San Luis Obispo City Council
September 5, 2023

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Reservoir, Nacimiento Reservoir, and recycled water (for irrigation), with groundwater serving as a fifth supplemental source. According to the city’s 2020 Urban Water Management Plan and based on the city’s available water supplies and estimates of future water demand, the city’s water resources are determined to be reliable during normal and extended drought periods (City of San Luis Obispo 2021c). The city’s Water Treatment Plant also has the capacity to meet projected water demand at build-out under the city’s most recent General Plan (City of San Luis Obispo 2014b).

Wastewater Treatment
The City of San Luis Obispo Water Resource Recovery Facility collects and processes wastewater from land uses in the city, California Polytechnic State University (Cal Poly), and the airport. In 2021, the Water Resource Recovery Facility treated an average of 2.96 million gallons per day of wastewater, before discharging it into the San Luis Obispo Creek (Metz 2022). The Water Resource Recovery Facility is undergoing a comprehensive upgrade to the facility, called SLO Water Plus, which will increase treatment capacity, provide a new treatment system, update the odor control system, and improve flood protections (City of San Luis Obispo 2022).

Solid Waste
San Luis Garbage provides waste and recycling services in the city, including the project site. The nearest landfill to the project site is the Cold Canyon Landfill at 2268 Carpenter Canyon Road, approximately 6.4 miles southeast of the project site. According to the city, the Cold Canyon Landfill accepts various construction-related waste, including asphalt/concrete and mixed construction and demolition debris (City of San Luis Obispo 2021e). The facility has a permitted capacity of 23.9 million cubic yards, with a remaining capacity of approximately 13 million cubic yards (CalRecycle 2021). The Cold Canyon Landfill has a maximum daily throughput of 1,650 tons per day with an estimated closure date of 2040 (CalRecycle 2021).

Electric Power and Natural Gas
As described in detail in Section 2.1.6, Energy, Pacific Gas and Electric provides electricity and Southern California Gas provides natural gas service to the city.

Environmental Consequences
a) Water
The project does not include any new housing or other development that would generate substantial long-term water demand and does not involve the construction of new or expanded water supply infrastructure. However, the project would include landscaped areas post-development, which would involve long-term use of water. Landscaping would consist of drought-tolerant species watered by efficient landscape irrigation systems, resulting in minor water use post-project construction. The proposed landscaping would be

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required to be consistent with the City’s Water Efficient Landscape Ordinance. During project construction activities, required Avoidance, Minimization, and/or Mitigation Measures implement San Luis Obispo Air Pollution Control District’s standard fugitive dust control measures, which require short-term watering of exposed soil during construction to reduce emissions. However, water demand for fugitive dust mitigation activities would be limited and temporary and would be met using recycled water supplies to minimize potable water demand. The project could result in the relocation of some existing water lines. However, the relocation activities would occur within the proposed project footprint. The project would not require or result in the construction of new or expanded water facilities, and this impact would be less than significant.

Wastewater Treatment
The project would not result in any new land uses that would increase sanitary wastewater generation or otherwise contribute to an increase in wastewater treatment requirements. The amount or characteristics of wastewater treated at the Water Resource Recovery Facility would not change compared to existing conditions with the implementation of the proposed project. The project could result in the relocation of some existing wastewater infrastructure. However, the relocation activities would occur within the proposed project footprint. Any necessary dewatering to the collection system would be conducted under a Temporary Discharge Permit from the city and would be required to comply with all permit requirements.

The project would not require or result in the construction of new wastewater treatment infrastructure, and this impact would be less than significant.

Stormwater Drainage
As discussed in Section 2.1.10, Hydrology and Water Quality, the project would replace existing impervious surfaces on a relatively flat project site. The project would result in an overall increase in impervious surface of up to 2 acres due to the extension of Prado Road (Dalidio Drive). Increases in the impervious surface cover have the potential to increase runoff volume and flow to existing stormwater facilities. The project would be required to implement postconstruction treatment control Best Management Practices to infiltrate, harvest, reuse, evapotranspire, or capture and treat runoff from the 85th percentile, 24-hour rainfall event, pursuant to the National Pollutant Discharge Elimination System Statewide Stormwater Permit Waste Discharge Requirements for State of California Department of Transportation (Order 2012-0011-DWQ and subsequent amendments) and the National Pollutant Discharge Elimination System Phase 2 Small MS4 General Permit (Order 2013-0001-DWQ). Stormwater capture, infiltration, or treatment Best Management Practices required pursuant to these permits include the following design and performance standards related to detention and infiltration basins or low-impact development flow-through treatment devices:

