hard to believe that this city owned adobe and it’s surrounding original rancho has been specifically excluded from any investigation as to whether or whether not it’s area of influence extended within the subject housing project site. Without investigation and research… how can one be sure that this property in question does not hold some important part of that La Loma site?
It is but 10 years younger than the mission… and was indeed an outbuilding of that very mission. It is most decidedly an important cultural site within the city…. But it has been completely ignored altogether. The Judges house… built more than 100 years later… is mentioned several times. Why was the La Loma, a city owned building and the oldest documented house in the county, IGNORED in this EIR!
In the Gibson records search and survey there is a letter from Matt Edwards, from the Department of Anthropology at the University of California Santa Barbara, that discusses various archaeological sites and previous surveys of the area within a quarter mile of the site. Evidently Mr. Edwards was consulted as to the various archaeological sites that may be nearby. Mr. Edwards states in his closing that a CULTURAL RESOURCE survey is recommended. Was one done? Where is this Cultural Resource Survey? If it was not done… then why was it not done?
In addition… According to the minutes of the Planning Commission public scoping meeting of May 9th, 2012, a meeting specifically to discuss the workscope of the Johnson Avenue Housing Project EIR, Commissioner Michael Multari specifically requested that the “compatibility with historic resources should be added to the scope of the project”. Yet there is absolutely NO discussion of the La Loma Adobe or it’s original configuration or site layout or where it’s boundaries or outbuildings, orchards, vineyards, etc were or may have been in the EIR. There is NO discussion of compatibility with the La Loma… the most historic resource on this side of town.
This Johnson Avenue Housing project includes a 38’ max depth 2.3 acre excavation of an area that very well could have been an integral part of the original rancho… yet there is NO DISCUSSION of this impact or the other potential impacts that this project could have on this historic cultural resource and/or it’s known or unknown outbuildings and surrounding property.
Indeed… The Natural Resource Manager of the City of San Luis Obispo is currently doing a title search on this La Vina and the Rancho La Loma de Nopalera Adobe property to ascertain the size of the original grant or claim. It is purported to have been at least a quarter section of land in some documents… while in others it is mentioned as being a thousand acres or more… the site in question was the front yard/orchard/vineyard of the original adobe. This is evident from historical photos and documents in the possession of city staff, within the local “history center”, and in possession of the group which meets with Phil Dunsmore, city Planner, in the community development dept of the City of San Luis Obispo to help guide the restoration, financing , and future potential efforts to more clearly understand this property and it’s deep history…. Which is currently being researched by this committee via documents in possession of the Catholic Church, the Bancroft Library in Berkeley CA, and various other Mission archives around the state… as well as private historical archives.
In similar EIR’s for projects within close proximity to other such historic resources… there are ALWAYS mitigation measures designed to protect known or unknown resources on or near the project site. I refer specifically to the EIR regarding the building of a Visitor Center and museum near the Dana Adobe in Nipomo. This center is to be built at a similar distance of several hundred feet from the Dana Adobe… and there are considerable mitigation measures included in that EIR… of a much younger adobe I should add… designed to protect the known and unknown cultural resources that may exist underground beneath the proposed Visitor Center. These mitigations include such things as not allowing trenching for utilities… rather allowing boring only… and providing fill over the site to a given depth such that the original earth is not disturbed… and placing a marker layer between that new fill and the original grade so that future archaeological researchers can determine the old from the new… and other mitigations… in order to protect the site from the effects of development.
And yet… there has been no cultural resource survey… nor any mention in the EIR that this large 2.5 acre excavation and apartment building project is being built in what was the front yard/vineyard/orchard of the oldest house in our county…. Indeed no mention of the adobe whatsoever… and thus no mitigation whatsoever.
The EIR states that a 2.3 acre portion of the site is to be disturbed… and that grading will be done to a maximum depth of 38 feet. This is incredible to me… considering that this work is basically being done in the former front yard of an adobe owned by the city… and that the city has open space easements over so much of the rest of the original rancho property and that the city claims to be so concerned about it’s natural and historic resources.
With respect to visual resources as they relate to the cultural resource: It is thought that the La Loma was originally built as an outpost of the mission San Luis Obispo. It and other missions outposts on other hillsides were situated such that the occupant of the outpost rancho building could view the entire valley below… a lookout as it were… so as to be able to see if any vaqueros were attempting to smuggle cattle or sheep around the mission without paying the fee that the mission collected for such transportation of cattle or sheep across it’s territory.
