Cities Index.
Agenda packet

San Luis Obispo City Council
April 4, 2023

Document
Agenda packet
Meeting
April 4, 2023
Body
San Luis Obispo City Council
Pages
1,373
Original file
167.3 MB
Text extracted from the city's file for reading and search. Open the original on pub-slocity.escribemeetings.com. That file is the official record.

83 337
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6+$//2:
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6+$//2:
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CORE

LANDSCAPE
PLAN
L-2

PROJECT MANAGER

WES AROLA

DRAWN BY

WES AROLA
DATE

01.11.2021

MICHAELS RESIDENCE
841 PATRICIA DRIVE | SAN LUIS OBISPO

LANDSCAPE PLANS
# DATE ITEM

,Q)HHW

LQFK IHHW
*5$3+,&6&$/(
     
1 INFINITY POOL 16x38

STONE PAVING WITH NATURALIZED

EDGENATURAL LAWN

WITH SUBSURFACE IRRIGATION

STAGGERED CONCRETE STEPS

DECKING WITH RAILINGRETAINING WALL, BOARD FORM

CONCRETE OR SMOOTH STUCCO

NATURAL LAWN OR MOWED MEADOW

SPA/GYM PATIO

GROTTO STYLE SPA

PLANTING AREA, TYPPAVER RIBBON DRIVEWAY TO ADUBRIDGELIGHTWEIGHT STEEL OVERHEAD SHADE

STRUCTURE

OUTDOOR KITCHENGRASS PAVINGGRAVITY BLOCK RETAINING WALL

STONE CLAD ACCENT WALL

DESIGN KEY
234
5 6789
10111213
1 2
2 3
4 4 5
6 7
8 9 10
10 10
10 11
12 13
14 14
15 15
15 16
16 16
10 ATTACHMENT 1

Page 837 of 1373 ends

83 346
347
348
349
351
352
353
345
350


6+$//2:
'((3
6+$//2:
6+$//2:
6+$//2:

LANDSCAPE
PLAN
L-3

PROJECT MANAGER

WES AROLA

DRAWN BY

WES AROLA
DATE

01.11.2021

MICHAELS RESIDENCE
841 PATRICIA DRIVE | SAN LUIS OBISPO

LANDSCAPE PLANS
# DATE ITEM

,Q)HHW

LQFK IHHW
*5$3+,&6&$/(
     
1 DRY STACKED BOULDER RETAINING WALLS TO CREATE

LANDSCAPE TERRACESBLOCK RETAINING WALL COVERED IN VINESPERMEABLE LINEAR PAVERS

ACCENT TREES POSITIONED TO PROVIDE PRIVACY

GAPPED STEPPERS WITH PLANTED JOINTS

CONCRETE PORCH / STEPS

PLANTING AREA, TYP

ADDITIONAL PARKING SPACE

TRASH STORAGE

DESIGN KEY
234
5 678
1 9
2 3
3 3
4 5
6 6
7 7
7 8
9 9
1 ATTACHMENT 1

Page 838 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A4
PROJECT NO.1973-01-RS20
MARCH 12, 2021

SITE SECTIONS
1” = 20’-0” (24X36 SHEET)
0 20 40 800 40 80 160
1” = 40’-0” (12X18 SHEET)
*5281')/225

 
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ATTACHMENT 1

Page 839 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A5
PROJECT NO.1973-01-RS20
MARCH 12, 2021

SITE AERIAL MAP
SITE AERIAL MAP 1 1" =20’ - 0” (24 X 36 SHEET)
1” = 40’-0” (24X36 SHEET)
0 20 40 800 40 80 160
1” = 80’-0” (12X18 SHEET)

VIEWS OF BISHOP PEAK

VIEWS OF CALIFORNIA POLYTECHNIC STATE UNIVERSITY
1 ATTACHMENT 1

Page 840 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A6
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 BASEMENT FLOOR PLAN 1/16” = 1’-0” (12X18 SHEET) YOGA
13'-3"x14'-0"

DRY SUANA
7'-6"x12'-0"
STOR
CAB.

T.

A-500 A1 1/8" = 1'-0"
1 FLOOR PLAN_BASEMENT
ATTACHMENT 1

Page 841 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A7
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 GROUND FLOOR PLAN 1/16” = 1’-0” (12X18 SHEET) UP
UP
W D
GREATROOM DINING 22'-6"x2'0" 15'0"x19'-6"

KITCHEN
22'-6"x24'-0"
NOOK
PWDR
PANTRY
6'-6"x11'-6"
BUTLER
8'-0"x6'-1"
ELEV.
5'-0"x6'-6"
FOYER
W.I.C.
9'-6"x7'-6"
BATH
7'-0"x12'-0"

EN-SUITE
16'-0"x14'-6"

MUD ROOM
12'0"x9'-6"
BBQ
2-CAR
1-CAR GARAGE

OUTDOOR LIVING

GREENHOUSE
30'-0"x13'-0"
TOOLS
CL.

UTILITY 1
PATIO
sink
bench
pet
wash
linen
seating
flex. station
hutch
built-in
built-inbuilt-in
coat
l
i
n
e
n
pergola
prep station
entertainment REF
STOVE
MICRO
9' - 6" MIN
1 8
' -
6 "
M
IN
19' - 0" MIN.
1 8
' -
6 "
M
IN
.

A-500 A2 1/8" = 1'-0"
1 FLOOR PLAN_LEVEL 1
ATTACHMENT 1

Page 842 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A8
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 SECOND FLOOR PLAN 1/16” = 1’-0” (12X18 SHEET) D
W
BEDROOM 3
12'-0"x11'-4"
W.I.C 3
8'-0"x4'-8"
BATH 2
W.I.C. 2
8'-0"x4'-8"
BATH 3
M. BEDROOM
15'-6"x14'-6"
HIS
5'-0"x6'-5"
HERS
6'-10"x6'-5"
T. M. BATH

OPEN TO BELOW

GALLERY
44'-0"x5'-9"
BEDROOM 2
12'-0"x11'-4"

VERANDA

BALCONY

FAMILY ROOM
15'-6"x14'-4" BALCONY
LNDRY.
7'-0"x10'-5"
ELEV.
bench
entertainment
built-in shelving
art niche
storage
A-500 A3 1/8" = 1'-0"
1 FLOOR PLAN_LEVEL 2
ATTACHMENT 1

Page 843 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A9
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 ROOF PLAN 1/16” = 1’-0” (12X18 SHEET) A-500 A4 1/8" = 1'-0"
1 SITE _ROOF PLAN
ATTACHMENT 1

Page 844 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A10
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 PROPOSED COLORS & MATERIALS 1/16” = 1’-0” (12X18 SHEET) A A
B
C
C
F
F
F
D
E
H
G
D
G
H
+RUL]RQWDO/DS6LGLQJ6DJH*UHHQ
3DLQWHG7ULP'DUN*UHHQ
A B
5DLQ6FUHHQ :RRG$FFHQW1DWXUDO&HGDU
*XWWHUV:HDWKHUHG&RSSHU$FFHQW
7HVOD6RODU5RRI7LOHV )LUHSODFH )HDWXUH:DOO
/RFDO9ROFDQLF6WRQH

C D E G H
6KDNH6KLQJOHV1DWXUDO&HGDU
F
:LQGRZV'RRUV'DUN%URQ]H0HWDO$FFHQW

CONTEMPORARY CRAFTSMAN - SAGE GREEN SCHEME
ALL EXTERIOR COVERINGS AND ROOFING WILL BE IGNITION RESISTANT CONSTRUCTION. NO COMBUSTIBLE EXTERIOR SIDIING IS PERMITTED.

ROOF ASSEMBLY SHALL BE CLASS A. ATTIC & SUBFLOOR VENTING SHALL BE DESIGNED TO INHIBIT EMBER INTRUSION (CRC 337)

TYPES OF LIGHTING PROPOSED WILL MEET

DARK SKY COMPLIANCE ZONING STANDARDS
(17.70.100). A LIGHT WILL BE PROVIDED AT ALL
EXTERIOR DOORS.
:$//6&21&(7(&+/,*+7,1*3($.
:$//6&21&((9(5*5((1/,*+7,1*6(5,(6
ATTACHMENT 1

Page 845 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A11
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 EXTERIOR ELEVATIONS 1/16” = 1’-0” (12X18 SHEET) 1/8" = 1'-0" (24 X 36 SHEET)
1/8" = 1'-0" (24 X 36 SHEET)
1 2
A
A
B
C
C
F
D
E
H
D
G
H
B
E
F
G
G
+RUL]RQWDO/DS6LGLQJ6DJH*UHHQ
3DLQWHG7ULP'DUN*UHHQ
A B
5DLQ6FUHHQ :RRG$FFHQW1DWXUDO&HGDU
*XWWHUV:HDWKHUHG&RSSHU$FFHQW
7HVOD6RODU5RRI7LOHV )LUHSODFH )HDWXUH:DOO
/RFDO9ROFDQLF6WRQH

C D E G H
6KDNH6KLQJOHV1DWXUDO&HGDU
F
:LQGRZV'RRUV'DUN%URQ]H0HWDO$FFHQW

CONTEMPORARY CRAFTSMAN - SAGE GREEN SCHEME
ALL EXTERIOR COVERINGS AND ROOFING WILL BE IGNITION RESISTANT CONSTRUCTION. NO COMBUSTIBLE EXTERIOR SIDIING IS PERMITTED.

ROOF ASSEMBLY SHALL BE CLASS A. ATTIC & SUBFLOOR VENTING SHALL BE DESIGNED TO INHIBIT EMBER INTRUSION (CRC 337)

TYPES OF LIGHTING PROPOSED WILL MEET

DARK SKY COMPLIANCE ZONING STANDARDS
(17.70.100). A LIGHT WILL BE PROVIDED AT ALL
EXTERIOR DOORS.
:$//6&21&(7(&+/,*+7,1*3($.
:$//6&21&((9(5*5((1/,*+7,1*6(5,(6
ATTACHMENT 1

Page 846 of 1373 ends

841 PATRICIA DRIVE RESIDENCE
SECOND AND THIRD FLOOR PLAN A12 PROJECT NO.1973-01-RS20 MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 EXTERIOR ELEVATIONS 1/16” = 1’-0” (12X18 SHEET) 1/8" = 1'-0" (24 X 36 SHEET)
1/8" = 1'-0" (24 X 36 SHEET)
1 2
A
A
B
C
C
F
D
E
H
D
G
H
B
E
F
G
D
D
+RUL]RQWDO/DS6LGLQJ6DJH*UHHQ
3DLQWHG7ULP'DUN*UHHQ
A B
5DLQ6FUHHQ :RRG$FFHQW1DWXUDO&HGDU
*XWWHUV:HDWKHUHG&RSSHU$FFHQW
7HVOD6RODU5RRI7LOHV )LUHSODFH )HDWXUH:DOO
/RFDO9ROFDQLF6WRQH

C D E G H
6KDNH6KLQJOHV1DWXUDO&HGDU
F
:LQGRZV'RRUV'DUN%URQ]H0HWDO$FFHQW

CONTEMPORARY CRAFTSMAN - SAGE GREEN SCHEME
ALL EXTERIOR COVERINGS AND ROOFING WILL BE IGNITION RESISTANT CONSTRUCTION. NO COMBUSTIBLE EXTERIOR SIDIING IS PERMITTED.

ROOF ASSEMBLY SHALL BE CLASS A. ATTIC & SUBFLOOR VENTING SHALL BE DESIGNED TO INHIBIT EMBER INTRUSION (CRC 337)

TYPES OF LIGHTING PROPOSED WILL MEET

DARK SKY COMPLIANCE ZONING STANDARDS
(17.70.100). A LIGHT WILL BE PROVIDED AT ALL
EXTERIOR DOORS.
:$//6&21&(7(&+/,*+7,1*3($.
:$//6&21&((9(5*5((1/,*+7,1*6(5,(6
ATTACHMENT 1

Page 847 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A13
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 PERSPECTIVE VIEWS 1/16” = 1’-0” (12X18 SHEET) 1/8" = 1'-0" (24 X 36 SHEET)
1/8" = 1'-0" (24 X 36 SHEET)
1 2
A
A
B
C
C
F
D
E
H
D
G
H
B
E
F
G
A
D
A
A
+RUL]RQWDO/DS6LGLQJ6DJH*UHHQ
3DLQWHG7ULP'DUN*UHHQ
A B
5DLQ6FUHHQ :RRG$FFHQW1DWXUDO&HGDU
*XWWHUV:HDWKHUHG&RSSHU$FFHQW
7HVOD6RODU5RRI7LOHV )LUHSODFH )HDWXUH:DOO
/RFDO9ROFDQLF6WRQH

C D E G H
6KDNH6KLQJOHV1DWXUDO&HGDU
F
:LQGRZV'RRUV'DUN%URQ]H0HWDO$FFHQW

CONTEMPORARY CRAFTSMAN - SAGE GREEN SCHEME
ALL EXTERIOR COVERINGS AND ROOFING WILL BE IGNITION RESISTANT CONSTRUCTION. NO COMBUSTIBLE EXTERIOR SIDIING IS PERMITTED.

ROOF ASSEMBLY SHALL BE CLASS A. ATTIC & SUBFLOOR VENTING SHALL BE DESIGNED TO INHIBIT EMBER INTRUSION (CRC 337)

TYPES OF LIGHTING PROPOSED WILL MEET

DARK SKY COMPLIANCE ZONING STANDARDS
(17.70.100). A LIGHT WILL BE PROVIDED AT ALL
EXTERIOR DOORS.
:$//6&21&(7(&+/,*+7,1*3($.
:$//6&21&((9(5*5((1/,*+7,1*6(5,(6
ATTACHMENT 1

Page 848 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A14
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 FLOOR AND ROOF PLAN - ADU 1/16” = 1’-0” (12X18 SHEET) UP

KITCHEN/LIVING

BEDROOM
W.I.C. BATHROOM
PATIO
DECK
3/16" = 1'-0"

DADU-ROOF PLAN SCHEMATIC
3/16" = 1'-0"

DADU-FLOOR PLAN SCHEMATIC

PERSPECTIVE - FRONT
ATTACHMENT 1

Page 849 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A15
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 ELEVATIONS - ADU 1/16” = 1’-0” (12X18 SHEET) RIGHT ELEVATION1/8" = 1'-0" (24 X 36 SHEET)
REAR ELEVATION1/8" = 1'-0" (24 X 36 SHEET)
LEFT ELEVATION1/8" = 1'-0" (24 X 36 SHEET)
FRONT ELEVATION1/8" = 1'-0" (24 X 36 SHEET)
1 1
1 1
+RUL]RQWDO/DS6LGLQJ6DJH*UHHQ
3DLQWHG7ULP'DUN*UHHQ
A B
5DLQ6FUHHQ :RRG$FFHQW1DWXUDO&HGDU
*XWWHUV:HDWKHUHG&RSSHU$FFHQW
7HVOD6RODU5RRI7LOHV )LUHSODFH )HDWXUH:DOO
/RFDO9ROFDQLF6WRQH

C D E G H
6KDNH6KLQJOHV1DWXUDO&HGDU
F
:LQGRZV'RRUV'DUN%URQ]H0HWDO$FFHQW
A
B
C
C
F
E
H
B G
E
F
A A F
F
G
H

CONTEMPORARY CRAFTSMAN - SAGE GREEN SCHEME
ALL EXTERIOR COVERINGS AND ROOFING WILL BE IGNITION RESISTANT CONSTRUCTION. NO COMBUSTIBLE EXTERIOR SIDIING IS PERMITTED.

ROOF ASSEMBLY SHALL BE CLASS A. ATTIC & SUBFLOOR VENTING SHALL BE DESIGNED TO INHIBIT EMBER INTRUSION (CRC 337)

TYPES OF LIGHTING PROPOSED WILL MEET

DARK SKY COMPLIANCE ZONING STANDARDS
(17.70.100). A LIGHT WILL BE PROVIDED AT ALL
EXTERIOR DOORS.
:$//6&21&(7(&+/,*+7,1*3($.
:$//6&21&((9(5*5((1/,*+7,1*6(5,(6
ATTACHMENT 1

Page 850 of 1373 ends

841 PATRICIA DRIVE RESIDENCE A16
PROJECT NO.1973-01-RS20
MARCH 12, 2021
1/8” = 1’-0” (24X36 SHEET)
0 4 8 160 8 16 32 PROPOSED COLORS & MATERIALS - ADU 1/16” = 1’-0” (12X18 SHEET) A
G
B
E
F
F
C
H
F
+RUL]RQWDO/DS6LGLQJ6DJH*UHHQ
3DLQWHG7ULP'DUN*UHHQ
A B
5DLQ6FUHHQ :RRG$FFHQW1DWXUDO&HGDU
*XWWHUV:HDWKHUHG&RSSHU$FFHQW
7HVOD6RODU5RRI7LOHV )LUHSODFH )HDWXUH:DOO
/RFDO9ROFDQLF6WRQH

C D E G H
6KDNH6KLQJOHV1DWXUDO&HGDU
F
:LQGRZV'RRUV'DUN%URQ]H0HWDO$FFHQW

CONTEMPORARY CRAFTSMAN - SAGE GREEN SCHEME
ALL EXTERIOR COVERINGS AND ROOFING WILL BE IGNITION RESISTANT CONSTRUCTION. NO COMBUSTIBLE EXTERIOR SIDIING IS PERMITTED.

ROOF ASSEMBLY SHALL BE CLASS A. ATTIC & SUBFLOOR VENTING SHALL BE DESIGNED TO INHIBIT EMBER INTRUSION (CRC 337)

TYPES OF LIGHTING PROPOSED WILL MEET

DARK SKY COMPLIANCE ZONING STANDARDS
(17.70.100). A LIGHT WILL BE PROVIDED AT ALL
EXTERIOR DOORS.
:$//6&21&(7(&+/,*+7,1*3($.
:$//6&21&((9(5*5((1/,*+7,1*6(5,(6
ATTACHMENT 1

Page 851 of 1373 ends

From: Jim apRoberts
To: Oetzell, Walter
Subject: Regarding Creek Setback Exception Request for 841 Patricia Drive, San Luis Obispo EID-0547-0201, ARCH-0040- 2021
Date: Friday, October 7, 2022 4:29:27 PM
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.

October 7, 2022
Dear Mr. Oetzell,
Regarding Creek Setback Exception Request for 841 Patricia Drive, San Luis Obispo:

Looking at the property at 841 Patricia Drive, the lot area contained by the minimum lot and creek setbacks and excluding the ‘flag’ for the driveway - effectively the ‘by-right’ developable envelope- is approximately 15,500 square feet. At 40% maximum coverage (6,200 square feet) this project and the ADU (5,260sf + 830sf = 6,120 sf) could be designed and constructed to be together on the west side of the creek. This very conservative approach to developable area and lot coverage clearly demonstrates the project could be redesigned to avoid the need for the requested creek setback exception - a request that is undeniably one of choice, not necessity.

Outside of the building footprints, the site development also includes a large pool, extensive patios and terraces, all choices made that inhibit the potential for the ADU to be included on the west side of the creek. With adjustments to those outdoor areas - and perhaps even by requesting a creek setback exception for the pool - additional space could be maintained on the west side of the creek and facilitate placement of the ADU without compromising separation and privacy between the two homes, and without requiring the severe impacts of installing a road and bridge to cross over and through the creek bed. The road and bridge are substantially larger impacts than the ADU itself in terms of surface area and creek encroachment.

Per the San Luis Obispo Municipal Code 17.70.030.G.4.c findings must be made to grant an exception to the required creek setbacks. Finding #4 indicates that there needs to be “circumstances applying to the site, such as size, shape, or topography, which do not apply generally to land in the vicinity with the same zoning, that would deprive the property of privileges enjoyed by other property in the vicinity with the same zoning.” Over 6,000 square feet of building footprint, large terraces, and a pool to not reflect a deprivation of privilege, is quite the opposite. Finding #7 requires that “site development cannot be feasibly accomplished with a redesign of the project.” As noted above, a redesign is entirely feasible, it just would not have a bridge. This is supported by text regarding Finding #8 that “in the case of new development (reasonable use of the property) may include less development than indicated by zoning.”
The Initial Study mentions that “without the bridge crossing, the eastern portion of the site would not be accessible.” This may be true, but the property owner has no right to vehicular access across a waterway. Undoubtedly, outside of the rainy season, access by foot across the creek would be easily achieved.

Page 852 of 1373 ends

Please include this correspondence in the City Files EID-0547-0201, ARCH-0040-2021 Respectfully,
Jim and Kathy apRoberts
251 Twin Ridge Drive
San Luis Obispo

Page 853 of 1373 ends

From: Schroeter Family
To: Oetzell, Walter
Cc: Schroeter Family
Subject: CEQA Comments for 841 Patricia Drive, San Luis Obispo, CA Date: Friday, October 7, 2022 5:00:17 PM
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.

Dear Mr. Oetzell,
As stated in the City of San Luis Obispo’s (City) Conservation Guidelines, it is critical to preserve and or restore riparian areas, creeks, wetlands and ephemeral seeps or springs to a natural state and provide suitable habitat to all native aquatic and riparian species. The City further states that it is critical to minimize the impacts of harmful activities in these waterways, wetlands and floodplains to enhance and preserve their natural function and to protect native fish and amphibian populations that utilize these areas as habitat.

This project is requesting an exception to riparian forest protection (creek setback) and if approved, the project will alter and degrade the riparian forest and the designated habitat corridor. The proposed changes sought by this project are specifically prohibited as exceptions within setbacks (include structures, paving and parking lots; San Luis Obispo Municipal Code17.70.030 Creek Setbacks).

It seems reasonable that the city may consider such exceptions when there is significant and substantial public benefit. However, in this case there is no realized public benefit and there will be significant environmental costs that do not justify granting such an exception. In addition, the applied for exception would prevent the implementation of city adopted plans regarding open space, riparian areas and habitat corridors and would likely constitute a grant of special privilege since other projects in the area have not been rewarded with similar exceptions. Finally, there are many alternatives to having a bridge built over pristine riparian forest including the relocation of the ADU to the south side of stream, which would leave 100% of the stream riparian forest intact.

The proposal also underestimates and understates the impacts to the riparian forest and the habitat corridor, as will be discussed in the following sections that specifically address the bioloigical resources assessment report (BRA).

BRA is not representative / accurate of true impact to the stream riparian and corridor:

The authors of the BRA state 17 oak saplings and 20-30 arroyo willow “stems” from four trees will need to be removed to accommodate the proposed bridge and that its construction and presence would have minimal impacts given the already limited connectivity of the stream corridor.

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In total, the 12’ x 50’ bridge will directly impact a minimum riparian forest area of 600 ft2 once constructed and there will likely be extensive additional damage to riparian plants and the soil and stream substrate as a result of the construction activities. In addition, it cannot be assumed that the removed forest vegetation will return at the bridge crossing as it would need to be continuously cut to maintain access. Any shaded plants under the bridge will also likely not survive the modification.

Furthermore, the use of the term stems is misleading. Stems are any above ground plant structure, but the reality of the proposed construction activities will be the removal of large limbs and possibly trunks of the existing arroyo willow to accommodate the space needed for the bridge. The size of the stems removed should be identified. The entire riparian forest on the property is very healthy and dense, thus using the affected area (600 ft2) is the best estimate of total impact and an appropriate mitigation would be the addition of riparian forest equivalent to the size that was removed.

According to California Department of Fish and Wildlife (Heather Rodriguez) removal of any riparian limb exceeding 2” in diameter would require mitigation and any limb exceeding 4” diameter would require the application for a 1600 permit. Having clarity on the size of limbs removed would allow for greater assessment of impact and appropriate permitting next steps.

It is important to point out that the landowners applying for this permit have already extensively thinned the riparian forest on this property. This occurred in the Fall of 2020. It is not clear what if any permits were obtained for this tree removal work, but since all work stopped once it was reported to city officials, it is likely that no permit was obtained. Many of the cut tree branches had diameters exceeding the 2-4” diameter criteria. The city biologist Freddy Otte can attest to scale of impact and the proposed mitigation that was suggested at the time, which was tree replanting. It is not clear if any mitigation has taken place to date. Furthermore, it is not clear as to the extent of the riparian forest that was removed from those activities.

The proposed mitigation for this projects stream riparian impacts, which include planned “stem” and oak sapling removal is planting more willow and oaks into existing riparian forest. As already stated, this will not mitigate the loss of 600 ft2 of riparian forest as it will only further crowd the existing plants in already established upstream riparian forest.

BRA states that the wildlife corridor provides little value to wildlife since it is blocked at the upper and lower end by culverts.

No data is provided within the BRA and the city biologists also provide no data on the use of this area by wildlife. My personal observations and accounts made by the surrounding homeowners are that the site is extensively used by wildlife. I carried out a site visit on 10/6/22 and observed turkey, quail, numerous species of small birds and there were signs of extensive deer use (droppings, deer rubs and game trails) along the edge and within the riparian forest. There was also a deer fawn carcass

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scattered between the stream channel and the upper flood plain suggesting that larger predators such as mountain lion are actively feeding in the area.