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 Low impact design of the project to minimize stormwater runoff and minimize disturbance of natural drainage features.
 Treatment of runoff from the 85th percentile, 24-hour event using infiltration, harvest and reuse, or capture Best Management Practices, such as a bioretention facility.
 Retaining the 95th percentile, 24-hour rainfall event.  Ensuring proposed and existing peak flows match for the 2-year through 10-year rainfall events.

Implementation of these practices would minimize potential impacts to the stormwater conveyance system. Therefore, compliance with applicable National Pollutant Discharge Elimination System permit requirements would ensure that the project would result in less than significant impacts to stormwater drainage facilities.

Electric Power
As discussed in Section 2.1.6, Energy, the project would not substantially increase long-term energy demand. Potential energy demand, such as that needed for streetlights or typical roadway maintenance activities, would be met with existing electric power infrastructure that currently serves the project site and vicinity. Therefore, no new or relocated energy facilities would be required as a result of the proposed project. The project was designed to avoid the high voltage tower on the west side of U.S. 101. The project would not require or result in the need for new or expanded electric power facilities, and this impact would be less than significant.

Natural Gas
The project would not involve any new land uses that would require natural gas service. While the project could result in the relocation of existing natural gas facilities, such activities would occur within the proposed project footprint.

Therefore, the project would not require or result in the need for new or expanded natural gas facilities that would result in physical environmental impacts beyond those identified throughout this Initial Study. This impact would be less than significant.

Telecommunications
The project would not involve any new land uses that would require telecommunications infrastructure. While the project could result in the relocation of existing telecommunications facilities, such activities would occur within the proposed project footprint. Therefore, the project would not require or result in the need for new or expanded telecommunications facilities that would result in physical environmental impacts beyond those identified throughout this Initial Study. This impact would be less than significant.

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b) As discussed in checklist item a) in this subsection, the project does not include any new development land uses that would generate substantial longterm water demand. The project would include landscaped areas postdevelopment, which would involve long-term use of water. Water use for landscaping would be minimized through the planting palette and installation of water-efficient irrigation systems. The proposed landscaping would be required to be consistent with the City’s Water Efficient Landscape Ordinance. Compliance with San Luis Obispo Air Pollution Control District’s standard fugitive dust control measures during project construction activities would require short-term watering of exposed soil during construction.

However, water demand for fugitive dust mitigation activities would be limited and temporary and would be met using reclaimed water supplies to the extent feasible. The project would not impact water supply availability for any reasonably foreseeable future development during normal, dry, and multiple dry years. Therefore, impacts related to the availability of water supply would be less than significant.
c) As discussed in checklist item a) in this subsection, the project would not increase sanitary wastewater generation or otherwise contribute to an increase in wastewater treatment requirements or wastewater treatment capacity at the Water Resource Recovery Facility. No impact would occur. d, e) Once constructed, project operation would not result in new solid waste.

Project construction activities would generate solid waste in the form of demolition debris, asphalt/concrete, and spoiled soils. Construction waste would be disposed of in accordance with all applicable federal, state, and local policies. The project would be required to comply with the State’s 65 percent construction/demolition waste diversion requirement and would be required to prepare a construction waste management plan to identify waste management and diversion procedures. Recycling facilities in the project site vicinity that accept demolished concrete/asphalt materials include North County Recycling in Templeton and Hanson Aggregates in Santa Margarita.

Local solid waste infrastructure can accept solid waste generated by project construction activities that are not diverted for recycling. Once constructed, long-term project operation would not generate solid waste, and the project would not otherwise impair the attainment of solid waste reduction goals.

Potential impacts associated with solid waste management would be less than significant.