The view from this property has been lessened by the homes built in front of it… but by simply walking onto the current Public Facility zoned school district property next door to the adobe, it is possible to view the entire valley of San Luis Obispo and imagine what the original Mission era lookout saw and why that building is where it is. The New Johnson Avenue Housing Project… at three stories tall or more, will completely obliterate any of what remains of that view that the original structure was built for… and this is a loss of a cultural resource.
If this building is built as proposed… it will be impossible to interpret the reason that the La Loma de Nopalera was built where it was… because you will no longer be able to ascertain that original viewshed from anywhere. Is this not the definition of “a substantial adverse effect on a scenic vista” as described by CEQA?
Please explain why this EIR doesn’t include any discussion of this resource or the impacts that this development and it’s included excavation and scale will have upon the known or unknown cultural history associated with this resource.
Please also explain why Commissioner Multari’s request… as well as the consultant from UCSB, Mr. Matt Edwards, request were specifically ignored in the EIR.
Is knowingly excluding any mention (in the Johnson Ave housing project EIR) of such an important city owned historical/cultural resource even legal? How can you determine that it is not important… when city staff are even at this very moment investigating the full extent of the importance of the resource… and do not fully yet understand it or know it’s boundaries or all of its components?
This Johnson Avenue Housing Project has the potential of actually destroying and preventing an accurate and full understanding of this cultural resource and it’s original purpose, scale, outbuildings etc. For this reason alone… there should be mitigations that will offset this loss. Should the project be allowed to grade at the levels described? Is this not going to be a class 1 impact?
Marsh and California intersection:
During the Planning Commission scoping meeting of this EIR for the Johnson Avenue Housing Project public speakers brought up the fact that the Traffic Study should also include the intersection of California and Marsh. I myself, as a planning Commissioner at the time, requested that the traffic study also include Marsh and California as well as Monterey and California. Yet neither of these intersections were included in the traffic study. The intersection of Marsh and California is approximately 150 feet north of the intersection of San Luis Drive and California… and is heavily impacted by peak hour traffic at the am peak, the lunch peak, and the pm peak. Perhaps even more so that the San Luis Drive and California intersection. But how would we know… because this intersection has been left out of the traffic study.
How will the mitigation efforts… of the traffic circle at San Luis Drive and California effect the intersection of Marsh and California? Indeed… we cannot know… because the EIR fails to understand this relationship… even though this intersection was specifically requested to be a part of the EIR by both the Planning Commission and the Public and is but 150 feet away.
How is it possible that the operation of the intersection at Marsh and California is not a crucial component of this EIR? Should it have been? Why was the public’s request, as well as my specific request, as a planning commissioner, to include this intersection of Marsh and California in the traffic study, ignored?
Traffic circle Mitigation:
The possible mitigation of traffic impacts via the EIR’s proposed traffic circle at California and San Luis drive only considers automobiles. There is no mention of pedestrian or bicycle impacts that this automobile traffic mitigation may create. What are the impacts to the pedestrians and bicyclists, mostly high school students, walking or biking to and from the high school… in the am, at lunch, and in the pm by this traffic circle? How will pedestrians and bicyclists be effected by this or other proposed automobile traffic mitigation measures. This is a high school here… and more or less half of the student body are not automobile drivers. They will be required to negotiate new traffic calming devices as pedestrians and bicyclists… and the automobile mitigations will raise or lower the MMLOS (multi modal level of service) of that intersection. Yet there is no discussion of how these kids will be affected by this new traffic calming… or whether it is safer than the current three way stop. Are there impacts? We don’t know… because it is not discussed at all.
There may very well be impacts to public safety from the mitigations of this Johnson Avenue Housing Project… and yet there is no discussion of the impacts of these mitigations and how they might affect the students walking and biking to the high school. Please explain how we can fully accept a given mitigation as being appropriate and acceptable… without understanding the impacts of that mitigation itself. What are the combined effects of the original project and the mitigation itself. Is a Traffic circle possible at California and San Luis Drive? How do we know that it is possible when we don’t understand it’s own possible impacts?
Wilding, Woodland, Bowden Ranch fire access, emergency access, and evacuation:
Many public speakers at the 2012 Planning Commission Johnson Ave Housing Project EIR Scoping meeting requested that the area above Lizzie… specifically Bowden Ranch, Woodland, Wilding etc… and the emergency access to, and the evacuation from… be specifically analyzed for the effects of this project upon public safety within that single access neighborhood. And yet this was not discussed in the EIR.
Why is the public safety of this neighborhood above fixlini street. specifically NOT discussed even after having been raised as a concern at the scoping meeting?
Please respond as per CEQA guidelines to EACH AND ALL of the many questions within each of the subject areas I have discussed.
San Luis Obispo, CA