The BRA alludes to the fact that there is limited direct connectivity of the habitat corridor at the project site to Bishops Peak, due to upstream culverts. Although it would be best to have direct connectivity, wildlife do have access to bishops peak and other surrounding riparian and upland habitat through the culverts and via backyards and side yards. The limited upstream access in no way should be an excuse to degrade and or diminish the value of the existing riparian forest at the project site.

BRA – Assessment conducted during drought year 2021
The BRA depends on a single year of assessment (April and October 2021) of biological life from an extreme drought time period 2021 as a basis for their ecological studies report. This is not a good way to gauge the potential impact of the proposed study because the full inventory of species use is not likely to be reflective of potential species (both aquatic and terrestrial) use under more natural non drought conditions and will prevent thorough consideration of the overall impact of the project. As Freddy Otte can attest to, bullfrogs are found on occasion within this drainage which indicates that habitat is suitable for other multistage amphibians including red legged frog.

Additional Concerns:

Stream Riparian edge depicted as a straight line, which is not accurate.

Natural riparian systems and their associated forests typically do not occur in straight lines. Current staking of the edge of riparian forest cuts off an extension measuring 15’ x 25’ which is 375 ft2 of riparian forest that would be excluded from protection as it is now staked. The current staking pattern runs counter to the “measurement of creek setbacks” listed in the San Luis Obispo Municipal Code 17. 70.030C. This area is on the North side of the property close to the proposed ADU driveway. The actual existing riparian forest edge should be corrected for accuracy and for further protection of this important habitat.

Sincerely,
Robert Schroeter PhD

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From: Schroeter Family
To: Oetzell, Walter
Subject: Re: CEQA Comments for 841 Patricia Drive, San Luis Obispo, CA Date: Friday, October 7, 2022 5:22:32 PM
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.

Dear Mr. Oetzell,
I would like to follow up my prior email (Dated 10/7/22 @ 4:59pm) with a statement summary of my position in regards to the proposed MND for the 841 Patricia Project.

An MND is not appropriate for the proposed project at 841 Patricia Drive. As described in my prior email, the project will result in potentially significant effects on the environment and does not sufficiently avoid or mitigate the effects to a point where clearly no significant effect on the environment would occur . In fact, there is substantial evidence that the project will likely have a significant effect on the environment. Therefore, a full EIR should be prepared by the City with sufficient opportunity for public comment.

Robert Schroeter PhD
On Fri, Oct 7, 2022 at 4:59 PM Schroeter Family <[email protected]> wrote:

Dear Mr. Oetzell,
As stated in the City of San Luis Obispo’s (City) Conservation Guidelines, it is critical to preserve and or restore riparian areas, creeks, wetlands and ephemeral seeps or springs to a natural state and provide suitable habitat to all native aquatic and riparian species. The City further states that it is critical to minimize the impacts of harmful activities in these waterways, wetlands and floodplains to enhance and preserve their natural function and to protect native fish and amphibian populations that utilize these areas as habitat.

This project is requesting an exception to riparian forest protection (creek setback) and if approved, the project will alter and degrade the riparian forest and the designated habitat corridor. The proposed changes sought by this project are specifically prohibited as exceptions within setbacks (include structures, paving and parking lots; San Luis Obispo Municipal Code17.70.030 Creek Setbacks).

It seems reasonable that the city may consider such exceptions when there is significant and substantial public benefit. However, in this case there is no realized public benefit and there will be significant environmental costs that do not justify granting such an exception. In addition, the applied for exception would prevent the implementation of city adopted plans regarding open space, riparian areas and habitat corridors and would likely constitute a grant of special privilege since other projects in the area have not been rewarded with similar exceptions. Finally, there are many alternatives to having a bridge built over pristine riparian forest including the relocation of the ADU to the south side of stream, which would leave 100% of the stream riparian forest intact.

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The proposal also underestimates and understates the impacts to the riparian forest and the habitat corridor, as will be discussed in the following sections that specifically address the bioloigical resources assessment report (BRA).

BRA is not representative / accurate of true impact to the stream riparian and corridor:

The authors of the BRA state 17 oak saplings and 20-30 arroyo willow “stems” from four trees will need to be removed to accommodate the proposed bridge and that its construction and presence would have minimal impacts given the already limited connectivity of the stream corridor.

In total, the 12’ x 50’ bridge will directly impact a minimum riparian forest area of 600 ft2 once constructed and there will likely be extensive additional damage to riparian plants and the soil and stream substrate as a result of the construction activities. In addition, it cannot be assumed that the removed forest vegetation will return at the bridge crossing as it would need to be continuously cut to maintain access. Any shaded plants under the bridge will also likely not survive the modification.

Furthermore, the use of the term stems is misleading. Stems are any above ground plant structure, but the reality of the proposed construction activities will be the removal of large limbs and possibly trunks of the existing arroyo willow to accommodate the space needed for the bridge. The size of the stems removed should be identified. The entire riparian forest on the property is very healthy and dense, thus using the affected area (600 ft2) is the best estimate of total impact and an appropriate mitigation would be the addition of riparian forest equivalent to the size that was removed.

According to California Department of Fish and Wildlife (Heather Rodriguez) removal of any riparian limb exceeding 2” in diameter would require mitigation and any limb exceeding 4” diameter would require the application for a 1600 permit.

Having clarity on the size of limbs removed would allow for greater assessment of impact and appropriate permitting next steps.

It is important to point out that the landowners applying for this permit have already extensively thinned the riparian forest on this property. This occurred in the Fall of 2020. It is not clear what if any permits were obtained for this tree removal work, but since all work stopped once it was reported to city officials, it is likely that no permit was obtained. Many of the cut tree branches had diameters exceeding the 2-4” diameter criteria. The city biologist Freddy Otte can attest to scale of impact and the proposed mitigation that was suggested at the time, which was tree replanting. It is not clear if any mitigation has taken place to date. Furthermore, it is not clear as to the extent of the riparian forest that was removed from those activities.

The proposed mitigation for this projects stream riparian impacts, which include planned “stem” and oak sapling removal is planting more willow and oaks into

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existing riparian forest. As already stated, this will not mitigate the loss of 600 ft2 of riparian forest as it will only further crowd the existing plants in already established upstream riparian forest.

BRA states that the wildlife corridor provides little value to wildlife since it is blocked at the upper and lower end by culverts.

No data is provided within the BRA and the city biologists also provide no data on the use of this area by wildlife. My personal observations and accounts made by the surrounding homeowners are that the site is extensively used by wildlife. I carried out a site visit on 10/6/22 and observed turkey, quail, numerous species of small birds and there were signs of extensive deer use (droppings, deer rubs and game trails) along the edge and within the riparian forest. There was also a deer fawn carcass scattered between the stream channel and the upper flood plain suggesting that larger predators such as mountain lion are actively feeding in the area.

The BRA alludes to the fact that there is limited direct connectivity of the habitat corridor at the project site to Bishops Peak, due to upstream culverts. Although it would be best to have direct connectivity, wildlife do have access to bishops peak and other surrounding riparian and upland habitat through the culverts and via backyards and side yards. The limited upstream access in no way should be an excuse to degrade and or diminish the value of the existing riparian forest at the project site.

BRA – Assessment conducted during drought year 2021
The BRA depends on a single year of assessment (April and October 2021) of biological life from an extreme drought time period 2021 as a basis for their ecological studies report. This is not a good way to gauge the potential impact of the proposed study because the full inventory of species use is not likely to be reflective of potential species (both aquatic and terrestrial) use under more natural non drought conditions and will prevent thorough consideration of the overall impact of the project. As Freddy Otte can attest to, bullfrogs are found on occasion within this drainage which indicates that habitat is suitable for other multistage amphibians including red legged frog.

Additional Concerns:

Stream Riparian edge depicted as a straight line, which is not accurate.

Natural riparian systems and their associated forests typically do not occur in straight lines. Current staking of the edge of riparian forest cuts off an extension measuring 15’ x 25’ which is 375 ft2 of riparian forest that would be excluded from protection as it is now staked. The current staking pattern runs counter to the “measurement of creek setbacks” listed in the San Luis Obispo Municipal Code 17.

70.030C. This area is on the North side of the property close to the proposed ADU driveway. The actual existing riparian forest edge should be corrected for accuracy and for further protection of this important habitat.

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Sincerely,
Robert Schroeter PhD

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Patricia Drive Response to Comments
Kathy apRoberts
– October 3, 2022
Comment Response I would like to specifically comment on the San Luis Obispo County CEQA Air Quality Handbook which evaluates project-specific impacts and determines if potentially significant health impacts could result from a project. "The project site is a flag lot and is directly adjacent to residential development in all directions. Construction activities, such as excavation, grading, vegetation removal, staging, and building construction would result in construction vehicle emissions and dust that will impact neighbors within 1,000 feet." Initial Study Environmental Checklist, page 18.*Earth Moving - 841 Patricia plans x In the recent past, we have had neighbors diagnosed with Valley Fever. To provide context, it's important to understand how much earth moving will be involved during proposed construction.
x "Project construction would require approximately 1,932 cubic yards (cy) of cut and 650 cy of fill, for a total of 2,582 cy total cut/fill. Construction is anticipated to last approximately 24 months. Construction would result in approximately 35,000 square feet (0.8 acre) of ground disturbance and would replace approximately 12,540 square feet of previous surface area." Valley Fever - How does it relate to the proposed project at 841 Patricia Drive? x SLO County has the third-highest number and rate of cases in California, after Kern and Kings counties. With Valley Fever, knowledge is power. Valley Fever (or Coccidioidomycosis) is an infection caused by inhalation of spores of the fungus, Coccidioides, which lives naturally in the soil. It is highly endemic in Arizona and some areas of California, including San Luis Obispo County, Monterey County and the Central Valley region. x SLO County Health Department - "Although the fungus that causes Valley Fever can live anywhere in our county, many local cases are from the northern part of the county where conditions are especially dry and windy.

As discussed in the Initial Study and reiterated by the commenter, project construction would require approximately 1,932 cubic yards (cy) of cut and 650 cy of fill, for a total of 2,582 cy of total cut/fill. Construction is anticipated to last approximately 24 months and would result in approximately 35,000 square feet (0.8 acre) of ground disturbance and would replace approximately 12,540 square feet of pervious surface area. Although the project would not result in significant construction-related emissions,
SLOAPCD’s CEQA Air Quality Handbook recognizes special conditions, such as proximity to sensitive receptors, that require implementation of standard construction mitigation measures to reduce diesel idling and fugitive dust. Due to the project’s proximity to surrounding residential areas, standard measures for reducing DPM and fugitive dust are required and have been included as Mitigation Measures AQ-1 and AQ-2. As the commenter identifies, many local cases of Valley Fever are from the northern part of the county where conditions are especially dry and windy. The project is located within western-central portion of the county in the city of San Luis Obispo. SLOAPCD’s CEQA Air Quality
Handbook does not include guidance for evaluating potential impacts related to valley fever.Mitigation Measure AQ-2 includes numerous requirements for dust control during construction activities, including spraying and covering dirt stockpile areas and using water trucks and/or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site. The risk of Valley Fever is low due to the project location. In addition,

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When this soil is disturbed by wind, construction, or other causes — people
can breathe in the spores from this fungus and develop Valley Fever. " Please include this letter in the case file for 841 Patricia Drive. (City Files EID0547-0201, ARCH-0040-2021) because construction-related dust would be controlled and managed within the project site, impacts to surrounding residents related to Valley Fever would be less than significant. The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

Kathy apRoberts
– October 4, 2022
Comment ResponseThe City’s Zoning Regulation 17.70.030 clearly established the purpose of Creek Setbacks. First, these setbacks are intended to “protect scenic resources, water quality, and natural creekside habitat, including opportunities for wildlife habitation, rest, and movement.” The second stated purpose is “the restoration of damaged or degraded habitat, especially where a continuous riparian habitat corridor can be established.”
Regarding Creek Setback Expectations, we understand that there are eight findings that must be made in order for the Director to approve such an exception. Within the design of the proposed project at 841 Patricia Drive, we believe there are five findings that are not possible to meet. They are:

1. Minimal impact should mean that there is no development in the creek itself. The location and design of the proposed bridge will absolutely not minimize impacts to scenic resources, water quality, and riparian habitat, including opportunities for wildlife habitation, rest and movement.

2. There are no circumstances applying to this site, such as size, shape or topography that would deprive the property privileges enjoyed by other property in the vicinity with the same zoning.

3. This exception would constitute a grant of special privilege. A creek setback exception would be inconsistent with the limitation upon other properties in the neighborhood.

As noted in the IS/MND and supporting documents, the span bridge has been located in a more open and less densely vegetated area of the riparian habitat that minimizes vegetation removal. The span bridge has footings above the 100-year water surface elevation to allow for unimpeded high flows and the project includes a revegetation plan to compensate for the proposed vegetation removal in order to maintain the riparian corridor for wildlife habitation, rest, and movement. With implementation of identified mitigation, the existing riparian corridor would be preserved within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use.As stated on page 2 of the IS/MND, the project includes a proposed Creek Setback Exception to allow an exception to the creek setback requirement for the placement of the bridge and associated footings and supports within this setback area. The requested exception would thus allow the use of the eastern portion of the site for the ADU residential unit. Without the bridge crossing, this eastern portion of the site would not be accessible by vehicle. To be approved, the exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). The question of

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4. Site development can be feasibly accomplished with a redesign of the project.

5. Redesign of the project would not deny the property owner reasonable use of the property given comparable development scale in the neighborhood, even on a larger than average lot.

We believe that incorporation of five of the mitigation measures into the project at 841 Patricia Drive will not reduce the significant impacts of the project. Please include this correspondence in the case file: EID-0547-0201, ARCH-00402021. whether the necessary findings can be made is a question of policy interpretation and not an environmental issue. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of an alternative project layout is not required.The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

Victoria Frydenlund and Daniel Alvarez
– October 4, 2022
Comment ResponseThe purpose of this letter is to provide comments to the initial study environmental checklist and draft Mitigated Negative Declaration (MND) for 841 Patricia Drive, San Luis Obispo in City Files EID-0547-2021 and ARCH-0040- 2021 and per the Notice of Availability and Intent to Adopt a Draft Mitigated Negative Declaration for the Michaels Residence Project.

As property owners adjacent to the 841 Patricia parcel, we have concerns regarding the extent of development within Twin Ridge Creek, the creek setback requirements and the City’s declaration of a Riparian Wildlife Corridor on the property. The initial study and MND provide for actions to mitigate impact to Twin Ridge Creek and Wildlife Corridor; however there are errors, omissions and potentially additional mitigations necessary to reduce impact to this sensitive environment on the property.We appreciate the desire to develop the property at 841 Patricia Drive, and given the unique characteristics of the property it is important to preserve wildlife and the creek environment. We believe it is possible to develop on this parcel without harming the creek and wildlife corridor by placing all structures within the building envelope on the west side of the creek and thus not disturb the creek In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures.

Therefore, evaluation of an alternative project layout is not required. As noted in the IS/MND and supporting documents, the span bridge has been located in a more open and less densely vegetated area of the riparian habitat that minimizes vegetation removal. The span bridge has
footings above the 100-year water surface elevation to allow for unimpeded high flows and the project includes a

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area or wildlife corridor. In doing so, much of the MND actions would become unnecessary and thus preserve this precious environment within the neighborhood. We do not claim to be land use planners, so simple common sense is what is driving our intentions for providing comments.Attached please find comments to the documents including proposed additional information needed in order to correct and or include within the study and MND.

Please feel free to contact us should you have any questions regarding these comments. revegetation plan to compensate for the small amount of vegetation removal in order to preserve the riparian corridor for wildlife habitation, rest, and movement. With
implementation of identified mitigation, the existing riparian corridor would be preserved within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use. The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

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width for that type of vehicle. In doing so, it would allow for less destruction within the creek and wildlife corridor.

The description should be revised to include the length of the bridge and the MND should recommend reducing the width of the bridge to 6-8 feet wide to accommodate the envisioned small vehicles e.g. electric cart.

The description of the bridge has been revised to identify the proposed length (55 feet).At this time, the bridge has not been fully designed; the 12-foot-width represents a maximum potential bridge width. The final design and width of the bridge will be as required by theCity, consistent with safety and emergency access requirements. As noted in the IS/MND and supporting documents, the span bridge has been located in a more open and less densely vegetated area of the riparian habitat that minimizes vegetation removal. The span bridge has footings above the 100-year water surface elevation to allow for unimpeded high flows and the project includes a revegetation plan to compensate for the small amount of vegetation removal in order to preserve the riparian corridor for wildlife habitation, rest, and movement. With implementation of identified mitigation, the existing riparian corridor would be preserved within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use.This comment has been provided to decision makers for consideration.

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These statements in paragraph 4 and Table 1 are in conflict with the statement about the creek set-back exception. The information in the fourth paragraph and Table 1 should be revised to state that there is an exception to the creek-set back and the proposed minimum setbacks are zero (0) for creek set-back due to the bridge, associated vehicle roadway, paving/parking and the exceptions being requested. In addition Table 1 states the allowed/required set-back for the ADU is 4 feet per city code, but for this property there is a sewer line easement that requires a 15 foot set-back and the 15 feet plus 4 feet should be listed in Table 1 under allowed/required.

Paragraph 5 in the IS/MND clearly states the project "would provide a minimum setback of 5 feet from the interior side yards, 15 feet from the rear property line, and 20-feet from a line representing the edge of riparian vegetation associated with the creek." As shown in Figure 2 (Site Plan Map) of the IS/MND, the project includes a 20-foot creek setback to the nearest residential structure, as established by the City Biologist.

This has been further clarified in the footnotes on page 2.

The project plans also reflect the 15-foot-wide sewer and access easement along the rear property line. The 15-footwide access easement is consistent with the proposed 15- foot rear setback, which is depicted in Table 1, and is coterminous with and overlaps the required/allowed 4-foot rear ADU setback. Because of the easement, the proposed rear setback would be more than triple the standard required setback for an ADU. This comment has been provided to decision makers for consideration.

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includes a swimming pool. Furthermore, per Figure 2 the design includes a wall within the creek set- back area but is not described in this section of the document. The wall height is depicted in the project plans as 5.5 feet above ground and is shown to span entirely in the set-back. Please revise this information to include the pool and that the 5.5 foot wall and roadway is entirely within the set-back area. The wall should be included in what is being requested in the exception for the set-back area.

The pool is located within the footprint of the proposed residence and is depicted on Figure 2 (Site Plan Map) of the IS/MND. Paragraph 2 of the Description of the Project clearly states that “Proposed site amenities include an infinity pool, an outdoor kitchen, outdoor decking, a gym/spa, and outdoor shade structures.”Per Section 17.70.030 of the City Zoning Ordinance, walls or fences are allowed within the creek setback area as long as they do not extend beyond the top of bank into the creek channel; will not cause the removal of native riparian vegetation; will not reduce any flooding capacity in compliance with the city’s flood damage prevention regulations; in total occupy not more than one-half of the total required creek setback area; and are consistent with

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other property development standards of the zoning
regulations.The IS/MND provides that “the project includes a proposed Creek Setback Exception to allow an exception to the creek setback requirement for the placement of the bridge and associated footings and supports within this setback area, and for any encroachment of associated paving and vehicle parking area into the required Creek Setback area (emphasis added)”. This section has been revised to further clarify that “associated paving” includes the internal access road and retaining wall, as shown in Figure 2. This comment has been provided to decision makers for consideration.

Pages 2-3: The last sentence on page 2 This sentence appears to be incomplete in terms of the type of accessibilitybeing stated. The eastern portion of the site is accessible by foot based upon the numerous visits to the site by the project manager, the project planner and City staff. Does this sentence imply the eastern portion is not accessible by a vehicle? If so, it should be revised to be clear on what type of access in not accessible.

This section has been clarified to refer to vehicular access.

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and vegetation? It is also unclear in the plans provided in Attachment 1 that the utilities would be placed underground as it appears they are alongside the bridge. There is no description in the plans that the utilities will be trenched/undergrounded. Please clarify where in the plans it is stated the utilities will either be underground or on the bridge span.

Given the sensitive nature of Twin Ridge Creek and Riparian Wildlife Corridor, it would be a better option to develop the ADU on the western portion of the parcel within the building envelope and thus mitigating all impacts to the creek and setAs discussed in the Description of the Project, trenching/undergrounding would be considered more impactful to the environment compared to hanging the utilities from the bridge span or within the bridge decking/enclosure. The Description of the Project has been clarified to explain this is because it would require additional undergrounding, trenching, and/or ground disturbance below the riparian corridor and/or within the creek. Because both possibilities are shown on the project plans, the IS/MND assumes that the project could include the trenching/undergrounding of the utilities below the creek to capture worst-case scenario impacts. Mitigation has been identified in Section 4, Biological Resources, which requires all utilities to be placed within or attached to the bridge span.

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back. Why isn’t there a mitigation calling for revised conceptual plans that would not disturb the creek and creek-set back areas at all?
In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of an alternative project layout is not required.

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associated with Valley Fever. Neighbors, not just those adjacent, should be notified of the risks of NOA and Valley Fever. Furthermore, are the mitigations listed in AQ-2 sufficient to reduce the risk and harms from Valley Fever? If not additional mitigations should be proposed. Reference: https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Coccidioidomycosis.aspx SLOAPCD’s CEQA Air Quality Handbook does not include
guidance for evaluating potential impacts related to valley fever. However, SLOAPCD’s CEQA Air Quality Handbook recognizes special conditions, such as proximity to sensitive receptors, that require implementation of standard construction mitigation measures to reduce diesel idling and fugitive dust. Due to the project’s proximity to surrounding residential areas, standard measures for reducing DPM and fugitive dust are required and have been included as Mitigation Measures AQ-1 and AQ-2.

Mitigation Measure AQ-2 includes numerous requirements for dust control during construction activities, including spraying and covering dirt stockpile areas and using water trucks and/or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site. The risk of Valley Fever is low due to the project location. In addition, because construction-related dust would be controlled and managed within the project site, impacts to surrounding residents related to Valley Fever would be less than significant.

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The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

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The IS/MND and supporting documents acknowledge the potential for Cooper’s hawks to occur as it is commonly associated with riparian habitats. They can be seen throughout the year (breeding, migrating, winter nomad) in and around San Luis Obispo and beyond. With implementation of identified mitigation, the existing riparian corridor would be preserved and/or restored within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use.The proposed single-family residential use of the project site would be consistent with surrounding residential uses and would not substantially alter ambient conditions for wildlife. Additionally, mitigation has already been included to require preconstruction nesting bird surveys and identifies the protocol to be followed if birds are found nesting within the project area to reduce project impacts on nesting birds, including Cooper’s hawk.

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either end of Twin Ridge Drive. These two collection points drain all of the runoff into Twin Ridge Creek. During the rainy season, these two storm drains empty large volumes of run-off into Twin Ridge Creek; and 2) we observe deer on a regular basis using the creek and riparian corridor to move through 841 Patricia and surrounding areas. One recent observation was on September 23, 2022 where there was a young buck, a doe and fawn using the creek corridor. Furthermore, in Attachment 3, the Biological Resources Assessment, it states “the site can provide habitat for a variety of wildlife species that have become adapted to the urban environment such as raccoons, opossums, skunks, with evidence of deer, gopher and ground squirrels observed”. We have observed The IS/MND and supporting BRA established evidence of deer, gopher, and ground squirrel usage of the site. A “movement corridor” suggests connectivity between habitat areas. The IS/MND and supporting documents establish the creek goes underground several blocks downstream of the project site thus lacking connectivity as a movement corridor between habitat areas. Wildlife usage of the site was established in the IS/MND and supporting documents; additional clarifying language has also been added to this section.

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these animals as well as rabbits, turkey vultures and wild turkeys. The sentence on page 27 should be revised to be consistent with the BRA report and reflect that deer and other wildlife actually do use the Twin Ridge Creek as a movement corridor.

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for replanting trees that were removed? The BRA addendum in Attachment 4, proposes to replant the up to 17 oak trees with 1 gallon trees and to replace the Arroyo Willow’s with 20 willow sprigs. According to the City’s Tree Regulations (Municipal Code 12.24), per 12.24.090 (C.2), removal of a tree in a creek setback area requires a permit. Therefore, it should be clearly stated that there needs to be a permit requested to remove any trees in the creek set-back area.