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2.1.20 Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones:

Question—Would the project:

CEQA Significance Determinations
for Wildfire
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
Less Than Significant Impact
b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and thereby
expose project occupants to pollutant
concentrations from a wildfire or the uncontrolled
spread of a wildfire?
Less Than Significant Impact
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?
Less Than Significant Impact
d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff, postfire slope instability, or drainage changes? Less Than Significant Impact
Affected Environment
The San Luis Obispo region is prone to potential wildfire events due to its warm, dry climate, surrounding rural hillsides and mountains, and expansive coverage of ignitable vegetation. During the summer and autumn months, strong off-shore Santa Ana winds can create fast-moving fires that spread rapidly from the sparsely populated hillsides in the Irish Hills, Santa Lucia foothills, Cerro San Luis Obispo, Bishop Peak, and Islay Hill areas downslope toward neighborhoods in the city. Recent wildfires near the city include the 1994 Highway 41 Fire, 1996 Highway 58 Fire, and the 2015 Cuesta Fire (City of San Luis Obispo 2014; California Department of Forestry and Fire Protection 2015).

While a natural ecological process in coastal chaparral and forest systems, wildfire return intervals have decreased throughout California, resulting in more frequent ecological disturbance, loss of biodiversity, and colonization by non-native grass species (U.S. Forest Service 2018). Furthermore, post-fire conditions leave exposed mountain slopes and hillsides vulnerable to surface erosion and runoff. Debris flows during post-fire rainy seasons can pose a risk to life and property and occur with little warning. In California, as little as 0.3 inch of rain in 30 minutes can produce debris flows on post-fire landscapes (U.S. Geological Survey 2018).

In 2019, San Luis Obispo County published the Community Wildfire Protection Plan, which identifies opportunities for agency coordination and

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pre-fire planning and management strategies (San Luis Obispo County 2019).

The city, including the project site, is located in Planning Area SLO-1 of the Community Wildfire Protection Plan.

The project site is located in a local responsibility area, Moderate Fire Hazard Severity Zone, according to the most recent San Luis Obispo County Fire Hazard Severity Zones Map (California Department of Forestry and Fire Protection 2007, 2009). The nearest state responsibility area is located south of Los Osos Valley Road, approximately 0.8 mile south of the project site. The nearest Very High Fire Hazard Severity Zone is a state responsibility area near the Irish Hills Natural Reserve, approximately 1.0 mile south of the project site.

Environmental Consequences
a, b, c, d) The project site is not located in a state responsibility area or Very High Fire Hazard Severity Zone. The project site is developed with existing roadway infrastructure and agricultural land, with limited potential to spark a widespread wildfire. The project would deliver long-term benefits to circulation in the city by creating an additional freeway overcrossing, facilitating potential emergency evacuation.

Project construction may require temporary lane closures or detours, which would have the potential to impair emergency response or evacuation.

However, as noted in Section 2.1.17, Transportation, any such closures or detours would be temporary in nature and subject to a Caltrans Transportation Management Plan, which would include public information strategies such as notification to emergency services, including fire, law enforcement, and ambulance services, of start dates, work schedules, significant traffic pattern changes, transit routes, traffic collisions, and other incidents in the work zone. Such notification would reduce potential temporary impacts to wildfire emergency response or evacuation during project construction.

The project involves the construction of new roadway infrastructure and connectivity in a developed portion of the city, which would improve emergency access and would not exacerbate wildfire risks. The project does not involve the construction of habitable structures and is located on a relatively flat landscape. As such, the project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Impacts related to wildfire would be less than significant.

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2.1.21 Mandatory Findings of Significance
Question:

CEQA Significance Determinations
for Mandatory Findings of Significance
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially
reduce the number or restrict the range of a
rare or endangered plant or animal or
eliminate important examples of the major
periods of California history or prehistory?
Less Than Significant Impact with
Mitigation Incorporated
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects.)
Less Than Significant Impact with
Mitigation Incorporated
c) Does the project have environmental
effects which will cause substantial adverse
effects on human beings, either directly or
indirectly?
Less Than Significant Impact with
Mitigation Incorporated
Environmental Consequences
a) As discussed in this Initial Study, project development has the potential to degrade the quality of the environment in several issue areas without the incorporation of the identified mitigation measures. As discussed in the Biological Resources section, the project’s potential impacts to special-status plants and animals would be less than significant with the following Avoidance, Minimization, and/or Mitigation Measures discussed throughout this Initial Study:
 BIO-1 including, but not limited to, preconstruction surveys, specifications for work within/near the arroyo willow tree thicket, and specifications for revegetation;
 BIO-2 including preconstruction survey and limitations on access routes, staging, and construction areas;
 BIO-3 including, but not limited to, construction personnel training, fencing, waste control, seasonal work limitations, erosion and water pollution minimization, and sedimentation control;
 BIO-4 requiring nesting bird surveys, seasonal limitations for removal of vegetation within suitable nesting bird habitats, and nesting bird avoidance;

