EIR Comment – Wendy Brown, 1/31/14

January 31, 2014

City of San Luis Obispo,
Community Development Department
Ms. Pam Ricci, Senior Planner
919 Palm Street
San Luis Obispo, CA 93401-3218

Dear Ms. Ricci,

RE: Environmental Impact Report for the Johnson Avenue Housing Project

State Clearing House #2012051022 & City Files 56-08

 I’m the property owner at the address above. I’ve lived there since 1982, and have seen many changes to the neighborhood and city. Change is not always bad, but this proposal has too many problems to be acceptable.  I’m requesting that the City deny any rezoning of the proposed site, for the reasons I outline below, and for the issues that will be raised by many other nearby residents.

First, some excerpts  from the City of San Luis Obispo’s Housing Element portion of the General Plan, which should be self-explanatory:

3.5 Preserve historic homes and other types of historic residential buildings, historic districts, and unique or landmark neighborhood features

3.6 Preserve the fabric, amenities, yards (i.e. setbacks), and overall character and quality of life of established neighborhoods.

4.3 Extremely-low and very low-income housing, such as that developed by the Housing Authority of the City of San Luis Obispo or other housing providers, may be located in any zone that allows housing, and should be dispersed throughout the City rather than concentrated in one neighborhood or zone. In general, 23 dwellings should be the maximum number of extremely low or very-low-income units developed on any one site.  ( I was told by someone at the SLCUSD office that the project avoided low-income requirements by being high-density. Whether or not this is true, it does seem appropriate to limit high-density projects to the same standards expressed here.)

5.4 In general, housing developments of twenty (20) or more units should provide a variety of dwelling types, sizes or forms of tenure.

 7.1 Within established neighborhoods, new residential development shall be of a character, size, density and quality that preserves the neighborhood character and maintains the quality of life for existing and future residents.

 7.5 The creation of walled-off residential enclaves, or of separate, unconnected tracts, is discouraged because physical separations prevent the formation of safe, walkable, and enjoyable neighborhoods.

7.6 Housing shall be sited to enhance safety along neighborhood streets and in other public and semi-public areas.

7.7 The physical design of neighborhoods and dwellings should promote walking and bicycling and preserve open spaces and views.  I’m sure others could find many more sections of the City’s General Plan which would demonstrate why this project is a bad idea.

Now, on to the EIR itself.

1. Traffic and parking:  it is interesting that SLCUSD already knows how to make the traffic in our neighborhood much better.  They should close off the access from the Admin buildings and Adult School to the High School right now to reduce the danger to everyone. If they won’t do anything about the current traffic mess unless they get their development, they are asking for everyone’s bad opinion and probably lawsuits. The School Access Management memorandum included in the EIR indicates that all the measures necessary to promote better traffic flow to the High School would cost over $1.5 million. There may be lower cost measures that could happen very soon.

Just from our own experience, I believe the construction traffic from the project would be horrifying. The traffic from building the homes in Bowden Ranch has been bad enough, and that has been from comparatively few trips spread out over a long period of time.  My partner’s car was badly damaged twice by construction vehicles while parked in front of our home, and traffic has been backed up at the Lizzie/Johnson intersection many times because there is not enough lane width at the intersection for big trucks and other traffic. In order to mitigate a small part of the problem at that intersection, parking between Johnson and Fixlini would need to be eliminated, resulting in even more of an impact on current residents, and pushing parking further up into the Wilding/Bowden Ranch neighborhood.

If the construction vehicles are expected to use the Adult and High School parking lots as indicated in the EIR, the overflow will spill into San Luis Drive and Lizzie/Fixlini/Wilding neighborhoods, resulting in many unhappy residents, students and employees.

If the project were to be completed, parking problems would remain from residents and their visitors.

Traffic and parking problems in the upper Lizzie/Wilding/Woodland areas were completely ignored in the EIR. Our neighborhood is captive to what happens in the bottleneck below us.

The Housing Element calls for several major high density projects along the Johnson Avenue corridor.  Before any are approved, it would make sense to have some idea about how to handle all the traffic.

2. The No Project/Existing Zoning alternative:  this was discussed in the EIR as though the SLCUSD was poised to add almost 94,000 square feet of additional administration office space.  I find this to be highly unlikely. At this time, they don’t have the money or the need.  If they need more space, they can cut back on Adult School classrooms, which could probably find a home at other locations. I doubt if taxpayers would be willing to support a huge bond issue for construction of offices.  Thus, I think the impacts described in this section are ludicrously exaggerated.

3. Reduced Project Alternative:  this appears to be the bargaining position – ask for a lot, settle for a bit less. I don’t think huge projects should be decided in a plea-bargain mode.  Yes, the Housing Element said this site could be used for high density development “… where land development patterns are suitable and where impact to Low-Density Residential areas is minimal.”  There is certainly room for argument about both suitability and minimal impact.

The SLCUSD wants a project they can sell to a developer.  I’m sympathetic with their wish to utilize their assets to the fullest, but this does not seem to be a responsible way to accomplish that end. Their original proposal of 14 – 15 SFR lots would probably have made them as much money as they hope to make with this project, with much less opposition.

The City wants more housing.  That is appropriate and understandable, and I think most of us realize that change over time is inevitable. However, one must ask – why are the new housing units downtown very expensive ones?  It may be that no developer was willing to risk investment on workforce or low-income housing. You now have a willing developer. That doesn’t mean you have to violate existing neighborhoods and your own clear policies.

I would support appropriate development on the subject property, perhaps even some increase in R-2 zoning, as long as it was truly suitable and the impact on the surrounding neighborhoods was truly minimal.

Informative neighborhood meetings, as opposed to the one that occurred last night at the Adult School, would be very helpful.  If staff is not allowed to give reports or answer questions at such meetings, then maybe more meetings at a higher level should be scheduled.


Wendy Brown


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