Some of these trees are being removed within the creek proper. Section

12.24.090(J), Compensatory Tree Planting, states “Tree removals authorized under subsection E or F of this section shall be compensated by planting a minimum of one new tree for each tree authorized to be removed when planted on the same property (on site).” Further in this section is a table indicating the size of tree to be replanted based upon diameter of the tree removed and the City’s engineering standards. According to this table, trees that are between

0.75” and 1.5” are to be replanted with a 15 gallon tree. Trees between 1.5” and 2.5” are to be planted with a 24” box. However, according to the proposed replanting plan in the BRA addendum, the sizes of the trees are 1 gallon for the Oak trees and sprigs for the Arroyo Willows. Bio-3 should be revised to recommend the same standards as defined by the City Code for Tree Removal

12.24.090 and to require larger trees to be replanted to ensure revegetation of the creek corridor. What are the implications if the project causes more trees that defined in the BRA addendum need to be removed? We strongly urge the City to preserve this wildlife corridor by asking that the project be redesigned to mitigate impacts to the creek by building all dwellings on the west side of the building envelope.

By design, tree removal has been minimized for the project and will be subject to review as part of this discretionary project. One gallon planting stock is appropriate in natural settings and has shown a greater level of survivorship than larger container of box trees.The project would require the removal of 17 coast live oak saplings and 20 to 30 arroyo willow stems from approximately four trees within the riparian corridor for construction of the new bridge crossing over the portion of Twin Ridge Creek on-site. Following construction activities, the project includes the replanting of 20 coast live oak onegallon trees (10 one each side of the corridor), four California bay laurel one-gallon trees (two on each side of the corridor), four California sycamore one-gallon (two on each side of the corridor), and 20 willow sprig trees (throughout the creek channel), which is consistent with the City’s Municipal Code (12.24.090), which requires the replanting of removed trees on-site at a minimum 1:1 ratio.

The size requirements in the referenced table apply to street trees and are not relevant to the revegetation plan or this project. Replanted trees would be irrigated for three years and maintained and monitored for five years to meet an 80% survival success. Other riparian trees would be protected through provision of a Creek Setback as determined by the City Biologist and depicted in plans.

In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the

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project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that
potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of an alternative project layout is not required.

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encroaches both the creek set-back and creek itself. The plans do conflict with local plans and policies and thus the need to mitigate harms and risks as well as requiring a request for an exception to the set-back criteria defined by City Municipal Code. This conclusion needs revision for accuracy to the facts of the proposed development.

The IS/MND provides that “the project includes a proposed Creek Setback Exception to allow an exception to the creek setback requirement for the placement of the bridge and associated footings and supports within this setback area, and for any encroachment of associated paving and vehicle parking area into the required Creek Setback area”. The improvements that would be located within the Creek Setback, if approved as part of the requested Creek Setback Exemption are shown in Figure 2. Refer to additional responses above. The conclusion on Page 29 of the IS/MND has been revised to consistently summarize the description of the project and analysis in the IS/MND. A Creek Setback Exception is allowed per the City’s Municipal Code if necessary findings are made, and would, therefore, not constitute a conflict with local plans or policies.

The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

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which dwellings.

A reference to Attachment 1 has been added to this section. The main residence is proposed to be mixed fuel and the ADU would be all electric. As stated in Table 6, the project would be required to document compliance with the City's Energy Reach Code and CBC requirements on final construction plans to be approved by the City.

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Given the mixed fuel use with this project, it should be very clear that the project should be fully compliant with CBC requirements for mixed fuel dwellings. Pages 40-42: Hazardous and Hazardous Materials This evaluation does not include the hazard of airborne illness due to the Valley Fever fungus (Coccidioides sp). This section should be revised to be consistent with the Air Quality Section regarding this risk of hazard within the ground to be disrupted during construction.

Potential impacts related to Valley Fever are evaluated in the Air Quality section of the IS/MND and comment responses related to Air Quality above.

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study to remove or reduce the driveway width where feasible, so this point should also be revised. There should be a specific point to reduce the size of the bridge and driveways to be consistent with the use of an electric cart as previously stated in the document.The project should be redesigned to mitigate impacts to the creek by building all dwellings on the west side of the building envelope.

Impact discussion 10.(b) states that the project would result in 12,540 sf of new impervious surfaces, which would result in an approximate 20% increase in impervious surface areas at the project site. The Description of the Project makes clear that this amount includes the single-family residence, the ADU, internal roadways and span bridge, and
associated impervious components including, i.e., a swimming pool, pool deck, patios, and all other impervious surfaces that would be developed at the site. No changes to the IS/MND are necessary. The 55-foot-long and 12-foot-wide bridge is clearly described in the Description of the Project. The estimate of resulting pervious/impervious surface areas that would result from the project is accurately stated. At this time, thebridge has not been fully designed; the 12-foot-width represents a maximum potential bridge width. The final design and width of the bridge will be as required by the City, consistent with safety and emergency access requirements. Within the scope of this environmental document, no potentially significant impact was identified that would provide a nexus for a mitigation requirement to reduce the size of the bridge or access way.

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In accordance with CEQA Guidelines Section 15126.6,
consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. Therefore, evaluation of an alternative project layout is not required.

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there be additional clearance for flows given the topography of the site and creek area? In this era of climate change, is a 100 year flood standard reasonable? We have observed flooding of this area in the past given the creek channel is very shallow. We recommend there be additional mitigations to address flooding risk from the alterations to the creek due to construction of the bridge. Those mitigations should include removing the bridge from the plans and building the ADU on the western side of the property.

As discussed in Section 10, Hydrology and Water Quality, according to FEMA Flood Insurance Rate Map 06079C1066G, effective date November 16, 2012, the project site is located within Zone X, area of minimal flood hazard. Based on the Preliminary Hydrology Study prepared by Chacon Associates, LLC for the project, the proposed bridge soffit would be constructed a minimum of 2 feet above the calculated 100-year peak flow water surface elevation. Standard regulatory requirements require projects to be designed to withstand a 100-year flood, and the
proposed bridge has been designed consistent with this requirement. As concluded in the IS/MND, impacts would be less than significant; therefore, mitigation is not necessary.

In accordance with CEQA Guidelines Section 15126.6,
consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. Therefore, evaluation of an alternative project layout is not required.This comment has been provided to decision makers for consideration.

Pages 45-46: Land Use and Planning This section does not include the points that the project requires an exception to the creek and creek set-back regulations in the City Municipal Code. This section should be explicit that while the use is consistent with the zoning of the As discussed on page 2 of the IS/MND, the project includes a proposed Creek Setback Exception to allow an exception to the creek setback requirement for the placement of the bridge and associated footings and supports within this

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property, the project is requiring exceptions in order to build an ADU on the eastern portion of the property. The impacts could be reduced if the project did not build on the eastern portion of the property and maintained all dwellings within the western side of the property. setback area, and for any encroachment of associated paving and vehicle parking area into the required Creek Setback area. To be approved, the exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). A Creek Setback Exception is allowed per the City’s Municipal Code if necessary findings are made, and would, therefore, not constitute a conflict with local plans or policies. Approval of an exception is subject to the required findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental
review of the project, but will be a primary consideration as the City considers final action on the project. In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of an alternative project layout is not required. This comment has been provided to decision makers for consideration.

Pages 47-50: Noise This statement is incorrect. This is not a mixed residential use (residential/commercial) as defined in the City Code for Noise Control-9.12. This project should be defined as residential per 9.12.020-Definitions. Furthermore, under 9.12.060, Exterior Noise limits states, “At residential properties, the

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maximum noise level from 7am-7pm daily except Sundays and Holidays is 75 dBA. Thus, the statement on Page 48 should be revised to reflect the City Code for Noise Control of 75 dBA. Furthermore, the equipment listed in Table 8 on page 48 exceeds the Noise Control limits. It is unclear whether the mitigations listed in N-1 to N-3 are sufficient to reduce the noise levels to an acceptable level below 75 dBA. Further evaluation is warranted and subsequent mitigations to reduce the noise level to the allowable maximum limit. and barriers) be employed as needed to ensure noise levels are maintained within levels allowed by the City of San Luis Obispo Municipal Code. As discussed on page 71 of the IS/MND, all construction noise reduction measures shall be reviewed and approved by the City Community Development Department prior to issuance of grading/building permits. Additionally, compliance with Mitigation Measures N-1 through N-3 shall be verified by the City prior to the start of construction and during regular inspections, as necessary. Required monitoring programs would ensure construction-related noise is consistent with City standards for maximum allowable noise-level at singlefamily residential properties during construction activities.

This comment has been provided to decision makers for consideration.

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pool at the property? It should be clearly stated in the evaluation that the estimates include not only used based upon the number of residents, but also that there is a swimming pool planned for the project.

The IS/MND evaluated an additional water demand of approximately 0.8 acre-feet per year (af/yr), with 0.491 acre of that estimate being landscaping, based on an individual review and estimate provided by the City’s Utilities Department. As evaluated in Section 19, Utilities and Service Systems Impact (b), the project would be provided water through the City’s water system, which has four primary water sources—Whale Rock Reservoir, Salinas Reservoir, Nacimiento Reservoir, and recycled water (for irrigation)—with groundwater serving as a fifth supplemental source. Development of this site is consistent with the City’s long-range planning documents and, thus, has been
anticipated by the City’s water supply planning, which considers the uses and type of development allowed in a particular location based on the site’s zoning designation and types of uses allowed within that particular zone. Swimming pools are a common residential amenity that are accounted for in water supply and demand planning for
residential development. The City’s diversification of water sources in the last several decades has allowed the City to maintain sufficient water supplies even following the driest

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years on record. The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided todecision makers for consideration.

Pages 60-61: Mandatory Findings of Significance This section on does not include the description of the 55 foot long by 12 foot wide steel bridge across the creek and within the creek area as well as the associated driveways and parking areas necessary to place the ADU in the eastern portion of the property. This span creates impact to the City’s own Municipal Code for creek preservation and requires an exception to those regulations. This section should state those facts and that the exception needs approval in order to build the bridge in the creek which significantly impacts the creek area. It should also be stated that other mitigations could be done, such as to build the project in the western side of the property within the building envelope and thus to not disturb the creek and maintain the creek set- back. This entire section should be revised to reflect the numerous mitigations that are necessary in order to mitigate the impacts of building the bridge and associated driveways and parking spaces for the eastern side of the property.

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be protected through provision of a Creek Setback as
determined by the City Biologist and depicted in plans. This section has been clarified to restate the required findings forthe proposed Creek Setback Exception, including a finding that the location and design of the features receiving the exception will minimize impacts to scenic resources, water quality, and riparian habitat, including opportunities for wildlife habitation, rest, and movement. Mitigation Measures BIO-1 through BIO-4 have been identified to reduce or avoid potential impacts to migratory birds, the on-site creek, and associated riparian habitat. The IS/MND and supporting
documents establish the span bridge is located in a more open area of the riparian habitat that minimizes vegetation removal. The span bridge has footings above the 100-year water surface elevation to allow for unimpeded high flows and the project includes a revegetation plan to compensate for the small amount of vegetation removal in order to
preserve the riparian corridor for wildlife habitation, rest, and movement. With implementation of identified mitigation, the existing riparian corridor would be preserved within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use.In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that

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potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of an alternative project layout is not required. This comment has been provided to decision makers for consideration.

Pages 67-72: Required mitigation and monitoring plan These sections should be revised based upon the comments provided for the specific sections of the initial study document to be consistent with the initial study corrections needed to make the report accurate and complete.

No additional mitigation measures are warranted nor do existing mitigation measures require revision as a result of public comments on the IS/MND. This comment has been provided to decision makers for consideration.

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refers to the nesting birds survey. However, BIO-2 mitigation is about the extension of the utilities and that no trenching across the creek shall occur for the extension of utilities. This error should be corrected as it appears in several monitoring programs in the MND. It would seem more appropriate that compliance for BIO-2 should be included in the plans for grading and/or construction, including the details on where the utilities will be located for the extensions. Verification then would be done through regular inspections of the project by City staff.

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refers to the nesting birds survey. However, BIO-2 mitigation is about the extension of the utilities and that no trenching across the creek shall occur for the extension of utilities. This error should be corrected as it appears in several monitoring programs in the MND. It would seem more appropriate that compliance for BIO-2 should be included in the plans for grading and/or construction, including the details on where the utilities will be located for the extensions. Verification then would be done through regular inspections of the project by City staff.

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The proposed compliance verification for BIO- 2 appears to be in error since it refers to the nesting birds survey. However, BIO-2 mitigation is about the extension of the utilities and that no trenching across the creek shall occur for the extension of utilities. This error should be corrected as it appears in several monitoring programs in the MND. It would seem more appropriate that compliance for BIO-2 should be included in the plans for grading and/or construction, including the details on where the utilities will be located for the extensions. Verification then would be done through regular inspections of the project by City staff.

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We believe this initial study/MND is in need of significant revision due to errors, omissions and additional mitigations needed. We would like to express our severe concerns about the project plans specifying the steel bridge across Twin Ridge Creek will be 12 feet wide by 55 feet long. The plans also show a retaining wall 5.5 feet high spanning about half of the property’s length. The wall is located within the riparian vegetation and creek set-back. The proposed bridge design is sufficiently wide to allow a car or truck to drive from the main house through a roadway, cross the bridge and park at the ADU. As our home is adjacent to 841, we are very concerned that headlights will add to the already increased light pollution created by this project.

The extensiveness of this development impacts the creek and wildlife corridor to such a degree that it is not consistent with the surrounding habitat and we believe the creek’s riparian vegetation will be negatively impacted. The trees surrounding the creek and wildlife corridor are native and protected. Even with any defined mitigations, the risks to permanently damaging this sensitive environment are too high. We do not think that the scale of the bridge and driveway are appropriate for this type of development and should not be allowed due to harmful impacts to the creek, wildlife corridor and neighborhood.

This comment summarizes the detailed comments above. Please refer to above responses. As evaluated in Section 1, Aesthetics, nighttime lighting for the project is required to comply with the Lighting and Night Sky Preservation Ordinance (17.70.100) standards for outdoor lighting and new development to avoid introducing new sources of light or glare within the project area. Therefore, the project would be consistent with existing surrounding uses and would not generate a source of significant light pollution in the area. Further, the bridge would be subject to limited use by project occupants and would not be substantially different than other residential traffic in the project vicinity. Therefore, impacts related to additional lighting from headlights would be less than
significant. The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

The proposed development project should be revised to place all dwellings on the western side of the creek set-back. This redesign would mitigate all the impacts to Twin Ridge Creek due to placing the roadways, walls, parking area In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified

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and extremely large bridge within the creek and set- back of the riparian vegetation by eliminating these design features and need for a creek set- back exception
According to San Luis Obispo Zoning Regulations under Creek Setbacks, 17.16.025(G.4),Discretionary Exceptions, a. Intent. Discretionary exceptions to creek setback standards are intended to allow reasonable use of sites that are subject to creek setbacks, where there is no practicable alternative to the exception. Generally, such exceptions are limited to small parcels that are essentially surrounded by sites that have been developed with setbacks smaller than those in subsection E of this section. In the case of pedestrian paths, bicycle paths and bridges, the site may be large but there are no options for avoiding a crossing of the creek or encroaching into the creek setback.

The development at 841 Patricia does not fit the intent of an exception given there are other options to develop on the 1.4 acre parcel and those options include redesign of the dwellings to all be located on the western side of the creek and within the larger building envelope of the parcel. Allowing such a large exception to the creek setback at 841 Patricia would set a damaging precedent for San Luis Obispo in this R-1 zoned area.
alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of a project redesign is not required.

As discussed on page 2 of the IS/MND, to be approved the proposed Creek Setback Exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). Approval of an exception is subject to the required findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental
review of the project, but will be a primary consideration as the City considers final action on the project.

The commenter's letter has been included in the case file for 841 Patricia Drive and will be provided to decision makers for consideration.

Dr. Bob Holzhauer and Ruth Holzhauer
– October 7, 2022
Comment ResponseAfter coming home from a vacation last week, we learned of building plans for a home in our neighborhood. Although we walk our dogs past 841 Patricia Drive almost daily, no sign has been posted to notify us of this project. We had no idea plans had been submitted. Why not? Project applicants are encouraged to consult with neighbors of a proposed project early in the development application process, and the applicant has described meetings and discussions held with neighbors to this site. This Department regularly publishes on the City’s website current listings of Planning and construction permit applications under review.

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Some changes affect us. We are writing to ask for reconsideration of this proposal.Adequate Public Notice has not been given to neighbors. I contacted three neighbors just this morning to ask if they were aware of the plans. They were not. It is the city's obligation to notify neighbors.

Several interested parties, including project neighbors, have been in communication with the City to stay updated on the details and status of the proposed project.Public notice for development applications is provided to owners and occupants of property near a subject site. In this case, such notice will be provided at least 10 days prior to consideration of the application by the appropriate decision making authority (e.g., Community Development Director, Planning Commission, etc.).

Creek and Public Access AlterationsThe San Luis Creek is a U.S. Blue Line Stream. It provides for run off of waters from Bishop Peak and surrounding areas. Where will this water be draining with the projected project?This stream has been documented for many years by the U.S. government. It is a real creek. Throughout those years our wildlife has thrived in the wetlands. For example and contrary to the project biologist, two years ago a red-legged frog was found in a neighbors yard a mile from the breeding prompt. Additionally, it is a wildlife corridor. Naming only a few examples, deer walk down our street, Patricia Court, from Bishop Peak to the creek. We watch wild turkey and quail walk their young up from the creek to Bishop Peak. It is an active area. Has proper permitting been received by CA Fish and Wildlife Stream Bed Alteration and the Water Quality Control Board? I didn't observe them in the packet. In reading the material provided, I would say this wildlife corridor, riparian area has clearly been underestimated.

As evaluated in Section 10, Hydrology and Water Quality, of the IS/MND, San Luis Obispo Creek flows to the Pacific
Ocean just west of Avila Beach and has six major tributary basins: Stenner Creek, Prefumo Creek, Laguna Lake, East Branch San Luis Obispo Creek, Davenport Creek, and See Canyon. The project site supports a portion of Twin Ridge Creek that flows in a north to south direction and bisects the central portion of the project area. The portion of Twin Ridge Creek on-site begins at a culvert in the northern portion of the project site and ultimately provides connection to other creeks within the city. Proposed physical improvement of the project site would be required to comply with the drainage requirements of the City’s Waterway Management Plan. This plan was adopted for the purpose of ensuring water quality and proper drainage within the city’s watershed. As part of these requirements, the City has been mandated to establish a set of minimum designated Best Management Practices (BMPs) and Pollution Prevention Methods (PPMs). BMPs are steps taken to minimize or control the amount of pollutants and runoff. PPMs are strategies to eliminate the use of polluting materials and/or exposure of potential pollutants to rainwater or other sources of runoff. Additionally, the project would be required to prepare an erosion and sediment control plan for short- and long-term erosion control in compliance with the City’s stormwater requirements. Therefore, potential impacts

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related to drainage and runoff were determined to be less than significant. As specified in Mitigation Measure BIO-3, the project is required to obtain and provide copies of the permits/authorizations from affected resource agencies prior to issuance of grading and building permits. A completed CEQA document is a requirement of regulatory permit
applications; therefore, permits are issued after completion of the CEQA process. The IS/MND and supporting BRA established evidence of deer, gopher, and ground squirrel usage of the site. A “movement corridor” suggests connectivity between habitat areas. The IS/MND and supporting documents establish the creek goes underground several blocks downstream of the project site thus lacking connectivity as a movement corridor between habitat areas. Wildlife usage of the site was established in the IS/MND and supporting documents.

Additional language has been added to this section to clarify the extent and type of wildlife observed using the area and surrounding neighborhoods.

Additionally, I also noticed much of the current percolating surface in the design will be covered with impervious surfaces. This is a concern. Provision has not been made clear for sheet flow and the water drainage.

As stated on page 44 of the IS/MND, the project would maintain approximately 80% of the site as pervious surface area. The project would maintain the on-site creek and
associated corridor, would construct driveways with permeable pavers, and would reduce driveway width where feasible. Proposed measures are included in the Stormwater Control Plan prepared for the project in accordance with the City’s post-construction stormwater requirements and would be subject to City review and approval. These requirements, and those of the Regional Water Quality Control Board, require stormwater flows to be managed onsite.

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Mitigation for Plant Replacement
Mature trees help stabilize soil preventing rapid run-off of rainwater, erosions and provide a buffer to filter pollutants out of water. Overhanging vegetation provides insects for wildlife and shade for animals and humans. Ripping out approximately 43 mature trees, 17 of them being mature oak trees, upsets this entire balance. The project has called for a one for one replacement of a mature tree with a one gallon baby tree. This is pathetic. How has the city ensured for the die ratio? For maintanence of the immature trees?
As described in the IS/MND and supporting BRA Addendum, the project would require removal of approximately 17 small coast live oak saplings (not mature oaks) and between 20-30 arroyo willow stems from four
trees may need removal or pruning for placement of the span bridge on the footings. The bridge location was sited in a more open and less vegetated area of the riparian corridor to minimize impacts on riparian vegetation. The project includes the replanting of 20 coast live oak one-gallon trees (10 on each side of the creek corridor), four California bay laurel one-gallon trees (two on each side of the creek corridor), four California sycamore one-gallon trees (two on each side of the creek corridor), and 20 willow sprig trees (throughout the creek channel).

The Applicant’s proposed compensatory riparian mitigation will provide supplemental irrigation for three years, and will be maintained and monitored for five years, to ensure the project meets 80% survival success criteria after two years without supplemental irrigation. (David Wolff Environmental 2021b; Attachment 4).

This home and land is on a portion of the creek that provides an interface of urban and rural life. Both the lives of people and the animals who live in the area would be effected. Please open the comment period, with proper notification, and allow the people who live in this area (and pay high property taxes) another thirty days.

Potential impacts to the environment were evaluated through preparation of an Initial Study, consistent with the provisions of the California Environmental Quality Act. This environmental review process included a 30-day review and comment period running from September 8th through
October 7th, 2022. In addition, the City encourages public participation in decisions made on development applications. Public notice will be provided to owners and occupants of property near the project site at least 10 days prior to consideration of the application by the appropriate decision making authority (e.g., Community Development Director, Planning

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Commission, etc.). The application will be considered at a public hearing which includes a public comment period.

Kathy apRoberts – October 7, 2022 Comment ResponseRegarding Creek Setback Exception Request for 841 Patricia Drive, San Luis Obispo:Looking at the property at 841 Patricia Drive, the lot area contained by the minimum lot and creek setbacks and excluding the ‘flag’ for the driveway - effectively the ‘by-right’ developable envelope- is approximately 15,500 square feet. At 40% maximum coverage (6,200 square feet) this project and the ADU (5,260sf + 830sf = 6,120 sf) could be designed and constructed to be together on the west side of the creek. This very conservative approach to developable area and lot coverage clearly demonstrates the project could be redesigned to avoid the need for the requested creek setback exception - a request that is undeniably one of choice, not necessity.

In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of a project redesign is not required. As discussed on page 2 of the IS/MND, to be approved the proposed Creek Setback Exception must meet the
requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). Approval of an exception is subject to the required findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental review of the project, but will be a primary consideration as the City considers final action on the project. This comment has been provided to decision makers for consideration. This comment has been provided to decision makers for consideration.

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Outside of the building footprints, the site development also includes a large pool, extensive patios and terraces, all choices made that inhibit the potential for the ADU to be included on the west side of the creek. With adjustments to those outdoor areas – and perhaps even by requesting a creek setback exception for the pool – additional space could be maintained on the west side of the creek and facilitate placement of the ADU without compromising separation and privacy between the two homes, and without requiring the severe impacts of installing a road and bridge to cross over and through the creek bed. The road and bridge are substantially larger impacts than the ADU itself in terms of surface area and creek encroachment.

In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that
potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of a project redesign is not required. This comment has been provided to decision makers for consideration. As discussed on page 2 of the IS/MND, to be approved the proposed Creek Setback Exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). Approval of an exception is subject to the required findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental review of the project, but will be a primary consideration as the City considers final action on the project. This comment has been provided to decision makers for consideration.

Per the San Luis Obispo Municipal Code 17.70.030.G.4.c findings must be made to grant an exception to the required creek setbacks. Finding #4 indicates that there needs to be “circumstances applying to the site, such as size, shape, or topography, which do not apply generally to land in the vicinity with the same zoning, that would deprive the property of privileges enjoyed by other property in the vicinity with the same zoning.” Over 6,000 square feet of building footprint, As discussed on page 2 of the IS/MND, to be approved, the Creek Setback Exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). The question of whether the necessary findings can be made is a question of policy interpretation and not an environmental issue. Approval of an exception is subject to the required

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large terraces, and a pool to not reflect a deprivation of privilege, is quite the opposite. Finding #7 requires that “site development cannot be feasibly accomplished with a redesign of the project.” As noted above, a redesign is entirely feasible, it just would not have a bridge. This is supported by text regarding Finding #8 that “in the case of new development (reasonable use of the property) may include less development than indicated by zoning.” findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental review of the project, but will be a primary consideration as the City considers final action on the project. This comment has been provided to decision makers for consideration.

The Initial Study mentions that “without the bridge crossing, the eastern portion of the site would not be accessible.” This may be true, but the property owner has no right to vehicular access across a waterway. Undoubtedly, outside of the rainy season, access by foot across the creek would be easily achieved.