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 BIO-5 including measures for removal from and prevention of invasive plant species spread on the project site;
 BIO-6 including, but not limited to, spill prevention measures, hazardous materials contamination prevention measures,
sedimentation controls, fencing, and seasonal work avoidance; and  BIO-7 requires the preparation of a Habitat Mitigation and Monitoring Plan to provide for the restoration of permanent impacts to riparian habitats.

As discussed in the Cultural Resources section, the project’s potential impacts to historical or prehistoric resources would be less than significant with the following Avoidance, Minimization, and/or Mitigation Measures discussed throughout this Initial Study:
 CR-1 including the stop-work and assessment measures that would be required if previously unidentified archaeological resources are exposed during construction.

As discussed in the Geology and Soils section, the project’s potential impacts to paleontological resources would be less than significant with the following Avoidance, Minimization, and/or Mitigation Measures discussed throughout this Initial Study:
 GEO-1 requires evaluating any finds following the unanticipated discovery of paleontological resources during project construction.

With the implementation of required Avoidance, Minimization, and/or Mitigation Measures described herein, the project would not substantially degrade the quality of the environment, reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. b) Cumulative impacts are those that result from past, present, and reasonably foreseeable future actions, combined with the potential impacts of this proposed project. All environmental issues considered in this Initial Study have been found to result in no impact, a less than significant impact, or a less than significant impact with mitigation incorporated at the project level. A cumulative effect assessment looks at the collective impacts posed by individual land use plans and projects. Cumulative impacts can result from individually minor but collectively substantial impacts taking place over a period of time.

Cumulative impacts to resources in the project area may result from other infrastructure development in the project vicinity or from residential, commercial, industrial, or other land use development. These activities can degrade habitat and species diversity through consequences such as

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displacement and fragmentation of habitats and populations, alteration of hydrology, contamination, erosion, sedimentation, disruption of migration corridors, changes in water quality, and introduction or promotion of predators. They can also contribute to potential community impacts such as changes in community character, traffic patterns, housing availability, and employment.

CEQA Guidelines Section 15130 describes when a cumulative impact analysis is necessary and what elements are necessary for an adequate discussion of cumulative impacts. The definition of cumulative impacts under CEQA can be found in Section 15355 of the CEQA Guidelines. A definition of cumulative impacts under NEPA can be found in 40 Code of Federal Regulations Section 1508.7 of the Council on Environmental Quality Regulations.

Cumulative impacts of several resource areas have been addressed in the individual resource sections, including Air Quality, Greenhouse Gas Emissions, Noise, Transportation/Circulation, and Utilities and Service Systems. Other issues (e.g., Geology/Soils, Hazards and Hazardous Materials) are by their nature project-specific, and impacts at one location do not add to impacts at other locations or create additive impacts. Therefore, the impacts of the proposed project would be individually limited and not cumulatively considerable.

Although incremental changes in certain issue areas would occur as a result of the project, the proposed project would be consistent with existing general plan goals, programs, policies, and zoning ordinance requirements for the transportation improvements. All environmental impacts that could occur as a result of the project would be reduced to a less than significant level through compliance with existing regulations and applicable General Plan policies and Municipal Code requirements discussed in this Initial Study and implementation of the mitigation measures recommended in this Initial Study for the following resource areas: agriculture and forestry resources, air quality, biological resources, cultural and tribal cultural resources, geology and soils, and hazards and hazardous materials. Therefore, the project would have less than significant cumulative impacts with the implementation of the mitigation measures included in this Initial Study.
c) Effects on human beings are generally associated with impacts related to such issue areas as air quality, agriculture, geology and soils, hazards, hydrology and water quality, noise, and traffic safety. As discussed in the respective sections of this Initial Study, project implementation would result in potential environmental impacts to human beings in the areas of air quality and hazards. Avoidance, Minimization, and/or Mitigation Measures AG-1, AQ1, and HAZ-1 through HAZ-4 HAZ-3 would reduce project impacts as a result of effects on human beings to a less than significant level. Potential impacts to human beings in the areas of hydrology and water quality, geology and

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soils, noise, and traffic safety would be less than significant. With the implementation of identified mitigation measures, the project would not cause substantial adverse effects on human beings, either directly or indirectly.

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Appendix A Title VI Policy Statement

Appendix B Comment Letters and
Responses
This appendix contains the comments received during the public circulation and comment period from February 2, 2023 to March 6, 2023, retyped for readability. The comment letters are stated verbatim as submitted, with acronyms, abbreviations, and any original grammatical or typographical errors included. A response follows each comment presented. Copies of the original comment letters and documents can be found in Volume 2 of this document.

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Comment Letter 1 from Jennifer Best
Comment 1.1: This project is a LONG time coming, and very long overdue.

The development of housing and shopping centers along Madonna Road should not have been allowed without concurrent construction of this interchange.

Looking forward to bridge at Prado Road/Dalidio
That said, omitting on/offramps on southbound 101 is an oversight.

Please include on/offramps on the southbound side to alleviate traffic at LOVR. The northbound onramp onto 101 from LOVR regularly backs up through two traffic signals toward the Costco/Target shopping centers. The southbound offramp also regularly backs up clear to the traffic lanes of 101.

Developing an alternative at Prado Road would give motorists other options, reduce traffic at the impacted intersection, and help drive traffic to and from a struggling shopping center (see: recent closure of another big store - Bed Bath Beyond).

Response to Comment 1.1: The scope of the current Prado Interchange project does not include the southbound ramps. As part of the approval of the initial phase of project development, the Project Development Team – consisting of Caltrans, City and consultant staff – reviewed the results of the Traffic Operations Analysis Report and determined that the full interchange option (including the southbound on and off ramps) was not warranted within the project horizon (20 years) but may be considered as a future stand-alone project. Under the full interchange option scenario the ramps would be designed per Caltrans standards, which may require addition of an auxiliary lane or similar modification to improve merging to/from the Southbound U.S. 101 mainline. However, the full interchange option is not proposed with the current project, and according to the traffic analysis is not warranted within the project planning horizon. The proposed alternatives would be constructed to facilitate future construction of the southbound ramps at a later date when determined to be necessary.

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Comment Letter 2 from Kenneth Riding
Comment 2.1: I think that there should be both on/off access to and from the bridge to both directions of the freeway. This bridge/access will become a very important access for SLO. Look to the future!
Response to Comment 2.1: For a discussion of the rationale for not including the southbound on and off ramps in the Project Description and Project Alternatives evaluated in this Initial Study-Mitigated Negative Declaration, refer to Response to Comment 1.1.

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Comment Letter 3 from Linda Busek
Comment 3.1: I am wondering why this project is so behind schedule already? The Avila Ranch development is already well on its way to completion and those poor folks are now looking at massive traffic congestion for the next 7 years! Such poor planning! This should have begun 7 years ago concurrent with the approvals for the housing development. It also would have been cheaper if undertaken years ago. Shame!
Response to Comment 3.1: The City originally conceived constructing the interchange concurrent with the San Luis Ranch development west of U.S. 101. In June 2018 the City Council adopted an Amendment to the San Luis Ranch Project Final Environmental Impact Report separating the San Luis Ranch development project from the interchange in order to expedite the construction of housing, adopting Findings and a Statement of Overriding Considerations for temporary traffic impacts associated with the San Luis Ranch development. Since that time, changes in the scope of the U.S. 101/Prado Road Interchange Project and the COVID-19 pandemic have resulted in project delays.

Comment 3.2: Of the choices, my selection is: A4R because the loop back will provide more space for cars to form a line to access 101 without causing congestion on the feeder roads.