The comment is noted. The decision-making authority may consider the feasibility of alternative means of providing adequate access to the proposed ADU in evaluating whether the required findings for a creek setback exception (set out in Zoning Regulations §17.70.030 (G)(4)(c)) can be made. While evaluation of alternative means of access is beyond the scope of environmental review of the project, it may be a consideration as the City considers final action on the project.

This comment has been provided to decision makers for consideration.

The commenter requests that correspondence be included in the City Files EIR0547-0201, ARCH-0040-2021. The commenter's letter has been included in the case file for 841 Patricia Drive and has been provided to decision makers for consideration.

Jud and Nara Clark – October 7, 2022 Comment ResponseWe are curious if all parties involved within the City have actually walked the property at 841 Patricia drive and witnessed what the creek and wildlife corridor look like in person? Although the City has in place protections for the creek and the surrounding riparian area, its hard to protect something that you've never seen. Our hope is that all parties involved take the time to visit the site and to Representatives of City departments and divisions including Planning, Engineering, and Natural Resources have conducted several site visits with the applicant team through the course of application review. A site survey was conducted at initiation of the environmental review process,

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take in the surrounding area as the proposed bridge through the creek and riparian area are not what the City laws have in place to protect. We believe the owners have every right to build on their property however feel that there is ample room to have an ADU and storage shed on the main development site without having to encroach upon a protected creek, riparian area, and wildlife corridor. with City staff and the City’s environmental consultant in attendance. No revisions to the IS/MND are necessary in response to this comment. This comment has been provided to decision makers for consideration.

We would like further information on the initial study environmental checklist as to why an Environmental Impact Report is currently not required? We don't feel like the Mitigated Negative Declaration truly delves into the negative environmental effects that will take place by cutting down a large quantity of naturally occurring willows along the creek to make way for a 55 foot long 12 foot wide bridge to cross the creek to get to an ADU unit and storage shed that will also impact a large portion of the riparian and wild life corridor areas.

The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures; therefore, an Environmental Impact Report is not necessary for the project pursuant to CEQA Guidelines Section 15063. The IS/MND and
supporting documents establish the span bridge is located in an open area of the riparian habitat that minimizes vegetation removal. In order to fully mitigate for the oak and willow tree riparian habitat removal, the proposed project includes planting of 20 coast live oak, four California bay laurel, and four California sycamore 1-gallon trees, and 20 willow sprigs planted throughout the channel bottom. The proposed compensatory riparian mitigation will add plant species diversity and density to increase the riparian habitat values on site.

Impacts to creeks are commonly evaluated in an MND for CEQA purposes due to the availability and applicability of well established mitigation options.

HYDROLOGY/FLOODING: We have lived in this neighborhood since 2002 and have witnessed on multiple occasions heavy rainfall that has resulted in the entire open are behind our house and within the proposed shed, ADU unit, and bridge flooded with water. As homeowners that back up to the proposed project, we are extremely worried that any change to the creek flow can result in a disastrous flooding situation that can affect neighbors within the entire creek area including further downstream from the project. We don't believe the impact CEQA generally does not require that public agencies analyze the impact existing environmental conditions might have on a project’s future users or residents, according to the California Supreme Court’s decision in California Building Industry Association v. Bay Area Air Quality Management District (S213478, December 17, 2015). The IS/MND evaluated the potential for the project to result in

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study takes into account current models of precipitation that could impact our area due to the adverse affects of climate change. Last year we didn't get much annual rainfall but the one big storm we had dropped almost 7 inches of rain in a 2 day period that did cause considerable ponding and areas of localized flooding. This is a situation that could happen more frequently than previously planned for based on the traditional 100 year or 500 year storm models. impacts related to flooding in Section 10, Hydrology, Impact Discussions (c) and (d). According to Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map 06079C1066G, effective date November 16, 2012, the eastern portion of the project site is located within Zone X, an area with limited potential for annual flooding. As described in the IS/MND and supporting documents, the span bridge would be placed on footings located above the 100-year water surface elevation to allow for unimpeded high flows. Therefore, no built structures or facilities would be constructed within the 100-year flood zone.

Implementation of the project would result in minor alterations to the on-site creek for construction of the span bridge and associated footings and supports. However,
contours within the limited area of disturbance would be returned to existing conditions upon completion of construction. The minor alterations would not reduce the flood capacity of the existing creek or impede or redirect flood flows because the channel would be maintained and all built structures would be located outside of the flood zone. Therefore, the project would not worsen or exasperate existing flood potential within the project site, and potential impacts associated with impeding or redirection of flood flows would be less than significant. No revisions to the IS/MND are necessary in response to this comment. This comment has been provided to decision makers for consideration.

We would also like to challenge the report under Aesthetics letter a: This project if approved with the bridge and ADU and shed, will have a potentially significant and substantial adverse effect on a scenic vista. I'm confused as to why the initial report is checked with a less than significant impact. This may be true for the main building site but not the bridge, ADU, and shed. Not only will neighbors that back up to the project have a significant aesthetic impact but anyone walking or running on Patricia past the creek area will be exposed to an anomaly that is not congruent with the aesthetics for the rest of the neighborhood or open As discussed in Section 1, Aesthetics, a scenic vista is generally defined as a high-quality view displaying good aesthetic and compositional values that can be seen from public viewpoints. Based on the City’s COSE, the project site is not located within or within close proximity to a designated scenic vista. Development of a single-family residence and ADU on the project site would therefore not change existing views within a designated scenic vista. The

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space. We would also like to challenge letter c: and believe that approval of the bridge, ADU unit and Shed will have a significant impact and degrade the existing visual character or quality of public views of the site and its surroundings. Under letter d) we also feel that the ADU unit and shed will create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. We would like to add that having the ADU unit will not only create light pollution for our neighborhood but potential noise issues as well depending on who the owners rent the property to.
project would not block or result in significant adverse change in public views from within the surrounding neighborhood. The single-family residential uses proposed are consistent with existing uses surrounding the project site on all sides and the project site is not visible from any scenic roadways designated in the City’s COSE. For these
reasons, the project would not substantially degrade the existing visual character or quality of public views of the site, nor would the project conflict with regulations that have been established for the purpose of preserving scenic quality or resources. Although the project would add built components across the creek and on the east side of the parcel, the channel and riparian habitat would be maintained and/or enhanced through replacement plantings. Thus, impacts to visual character would be less than significant. Existing sources of nighttime lighting near the project site include residential street lighting and intermittent vehicle lighting from vehicles traveling along Patricia Drive. Nighttime lighting for the residence is required to comply with the Lighting and Night Sky Preservation Ordinance (17.70.100) standards for outdoor lighting and new development, which include, but are not limited to, requirements for new outdoor light sources to be shielded and directed away from adjacent properties and public rights-of-way, requirements for minimum levels of lighting consistent with public safety standards, and limits to hours of lighting operation. Therefore, impacts from new sources of light or glare would be consistent with surrounding uses and less than significant. Noise levels are regulated by the City’s Noise Ordinance, which identifies maximum exterior and interior noise limits for residential areas. In the project vicinity, the Noise Ordinance prohibits exterior noise in excess of 50 dBA and interior noise in excess of 40 dBA between the hours of 10:00 pm and 7:00 am. Noise generated from the ADU would be expected to be similar to comparable small

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housing units. Excessive noise in excess of established limits would be subject to City enforcement actions. No revisions to the IS/MND are necessary in response to this comment. This comment has been provided to decision makers for consideration.

Land Use and Planning letter b: We would also like to challenge the finding that this project will have less than a significant impact with mitigation incorporated environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect: We believe the City has standards and laws in place to protect the creeks, riparian areas and wildlife corridors for a reason. It is one of the City's missions and to establish a precedent of approval to build a bridge, ADU unit and shed across a protected creek, riparian area and wildlife corridor goes against what the City of San Luis Obispo is trying to protect. If approved this project will literally pave the way for any landowner with property spanning across a creek, riparian area and wildlife corridor in San Luis Obispo to ask for an exception to build a bridge, ADU unit and storage sheds in what was once a protected area. I will reiterate, we are not against the owners building on the primary site, however feel it is unnecessary given the lot size and dimensions to encroach or build through a riparian area by removing naturally occurring protected willows over a protected creek into a wildlife corridor.

The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. The project includes a proposed Creek Setback Exception to allow the placement of the bridge and associated footings and supports within this setback area, as well as other project components (e.g., retaining wall, internal access road, pool deck). The requested exception would thus allow the use of the eastern portion of the site for the ADU residential unit. Without the bridge crossing, this eastern portion of the site would not be accessible. To be approved, the exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). The City’s Zoning Regulations allow for exceptions to established creek setbacks if certain mandatory findings can be made. The project proposes a Creek Setback Exception pursuant to the Zoning Regulations and is, therefore, not in conflict with City Zoning Regulations. Approval of an exception is subject to the required findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception requests against these required findings is beyond the scope of environmental review of the project, but will be a primary consideration as the City considers final action on the project. Future proposals that include creek crossings and/or

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requests for a creek setback exception would be subject to the same discretionary review process and mandatory findings. This comment has been provided to decision makers for consideration.

Biological Resources Assessment: I would like to state that in fact there are multiple areas along the creek within the building area that have ponding that can be present into late May and sometimes June depending on how much rain we received in the prior months. Years ago when my daughter was 7 or 8 years old we were cleaning up debris in the creek and were surprised and excited to find turtles in one of the ponding areas located within the proposed building site. We haven't seen turtles in a long time but haven't been specifically looking for them. We can also say with certainty that Coopers Hawk's frequent the creek and riparian areas almost daily. We have also witnessed the yellow-breasted chat on occasion. The creek and riparian areas also have many deer on a year round basis and higher rates during birthing months.

The IS/MND and supporting documents acknowledge the potential for Cooper’s hawks to occur as it is commonly associated with riparian habitats. They can be seen throughout the year (breeding, migrating, winter nomad) in and around San Luis Obispo and beyond. Additionally, mitigation has already been included to require preconstruction nesting bird surveys and identifies the protocol to be followed if birds are found nesting within the project area to reduce project impacts on nesting birds, including Cooper’s hawk and yellow-breasted chat. As identified on page 25 of the IS/MND, the riparian corridor associated with the on-site creek does not provide habitat for special-status riparian species (i.e., special status turtles, frogs) due to the lack of understory shrub and natural debris. The IS/MND and BRA Addendum field survey established the existing conditions of the creek corridor and lack of onsite suitable aquatic habitat for California redlegged frog (long duration ponding) within the narrow and shallow braided channel topography through the property. The IS/MND and supporting BRA established evidence of deer, gopher, and ground squirrel usage of the site; additional information has been added to the MND to clarify other observations of wildlife within the site. With required mitigation and plantings, the existing riparian corridor would be preserved within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use. The proposed compensatory riparian mitigation will add plant species diversity and density to increase the riparian habitat values on site. The project would not

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substantially alter drainage patterns within the site or the ability for the site to support ponding, similar to existing conditions.

Is it possible for the City to post at the entrance to the 841 property the proposed project with a concept design so the community can better understand the significance of this project and how it will negatively impact the creek, riparian area, and wildlife corridor? It's easy for community members to not know what's going on unless something is visibly in place for them to read while they are out and about on a walk or run.

Potential impacts to the environment were evaluated through preparation of an Initial Study, consistent with the provisions of the California Environmental Quality Act. The Initial Study concluded that potential environmental impacts to biological resources would be reduced to a less than significant level with incorporation of certain mitigation measures described in the Mitigated Negative Declaration that is the subject of this comment.

The Initial Study and Mitigated Negative Declaration, which include site plans and project drawings, have been made available on the City’s website. Planning staff are available for contact by phone, email, or visit to the Community Development Department offices to answer questions or concerns about environmental review of the project, and the project application materials are available at our offices for review.

Thomas E. and Mary Kay Eltzroth – October 7, 2022 Comment ResponsePlease consider this response to the Notice of Availability and Intent to Adopt a Draft Mitigated Negative Declaration for the Michaels Residence Project (City Files EID- 0547-0201, ARCH-0040-2021). Project Location 841 Patricia Drive.

We own and reside permanently at 847 Patricia Drive. Ours is the property immediately to the left of the Michaels' driveway and immediately in front of the main portion of the proposed residence. We are responding to a portion of The Initial Study and Mitigated Negative Declaration. Specifically we are responding to the 21-page document that is referred to as "Project Plans (Jun [sic] 17, 2022)", also sometimes referenced as Attachment 1. We are uncertain about the exact title and date of this document because dates other than Jun/June 17, The applicant’s project architect confirmed the referenced elevation heights are in keeping with the design of the residence and are not expected to increase above the reference points noted. The roof structural assembly would need to be coordinated during preparation of construction documents to finalize roof materials and insulation thickness required for code compliance. The roof material thickness may adjust in thickness but would be negligible to the overall height of the project.

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2022 appear on several pages of the document, so to make clear which document we are referencing it is included as an attachment to this email with the title we have given it - "Referenced Document". Please consider the attachment as part of our response. From our reading and careful review of the referenced document, it is our understanding that:

1. As shown in "Site Section 2 @ Living" (page A4?) the highest point of the residence roof will not exceed an elevation of 375.57

2. As shown in "Site Section 1 @ Garage" (page A4?) the highest point of the garage roof will not exceed an elevation of 376.48

3. As shown in the "Schematic Site Plan" (AS-1) no portion of the residence will be closer than 27' 11" to our back property line Overall, we are favorably impressed by the plans as shown in the referenced document. More specifically, we favor the style, color scheme, and exterior materials and details of the buildings as called out in the plans. We are also happy to see the planned use of extensive permeable paving and a landscape plan that suggests the intention to use what appears to be appropriate plants, mulching, and hardscaping along with appropriate irrigation technology. We note that several plants have been called out that are favorable to birds, bees, butterflies, and other pollinators.Landscape plans are sometimes difficult to read and interpret, in part because of the use of symbols that are very similar to other symbols on the plan; consequently, we make this note regarding the landscape plan as presented:
from the Master Landscape Plan (L-1) it appears that Citrus X sinensis will be planted along the left side of the driveway parallel to our property. The ultimate height of Citrus X sinensis varies depending largely on cultivar selection, rootstock, and ongoing maintenance – especially pruning. In a typical residential setting most selections of Citrus X sinensis are kept at about 8’ to 10’ tall for convenience of harvesting, maintenance, etc. However, many cultivars of this species can reach an ultimate height of nearly 30’, especially if left unattended.

At that height the plants will possibly negatively impact solar collection on existing and/or future solar panels.

The citrus x sinensis would be maintained to a typical residential setting height. No revisions to the IS/MND are necessary in response to this comment.

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Though grading and drainage are somewhat addressed in the referenced document, we want to express this concern: any changes in grading and/or drainage in the referenced project shall not cause water to flow onto or seep or otherwise permeate into any neighboring property other than what may be occurring presently.

Grading of the site would be designed to drain away from the neighboring parcels to maintain proper drainage with the proposed improvements. As discussed in Section 10, Hydrology and Water Quality Impact Discussion (c), the project would be required to develop and implement a SWPPP that includes BMPs to protect stormwater runoff, including measures to prevent soil erosion. In addition, the project would be required to prepare an erosion and sediment control plan in compliance with the City’s stormwater requirements to reduce the potential for shortand long-term erosion from implementation of the project.

Following project construction, the project site would be developed with new residential units, hardscapes, or otherwise landscaped areas, reducing the potential for substantial erosion or loss of topsoil. Implementation of the project would result in new impervious surfaces that have potential to increase polluted or other surface runoff. However, the project would maintain the majority of the site as pervious (approximately 80%) and would further reduce impervious surface area by maintaining the on-site creek and associated corridor, constructing driveways with
permeable pavers, and reducing driveway width where feasible as required by the City’s post-construction stormwater requirements. Standard Regional Water Quality Control Board requirements require that all stormwater be controlled and managed within the project site. Compliance with existing regulations would minimize potential impacts to drainages during project construction. No revisions to the IS/MND are necessary in response to this comment.

Jim apRoberts – October 7, 2022 Comment Response

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Regarding Creek Setback Exception Request for 841 Patricia Drive, San Luis Obispo:Looking at the property at 841 Patricia Drive, the lot area contained by the minimum lot and creek setbacks and excluding the ‘flag’ for the driveway - effectively the ‘by-right’ developable envelope- is approximately 15,500 square feet. At 40% maximum coverage (6,200 square feet) this project and the ADU (5,260sf + 830sf = 6,120 sf) could be designed and constructed to be together on the west side of the creek. This very conservative approach to developable area and lot coverage clearly demonstrates the project could be redesigned to avoid the need for the requested creek setback exception - a request that is undeniably one of choice, not necessity.

In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures.

Therefore, evaluation of a project redesign is not required. This comment has been provided to decision makers for consideration. This comment has been provided to decision makers for consideration.

Outside of the building footprints, the site development also includes a large pool, extensive patios and terraces, all choices made that inhibit the potential for the ADU to be included on the west side of the creek. With adjustments to those outdoor areas - and perhaps even by requesting a creek setback exception for the pool - additional space could be maintained on the west side of the creek and facilitate placement of the ADU without compromising separation and privacy between the two homes, and without requiring the severe impacts of installing a road and bridge to cross over and through the creek bed. The road and bridge are substantially larger impacts than the ADU itself in terms of surface area and creek encroachment.

In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of a project redesign is not required. This comment has been provided to decision makers for consideration. This comment has been provided to decision makers for consideration.

Per the San Luis Obispo Municipal Code 17.70.030.G.4.c findings must be made to grant an exception to the required creek setbacks. Finding #4 indicates that there needs to be “circumstances applying to the site, such as size, shape, or topography, which do not apply generally to land in the vicinity with the same As discussed on page 2 of the IS/MND, to be approved, the Creek Setback Exception must meet the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c).Approval of an exception is subject to the required findings

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zoning, that would deprive the property of privileges enjoyed by other property in the vicinity with the same zoning.” Over 6,000 square feet of building footprint, large terraces, and a pool to not reflect a deprivation of privilege, is quite the opposite. Finding #7 requires that “site development cannot be feasibly accomplished with a redesign of the project.” As noted above, a redesign is entirely feasible, it just would not have a bridge. This is supported by text regarding Finding #8 that “in the case of new development (reasonable use of the property) may include less development than indicated by zoning.” set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental review of the project, but will be a primary consideration as the City considers final action on the project. This comment has been provided to decision makers for consideration.

The Initial Study mentions that “without the bridge crossing, the eastern portion of the site would not be accessible.” This may be true, but the property owner has no right to vehicular access across a waterway. Undoubtedly, outside of the rainy season, access by foot across the creek would be easily achieved.

The comment is noted. The decision-making authority may consider the feasibility of alternative means of providing adequate access to the proposed ADU in evaluating whether the required findings for a creek setback exception (set out in Zoning Regulations §17.70.030 (G)(4)(c)) can be made. While evaluation of alternative means of access is beyond the scope of environmental review of the project, it may be a consideration as the City considers final action on the project.

This comment has been provided to decision makers for consideration.

The commenter requests that correspondence be included in the City Files EIR0547-0201, ARCH-0040-2021. The commenter's letter has been included in the case file for 841 Patricia Drive and has been provided to decision makers for consideration.

Robert Schroeter – October 7, 2022 Comment ResponseAs stated in the City of San Luis Obispo’s (City) Conservation Guidelines, it is critical to preserve and or restore riparian areas, creeks, wetlands and ephemeral seeps or springs to a natural state and provide suitable habitat to all native aquatic and riparian species. The City further states that it is critical to minimize the impacts of harmful activities in these waterways, wetlands and The project includes a proposed Creek Setback Exception to allow the placement of the bridge and associated footings and supports within this setback area, as well as other project components (e.g., retaining wall, internal access road, pool deck). To be approved, the exception must meet

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floodplains to enhance and preserve their natural function and to protect native fish and amphibian populations that utilize these areas as habitat. This project is requesting an exception to riparian forest protection (creek setback) and if approved, the project will alter and degrade the riparian forest and the designated habitat corridor. The proposed changes sought by this project are specifically prohibited as exceptions within setbacks (include structures, paving and parking lots; San Luis Obispo Municipal Code17.70.030 Creek Setbacks).It seems reasonable that the city may consider such exceptions when there is significant and substantial public benefit. However, in this case there is no realized public benefit and there will be significant environmental costs that do not justify granting such an exception. In addition, the applied for exception would prevent the implementation of city adopted plans regarding open space, riparian areas and habitat corridors and would likely constitute a grant of special privilege since other projects in the area have not been rewarded with similar exceptions. Finally, there are many alternatives to having a bridge built over pristine riparian forest including the relocation of the ADU to the south side of stream, which would leave 100% of the stream riparian forest intact. the requirements of the Zoning Code specified in Section 17.70.030 (G)(4)(c). The City’s Zoning Regulations allow for exceptions to established creek setbacks if certain mandatory findings can be made. There is no required finding that the project provide a “public benefit”. Approval of an exception is subject to the required findings set out in that section, including consideration of whether site development can be feasibly accomplished with a redesign of the project and whether redesign of the project would deny reasonable use of the property. Evaluation of the exception request against these required findings is beyond the scope of environmental review of the project, but will be a primary consideration as the City considers final action on the project. In accordance with CEQA Guidelines Section 15126.6, consideration and discussion of alternatives is only required when a lead agency is preparing an EIR and an identified alternative would substantially lessen significant effects identified in the EIR. No significant and unavoidable impacts were identified in the IS/MND. The potential impacts of the project on the riparian and wildlife corridor areas were evaluated in Section 4, Biological Resources, of the Initial Study. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures. Therefore, evaluation of a project redesign is not required. This comment has been provided to decision makers for consideration.

The proposal also underestimates and understates the impacts to the riparian forest and the habitat corridor, as will be discussed in the following sections that specifically address the bioloigical resources assessment report (BRA).

As described in the IS/MND and supporting documents, the span bridge has been located in a more open and less
vegetated area of the riparian habitat that minimizes vegetation removal. The span bridge has footings above the 100-year water surface elevation to allow for unimpeded

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BRA is not representative / accurate of true impact to the stream riparian and corridor:The authors of the BRA state 17 oak saplings and 20-30 arroyo willow “stems” from four trees will need to be removed to accommodate the proposed bridge and that its construction and presence would have minimal impacts given the already limited connectivity of the stream corridor.

In total, the 12’ x 50’ bridge will directly impact a minimum riparian forest area of 600 ft2 once constructed and there will likely be extensive additional damage to riparian plants and the soil and stream substrate as a result of the construction activities. In addition, it cannot be assumed that the removed forest vegetation will return at the bridge crossing as it would need to be continuously cut to maintain access. Any shaded plants under the bridge will also likely not survive the modification.
high flows and the project includes a revegetation plan to compensate for the limited amount of vegetation removal.

The project would require the removal of 17 coast live oak saplings and 20 to 30 arroyo willow stems from approximately four trees within the riparian corridor for construction of the new bridge crossing over the portion of Twin Ridge Creek on-site. In order to fully mitigate for the oak and willow tree riparian habitat removal, the proposed project includes planting of 20 coast live oak, four Californiabay laurel, and four California sycamore 1-gallon trees, and 20 willow sprigs planted throughout the channel bottom, which is consistent with the City’s Municipal Code (12.24.090), which requires the replanting of removed trees at a minimum 1:1 ratio when planted on-site. The proposed compensatory riparian mitigation will add plant species diversity and density to increase the riparian habitat values on site. Replanted trees would be irrigated for three years and maintained and monitored for five years to meet an 80% survival success. Other riparian trees would be protected through provision of a Creek Setback as determined by the City Biologist and depicted in plans.

This comment has been provided to decision makers for consideration.

Furthermore, the use of the term stems is misleading. Stems are any above ground plant structure, but the reality of the proposed construction activities will be the removal of large limbs and possibly trunks of the existing arroyo willow to accommodate the space needed for the bridge. The size of the stems removed should be identified. The entire riparian forest on the property is very healthy and dense, thus using the affected area (600 ft2) is the best estimate of total impact and an appropriate mitigation would be the addition of riparian forest equivalent to the size that was removed.According to California Department of Fish and Wildlife (Heather Rodriguez) removal of any riparian limb exceeding 2” in diameter would require mitigation and any limb exceeding 4” diameter would require the application for a 1600 See previous response. The size of all trees/stems to be removed are shown on Sheet L-1 attached to the BRA Addendum (refer to IS/MND Attachment 4 – BRA
Addendum). As reflected on Page 4 of the IS/MND, a permit/approval from CDFW would be required for the proposed project. As discussed in the IS/MND, implementation of Mitigation Measure BIO-3 would require the Applicant to provide copies of the permits/authorizations from affected resource agencies, including a final revegetation plan that is consistent with the revegetation plan provided in the

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permit. Having clarity on the size of limbs removed would allow for greater assessment of impact and appropriate permitting next steps.