Response to Comment 3.2: Section 1.5 describes the selection of the preferred alternative. The Project Development Team has met to evaluate the costs, right-of-way needs, traffic impacts and benefits, stakeholder preferences, and other aspects of each alternative that has been under consideration.

Comment 3.3: However, it is cockamamie to not have a southern direction on/off ramp incorporated NOW! In seven years the lack of that will be another folly to contend with.

Response to Comment 3.3: For a discussion of the rationale for not including the southbound on and off ramps in the Project Description and Project Alternatives evaluated in this Initial Study-Mitigated Negative Declaration, refer to Response to Comment 1.1.

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Comment Letter 4 from Steven Hoyt, Ph.D.

Comment 4.1: I was reading a summary of the Meeting on the Proposed Prodo Road Overpass in San Luis Obispo. I have resided in San Luis Obispo for 35 years, and have been awaiting this project forever.

I live and work within 1 mile of Prado Road and certainly agree that this area of town desperately needs an overpass on the freeway and on and off ramps.

In addition to the San Luis Ranch development there is the Sara Meadows development and Toscano development which are just off Prado Road. All of these residents have been anxiously awaiting the overpass to access their homes – currently we have to get off at Madonna road when going South (already conjected) and drive from there to Prado Road. There are also Mobile home parks, Low income housing, the Social Services Building, DMV, Social Security that would make use of the exit.

I was horrified when I read the article to find out that there was talk about not having Southbound exits from 101, because Cal Trans did some study that said that it would not be used that much. First of all, how could they even do a study because all the residents and people that desperately need the southbound exit are now forced to get off elsewhere and are not counted. The fastest way to get from the rest of town and North County would be to get on 101 southbound and exit Prodo Road – What are they thinking.

Response to Comment 4.1: For a discussion of the rationale for not including the southbound on and off ramps in the Project Description and Project Alternatives evaluated in this Initial Study-Mitigated Negative Declaration, refer to Response to Comment 1.1.

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Comment Letter 5 from Dale Sutliff
Comment 5.1: I have reviewed the options and the EIR for the project.

I ask that my following comments be considered for the successful and most usable conditions of the interchange and nearby area.

1. I encourage that the Alternative A7 Concept (Figure 1-6) be used, with some variations.
a. re-route Elks Lane in the area behind the Sunset Drive In Theater.  this route would be the most direct and convenient way for drivers using Elks Lane.
 the entry to the Sunset Drive In is close to where the new route would connect with the existing Elks Lane, so a short connect could be used to access the theater. This would allow for the removal of a section of existing Elks Lane that connects with the RTA site.
 project development would need to assure that the Sunset Theater is not disrupted by any vehicle traffic, or lighting issue, from the new Elks Lane route, and assure that the Elks Lane route is not disrupted by lights and movie projection.
 this route behind the Sunset Drive In, connecting to Prado Road, would create fewer required turns and visibility matters on Elks Lane, and reduce any vehicle conflicts with Regional Transportation Area buses.

2. The roundabout at Prado Road and Elks Lane at the Homeless Services Center is a better location to assist local traffic, without it being part of the on and off ramp highway system adjacent to the highway.

3. I am concerned about the Hwy. 101 auxiliary lane and extension. The San Luis Creek area between Hwy. 101 and the Elks Lodge and its RV storage site is a narrow area. Some San Luis Creek overflow crossed the site during the January storm period. This area needs to be protected, and not additionally narrowed. I am a member of Elks, and I store my trailer at the RV site.

4. The city's widening of Prado Road and the the bridge at San Luis Creek is essential.

5. The protecting of bike and pedestrian lanes along Prado Road and across the overpass is essential. Also, the width of these lanes is increasingly important. I have been a bicycle rider in the San Luis Obispo area for over forty years. I now ride a trike. Trikes have been on the increase by many cyclists. Many cyclists also pull trailers with their bikes to haul materials.

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Therefore, bike lanes need to be a minimum of six feet wide for the convenience and safety of all users of the lanes.

I appreciate the work Cal Trans has been doing regarding this project. I am willing to meet with anyone regarding conditions and options if desired. I will copy this message to others of concern and interest.

Response to Comment 5.1: For a discussion of the alternative selection process, refer to Section 1.5 and Response to Comment 3.2. Potential project effects on San Luis Obispo Creek are discussed in Section 2.1.4, Biological Resources. Potential effects of the project related to drainage and flooding are discussed in Section 2.1.10, Hydrology and Water Quality. Although the project would add an auxiliary lane next to the west bank of San Luis Obispo Creek, the project would not narrow or otherwise modify the creek channel or the existing concrete slope protection along the western bank of the creek.

See Response to Comment 8.1 for detail on the minimum width of bicycle lanes.

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Comment Letter 6 from Jake Hudson
Comment 6.1: For sections 2.1.1 Aesthetics and 2.1.5 Cultural Resources I agree that the impacts on aesthetics and resources can be less than significant with mitigation incorporated. However, the significant number of columns necessary to pass flood waters is out of character with surrounding specific plans design guidelines and the drive-in historical/cultural character.

There is discussion regarding community design guidelines and architectural features being applied to the project, however there is no specific mitigation measures to ensure the columns have some aesthetic/architectural design feature that incorporates the architectural styles defined in the Margarita Area Specific Plan, San Luis Ranch Specific Plan, and the Historical character of the Drive-in. I recommend adding a mitigation measure that requires some aesthetic/architectural features to be applied to the Columns consistent with the surrounding specific plan design guidelines and historical character of the Drive-in, to be reviewed and approved by the City Architectural Review Commission and CalTrans.

Response to Comment 6.1: The renderings included in this Initial StudyMitigated Negative Declaration are conceptual for the purpose of the environmental analysis, and do not precisely depict the number or architectural style of columns that would be needed to support the bridge structures. As discussed in Section 2.1.1, Aesthetics, the construction of a new dominant infrastructural feature would affect existing views in the project vicinity. However, the project would not result in a significant adverse change in any area designated as having moderate or high scenic value under the city’s General Plan. Auxiliary structures, including structural columns, would be required to be designed and built consistent with the City of San Luis Obispo Community Design Guidelines and will be reviewed and approved by the City Architectural Review Commission. The design, placement, site features, and visual treatments would relate to building architecture and site topography. As a result, these elements are expected to be of the same quality in design and materials as surrounding infrastructure. In addition, aesthetic treatments within the State Right-of-Way would be required to be reviewed and approved by Caltrans. As a result, mitigation is not required to reduce a potential impact associated with aesthetic/architectural features.

During the design phase, the consultant structural designer will coordinate with the Caltrans Office of Structures Design, Caltrans Bridge Architecture, and Caltrans Landscape Architecture to determine the necessary number and spacing of columns for structural purposes, as well as any aesthetic treatment for the columns and bridge structures.

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Comment Letter 7 from Pat McClure
Comment 7.1: Leaving out southbound access to the 101 in the plan for the Prado overpass seems to overlook the new realities of the hundreds of homes about to be occupied on Dalidio and their owners' need to exit some other way than Madonna Road, which is already backed up to, and past, the next intersection on many busy days. Getting over to Prado will relieve some of the pressure (and take some off of the LOVR interchange), but having to get to the Madonna exit (or LOVR) to go south will be maddening for them and an ordeal for the rest of us.

It was exciting to hear that Dalidio would finally be developed, but to leave out the backside access that most of us hoped would be the result immensely frustrates our hopes for relief from traffic snarls and direct access to the shopping center from the highway. Surely the hotel and merchants in the center would have anticipated such a project would result in better flow to and from their businesses, and separating residential and commercial traffic somewhat might ease the irritation of dealing with the clash of local and highway speeds. Madonna and LOVR are already vexing.

How much room is there for changes in the plan? The fact that completion is already projected so far out (why so far?) seems to imply that the project is still in flux. Why not make it ideal in all directions now and avoid the inevitable disappointment in half measures?
Response to Comment 7.1: For a discussion of the rationale for not including the southbound on and off ramps in the Project Description and Project Alternatives evaluated in this Initial Study-Mitigated Negative Declaration, refer to Response to Comment 1.1.

For a discussion of delays to the originally envisioned project schedule for the U.S. 101/Prado Road Interchange Project, refer to Response to Comment

3.1.

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Comment Letter 8 from Mila Vujovich LaBarre
Comment 8.1: This letter is for the official comment period about the Prado Road interchange and overpass.