Addendum to the BRA for approval by the City Natural Sustainability and Natural Resources Official, Community Development Department. Plans submitted for grading and building permits would be required to show tree removals consistent with the November 2021 revegetation plan, including the locations and quantities of the maximum number of trees identified for removal to facilitate the bridgeconstruction. Vegetation removal would be required to be kept to the minimum necessary for bridge clearance and construction of the necessary footings and supports. Initial removal of vegetation would be monitored full-time by a qualified biologist, and weekly spot-check monitoring would continue throughout the construction of the bridge structure. Supplemental irrigation would be provided to the revegetated area of the riparian corridor for three years, and maintained and monitored for five years, to meet 80% survival success criteria after two years without supplemental irrigation. Monitoring reports demonstrating compliance with the revegetation plan would be prepared and submitted to the affected resource agencies and the City annually. Permits and/or authorizations from the regulatory agencies (CDFW, Regional Water Quality Control Board, and USACE), or documentation from the respective agency that the permit/authorization is required, would be submitted to the City prior to any grading and/or construction activities within the on-site riparian area. This comment has been provided to decision makers for consideration.

It is important to point out that the landowners applying for this permit have already extensively thinned the riparian forest on this property. This occurred in the Fall of 2020. It is not clear what if any permits were obtained for this tree removal work, but since all work stopped once it was reported to city officials, it is likely that no permit was obtained. Many of the cut tree branches had diameters exceeding the 2-4” diameter criteria. The city biologist Freddy Otte can attest to scale of impact and the proposed mitigation that was suggested at the time, which was tree replanting. It is not clear if any mitigation has taken This comment does not require any revisions to the IS/MND prepared for the project. This comment has been provided to decision makers for consideration.

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place to date. Furthermore, it is not clear as to the extent of the riparian forest that was removed from those activities.The proposed mitigation for this projects stream riparian impacts, which include planned “stem” and oak sapling removal is planting more willow and oaks into existing riparian forest. As already stated, this will not mitigate the loss of 600 ft2 of riparian forest as it will only further crowd the existing plants in already established upstream riparian forest.

As discussed in the IS/MND, Mitigation Measure BIO-3 would require vegetation removal to be kept to the minimum necessary and would require revegetation, supplemental irrigation for the revegetated area for three years, and maintenance and monitoring of the revegetated area for five years to meet 80% survival success criteria after two years without supplemental irrigation. Monitoring reports demonstrating compliance with the revegetation plan would be prepared and submitted to the affected resource agencies and the City annually. . The proposed compensatory riparian mitigation will add plant species diversity and density to increase the riparian habitat values on site.

No data is provided within the BRA and the city biologists also provide no data on the use of this area by wildlife. My personal observations and accounts made by the surrounding homeowners are that the site is extensively used by wildlife. I carried out a site visit on 10/6/22 and observed turkey, quail, numerous species of small birds and there were signs of extensive deer use (droppings, deer rubs and game trails) along the edge and within the riparian forest. There was also a deer fawn carcass scattered between the stream channel and the upper flood plain suggesting that larger predators such as mountain lion are actively feeding in the area.

The IS/MND and supporting BRA established evidence of deer, gopher, and ground squirrel usage of the site. Additional information has been added to the IS/MND to clarify the extent and type of wildlife observed using the area and surrounding neighborhoods. A “movement corridor”
suggests connectivity between habitat areas. The IS/MND and supporting documents establish the creek goes underground several blocks downstream of the project site thus lacking connectivity as a movement corridor between habitat areas. Twin Ridge Creek flows onto the property through an underground culvert under Patricia Drive and is undergrounded again south of the project site at Westmont Avenue. The lack of a consistent open channel impedes larger wildlife, such as deer, from effectively using the creekas a movement corridor; however, deer and other wildlife (wild turkey, quail) that have become adapted to the urban environment have been seen within the site and vicinity. Therefore, wildlife usage of the site was established in the IS/MND and supporting documents.

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The BRA alludes to the fact that there is limited direct connectivity of the habitat corridor at the project site to Bishops Peak, due to upstream culverts. Although it would be best to have direct connectivity, wildlife do have access to bishops peak and other surrounding riparian and upland habitat through the culverts and via backyards and side yards. The limited upstream access in no way should be an excuse to degrade and or diminish the value of the existing riparian forest at the project site.

As discussed in the BRA and IS/MND, given the infill urban setting, the lack of accumulated cover (vegetation and debris), and likely sheet flows through the bottom of the corridor, the riparian creek corridor is considered to have low potential for special-status wildlife species and other riparian-associated species. Twin Ridge Creek flows onto the property through an underground culvert under Patricia Drive and again along Westmont Avenue. The lack of a consistent open channel impedes larger wildlife, such as deer, from effectively using the creek as a movement corridor, though it may not prohibit movement entirely, as suggested by the commenter. Regardless, the corridor’s current value as a wildlife corridor is limited. The addition of a span bridge over the creek, a single-family residence, and an ADU adjacent to the creek on the project site, consistent with the surrounding residential development on all sides of the project site, would not substantially alter wildlife movement throughout the area. Deer and other wildlife (wild turkey, quail) that have become adapted to the urban environment would continue to traverse the site and surrounding areas in substantially the same manner.

The BRA depends on a single year of assessment (April and October 2021) of biological life from an extreme drought time period 2021 as a basis for their ecological studies report. This is not a good way to gauge the potential impact of the proposed study because the full inventory of species use is not likely to be reflective of potential species (both aquatic and terrestrial) use under more natural non drought conditions and will prevent thorough consideration of the overall impact of the project. As Freddy Otte can attest to, bullfrogs are found on occasion within this drainage which indicates that habitat is suitable for other multistage amphibians including red legged frog.

Pursuant to CEQA Guidelines Section 15125, the baseline for the project includes the physical environmental conditions in the vicinity of the project as they exist at the time the environmental analysis is commenced. As discussed in the BRA, the methods included a biological resources reconnaissance and floristic inventory and rare plant survey and follow-up field reconnaissance to evaluate existing conditions. Based on these surveys, the BRA included a complete list of species observed at the project site. The IS/MND also reviewed historical records and other available data to identify additional species that have the potential to occur at the project site, even if not observed, due to the presence of suitable habitat to support the

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species. Therefore, the IS/MND included a review of all species with the potential to occur at the project site. As identified on page 25 of the IS/MND, the riparian corridor associated with the on-site creek does not provide habitat for special-status riparian species (i.e., special status turtles, frogs) due to the lack of understory shrub and natural debris. The IS/MND and BRA Addendum field survey identified the existing conditions of the creek corridor and lack of onsite aquatic habitat suitable for California red-legged frog (long duration ponding) within the narrow and shallow braided channel topography through the property. With implementation of identified mitigation, the existing riparian corridor would be preserved and/or restored within the required creek setback consistent with City policies to maintain availability of habitat for the existing wildlife use.

Natural riparian systems and their associated forests typically do not occur in straight lines. Current staking of the edge of riparian forest cuts off an extension measuring 15’ x 25’ which is 375 ft2 of riparian forest that would be excluded from protection as it is now staked. The current staking pattern runs counter to the “measurement of creek setbacks” listed in the San Luis Obispo Municipal Code 17. 70.030C. This area is on the North side of the property close to the proposed ADU driveway. The actual existing riparian forest edge should be corrected for accuracy and for further protection of this important habitat.

The IS/MND analysis is based on the field staked and surveyed edge of riparian vegetation consistent with City policies for establishing creek setbacks from top of bank or outside edge of predominant riparian vegetation, whichever is greater. The City Biologist established the location and course of the edge of riparian vegetation associated with the creek based on conditions observed during a site visit conducted in November 2020 and verified this as the edge of riparian vegetation during a subsequent site visit conducted June 30, 2022. This line is depicted and labeled in plans as “Edge of Riparian Vegetation” (Sheet A2) and “Surveyed Vegetation Line” (Sheet AS-1).

Robert Schroeter – October 7, 2022 Comment ResponseAn MND is not appropriate for the proposed project at 841 Patricia Drive. As described in my prior email, the project will result in potentially significant effects As detailed in the IS/MND prepared for the proposed project, mitigation has been identified for all potentially

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on the environment and does not sufficiently avoid or mitigate the effects to a point where clearly no significant effect on the environment would occur. In fact, there is substantial evidence that the project will likely have a significant effect on the environment. Therefore, a full EIR should be prepared by the City with sufficient opportunity for public comment. significant impacts and have been determined to be sufficient to reduce impacts to a less-than-significant level; therefore, an EIR was not determined to be appropriate or necessary for the project. Pursuant to CEQA Guidelines Section 21091, the IS/MND was circulated for public review for 30 days. The commenter's letter has been included in the case file for 841 Patricia Drive and has been provided to decision makers for consideration.

The potential impacts of the project were evaluated in the IS/MND. The analysis included therein concluded that potential impacts could be reduced to less than significant with implementation of identified mitigation measures; therefore, an Environmental Impact Report is not necessary for the project pursuant to CEQA Guidelines Section 15063. Impacts to creeks, riparian habitat, and similar resources are commonly evaluated in an MND for CEQA purposes due to the availability and applicability of well-established mitigation options.

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City of San Luis Obispo, Council Memorandum
City of San Luis Obispo
Council Agenda Correspondence
DATE: April 4, 2023
TO: Mayor and Council
FROM: Greg Hermann, Deputy City Manager
Robert Hill, Sustainability & Natural Resources Manager VIA: Derek Johnson, City Manager
SUBJECT: ITEM 6b - ADOPTION OF THE COMMUNITY FOREST PLAN Staff received a request from a Council Member to provide a response to a portion of the agenda correspondence provided by Mr. Allan Cooper on behalf of Save Our Downtown.

The question is below with staff’s response shown in italics:

1. Save Our Downtown disagrees with the following: “One example of a species that is not particularly well-suited for San Luis Obispo is the coast redwood (Sequoia sempervirens). The city’s climate is very dissimilar to the fog-shrouded, damp coastal environment where redwood grows naturally. While some local redwoods are reasonably healthy, many others are in poor condition, unable to thrive in our present climate and presumably even less so in the future considering the predicted effects of climate change.”
San Luis Obispo is located 12 miles from the ocean where coastal redwoods can thrive. Coastal redwoods do well in SLO if they are regularly irrigated. Four of the seventeen Heritage Trees are mature, healthy redwoods. Why is this the case if this particular type of tree is not “well suited” to San Luis Obispo? Office of Sustainability & Natural Resources staff conferred with Public Works Urban Forest Services staff in providing this response. The reason why the Community Forest Plan document states that coast redwoods are “not particularly well-suited for San Luis Obispo” is that, as stated, these trees require a lot of water to thrive in our area and water conservation is one of the sustainability principles set forth in the plan document. It is accurate that some older redwoods that were established a long time ago continue to thrive, while there are also numerous examples of redwoods that exhibit signs of noticeable drought stress. As prolonged periods of drought and extreme heats days are anticipated with climate change, continuing to plant new redwoods for City street trees or park trees is not advisable. Existing heritage trees will continue to be honored and protected, and private property owners will continue to have the prerogative to plant redwoods on their own property if they so choose.

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Item 6b
Department: Administration
Cost Center: 1005
For Agenda of: 4/4/2023
Placement: Business
Estimated Time: 20 minutes
FROM: Greg Hermann, Deputy City Manager
Prepared By: Robert Hill, Sustainability & Natural Resources Official SUBJECT: ADOPTION OF THE COMMUNITY FOREST PLAN

RECOMMENDATION
As recommended by the Tree Committee, adopt a Draft Resolution entitled, “A Resolution of the City Council of San Luis Obispo, California, approving the Community Forest Plan and a determination of Categorial Exemption from the California Environmental Quality Act.”

POLICY CONTEXT
Climate Action, Open Space & Sustainable Transportation is one of four Major City Goals, identified by the City Council as part of the 2021-23 Financial Plan. The preparation of the Community Forest Plan (CFP) is one of the work program items for this major city goal.

The CFP was also identified in the City’s 2020 Climate Action Plan (CAP) for Community Recovery and CAP Volume III, the 2023-2027 Work Program.

DISCUSSION
Background
The City’s urban forest is a living and dynamic resource that offers many social, economic, and environmental benefits. Increasing the number of trees within the City’s urban forest will be critical in fighting climate change, which aligns with the City’s current Major City Goal of Climate Action, Open Space & Sustainable Transportation. This will be accomplished by integrating best practices for urban forestry throughout the community and landscape to accrue the multiple benefits trees provide including shading and cooling, beautification, habitat, stormwater retention, and carbon sequestration. Properly maintaining the current inventory of trees and planting additional trees to grow the living canopy is considered an urban forestry best management practice.

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Item 6b
Community Forest Plan Overview
The Community Forest Plan (CFP) is recommended for adoption by City Council Resolution, Attachment A, and is included as Attachment B to this report. The CFP is a community-focused urban forest management plan that sets forth a guiding vision, goals, objectives, and recommended actions for the City and its external partners as they work to strengthen and expand the City’s urban forest – and therefore the health and well-being of all City residents and visitors – in the coming years. The CFP can be considered a “road map” that provides background and historical information on San Luis Obispo’s urban forest, references other City documentation which supports and is supported by the plan, and describes City outreach efforts – past, present, and future. The CFP also describes the 10 Tall Initiative, the City’s plan to plant 10,000 new trees by 2035.

The City’s urban forest is comprised of both private and public trees in the public right-ofway (streets), parks, City facilities, riparian (creek) corridors, open space, and on private property. The main focus of the CFP is tree cover in the public right-of-way, parks, and City facilities, but it also covers City-owned open space properties and riparian areas.

The CFP’s high-level goals are stated below. These concepts are derived from stakeholder interviews, current peer-reviewed academic literature, and comparative review of other cities’ urban forest management plans as well as previous Council direction.

Goals

1. Maintain and expand San Luis Obispo’s urban forest to maximize environmental, social, and economic benefits for all, while minimizing undesirable conditions (Maintain/expand forest).

2. Adopt a “right tree, right place,” lifecycle-based perspective towards urban trees which includes the planting, care, and end-of-life use of climate-ready trees in locations where they will have the greatest opportunity to thrive (Sustainability/climate resilience).

3. Foster a spirit of collaboration between and within City departments that are involved in urban forest management, as well as between the City and other local stakeholders (e.g., community groups, nonprofit organizations, businesses, utilities, other cities, Cal Poly, and State agencies) (Collaboration).

4. Educate and seek the involvement of City residents and visitors, including underserved/underrepresented groups, to obtain their interest and participation in the creation of a thriving urban forest. (Outreach/equity).

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Item 6b
The CFP provides a vision statement, urban forest history, goals and objectives, and ongoing suggested guidance through an implementation matrix. In addition, key elements and areas of discussion in the CFP include:

1. An overview of the Urban Forest Services (UFS) Program

2. Updated Tree Inventory

3. Current tree maintenance standards and scheduling

4. Strategies for tree plantings

5. Addressing the Commemorative Grove Program

6. Suggestions for future policy discussions regarding tree removals and mitigation standards

7. An overview of the value and importance of the City’s numerous urban forest partnerships

8. A focus on sustainability and equity objectives
The CFP relies on several recent background documents that are included as attachments to this report. These are as follows:

1. SLO Urban Forest Organizational Assessment (Attachment C). This report by Davey Resource Group provides an analysis of the Urban Forest Services Program and staffing structure. Its recommendations are reiterated in the CFP.

2. Tree Inventory Overview Report (Attachment D). This overview of City-owned trees (streets, parks, and facilities) managed by the UFS program summarizes the results of an updated tree inventory by West Coast Arborists.

Previous Council or Advisory Body Action
The San Luis Obispo City Council adopted the 2020 Climate Action Plan for Community Recovery (2020 CAP) in August 2020. The 2020 CAP, under Pillar 6: Natural Solutions, calls for a contemporary, holistic approach to urban forestry that includes an updated urban tree inventory, a database and tracking system accessible to the City’s urban forest partners, the creation of a Community Forest Master Plan, and a goal to plant 10,000 trees by 2035. Based on these objectives, in February 2021 the City Council identified a strengthened and expanded urban forest as a Major City Goal for the 2021-2023 Financial Plan.

On January 12, 2023, the Public Works Department and the Office of Sustainability & Natural Resources held a study session with the City Council to invite comments and questions and to seek general input and direction on the Urban Forest Services Program, the draft Community Forest Plan, and preparation of the 2023-25 Financial Plan. At this study session, Council received a summary presentation, heard input from the community, and provided feedback that guided the ongoing development of the City’s Urban Forest Services Program and provided strategies to strengthen the City’s urban forest through guidance in the draft Community Forest Plan.

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Item 6b
Key directional items from the study session included not continuing the with Commemorative Grove at Laguna Lake Park, reviewing and updating compensatory planting requirements, and supporting a complimentary tree give-away or grant program to assist in meeting the 10 Tall initiative. These items are addressed accordingly in the Implementation Matrix of the CFP. See Attachment E, Meeting Minutes of the City Council for January 12, 2023. Continued support for the urban forest and tree planting initiatives was also expressed by Council at the 2023-25 Financial Plan Goal Setting workshop that took place on February 11, 2023.

In addition, the Tree Committee specifically reviewed the Community Forest Plan at its meeting on February 27, 2023. The Tree Committee has provided their recommendation to the City Council for approval, along with several points of emphasis, including increasing communication and outreach, prioritizing underrepresented communities, revisiting tree replacement standards and processes, and enhancing partnerships. These items are all reflected in the narrative and Implementation Matrix of the draft CFP and staff will be able to incorporate these areas of emphasis into ongoing work plans. See Attachment F, Draft Meeting Minutes of the Tree Committee for February 27, 2023.

Public Engagement
During the Organizational Assessment Study conducted by Davey Resource Group, an online survey was conducted for community members to answer questions and provide feedback regarding the City’s UFS Program. The online survey was linked to the City’s website and participation was encouraged through a press release, social media advertisements, Tree Committee and City Council meetings, and signage throughout the City’s parks and open space trailheads. The survey was very successful with 644 community member responses, the second highest of any urban forest assessment completed by Davey Resource Group. The survey included 9 questions about community members’ views on tree benefits, education, and outreach, UFS operations, and preferences for future plantings. The survey offered participants a chance to expand on their answers and provided space for thoughts and suggestions at the end. The complete survey and results are available in Appendix E (page 118) in Attachment C.

In addition to the online survey, Davey Resource Group interviewed a group of stakeholders including City staff, Council and Tree Committee members, community partners, and Cal Poly faculty. To prepare for the Climate Action Plan 2023-27 Work Program, a series of technical stakeholder meetings were held over the summer of 2022 that focused, in part, on the urban forest and tree planting in creeks and open space areas. Lastly, department staff has been discussing the different assessments with the Tree Committee over the past 18 months, including on December 5, 2022, and February 27, 2023, where additional public input and testimony was received.

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Item 6b
The City is very fortunate to have many external community partners such as ECOSLO, Rotary de Tolosa, Cal Poly, Downtown SLO, Cal Fire, the SLO County FireSafe Council, and PG&E, as well as numerous resident volunteers that provided input and engagement with Community Forest Plan. Increased coordination between these entities and others will ensure success in meeting long-term urban forest goals.

In summary, public engagement activities reached all levels prescribed in the City’s Public Engagement and Noticing Manual (i.e., Inform, Consult, Collaborate).

CONCURRENCE
Over the past 18 months, the Office of Sustainability & Natural Resources has been working closely with Public Works Department and they concur with the proposed guidance and direction provided by the Community Forest Plan. The CFP also received unanimous support from the Tree Committee.

ENVIRONMENTAL REVIEW
The Community Forest Plan is categorically exempt from CEQA under Section 15262, Feasibility and Planning Studies, as an advisory planning document that has no binding effect on future activities. As an overarching planning and guidance document that provides recommendations only, without regulatory authority or entitlement of projects that can be implemented directly that would have a physical effect on the environment, the project is also exempt under the General Rule, Section 15061 (b)(3) since it can be seen with certainty that the Community Forest Plan will not have a significant effect on the environment. The Community Forest Plan is also consistent with the Climate Action Plan for Community Recovery and the Negative Declaration that was filed for that project with the County-Clerk Recorder and with the State Clearinghouse on August 19, 2020.

FISCAL IMPACT
Budgeted: No Budget Year: 2022-23
Funding Identified: No
Fiscal Analysis:

Funding
Sources
Total Budget
Available
Current
Funding
Request
Remaining
Balance
Annual
Ongoing
Cost
General Fund
State
Federal
Fees
Other:

Total N/A N/A N/A N/A

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Item 6b
Adoption of the Community Forest Plan does not have a fiscal impact in and of itself.

Staff is currently preparing budgets for the 2023-25 Financial Plan for Urban Forestry Services and the 10 Tall tree planting initiative that are consistent with prior Council feedback received at the February 11, 2023, Goal Setting workshop to include a new fulltime Urban Forester position (approximately $100,000 per year on an ongoing basis) and dedicated funding for tree planting in creeks and open space areas throughout the City ($50,000 per year during the 2023-25 Financial Plan period).

Consistent with feedback received from Council at the Study Session that took place on January 12, 2023, the urban forest as a whole will be managed and supported by the budgets for the Urban Forest Services Program in the Public Works Department, the Office of Sustainability and Natural Resources in the Administration Department, the Community Development Department, and the Parks and Recreation Department.

ALTERNATIVES

1. Council may direct staff to make changes to the Community Forest Plan prior to publishing the completed document.

2. Council may direct staff to return at a later meeting to review requested changes before taking final action.

ATTACHMENTS
A - Draft Resolution adopting the Community Forest Plan B - Draft City of San Luis Obispo Community Forest Plan C - Urban Forest Organizational Assessment - Davey Resource Group D - Tree Inventory Overview Report - West Coast Arborists E - City Council Minutes 01-12-2023
F - Draft Tree Committee Minutes 02-27-2023

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R ______
RESOLUTION NO. _____ (2023 SERIES)

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS

OBISPO, CALIFORNIA, APPROVING THE COMMUNITY FOREST PLAN

AND A DETERMINATION OF CATEGORICAL EXEMPTION FROM

CALIFORNIA ENVIRONMENTAL QUALITY ACT
WHEREAS, San Luis Obispo residents and officials have long supported efforts to maintain and expand the city’s urban forest; and
WHEREAS, urban forests provide environmental benefits including creating wildlife habitat, reducing stormwater runoff, filtering air pollution, producing oxygen; and WHEREAS, urban forests provide social benefits including creating green spaces for recreation, improving aesthetics of streetscapes, improving public health, calming traffic and promoting pedestrian and cyclist safety, reducing noise pollution, and helping to reduce crime rates; and
WHEREAS, urban forests have been found through peer-reviewed academic literature to provide economic benefits including increasing property values, reducing building cooling costs and energy use due to shading and cooling effects of trees, increasing economic activity in commercial areas, and reducing demand on capital infrastructure; and
WHEREAS, investments in street tree planting and care therefore result in positive returns to communities by accruing environmental, social, and economic benefits; and WHEREAS, despite the growing recognition of the value created by urban forests, the United States as a whole, and San Luis Obispo specifically, is losing trees due to development, pests and disease, wildfire, extreme weather, and deferred maintenance; and
WHEREAS, the City of San Luis Obispo Community Forest Plan provides a vision for a strengthened and expanded urban forest, and all the attendant multiple benefits to residents and visitors; and
WHEREAS, the Community Forest Plan comprises part of the City’s climate action planning efforts through its addressing of the proposal to plant 10,000 trees by 2035, which would sequester and store carbon that would otherwise remain in the atmosphere; and
WHEREAS, on August 18, 2020, City Council adopted Resolution 11159, which approves the 2020 Climate Action Plan for Community Recovery and provides foundational actions to establish a trajectory towards achieving those goals, including an action to prepare a Community Forest Plan; and

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Resolution No. _____ (2023 Series) Page 2
R ______
WHEREAS, on December 13, 2020, City Council adopted Resolution 11381, which approves the Climate Action Plan 2023-27 Work Program and provides work program tasks to advance climate action, including a task to adopt and implement the Community Forest Plan and make significant progress on the 10 Tall goal of planting and maintaining 10,000 new trees by 2035; and
WHEREAS, the preparation of the Community Forest Plan is also identified in the Major City Goal work program for Climate Action, Open Space, and Sustainable Transportation that is included in the City’s 2021-23 Financial Plan; and WHEREAS, the Community Forest Plan is categorically exempt from CEQA under Section 15262, Feasibility and Planning Studies, as an advisory planning document which has no binding effect on future activities; and
WHEREAS, as an overarching planning and guidance document that provides recommendations only, without regulatory authority or entitlement of projects that can be implemented directly that would have a physical effect on the environment, the project is also exempt under the General Rule, Section 15061 (b)(3) since it can be seen with certainty that the Community Forest Plan will not have a significant effect on the environment.

WHEREAS, as an implementation action of the Climate Action Plan, the proposed Community Forest Plan is consistent with the Climate Action Plan Negative Declaration filed with the County-Clerk Recorder and with the State Clearinghouse on August 19, 2020; and
WHEREAS, on February 27, 2023, the Tree Committee received a presentation on the City of San Luis Obispo Community Forest Plan and recommended that City Council approve the plan.

NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo as follows:

SECTION 1. Recitals. The recitals set forth above are hereby adopted as the findings of the City in adopting the policies herein.

SECTION 2. Environmental Review. The City Council has determined that the Community Forest Plan is categorically exempt from CEQA under Section 15262, Feasibility and Planning Studies, as an advisory planning document that has no binding effect on future activities. As an overarching planning and guidance document that provides recommendations only, without regulatory authority or entitlement of projects that can be implemented directly that would have a physical effect on the environment, the project is also exempt under the General Rule, Section 15061 (b)(3) since it can be seen with certainty that the Community Forest Plan will not have a significant effect on the environment.

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Resolution No. _____ (2023 Series) Page 3
R ______
SECTION 3. Community Forest Plan. The City Council hereby approves the Community Forest Plan.

Upon motion of Council Member ___________, seconded by Council Member ___________, and on the following roll call vote:

AYES:

NOES:

ABSENT:

The foregoing resolution was adopted this _____ day of _______________ 2023. ___________________________
Mayor Erica A. Stewart
ATTEST:
______________________
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
______________________
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City of San Luis Obispo, California, on ______________________. ___________________________
Teresa Purrington
City Clerk

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City of San Luis Obispo Community Forest Plan
Office of Sustainability & Natural Resources April 2023

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 2 of 114 Acknowledgments
City of San Luis Obispo
Community Forest Plan
Adopted
April 4, 2023
City Council
Erica A. Stewart, Mayor Jan Marx, Vice Mayor
Andy Pease Michelle Shoresman
Emily Francis
Tree Committee
Richard (Alan) Bate
Henry Bonifas
Daniel Canella
Elizabeth Lucas
Emily Rosten
City Management
Derek Johnson, City Manager
Shelly Stanwyck, Assistant City Manager, Community Services Greg Hermann, Deputy City Manager
City Staff
Michael Codron, Greg Cruce, Christopher Hamma, Robert Hill, Matt Horn, Freddy Otte, Lucia Pohlman, Chris Read, Anthony Whipple Technical Experts, Urban Forestry Stakeholders & Others Who Helped Mike Boswell, Joe Carotenuti, Ron Combs, Kim Corella, Chris Dicus, Thomas Kessler and SLO History Center volunteer staff, Jeff Reimer, Matt Ritter, Nathan Slack, Bettina Swigger, Rodney Thurman, Danny Torres, Matthew Wells, Jenn Yost City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
All photos taken by Christopher Hamma unless otherwise noted.

Cover photo: 60-year-old Indian laurel figs (Ficus microcarpa) along Higuera Street, San Luis Obispo.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 3 of 114 Table of Contents
Acknowledgments.........................................................................................................................................2 Table of Contents..........................................................................................................................................3 List of Tables .................................................................................................................................................6 List of Figures................................................................................................................................................7 List of Acronyms............................................................................................................................................8 I. Vision and Mission Statements.............................................................................................................9 A. Vision.............................................................................................................................................9 B. Mission..........................................................................................................................................9 II. Goals ...................................................................................................................................................10 III. Summary of Key Findings................................................................................................................11 IV. Introduction ....................................................................................................................................13 V. Historical Context................................................................................................................................15 VI. Relationship to Other City Documents...........................................................................................19 A. General Plan................................................................................................................................19 B. Municipal Code ...........................................................................................................................19 C. 2021-23 Financial Plan................................................................................................................21 D. Climate Action Plans ...................................................................................................................21 E. Other Planning Documents.........................................................................................................21 F. Urban Forest Services Organizational Assessment and Tree Inventory Update ........................22 VII. Sustainability...................................................................................................................................23 VIII. Outreach .........................................................................................................................................27 IX. Equity ..............................................................................................................................................30 X. Implementation ..................................................................................................................................31 A. Goals and Objectives...................................................................................................................31 B. Targets and Metrics....................................................................................................................32 C. Downtown San Luis Obispo’s Trees............................................................................................33 D. 10 Tall: An Initiative to Plant 10,000 Trees by 2035 ..................................................................35 E. Community Forest Plan Implementation Matrix ........................................................................36 XI. Next Steps.......................................................................................................................................48 References Cited.........................................................................................................................................49

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 4 of 114 Appendix A: Additional Background Information and Research ...............................................................58 A. Design and Implement the Program; Accrue and Analyze Data.................................................58

1. Davey Resource Group Organizational Assessment Report (2021)............................................58

2. West Coast Arborists Tree Inventory Update (2021-22) ............................................................60

3. Urban Forest Ecosystems Institute (UFEI) Data..........................................................................61

4. Targets ........................................................................................................................................62

5. Metrics........................................................................................................................................62

6. Data Analysis...............................................................................................................................65 B. Strengthen Maintenance Practices and Clear the Backlog.........................................................65 C. Increase New Plantings and Implement the 10 Tall Initiative ....................................................66 D. Reexamine Tree Removal and Mitigation Policies......................................................................67 E. Focus on Sustainability................................................................................................................69

1. Right Tree, Right Place ................................................................................................................70

2. Climate Readiness.......................................................................................................................72

3. Urban Forest Diversity ................................................................................................................73

4. Pests and Disease........................................................................................................................74

5. Lifecycle Perspective...................................................................................................................75

6. Soil Enhancement and Stormwater Management......................................................................77

7. Safety ..........................................................................................................................................78

8. Water Conservation....................................................................................................................79 F. Address Issues Unique to Downtown .........................................................................................80 G. Increase Outreach to Officials and the Public.............................................................................81 H. Address Equity Issues..................................................................................................................83 Appendix B: City of San Luis Obispo Designated Heritage Trees...............................................................85 A. Dawn Redwood, Del Mar Ct........................................................................................................86 B. Torrey Pine, Casa St. ...................................................................................................................88 C. Cork Oak, Lincoln St. ...................................................................................................................90 D. California Bay Laurel, Brizziolari Creek .......................................................................................91 E. Coast Redwood, Mission Plaza (“Moon Tree”)...........................................................................93 F. Japanese Maple, Jack House & Gardens.....................................................................................95 G. Incense Cedar, The Monday Club ...............................................................................................97 H. Olives, Conejo Ave. .....................................................................................................................99

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 5 of 114 I. Coast Redwood, Higuera St.......................................................................................................100 J. Coast Redwoods, Dallidet Adobe & Gardens............................................................................102 K. Deodar Cedar, Buchon St..........................................................................................................104 L. Western Redbud, Pismo St. ......................................................................................................106 M. Shamel Ash, Mitchell Park ........................................................................................................107 N. California Sycamore, Old Mission Cemetery, Bridge St. ...........................................................109 O. Incense Cedars, California Sycamores, Queen Palm – CalTrans District 5 Offices, Higuera St. 111 Figure 1. Coast live oaks (Quercus agrifolia) at Bishop Peak Natural Reserve.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 6 of 114 List of Tables
Table 1. Selected Existing and Potential City Urban Forest Partners. ........................................................27 Table 2. Community Forest Plan Objectives. ..............................................................................................31 Table 3. Involved City Staff, Departments, and Offices. .............................................................................32 Table 4. Estimated allocation of tree planting responsibilities for the 10 Tall Initiative. ...........................35 Table 5. Community Forest Plan Implementation Matrix. .........................................................................36 Table 6. Davey Resource Group Sustainability Indicators Analysis for San Luis Obispo’s Urban Forest (Public and Private).....................................................................................................................................64 Table 7. City Heritage Trees by Site. ...........................................................................................................85 Figure 2. The Japanese maple (Acer palmatum) at the Jack House and Gardens – a City Heritage Tree.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 7 of 114 List of Figures
Figure 1. Coast live oaks (Quercus agrifolia) at Bishop Peak Natural Reserve. ............................................5 Figure 2. The Japanese maple (Acer palmatum) at the Jack House and Gardens – a City Heritage Tree. ...6 Figure 3. Rotary de Tolosa volunteer tree planting event, South Hills Natural Reserve, 2023. ...................8 Figure 4. Carrot wood (Cupaniopsis anacardioides) trees along Chorro Street, downtown San Luis Obispo...........................................................................................................................................................9 Figure 5. A West Coast Arborists crew prunes Brisbane box trees (Lophostemon confertus) along Palm Street in downtown San Luis Obispo, July 2022. ........................................................................................10 Figure 6. The City’s 2021-2026 Tree Pruning Schedule by Zone (Pavement Area).. ..................................12 Figure 7. A partial list of the benefits provided by urban trees..................................................................13 Figure 8. The City of San Luis Obispo has been a Tree City USA participant since 1983. ...........................14 Figure 9. Excerpt from an 1874 map of San Luis Obispo. ...........................................................................15 Figure 10. Mill Street Historic District.........................................................................................................16 Figure 11. Looking east on Higuera Street at Garden Street, 1963.. ..........................................................17 Figure 12. “Higuera Street then and now.” Photo dates unknown............................................................18 Figure 13. A West Coast Arborists crew trims a London plane tree (Platanus × hispanica) in front of the San Luis Obispo Repertory Theatre, August 2022. .....................................................................................20 Figure 14. The City’s Downtown Concept Plan visualizes Downtown SLO as a verdant, highly walkable destination. .................................................................................................................................................22 Figure 15. Invasive shothole borer-infested tree in southern California....................................................24 Figure 16. Cork Oak (Quercus suber), Lincoln Street – a City Heritage Tree. .............................................26 Figure 17. Climate Action Plan Natural Solutions Forum in Mission Plaza.................................................28 Figure 18. San Luis Obispo community member opinions on the most important benefits of trees. .......29 Figure 19. The Santa Lucia Range and Terrace Hill frame SLO's urban forest. ...........................................30 Figure 20. ECOSLO volunteers planting trees at Throop Park. ...................................................................33 Figure 21. ECOSLO volunteers with a newly planted oak sapling...............................................................34 Figure 22. Murray Avenue’s unique tree-lined pedestrian median, San Luis Obispo. ...............................48 Figure 23. Terrace Hill and Islay Hill beyond Court Street Plaza in downtown San Luis Obispo. ...............57 Figure 24. Bishop Peak Natural Reserve. ....................................................................................................60 Figure 25. Ten most common urban tree species in San Luis Obispo. .......................................................61

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 8 of 114 List of Acronyms
CAP Climate Action Plan
CASE Climate Adaptation and Safety Element
CFP Community Forest Plan
DCP Downtown Concept Plan
DEI Diversity, Equity, and Inclusion
DRG Davey Resource Group
ECOSLO The Environmental Center of San Luis Obispo County GHG Greenhouse Gas
ISA International Society of Arboriculture
ISHB Invasive Shothole Borer
LIDAR Light Detection and Ranging
MPCP Mission Plaza Concept Plan
NAIP National Agriculture Imagery Program
OA Organizational Assessment
SFR Single-Family Residential
SLO San Luis Obispo
SOD Sudden Oak Death
UFEI Cal Poly SLO Urban Forest Ecosystems Institute
UFS Urban Forest Services
USDA United States Department of Agriculture
WCA West Coast Arborists
WUI Wildland-Urban Interface
Note: A list of acronyms specific to the Implementation Matrix is provided in Section X.

Figure 3. Rotary de Tolosa volunteer tree planting event, South Hills Natural Reserve, 2023.

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 9 of 114 I. Vision and Mission Statements
A. Vision
The City of San Luis Obispo is a community identified and shaded by a diverse, resilient, thriving urban forest. Relying on the Community Forest Plan, the City actively encourages participation in tree planting and stewardship, preserves and protects trees, and promotes public safety and tree health.

The Plan helps the City implement cost-effective enhancement and maintenance of the urban forest, increases public awareness of the value of our community forest, and maximizes its social, economic, and environmental benefits for current residents and future generations.

B. Mission
The mission of the City of San Luis Obispo Community Forest Plan (CFP) is to achieve the stated Vision by working with and empowering city residents and partners to establish innovative, science-grounded goals and strategies to protect, expand, and nurture the City’s public tree cover and the associated benefits over the coming decades.

Figure 4. Carrot wood (Cupaniopsis anacardioides) trees along Chorro Street, downtown San Luis Obispo.

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 10 of 114 II. Goals
The goals of the CFP are as follows:

1. Maintain and expand San Luis Obispo’s urban forest to maximize social, economic, and environmental benefits for all, while minimizing undesirable conditions (Maintain/expand forest)

2. Adopt a “right tree, right place,” lifecycle-based perspective towards urban trees which includes the planting, care, and end-of-life use of climate-ready trees in locations where they will have the greatest opportunity to thrive (Sustainability/climate resilience)

3. Foster a spirit of collaboration between and within City departments that are involved in urban forest management, as well as between the City and other local stakeholders (e.g., community groups, nonprofit organizations, businesses, utilities, other cities, Cal Poly, other State agencies) (Collaboration)

4. Educate and seek the involvement of City residents and visitors, including historically marginalized groups, in order to obtain their interest and participation in creation of a thriving urban forest. (Outreach/equity)
Figure 5. A West Coast Arborists crew prunes Brisbane box trees (Lophostemon confertus) along Palm Street in downtown San Luis Obispo, July 2022.

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 11 of 114 III. Summary of Key Findings
This Community Forest Plan (CFP) and the additional
background information provided in Appendix A are
based on the results of research conducted in 2021 and
2022 regarding the state of San Luis Obispo’s publicly
owned urban forest – primarily street and park trees, as well as those located at City facilities. City open space and creek corridor trees are also covered by the plan. The
projected lifespan of the CFP is 2023-2035.

The contents of the CFP are based on extensive review of City of San Luis Obispo documents, published urban
forestry literature, other cities’ forest management plans, and consultant reports and outreach (including a
community survey) commissioned by the San Luis Obispo
Public Works Department.

Additional sources of information included over a dozen interviews with knowledgeable urban forestry
stakeholders, and ongoing interdepartmental
collaboration primarily between the Public Works
Department and the Office of Sustainability & Natural
Resources.

Key plan recommendations for improving the health and
strength of the urban forest, and thus the well-being of City residents and visitors, include the following:
 Update and maintain the City’s inventory of
street, park, and City facilities trees
 Continue to use contract services for tree pruning
and move toward a proactive, 5-to-6-year
maintenance cycle (refer to Figure 6)
 Update the City Street Tree List to focus on
species that are both appropriate for urban uses
and climate-resilient
 Create a City tree planting and care plan and a
City urban wood lifecycle plan which, although
citywide, devote considerable attention to downtown’s high-profile urban forest trees SLO’s Urban Forest –
Fast Facts (2023)
Number of City-owned street,
park, and facilities trees:
12,4551 or 12,4962
Percent of public street, park,
and City facilities trees in
“good” condition: 90.41
Total value of street, park,
and City facilities trees: over
$39 million1
Total number of trees
citywide (public & private)
within the urban boundary
(excludes City open space):
48,7102
Number of tree species
citywide: At least 2212
Estimated percent canopy
cover, citywide (2012): 13.23
“Reasonable baseline”
percent canopy cover for a
dry western city: 15
4 Sources:
1 West Coast Arborists, 2022
2 UFEI, no date
3 Nessen, 2012
4 American Forests, 2017

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 12 of 114  Strengthen social and environmental equity by assessing and working to enhance tree cover in disadvantaged neighborhoods
 Reexamine compensatory planting requirements related to development-related tree removals; any changes made may ultimately impact the role, responsibilities, and authority of the Tree Committee (please refer to Appendix A, Section D)  After tree removals on private property, require follow-up monitoring by City staff to ensure that replanting took place as required
 Require City arborist review of all development plans  Implement a comprehensive urban forest database management system that allows for multiple administrative functions and facilitates internal/external partner access to the inventory for updating purposes
 Restart the Commemorative Grove program as resources become available  Expand engagement with key stakeholders and the community.

Figure 6. The City’s 2021-2026 Tree Pruning Schedule by Zone (Pavement Area). Source: City of San Luis Obispo Public Works Department.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 13 of 114 IV. Introduction
Urban forests provide a myriad of social, economic, and environmental benefits to a city’s residents, visitors, and business owners (Nowak, 2016; Janowiak et al., 2021; see Figure 7).

Urban trees and landscaping beautify our cities (Schroeder, 1989), cool our buildings through shading and evapotranspiration (Ko, 2018), and create wildlife habitat (Strohbach et al., 2013).

They clean our air (Nowak et al., 2006), reduce flooding, erosion, noise, and wind (Livesley et al., 2016), and fight climate change by storing greenhouse gases (GHGs) in the form of wood (Nowak and Crane, 2002).

Trees also increase traffic and pedestrian safety (Dumbaugh and Gattis, 2005), extend pavement life (Burden, 2006), enhance property value and increase business traffic (Staats and Swain, 2020), increase happiness and social interaction (Kwon et al., 2021), and reduce crime (Schertz et al., 2021). Their presence encourages us to engage in outdoor recreation, strengthening our physical and mental health (Pretty et al., 2005). Some trees warrant special treatment, such as heritage tree designation, because they have outstanding traits or significant cultural value (Jim, 2017).

Figure 7. A partial list of the benefits provided by urban trees. Source: AECOM, 2013.

These ecosystem services are worth billions of dollars annually to the 83 percent of Americans who live in urban areas (University of Michigan Center for Sustainable Studies, 2021). Trees are a good investment as well – in California, every dollar put into street tree planting and care returns nearly $6 to its community in ecosystem services and increased property values (McPherson et al., 2016).

Yet despite growing recognition of the value created by urban forests, the United States is losing many tens of millions of trees per year due to causes including development, pests and disease, wildfire, and extreme weather (Nowak and Greenfield, 2018; USDA Forest Service Region 5,

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 14 of 114 2023). San Luis Obispo’s urban forest is not immune to this trend. For example, destructive, nonnative insects and disease that have wreaked havoc elsewhere in California are approaching our county from both north and south, and the fierce winter storms of 2022-2023 resulted in notable tree losses across San Luis Obispo County. Furthermore, until recently the City’s roughly 12,500 public street, park, and facilities trees suffered from a multi-year backlog of deferred maintenance due to staff injuries, retirements, and the effects of the Covid-19 pandemic.

San Luis Obispo residents and officials have long supported efforts to maintain and expand the city’s urban forest. The City is a 39-year participant in the Arbor Day Foundation’s “Tree City USA” program (Arbor Day Foundation, 2022; Figure 8). Additionally, in adopting the 2020 and 2022 climate action plans (CAPs) and recognizing urban forest stewardship as part of San Luis Obispo’s 2021-23 Major City Goals, the City Council has endorsed revitalizing tree operations and maintenance as well as the planting of 10,000 new trees within the city by 2035 (the 10 Tall Initiative). This Community Forest Plan is intended to work together with the City’s general plan, municipal code, CAPs, and other guiding documents to support City efforts to become carbonneutral by 2035 and to adapt to the disruptive effects of a rapidly changing climate.

San Luis Obispo’s publicly owned urban forest contributes greatly to “the SLO life” and the high level of environmental quality enjoyed by residents and visitors alike. By highlighting the valuable benefits provided by the City’s urban trees, acknowledging the challenges faced in their care, and striving to include the public in adaptive management-based forest planning and activities, it is hoped that this plan and its future iterations will contribute to enhanced community health and well-being in San Luis Obispo for many years to come.

Figure 8. The City of San Luis Obispo has been a Tree City USA participant since 1983.

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 15 of 114 V. Historical Context
Due to its geographic location and climate, the San Luis Obispo area has historically had relatively little native tree cover. However, the planting of many thousands of non-native trees in the city over the past two centuries has resulted in the area now having far more trees and species diversity than at any previous time in human history (Seymour, 1986, p. 50).

The Chumash people who occupied what is now the city of San Luis Obispo for over 10,000 years likely lived in a landscape dominated by grassland and chaparral with patchy woodlands of coast live oak, California bay laurel, toyon, and perhaps a dozen other tree species.

Watercourses were dominated by riparian species such as California sycamore, black and Fremont cottonwood, and arroyo willow.

The era of Euroamerican settlement and urbanization in the San Luis Obispo area began over 250 years ago with the establishment of Mission San Luis Obispo de Tolosa in 1772 (Figure 9).

The arrival of the missionaries saw the beginning of landscape conversion to agricultural and eventually urban uses. Up to half of the area’s native tree cover may have been lost fairly quickly, as there was a continuous need for building lumber as well as heating and cooking fuel (Carotenuti, 2006).

Figure 9. Excerpt from an 1874 map of San Luis Obispo. The Mission is seen in the center between Broad and Chorro Streets (“11. Catholic Church”), with the Mission orchard and grounds to the north and northwest, respectively. Source: History Center of San Luis Obispo archives.

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Office of Sustainability and Natural Resources Page 16 of 114 With the establishment of the Mission, the missionaries began to grow food crops including olive, fig, pear, grape, and prickly pear cactus, as well as grains and vegetables. Olive oil and wine were needed for use in religious ceremonies. In the mid-1830s the missions were secularized by the Mexican government. Despite the resulting changes experienced by the residents, Mission San Luis Obispo never ceased being an active church and never fell to complete ruin as did some of the other missions (Engelhardt, 1933; Carotenuti and Olson, 2004).

By the post-Civil War era, tree planting and creation of park-like landscapes had begun to capture the fancy of the American public. In San Luis Obispo, local newspapers sang the praises of urban trees in their pages and lamented the general citywide lack of them, citing their beauty, their value as sources of “relief and coolness,” and their usefulness as sources of lumber, food, and medicinal products (e.g., eucalyptus oil).

In fact, the area briefly went through a timber speculation craze when blue gum eucalyptus was planted widely in anticipation of a lumber shortage in California (e.g., San Luis Obispo (Weekly) Tribune, November 2, 1872, p. 2). Unfortunately for prospective timber barons, blue gum makes a poor building material due to its tendency to split and warp while drying and the predicted boom fizzled.

Over the years, hundreds of non-native tree and plant varieties from across the globe were brought to San Luis Obispo. One notable example is the two rows of camphor trees along Mill Street between Pepper Street and Johnson Avenue, which were planted in 1912 by D.J. Riley of Riley’s Department Store (Zeuschner, 1989). The surviving trees are now 110 years old, make the block uniquely beautiful, and indeed define the Mill Street Historic District (Figure 10).

Figure 10. Mill Street Historic District.

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Office of Sustainability and Natural Resources Page 17 of 114 Yet despite sporadic efforts to plant trees throughout the city, San Luis Obispo remained largely depauperate of greenery for decades (Figures 11 and 12), to the extent that new residents and visitors passing through found it worthy of comment (Fairbanks, 1989). Historical photographs of downtown San Luis Obispo taken prior to the 1960s show an urban setting that looks utterly desolate in comparison to its current verdant state (Middlecamp, 2021 Sep. 11).

Starting in the late 1950s, a beautification program initiated by City Councilman R.L. Graves and City Engineer (later Mayor) Dave Romero led to the green downtown we are familiar with today (Carotenuti, 2006; Middlecamp, 2021 Oct. 9). About a decade later the segment of Monterey Street in front of the Mission was torn out and the area was converted into a car-free pedestrian square, creating today’s Mission Plaza. Beautifying the plaza with landscaping was a high priority for the City, which moved mature trees from elsewhere in the city to the Plaza, including two old olive trees that had once been part of the Mission’s olive grove.

Figure 11. Looking east on Higuera Street at Garden Street, 1963. Source: Middlecamp, 2021 Sep. 11.

The City became an Arbor Day Foundation “Tree City USA” in 1983 and revived its Heritage Tree program several years later. Currently, 15 properties within the city host one or more designated (historically or otherwise significant) Heritage Trees (Andrews, no date; see Appendix B). Perhaps the highest-profile Heritage Tree in San Luis Obispo at present is the “Moon Tree,” a coast redwood that was planted as a sapling near Mission Plaza for the national

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 18 of 114 Bicentennial Celebration in 1976, five years after having visited the moon as a seed aboard Apollo 14 (Sheeler, 2018).

In 1989 the City’s Commemorative Grove was established at Laguna Lake Park. Nine commemorative trees and 38 windbreak trees were planted for the occasion, with many more trees having been planted over the intervening years (City of San Luis Obispo, 2022a).

Figure 12. “Higuera Street then and now.” Photo dates unknown. Source: Davey Resource Group, 2021.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 19 of 114 VI. Relationship to Other City Documents
This Community Forest Plan supports and is supported by existing City of San Luis Obispo goals, regulations, and policies as set forth in the City’s general plan, municipal code, Major City Goals for 2021-2023, climate action plans, and other applicable plans, specifications, and standards.

The CFP is also informed by the Davey Resource Group Organizational Assessment Report (2021) and the West Coast Arborists Urban Tree Inventory Update (2022).

A. General Plan
The Land Use Element (2014), in its Sustainability policies, calls on the City to develop a longterm tree planting program and recommendations to renew and maintain the urban forest; the latter includes planting more trees.

The Conservation and Open Space Element (2006) addresses various facets of the urban forest in its policies relating to Materials, Natural Communities, and Views. The element specifically mentions fostering the reuse and recycling of lumber from removed trees; protecting “significant” trees (including Heritage Trees) and oak woodlands; and creating and maintaining “desired streetscape characteristics” through the planting and retention of trees, with an emphasis on California native species.

The Parks and Recreation Plan and General Plan Element Update (2021), also known as the Parks + Recreation Blueprint for the Future: 2021-2041, calls for shading of play areas in part through the use of trees, and devotes a section to the selection of appropriate park trees.

The Climate Adaptation and Safety Element Update (CASE; 2023) combines two State-required general plan elements: Safety and Environmental Justice. The element addresses individual natural hazards such as wildfire, flooding, and extreme heat (and related urban forest concerns) in the overall contexts of climate resilience and diversity, equity, and inclusion (DEI). The San Luis Obispo County Multi-Jurisdiction Hazard Mitigation Plan is incorporated by reference into the CASE.

B. Municipal Code
The San Luis Obispo Municipal Code, Chapter 12.24 – Tree Regulations, establishes policies, regulations, and specifications pertaining to installation, maintenance, and preservation of trees within the city. Topics include the City Tree Committee, street tree master lists and management, tree removal, tree protection, heritage trees, enforcement, and appeals, among others.

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Office of Sustainability and Natural Resources Page 20 of 114 Figure 13. A West Coast Arborists crew trims a London plane tree (Platanus × hispanica) in front of the San Luis Obispo Repertory Theatre, August 2022.

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 21 of 114 C. 2021-23 Financial Plan
In its Major City Goals for the 2021-2023 Financial Plan period, the San Luis Obispo City Council included the following direction:
 The City will engage in projects and initiatives favoring accrual of the many benefits provided by trees, including shading and cooling, beautification, habitat, stormwater retention, and carbon sequestration;
 The City should focus renewed efforts on completing several urban forest-related tasks that will contribute to the adoption of an integrated, holistic, and equitable approach to urban forestry.

D. Climate Action Plans
The 2020 Climate Action Plan for Community Recovery (2020 CAP; City of San Luis Obispo, 2023a), under “Pillar 6: Natural Solutions,” called for increased carbon sequestration in the City’s greenbelt and urban forest as an important component of the City’s path to carbon neutrality by 2035. The 2020 CAP included the foundational action Natural Solutions 2.1, which directs staff to “Prepare the City’s first Urban Forest Master Plan by 2021 and plant and maintain 10,000 new trees by 2035.” Detailed implementation recommendations for this action include updating the tree inventory, identifying future tree planting opportunities with climateready species, and identifying strategies for ongoing operations and maintenance.

The 2022 CAP update – Climate Action Plan Volume 3: 2023-27 Work Program (City of San Luis Obispo, 2023a) – was adopted by the City Council in November 2022. This update continues and expands the strategies previously identified in the 2020 CAP and includes the FY 2023-25 work program task Natural Solutions 2.1A, directing staff to “Adopt and implement the Community Forest Plan and make significant progress on the 10 Tall goal of planting and maintaining 10,000 new trees by 2035.”
E. Other Planning Documents
Urban forest-related matters are further addressed in the following City documents:
 Conservation Guidelines for Open Space Lands (2002) and various Open Space Conservation Plans
 Waterway Management Plan (2003)
 Community Design Guidelines (2010)
 Downtown Concept Plan (2017) (see Figure 14)
 Mission Plaza Concept Plan (2017)

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Office of Sustainability and Natural Resources Page 22 of 114 Figure 14. The City’s Downtown Concept Plan visualizes Downtown SLO as a verdant, highly walkable destination. Source: City of San Luis Obispo Community Development Department, 2017.

F. Urban Forest Services Organizational Assessment and Tree Inventory Update This Community Forest Plan is in part informed by an Urban Forest Organizational Assessment Report (OA) prepared by Davey Resource Group (DRG; 2021) and an Urban Tree Inventory Update completed by West Coast Arborists (WCA; 2022). These efforts were commissioned by the City’s Public Works Department to help address some of the same urban forestry challenges that have been experienced by cities nationwide in recent years: declining tree age and species diversity, undesirable effects of climate change (drought-induced water stress, increased susceptibility to pest and disease attack, damage from extreme weather events), and reduced staffing levels resulting in a significant backlog of deferred maintenance.

DRG’s OA summary report contains extensive information and recommendations, including the results of stakeholder interviews and a month-long community survey, that informed the writing of this Community Forest Plan. WCA’s updated public tree inventory provides a foundation on which annual work plans and budgets, and thus an effective tree care program, can be based.

Certain OA recommendations (e.g., inventory update, expedited contractor pruning, hiring of a City volunteer coordinator) have already been implemented, and the WCA inventory update was successfully completed in 2022. Both documents are available to the public on the City’s Trees and Urban Forestry webpage at https://www.slocity.org/living/natural-resources/treesand-urban-forestry.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 23 of 114 VII. Sustainability
Sustainability is commonly defined as “meeting the needs of the present without compromising the ability of future generations to meet their own needs” (Brundtland, 1987). As awareness of global climate change, increasing pollution, and other environmental issues has entered the general consciousness in recent years, the importance of urban forestry has begun to receive more attention from the public.

Tree planting has increasingly come to the fore as a “low-hanging fruit” climate change solution (Mandel, 2021). In many locales, planting sites are numerous and trees and volunteer labor are readily available. The number of tree planting initiatives sponsored by government agencies, corporations, and other entities has dramatically increased since the beginning of the 21st century. However, planting in the wrong location, planting species that may not be able to withstand the local effects of climate change, or failing to provide adequate care to young trees until they establish can diminish or negate the desired outcomes. Thus, planning ahead is essential to avoid undesirable results.

The preparation of this Community Forest Plan involved extensive research and discussion around multiple aspects of sustainability, including the following topics. Please refer to Appendix A, Section E for additional discussion on each of these.  The “Right Tree, Right Place” Philosophy. A thriving, productive urban forest contains a mix of species and individual trees that are appropriate for the physical location and environmental conditions in which they were planted. Urban trees experience more challenging conditions than trees in natural environments, have shorter lifespans (averaging 19 to 40 years; Roman and Scatena, 2011), and require regular maintenance with associated costs. Like other cities in California, San Luis Obispo has begun to reevaluate its approved tree species lists for improved resilience in the face of climate change (see “Climate Readiness” below).
 Climate Readiness. Climate readiness refers to the resilience of an urban forest to environmental stressors caused or amplified by the effects of global climate change (McPherson et al., 2018). Climate change has been predicted to inflict increasing heat, drought, wildfire, and extreme weather events on California in the coming years, along with secondary effects including increased urban tree exposure to insect and disease attack. The San Luis Obispo Public Works Department and City Tree Committee have recently worked with Cal Poly San Luis Obispo’s Urban Forest Ecosystem Institute (UFEI) to revise the City’s Street Tree List, emphasizing climate-resilient trees and eliminating types no longer considered appropriate for projected hotter and drier climatic conditions.

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City of San Luis Obispo Community Forest Plan April
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Office of Sustainability and Natural Resources Page 24 of 114  Urban Forest Diversity. Diversity is a core ecological concept that refers to the variety and relative abundance of a species (Magurran, 1988). High species diversity, age diversity, and geographic distribution are believed to lead to greater overall ecosystem resilience. Although urban forests in the United States – including San Luis Obispo’s – typically have far higher species diversity than adjacent native forests or woodlands (Robertson and Mason, 2016), 80 percent of inventoried communities in California were identified as being over-reliant on a single species of street tree, typically either London plane, sweetgum, Chinese pistache, velvet ash, or Callery pear (McPherson et al., 2016).

When one of these trees dies or is removed, it may be wise to consider replacing it with a different type to enhance both diversity and climate resilience of the urban forest.  Pests and Disease. With each passing
decade the number of non-native,
invasive pests and diseases in California
increases through commercial activity or
other means of transportation from
distant areas, over time resulting in
significant economic damage and
mortality to crops, wildlands, and urban
plants and trees. Furthermore, the effects
of climate change actively contribute to
the spread of invasive species (Finch et
al., 2021). San Luis Obispo County has
been living with one such invasion since
at least the early 1990s – Fusarium
circinatum, a.k.a. Monterey pine pitch
canker – which has caused enormous
morbidity and mortality of pines.

Numerous additional threats including
sudden oak death (SOD) and invasive
shothole borer (ISHB; Figure 15) are either
confirmed to be or potentially headed
towards SLO County from both north and south. Thus, monitoring and early detection are essential. The City should work with its partners to keep up with the latest information and best practices, and must be ready to respond to fast-breaking situations using an “early detection, rapid response” mantra.  Adoption of a Lifecycle Perspective. The United States generates 46 million tons of urban lumber annually (Nowak et al., 2019). This potential job- and income-producing resource is worth anywhere from $89 million to $786 million, yet it is largely wasted.

The material is commonly chipped, burned, cut into firewood, or buried in a landfill. In Figure 15. Invasive shothole borerinfested tree in southern California.

Source: Nobua-Behrmann, 2018.

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 25 of 114 each case, the carbon stored in the wood returns to the atmosphere, exacerbating the effects of global climate change. This Community Forest Plan includes a recommendation for the City of San Luis Obispo to develop and implement an urban wood lifecycle plan, which would require consideration of end-of-life use in addition to other desired characteristics when choosing tree species to plant. The lifecycle plan would also include a replacement program based on planned rotation (replacement age; probably 20-30 years) and “right tree, right place” principles. The lumber retrieved could be used in a variety of ways, including for handcrafted furniture, benches, sheds, cabins, flooring, paneling (collectively, “biophilic design”; see Buffalo, 2016), or as public art.

Additional uses for urban lumber include cogeneration (energy production from waste biomass), biochar (Hawken, 2017, pp. 64-65), feedstock for engineered woods, landscape mulch, soil conditioner, animal bedding, compost additive, sewage sludge bulking medium, and boiler fuel (CalRecycle, 2022c).
 Soil Enhancement and Stormwater Management. Street trees often exist in harsh urban environments with large amounts of impervious surface, lack of growing space, poor soil and drainage conditions, and high exposure to pollutants. These conditions can significantly limit tree health and lifespan (Lawrence et al., 2012). The City could consider piloting or continuing the use of new technologies developed for the dual applications of stormwater infiltration/water quality improvement and urban tree growth enhancement. These products are designed to improve infiltration and remove soluble pollutants while facilitating the growth of larger trees than would otherwise be possible in confined urban settings, without damaging sidewalks, streets, or utilities. The City is also subject to a 2022-2026 compost procurement target of 3,685 tons per year (CalRecycle, 2022b) under California’s Short-Lived Climate Pollutant Reduction law (SB 1383). This material could potentially be used in City tree planting and care if various concerns, including plastic contamination, can be addressed.  Public Safety. Both the City’s 2023 General Plan Climate Adaptation and Safety Element (CASE; City of San Luis Obispo, 2023b) and San Luis Obispo County’s 2019 MultiJurisdiction Local Hazard Mitigation Plan (LHMP; County of San Luis Obispo, 2019) address potential hazards to public health and safety that may relate to San Luis Obispo’s urban forest; specifically, these include wildland fire, adverse weather, flooding, and tree mortality resulting from drought stress and pathogen attack. The Community Forest Plan recommends that the City continue to work with CalFire, SLO County, and other City partners to identify and proactively work to reduce these hazards.
 Water Conservation. Despite the record-setting rainfall seen across California in early 2023, the overall trend towards increasing unreliability of winter rains in central California means that water conservation will necessarily continue to be an important

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 26 of 114 part of the conversation around San Luis Obispo’s urban forest. New policies, practices, and technologies – as well as increased reliance on existing ones – are needed going forward. Substantial and as yet unrealized water savings are possible in California through more stringent water conservation, recycling, and stormwater capture efforts (Gleick et al., 2014). The City currently uses tree watering bags and recycled water (indicated by purple signs and piping) for irrigation of street and park trees (City of San Luis Obispo, 2022b), and has piloted the use of water-retaining hydrogels in new plantings. The Community Forest Plan makes several recommendations around water conservation; please refer to Table 5, Implementation Matrix.  Sustainability Indicators. Sustainability indicators are an urban forestry analysis tool described by Clark et al. (1997). The tool uses specific criteria that can be used in conjunction with measurable indicators to evaluate current urban forest conditions and therefore identify areas in need of improvement. The Davey Resource Group Organizational Assessment (OA) report provides a sustainability indicators analysis for San Luis Obispo’s urban forest as of 2021. Going forward, the City’s Urban Forest Services program may choose to use this tool to assess, evaluate, and indicate performance levels. Please refer to Appendix A, Section A.5, and the OA report for additional discussion.

Figure 16. Cork Oak (Quercus suber), Lincoln Street – a City Heritage Tree.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 27 of 114 VIII. Outreach
San Luis Obispo has worked with a variety of external partners to maintain and expand its urban forest for many years now, and the potential exists for additional partnerships in the future (Table 1). These relationships are essential for increasing awareness of the value of our urban tree cover and promoting public interest and participation. Volunteers bring their energy and enthusiasm to both tree planting and the long-term care that is necessary for young trees to establish and grow. In 2023, the City created a new Volunteer Coordinator position that will work across all departments to facilitate and increase volunteer involvement.

Table 1. Selected Existing and Potential City Urban Forest Partners.

California Conservation Corps
California Department of Transportation (CalTrans), District 5 California Polytechnic State University, San Luis Obispo (Cal Poly) Coastal San Luis Unified School District
Downtown SLO (Downtown Foresters program)
The Environmental Center of San Luis Obispo County (ECOSLO) Northern Chumash Tribal Council (NCTC)
One Cool Earth
Pacific Gas & Electric (PG&E)
Rotary de Tolosa Service Club
San Luis Obispo County Fire Safe Council
yak titʸu titʸu yak tiłhini Northern Chumash (ytt)
Several types of outreach helped inform this Community Forest Plan. Over a dozen stakeholder interviews were conducted, some by Davey Resource Group (DRG) in the preparation of their Urban Forest Organizational Assessment Report, and some by a Cal Poly San Luis Obispo graduate student working on a Master’s in City & Regional Planning degree. Davey also conducted an urban forestry community survey for the City. This online survey received 644 responses, a relatively high response rate for this type of outreach.

In addition, the Office of Sustainability & Natural Resources held three technical stakeholder meetings (“Natural Solutions forums”) as part of its climate action planning outreach in 2022 (Figure 17). Finally, preparation of the CFP has also benefited from continued collaboration between the City Public Works Department, the Office of Sustainability & Natural Resources, and the City Tree Committee throughout the 2022-23 period.

Davey Resource Group Benchmark Community Survey
In September and October 2021, DRG conducted a Benchmark Community Survey as an initial assessment of the community’s interest in, and vision for, San Luis Obispo’s urban forest. The

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 28 of 114 online survey was widely advertised by the City through a press release, social media advertisements, Tree Committee and City Council meetings, and signage at City parks and open space trailheads. 644 responses were obtained. The complete survey and responses are available as part of the DRG Organizational Assessment report on the City’s Trees and Urban Forestry webpage.

Figure 17. Climate Action Plan Natural Solutions Forum in Mission Plaza. Source: City of San Luis Obispo Office of Sustainability & Natural Resources, 2022.

The survey’s nine questions covered topics that included the most important benefits provided by urban trees (further split out into environmental and socioeconomic benefits), most important planting locations, how to encourage planting on private property, and community awareness of and satisfaction with the City’s Urban Forest Services (UFS) Program. Respondents were also encouraged to expand on their answers and offer thoughts and suggestions at the end if they desired.

According to survey respondents, the top five benefits of San Luis Obispo’s urban trees are shading/cooling, beautification, wildlife habitat, improved air quality, and connection with nature (Figure 18). Additional high-level takeaways from the survey included the following:

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 29 of 114  Top three most important places to plant trees: residential streets, parks, open space  Top three best ways to encourage tree planting on private property: free or low-cost trees, water bill rebate, rebate on purchased tree
 Awareness of the UFS Program: 75 percent
 Level of satisfaction with UFS: somewhat satisfied, 38 percent; neutral/no opinion, 32 percent
 Equality of access to UFS services: unsure, 63 percent; not equal, 20 percent; equal, 16 percent.

Figure 18. San Luis Obispo community member opinions on the most important benefits of trees.

Source: Davey Resource Group, 2021.

Respondents also expressed interest in receiving more tree education and outreach from the City. The most common requests pertained to information about which trees to plant in San Luis Obispo, how often to water during drought conditions, and how to plant a tree.

Overall, survey respondents, CFP interviewees, and others consulted during the preparation of the CFP provided many suggestions for outreach around the City’s urban forest. For a full listing of proposed outreach actions, please refer to Objective 1.7 in Table 5, Implementation Matrix.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 30 of 114 IX. Equity
Urban neighborhoods throughout the United States that historically experienced systematic discrimination commonly lack adequate tree cover and other landscaping (Locke et al., 2021). As a result, residents of these areas are deprived of access to the many benefits associated with urban trees (e.g., shading and cooling; see Wilson, 2020) and experience disproportionately poor public health and safety outcomes as compared to individuals in wealthier neighborhoods.

Furthermore, disadvantaged populations have the greatest vulnerability to the increasingly severe effects of climate change, such as extreme heat, drought, wildfire, and flooding (Islam and Winkel, 2017).

As stated in the City of San Luis Obispo’s 2023 Climate Adaptation and Safety Element (CASE), “The City is committed to integrating diversity, equity, and inclusion (DEI) in its operations and delivery of community services. The intersection of equity, environmental justice, and public safety is particularly important as the impacts of climate change will inequitably affect vulnerable and disadvantaged communities.” DEI is both a Major City Goal in the 2021-2023 Financial Plan and an important component of the City’s climate action and other plans.

Davey Resource Group addressed equity in their 2021 Urban Forestry Organizational Assessment Report for the City Public Works Department, which contained the following recommendations:
 Conduct an assessment to explore the distribution of public tree canopy and associated benefits by neighborhood, census tract, and/or other geographic metrics (refer to CASE Section C.2, Equity and Environmental Justice, for additional information on this topic)  Coordinate with the City’s Diversity, Equity, and Inclusion Task Force to identify gaps in equity as regards urban forest access and benefits
 Develop equity strategies around the urban forest.

Please refer to Table 5, Implementation Matrix, for proposed actions regarding equity, and refer to Appendix A, Section H for additional discussion on this topic.

Figure 19. The Santa Lucia Range and Terrace Hill frame SLO's urban forest.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 31 of 114 X. Implementation
The Implementation section summarizes proposed urban forest goals, objectives, and actions to be carried out by the City and its external partners. A full list of actions organized by objective is included in Table 5, the Community Forest Plan Implementation Matrix. All activities are intended to be informed by the CFP’s vision, mission, and goals.

This section also includes discussion on data collection, downtown’s urban forest, and the City’s plan to plant 10,000 new trees by 2035. Please refer to Appendix A for additional background information on these topics.

A. Goals and Objectives
The goals of the Community Forest Plan can be summarized as follows, while its objectives and the associated goals for each are shown in Table 2:

1. Maintain and expand the urban forest

2. Promote sustainability and climate resilience

3. Pursue internal and external collaboration

4. Perform public outreach and emphasize equity
Table 2. Community Forest Plan Objectives.

Plan Objective Associated Goal
Objective 1.1: Accrue and Analyze Data All
Objective 1.2: Strengthen Maintenance Practices and Clear the Backlog 1 Objective 1.3: Increase New Plantings and Implement the 10 Tall Initiative
All
Objective 1.4: Reexamine Tree Removal and Mitigation Policies 1,3 Objective 1.5a: Focus on Sustainability – Climate Resilience All Objective 1.5b: Focus on Sustainability – Lifecycle Perspective All Objective 1.5c: Focus on Sustainability – Soil Enhancement and Stormwater Management
1 Objective 1.5d: Focus on Sustainability – Safety 1,3,4 Objective 1.5e: Focus on Sustainability – Water Conservation 2,4 Objective 1.6: Address Issues Unique to Downtown All
Objective 1.7: Increase Outreach to Officials and the Public All Objective 1.8: Address Equity Issues 3,4

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 32 of 114 Table 3 lists the City of San Luis Obispo municipal departments and offices that are anticipated to be involved in urban forest planning and management going forward.

Table 3. Involved City Staff, Departments, and Offices.

Administration/Diversity, Equity & Inclusion DEI
Administration/Economic Development ECON
Administration/Information Technology IT
Administration/Sustainability & Natural Resources SNR
City Arborist CA
Community Development CDD
Fire Department FD
Parks & Recreation PR
Public Works PW
Utilities UT
Note: For implementation actions where more than one City Department is identified (see Table 5, Implementation Matrix), an inter-departmental, team-based approach is envisioned.

B. Targets and Metrics
The purpose of establishing goals and gathering data on the urban forest is to obtain information that is as complete and current as reasonably possible to help inform the City’s planning and budgeting processes. For instance, use of certain species or certain types of planting locations may need to be changed, pruning cycles may need adjustment, or program funding and staffing may undergo modification. Because of the likelihood that adjustments will be needed over time, it will be important for the City to retain flexibility by taking an adaptive management-based approach.

Targets can be thought of as goals or specific desired future conditions to aim for. The City’s 2020 and 2022 climate action plans, under “Pillar 6: Natural Solutions,” identified two targets for San Luis Obispo’s urban forest: plant 10,000 new urban trees in San Luis Obispo by 2035 (the 10 Tall Initiative), and reduce annual greenhouse gas (GHG) emissions by 1,490 metric tons of carbon dioxide equivalent (MTCO2E) in 2035. Potential urban forest targets that may be chosen by the City in the future are numerous; examples include planting a given number of new trees per time period (e.g., year) or location (e.g., neighborhood); performing maintenance on a certain proportion of City-owned trees within a given time period; or attaining 100 percent stocking (filling) of vacant City tree wells and other spots where trees have been removed.

Metrics are measures of specific characteristics. They can be used to obtain a one-time “snapshot” of current conditions; however, metrics are more useful when measurements are taken on the same trees repeatedly over time, allowing for observation of trends that can guide management actions and confirm whether targets are being attained. Basic examples of urban

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 33 of 114 forest metrics include average tree diameter, height, and condition; percent survival of newly planted trees at x years (5, 10, 20…); or percent canopy cover (percent ground area, as viewed from above, that is shaded by tree crowns). The City’s 2022 tree inventory update, conducted by West Coast Arborists, documented roughly two dozen metrics for each surveyed tree.

Please refer to Appendix A, Section A for additional discussion of targets and metrics.

Figure 20. ECOSLO volunteers planting trees at Throop Park. Source: ECOSLO, 2022.

C. Downtown San Luis Obispo’s Trees
San Luis Obispo’s central business district would be unrecognizable to most locals without its big, beautiful trees – notably including its iconic, roughly 60-year-old Indian laurel figs (Ficus microcarpa; see cover photo). As in other cities across California, downtown’s Ficus trees were planted during an urban beautification movement in the 1960s based on their reputation as hardy “miracle trees” that could withstand heat, drought, air pollution, and other hardships (Gordon, 1996).

For decades now, these evergreens have provided an ambience that enhances and serves as backdrop for special events, the weekly Downtown Farmer’s Market, and everyday shopping, dining, and entertainment opportunities. Their large, shady canopies confer a pleasing “sense of place” that enhances walkability, increases contentment, and encourages us to spend time outdoors. The presence of these trees also raises property values and drives increased retail business traffic.

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 34 of 114 However, the same trees drop debris; attract birds and insects that can enter businesses; disrupt sidewalks and underground utilities; block views and street signs; and incur ongoing taxpayer expense through their need for expensive maintenance. By the mid-1990s, cities throughout California had either stopped planting Ficus microcarpa for these reasons or were actively removing and replacing them, often with palms (Gordon, 1996). Although some cities have opted to play the waiting game by performing root trimming, installing underground root barriers, and replacing sidewalks with stone pavers around the trees, the overall feeling on the part of arboricultural professionals is that this is a case of “wrong tree, wrong place” – that many Ficus trees in downtown have simply gotten too big for their surroundings.

As the number of Ficus and other large, 1960s-era trees in downtown San Luis Obispo dwindles through attrition, the City may consider implementing a replacement program based on planned rotation and “right tree, right place” principles. The most likely plan is for a regular 20- to 30- year replacement cycle to be established. Some trees of the same species, including Ficus microcarpa, may be replanted but they will not again be allowed to attain such enormous size in cramped sidewalk spaces. Other species that were planted in the past but do not particularly thrive in the San Luis Obispo area may be used less or not at all. The hope is that the downtown San Luis Obispo of the future will have a more diverse, mixed-age and mixed-species tree palette containing a preponderance of species that, while still beautiful and inspiring, will be more appropriate for their surroundings.

Figure 21. ECOSLO volunteers with a newly planted oak sapling. Source: ECOSLO, 2023.

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 35 of 114 D. 10 Tall: An Initiative to Plant 10,000 Trees by 2035 In 2019, local stakeholders created the 10 Tall tree planting initiative to raise awareness of the benefits of urban trees and expand the city’s urban forest. 10 Tall is a City campaign nested in the 2020 CAP, Pillar Six: Natural Solutions. 10 Tall continued to be a priority area of focus in the City’s 2022 CAP update (CAP Volume 3, the 2023-2027 Work Program).

City staff anticipate that a large proportion (perhaps 40 percent) of the 10,000 trees proposed for planting will be native species that will be planted in City open space areas and creek corridors. Many of these will be planted by volunteer groups in coordination with the City’s external partners.

A rough estimate of the allocation of tree planting responsibilities under the 10 Tall Initiative between 2020 and 2035 is shown in Table 4.

Table 4. Estimated allocation of tree planting responsibilities for the 10 Tall Initiative.

Responsible Party(ies) Number of Trees Allocated
(Estimate)
City of SLO (Streets, Parks, Open Space, Riparian Areas)  Public Works (Streets, Parks, Right-of-Way,
Facilities)
1,000
 Natural Resources & Ranger Services (Creeks,
Open Space)
1,500
Standards for New Development 3,000
Volunteers and External Partners1 1,000
Private Residents and Property Owners through
complimentary trees
1,500
Trees planted to date since 2020 CAP (approximate) 2,000 Total 10,000

1 Volunteers and external partners will be employed largely to plant trees in public right-of-way and open space areas.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 36 of 114 E. Community Forest Plan Implementation Matrix
Table 5. Community Forest Plan Implementation Matrix.

Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)
Objective 1.1: Design and Implement the Program; Accrue and Analyze Data

1.1.1 Ensure Urban Forest Services’ tree database can
incorporate data from the 10 Tall website into the
City's records on a quarterly basis
3,4 CA, PW,
SNR
IT, EXT Near-term Ongoing

1.1.2 Continue to research and apply for public grant
funding opportunities for the community forest
and urban lumber uses
1,3 CA, SNR EXT Near-term Ongoing

1.1.3 Incorporate urban forestry into the City's existing Green Team process to ensure interdepartmental
implementation
1,3 CA, PW,
SNR
CDD, UT, PR Near-term Expanded

1.1.4 Identify urban forest targets and metrics 1,4 CA, SNR CDD, EXT Near-term Expanded

1.1.5 Utilize the GIS land cover and equity analysis (tree cover, impervious surfaces, socioeconomic
characteristics) from the City’s Climate
Adaptation and Safety Element (CASE) to inform
tree planting and care priorities (see also Actions

1.3.4 and 1.8.2)
All SNR, DEI CA, PW, IT,
EXT
Near-term New

1.1.6 Acquire an updated LIDAR dataset for entire City
(public and private trees) for improved canopy
cover and species diversity analysis, as resources
permit
1 IT, SNR PW, EXT Mid-term New

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 37 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.1.7 Collaborate with Cal Poly to conduct a contingent (nonmarket) valuation study of City right-of-way
trees using i-Tree Eco or equivalent software
1,4 SNR CA, EXT, IT,
ECON
Mid-term New

1.1.8 Plan to update the tree inventory every five years 1 PW CA, SNR, EXT Mid-term New Objective 1.2: Strengthen Maintenance Practices and Clear the Backlog

1.2.1 Continue with expedited pruning by contractors
to catch up on maintenance backlog
1 PW CA, EXT Near-term Ongoing

1.2.2 Ensure that palms, cottonwoods, and other highmaintenance species are maintained at recommended intervals (1-2 years), i.e., more
frequently than the regular ~5-year pruning cycle
1 PW − Near-term Ongoing

1.2.3 Conduct annual, or as needed, “windshield
surveys” to identify higher-priority existing or
incipient problems
1 CA PW Near-term Expanded

1.2.4 Follow up on every City-required replacement
planting after tree removals
1 CA, CDD EXT Near-term New
Objective 1.3: Increase New Plantings and Implement the 10 Tall Initiative

1.3.1 Maintain existing relationships with external City partners (and establish new ones) for tree
planting, long-term care (e.g., watering),
outreach, provision of training, etc. across public
and private property in the city
1,3,4 CA, PW,

PR, SNR
EXT Near-term Ongoing

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 38 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.3.2 Implement the 10 Tall goal of planting 10,000
new trees in the City by 2035 (see also 1.7.6,
below)
All CA, PW,

SNR, PR
CDD, EXT Near-term Expanded

1.3.3 Create and implement a detailed, comprehensive
tree planting plan adopting “right tree, right
place” as its guiding principle; specify planting
sites and installation procedures
All CA, SNR,
PR

PW, CDD,
EXT
Near-term New

1.3.4 Achieve 100 percent stocking of empty street tree wells (~350 as of 2023) and consider creating new
tree wells based on land cover assessment and
equity goals (see also Actions 1.1.5 and 1.8.2)
1,4 PW CA, SNR, DEI

CDD, EXT
Mid-term Expanded

1.3.5 Pilot a City tree and mulch giveaway program if
outreach efforts indicate public interest
1,3,4 PW, SNR CA, UT, EXT Mid-term Expanded
Objective 1.4: Reexamine Tree Removal and Mitigation Policies

1.4.1 Work with the Tree Committee and community to
adopt stronger protections for existing, mature
trees that would be affected by planned new
development
1 CA, PW,
CDD
− Near-term New

1.4.2 Set a minimum target size(s) for replacement
trees (mitigation planting) that will maximize
survival chances and benefits provided (e.g.,
carbon sequestered)
1,3 CA, PW,
CDD
EXT Near-term New

1.4.3 Require compensatory planting after tree
removal to match total diameter of mature trees
removed, or another determined metric that
1,3 CA, PW,
CDD
− Mid-term New

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 39 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)
ensures that compensatory tree planting efforts
are commensurate with impacts

1.4.4 In cases where on-site replanting after private
property tree removal is infeasible, explore the
possibility of compensatory planting in
ecologically appropriate locations which may
include City open space, parks, or other
properties within the city
1 CA, PW,

PR, CDD
SNR Mid-term New

1.4.5 In cases where on-site replanting after private
property tree removal is infeasible, explore the
possibility of modifying regulations to add an inlieu fee option with funds to be paid into a formal, dedicated urban forestry fund
1 CA, PW,
CDD
SNR Mid-term New

1.4.6 Evaluate modifying City engineering standards for new development (currently 1 street tree per 35
ft of sidewalk) with a required number of trees
per dwelling unit (residential), sq. ft.
(commercial), or floors (multistory, all zones)
1,3 PW, CDD CA Mid-term New
Objective 1.5a: Focus on Sustainability – Climate Resilience (“Right Tree, Right Place”)

1.5a.1 Continue working with external City partners
(e.g., Cal Poly and interested wholesale growers)
to identify and obtain promising new climateready tree species; update the City's Tree List(s) accordingly
1,2 CA, EXT SNR, PR,
CDD
Near-term Ongoing

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 40 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.5a.2 Monitor overall urban forest health and avoid
planting tree species known to be invasive or
highly susceptible to existing or incipient pests
and disease, to reduce future tree losses
1,2,3 CA, PW,

SNR, EXT
PR Near-term Ongoing

1.5a.3 Work with contractors and partners to monitor
tree health citywide for new pest and disease
outbreaks; plan for a coordinated, rapid response
to threats
1,3 CA, PW,
SNR
PR, EXT Near-term Ongoing

1.5a.4 Use or require tree species that are considered
suitable for urban spaces, climate change-ready,
and appropriate for their proposed location and
desired benefits
2 CA, PW,

SNR, PR
CDD, EXT Near-term Expanded

1.5a.5 Plant in locations that maximize long-term tree
health and growth while minimizing potential
conflicts relating to infrastructure and other
concerns
1,2 PW, UT CA, SNR, PR,
CDD
Near-term Expanded

1.5a.6 Focus on planting where canopy cover is lowest
to maximize urban forest benefits (underserved
neighborhoods, parking lots, schoolyards,
transportation corridors)
2 SNR, CDD,
DEI
CA, PW, EXT Near-term Expanded

1.5a.7 Use up-to-date Best Management Practices
(BMP) resources such as “Climate Adaptation
Actions for Urban Forests and Human Health”
(Janowiak et al., 2021) to help guide future City
urban forest policy and actions
All CA, PW,

PR, SNR
CDD Near-term Expanded

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 41 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.5a.8 Consider adopting the use of sustainability
indicators (Clark et al., 1997) to regularly assess,
evaluate, and indicate the current performance
levels of the urban forest
1 CA, SNR CDD Mid-term New

1.5a.9 Ensure that open space and riparian plantings use native tree and shrub species in ecologically
appropriate areas (e.g., oaks are most
appropriate on north-facing slopes and in
drainages)
2 SNR, PR EXT Mid-term Expanded

1.5a.10 Create multiple City tree lists for different
locations (street, park, creek, open space) and
tree well sizes
2 CA, SNR,
EXT
PW, PR, CDD Mid-term New
Objective 1.5b: Focus on Sustainability – Lifecycle Perspective

1.5b.1 Prepare a detailed, comprehensive lifecycle plan for City trees that includes long-term care,
replacement strategies for aging trees, and endof-life lumber uses All SNR, EXT CA, PW,

CDD, PR
Near-term New

1.5b.2 Work with internal and external stakeholders
(businesses and nonprofits) to establish a multiuse facility that will handle and distribute organic debris that is too large for the Hitachi-Zosen
anaerobic digester; this "green sort yard" could
potentially host composting, biochar, cellulosic
ethanol, and/or electricity generation uses
2,3 SNR, UT,
EXT

PW, PR,
ECON
Near-term New

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 42 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.5b.3 To support the above actions, work with partners to place roll-off bins at strategic locations where
feasible (e.g., tree companies' yards) to collect
the raw material; allow the public to drop off
materials at these locations
2,3 SNR, EXT PW, UT Near-term New

1.5b.4 Promote reuse and recycling of, and work to
increase supply of, urban wood waste and lumber
for multiple uses: furniture, small buildings,
interior decoration ("biophilic design"), fencing,
artwork, biogas and biofuels, mulch
All SNR, UT,
EXT
PW, PR Mid-term New

1.5b.5 Set a target requirement for urban wood waste
and lumber to be used in construction or
otherwise dedicated to sustainable use within the
city, where feasible (including but not limited to
the uses described above)
2,3,4 SNR, UT,
CDD
EXT Mid-term New

1.5b.6 Place a QR code or other mechanism on newly
planted trees to connect the public to educational
information on publicly accessible recycled urban
lumber products (e.g., park benches, fencing,
downtown public art)
4 SNR, UT EXT Mid-term New

1.5b.7 Organize educational opportunities to inform
industry professionals and the public on
sustainable uses of urban lumber and its place in
the circular, carbon-neutral economy
3,4 SNR, UT,
EXT
- Mid-term New

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 43 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)
Objective 1.5c: Focus on Sustainability – Soil Enhancement and Stormwater Management

1.5c.1 Consider the use of technology including
engineered soils, soil cells, permeable hardscape,
and new planter designs, for optimal tree health
and stormwater management outcomes in highprofile locations with space constraints or poor soils (e.g., downtown streetscapes) and
implement as appropriate
1 PW UT, EXT Mid-term New

1.5c.2 Evaluate requiring the use of SB 1383-procured
compost in all new plantings and implement as
feasible
1 CA, UT,
SNR
PW, EXT Mid-term New
Objective 1.5d: Focus on Sustainability – Safety

1.5d.1 Continue to work with CalFire, SLO County, and
other City partners to identify and reduce wildfire
hazards, flooding, and other vulnerabilities in the
city as per the Climate Adaptation and Safety
Element (CASE)
1,3,4 SNR, PW,

FD, PR,
EXT
− Near-term Ongoing

1.5d.2 Continue to monitor and maintain locations
within the City’s creek drainages where flooding
could be exacerbated by fallen trees in the wake
of storms, wildfires, and/or large-scale tree
mortality events
1,3,4 SNR, PW,

FD, PR,
EXT
− Near-term Ongoing
Objective 1.5e: Focus on Sustainability – Water Conservation

1.5e.1 Prioritize water conservation in all urban forestrelated actions2,4 UT, PW, SNR
EXT Near-term Ongoing

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 44 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.5e.2 Require mulching of existing and newly planted
trees; check once a year and supplement if
needed
2 CA, PW,
SNR
UT, EXT Near-term Ongoing

1.5e.3 In City open space areas, plant new trees near
natural drainages where possible
2 SNR, PR EXT Near-term Ongoing

1.5e.4 Work with City partners to perform outreach to
property owners about correct watering of trees
during drought conditions
2,4 CA, UT EXT Near-term Expanded

1.5e.5 Continue to pilot the use of existing or upcoming water-conserving technologies such as tree bags,
hydrogels, pervious (permeable) hardscape
materials, engineered soils, soil cells, wireless tree
data monitoring, etc.
2 CA, PW EXT Near-term Expanded

1.5e.6 In hardscape areas, consider redirecting
stormwater runoff to new or existing trees and
landscaping as feasible
2 PW, CDD,
UT
− Mid-term New
Objective 1.6: Address Issues Unique to Downtown

1.6.1 Continue to implement downtown streetscape
improvements as described in the DCP and the
Community Design Guidelines
All PW, CDD SNR, EXT Near-term Ongoing

1.6.2 Continue to work with internal and external City
partners to address tree-related problems
affecting the downtown area to ensure citizen
safety, comfort, and tree health (e.g., evaluation
All PW, SNR,
ECON,
CDD
EXT Near-term Ongoing

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 45 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)
and as-needed replacement of tree grates;
sidewalk repairs; bird and insect control)

1.6.3 Continue to support and provide training for the
existing Downtown Foresters volunteer group
1,4 CA, PR EXT Near-term Expanded

1.6.4 Ensure that the proposed urban wood lifecycle
plan (see Objective 1.5b) includes substantial
discussion on downtown's Ficus microcarpa trees,
as these are of high public interest
1,2,4 CA, CDD,

ECON, UT,
SNR
EXT Near-term New

1.6.5 Perform a trial(s) with growth-regulating
chemicals where trees are installed in spaceconstrained areas downtown 2 PW CDD, EXT Mid-term New

1.6.6 Support implementation of the City’s Downtown
Concept Plan (DCP) and Mission Plaza Concept
Plan (MPCP)
All PW, CDD,

ECON, PR,
SNR
EXT Long-term Ongoing
Objective 1.7: Increase Outreach to Officials and the Public

1.7.1 Continue to maintain the City's 39-year long "Tree City USA" designation
3,4 CA, PW − Near-term Ongoing

1.7.2 Continue to work with external partners to
publicize urban forestry’s importance in climate
action and natural resources management,
emphasizing long-term urban forest care and
health over merely “planting trees”
2,3,4 SNR, EXT PW Near-term Ongoing

Page 959 of 1373 ends

City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 46 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)

1.7.3 Tie in urban forestry outreach with other City
marketing or tourism-oriented programs (e.g.,
“Keys for Trees”)
3,4 SNR,
ECON
EXT Near-term Ongoing

1.7.4 Update the City’s urban forest website: add
pruning schedules; create a publicly viewable,
interactive online map of all City-owned trees;
add photos and descriptions of Heritage Trees;
add discussion of ecosystem services values
3,4 CA, PW,

SNR, IT
- Near-term Expanded

1.7.5 Use more storytelling in urban forestry public
engagement: honor volunteers, partners, and
sponsors in annual or semiannual outreach
events and/or with tree tags or plaques
3,4 ADMIN,

SNR, PR
EXT Near-term Expanded

1.7.6 Support development of the 10 Tall Initiative
website; go live with it by the beginning of FY
2023-24
3,4 SNR, PW EXT, IT Near-term New

1.7.7 Create an interpretive and/or commemorative
plaque program for street, park, and Heritage
trees
3,4 CA, ECON,

SNR, PR
EXT Mid-term Expanded

1.7.8 Attract statewide or national urban forestry
conferences to San Luis Obispo
3,4 CA, SNR,
ECON
EXT Mid-term Expanded

1.7.9 Explore initiating a program to provide financial support to income-qualifying private landowners
for needed care and maintenance of their trees
1,3,4 SNR, CDD,
DEI
EXT Mid-term New

1.7.10 Work with City partners to create an “urban
forestry community outreach week,” possibly
3,4 CA, SNR,

PR, EXT
- Mid-term New

Page 960 of 1373 ends

City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 47 of 114 Action
Number
Action Primary
Associated
Goal(s)
Lead(s) Partners
(EXT =
External)
Timeframe
(Near-term,
Mid-term,
Long-term)
Status
(Ongoing,
Expanded,
New)
combined with the City's annual Earth Day or
Arbor Day celebrations

1.7.11 Approach Cal Poly and/or Cuesta College to
create a new student urban forest steward club
or program (possibly including a tree nursery)
that would work with the City
3,4 SNR, EXT − Mid-term New

1.7.12 Restart the City Commemorative Tree program
when staffing and new, additional site location(s)
become adequate
1,4 CA, PW − Long-term Expanded
Objective 1.8: Address Equity Issues

1.8.1 Continue to conduct City outreach in, at a
minimum, English and Spanish; consider
additional languages as well, if deemed
warranted based on Census or other demographic
data and indicators
4 SNR, DEI EXT Near-term Ongoing

1.8.2 When planning tree planting activities, prioritize and perform outreach in areas of the City
identified as low-income, vulnerable to heat
stress, and in tree-poor areas where residents
express interest in new trees (see also Actions

1.1.5 and 1.3.4)
3,4 SNR, PR,
DEI
PR, IT Near-term Expanded

1.8.3 Coordinate regularly with the City’s DEI Manager, local indigenous leaders, and other external
equity-focused partners on tree planting activities
3,4 SNR, DEI PW, PR, EXT Near-term Expanded

Page 961 of 1373 ends

City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 48 of 114 XI. Next Steps
Upon adoption of the CFP by the City Council, the most pressing actions for the City will be to continue catching up on the tree maintenance backlog, moving forward with the hiring of new City urban forest staff and seeking new sources of urban forest funding (as resources allow), and continuing to work with City partners to implement the 10 Tall Initiative to plant 10,000 new trees by 2035.

Other high priorities include creating urban tree planting and lifecycle plans, and considering modification of the City’s engineering standards and/or municipal code around tree removals and mitigation requirements.

Figure 22. Murray Avenue’s unique tree-lined pedestrian median, San Luis Obispo.

Page 962 of 1373 ends

City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 49 of 114 References Cited
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2023
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Office of Sustainability and Natural Resources Page 53 of 114 Kwon, O. H., Hong, I., Yang, J., Wohn, D. Y., Jung, W. S., & Cha, M. (2021). Urban green space and happiness in developed countries. EPJ data science, 10(1), 28.

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Staats, H., & Swain, R. (2020). Cars, trees, and house prices: Evaluation of the residential environment as a function of numbers of cars and trees in the street. Urban Forestry & Urban Greening, 47, 126554.

Strohbach, M. W., Lerman, S. B., & Warren, P. S. (2013). Are small greening areas enhancing bird diversity? Insights from community-driven greening projects in Boston. Landscape and Urban Planning, 114, 69-79.

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City of San Luis Obispo Community Forest Plan April
2023
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Ziska, L. H., Makra, L., Harry, S. K., Bruffaerts, N., Hendrickx, M., Coates, F., ... & Crimmins, A. R. (2019). Temperature-related changes in airborne allergenic pollen abundance and seasonality across the northern hemisphere: a retrospective data analysis. The Lancet Planetary Health, 3(3), e124-e131.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 57 of 114 Figure 23. Terrace Hill and Islay Hill beyond Court Street Plaza in downtown San Luis Obispo.

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City of San Luis Obispo Community Forest Plan April 2023 Office of Sustainability and Natural Resources Page 58 of 114 Appendix A: Additional Background Information and Research The following information is intended to provide additional detail and discussion around some of the major issues identified by the CFP and serves as the basis for the recommendations in the CFP.

1. Design and Implement the Program; Accrue and Analyze Data a. Davey Resource Group – Organizational Assessment Report (2021) b. West Coast Arborists – Tree Inventory Update (2022)
c. Urban Forest Ecosystems Institute (UFEI) Data
d. Targets
e. Metrics
f. Data Analysis

2. Strengthen Maintenance Practices and Clear the Backlog

3. Increase New Plantings and Implement the 10 Tall Initiative

4. Reexamine Tree Removal and Mitigation Policies

5. Focus on Sustainability
a. Right Tree, Right Place
b. Climate Readiness
c. Urban Forest Diversity
d. Pests and Disease
e. Lifecycle Perspective
f. Soil Enhancement and Stormwater Management
g. Safety
h. Water Conservation

6. Address Issues Unique to Downtown

7. Increase Outreach to Officials and the Public

8. Address Equity Issues
Additional information included in this section was provided by Cal Poly San Luis Obispo’s Urban Forest Ecosystem Institute (UFEI).

A. Design and Implement the Program; Accrue and Analyze Data

1. Davey Resource Group Organizational Assessment Report (2021) DRG reviewed the structure and operations, background documents, and existing policies of the City’s Urban Forest Services program, which is housed in Public Works. They also engaged key partners and community members, including conducting an online survey to gauge community awareness and support for the urban forest.

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 59 of 114 DRG’s findings were summarized in a 145-page OA report that included approximately 150 recommendations in the categories of Urban Forest Resource, Operations and Programs, Urban Forest Partners, and Organizational Structure and Staffing. Additional discussion centered on Policy and Regulation, the Benchmark Community Survey, and Analysis of Sustainability Indicators.

Some of the OA’s more significant recommendations for improving the health and strength of the urban forest, and therefore of City residents and visitors, included:
 Update the City’s inventory of street, park, and City facilities trees (completed in 2022)  Continue to use contract services for tree pruning and move toward a proactive, 5-to-6- year maintenance cycle
 Update the City Street Tree List to focus on climate-resilient species  Create a tree planting and care plan, and an urban wood lifecycle plan  Strengthen social and environmental equity by assessing and working to enhance tree cover in disadvantaged neighborhoods
 Reexamine compensatory planting requirements related to development-related tree removals; any changes made may ultimately impact the role, responsibilities, and authority of the Tree Committee
 After tree removal, require follow-up monitoring of replanting by City staff  Require City arborist review of all development plans  Implement a comprehensive urban forest database management system that allows for multiple administrative functions and facilitates internal/external partner access to the inventory for updating purposes
 Restart the Commemorative Grove program as resources become available  Expand engagement with key stakeholders and the community.

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2023
Office of Sustainability and Natural Resources Page 60 of 114 Figure 24. Bishop Peak Natural Reserve.

2. West Coast Arborists Tree Inventory Update (2021-22) The urban forest inventory update conducted by WCA was another important step in moving forward with efforts to protect, strengthen, and expand the City-owned portion of SLO’s urban forest. Urban forest planning and budgeting efforts achieve the best outcomes when they are based on complete and up-to-date information.

WCA inventoried 12,455 trees in the City’s public right-of-way (streets, parks, and City facilities).

Address, species, diameter, height, condition, and other data were gathered for each tree. In their summary report, WCA estimated the total value of these trees at over $39 million (West Coast Arborists, 2022).

90.4 percent of the inventoried trees were characterized as being in good condition, with another 4.2 percent being considered fair. Approximately two-thirds of the inventoried trees were 12 inches or less in diameter (measured at 4.5 feet above the ground) and were under 30 feet tall.

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City of San Luis Obispo Community Forest Plan April
2023
Office of Sustainability and Natural Resources Page 61 of 114 The 10 most common species and their estimated value are shown in Figure 25:

Figure 25. Ten most common urban tree species in San Luis Obispo. Source: West Coast Arborists, 2022.

Based on their inventory findings, WCA made several recommendations which broadly match recommendations provided in the DRG OA:
 Establish a grid trimming schedule to prune all trees on a routine cycle (most agencies average 3 to 5 years per cycle)
 Initiate inspection and mitigation for trees identified at risk of disease or decline  Create a tree removal plan
 Create a planting plan to fill vacant sites
 Provide young tree maintenance to ensure proper establishment.

3. Urban Forest Ecosystems Institute (UFEI) Data
Cal Poly’s Urban Forest Ecosystems Institute (UFEI) (https://ufei.calpoly.edu/) maintains a statewide street tree inventory database based on data provided by California’s largest tree companies (UFEI, no date). For San Luis Obispo, this inventory shows a current tally of 12,496 trees encompassing at least 221 species. This number of trees tracks closely with WCA’s inventory of 12,455 street, park, and City facility trees.

UFEI is also host to an image-processing tool called the Urban Tree Detector. Recent UFEI research used this artificial neural network-based algorithm to process aerial photography from the National Agriculture Imagery Program (NAIP), resulting in an estimate of 48,710 trees (public and private) within San Luis Obispo’s urban boundary as of 2020. This figure is likely an underestimate for the city as a whole, as it does not include areas of dense closed canopy such as oak woodlands that are within the city limits.

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