These matters are currently identified as “The Prado Road Bridge Widening Project” and “The Prado Road Interchange Project.”
I have sent under separate communication these same comments to Mayor Stewart and the City of San Luis Obispo Council members.

Although there have been a substantial amount of funds and time devoted to studying and designing the Prado Road overpass, there are numerous concerns that still need to be addressed.

As a citizen, I would like to have these concerns about The Prado Road Bridge Widening Project and the Prado Road Interchange Project addressed.

These comments are due to my past research on and communication about this endeavor with City staff and with Caltrans for over two decades.

If we, as a City, are going forward with the construction of a Prado Road Interchange and the Prado Road Bridge Widening project at this location, it is critical that a comprehensive Environmental Impact Report (EIR) of Prado Road be done from Broad Street to Madonna Road.

Prado Road as an East-West connector has been on the San Luis Obispo City Plan since 1960. There has never been a comprehensive Environmental Impact Report (EIR) of Prado Road analyzing the cumulative impacts, the cost, and the feasibility of it. Our City staff will say that Prado Road has been adequately “studied” over the years.

Now is the time for facts, figures, costs, and a timeline to be exposed for transparency so that the benefits or detriments of these projects will be revealed.

Most recently in the Land Use Circulation Element (LUCE) Plan, “Prado Road” is inked in as a “four-lane truck highway, complete with a turn lane, bike lanes, and sidewalks.”
During the LUCE process, I did attend a majority of the meetings. Many of the residential units approved via the LUCE Master Plan have been built, without the approved traffic infrastructure to support them.

Again, “Prado Road” is in the General Plan as a “four-lane truck highway” however, when portions of Prado Road have been built by developers, they have been allowed to build roads that are more narrow, as in the Serra Meadows home development on the East side of Highway 101. The other

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section of “Prado Road” on the west side of Highway 101 is now known as “Dalidio Drive.”
Currently, the construction of Prado Road is being “piecemealed” or “segmented” which, in my research, is not legal and is in violation of CEQA guidelines. Please feel free to correct me if I am wrong.

If one takes a tape measure and physically goes along the proposed course of Prado Road, one can see what my concerns are. “Prado Road” does not fit.

The basic math is as follows:

Four lanes for cars and trucks: 4 lanes x 12 feet 48 feet Turn lane: 12 feet 12 feet
Bike paths: 2 lanes x 6 feet 12 feet
Sidewalks: 2 sidewalks x 6 feet 12 feet
Total: 84 feet
A comprehensive Environmental Impact Report (EIR) involving all of the stakeholders including the residents of the developments should be conducted before one more hour is spent on the design of the interchange and overpass.

From the posted documents, it appears that Caltrans’ primary involvement is with the area that is on Highway 101. It is my opinion that both the NorthSouth impacts and the East-West impacts must be addressed together by Caltrans and the City of San Luis Obispo.

Also, I have long expressed my concerns about the proximity of the southbound exit for the Prado Road Interchange and the exit so close to the southbound onramp at Madonna Road. If one simply gets in their vehicle and accelerates at the location of the southbound onramp, one can see how cars and trucks trying to exit slightly south on Prado Road, in the proximity of that same location, will be extremely problematic.

Also, this “four-lane truck highway, with bike lanes and sidewalks” will detract from the access and usability of the Prado Road shelter – 40 Prado Road – as well as the newly constructed treatment facility.

Response to Comment 8.1: A combined Environmental Impact Report for the two proposed improvement projects along Prado Road between U.S. 101 to South Higuera Street (the U.S. 101/Prado Road Interchange Project and San Luis Obispo Creek Bridge Widening Project), was determined to be

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unnecessary after review by both City and Caltrans staff. The question of segmentation has been considered by Caltrans at the CEQA and NEPA level for the San Luis Obispo Creek Bridge Widening Project and U.S. 101/Prado Road Interchange Project. Upon review, it was determined that there was no nexus for federal or State agencies to request these projects be combined due to their distinct scopes, project goals, and independent utility (i.e., each project has a unique purpose and need and could function with or without the other project). The segment of Dalidio Drive north of Froom Ranch Way was already evaluated as part of the San Luis Ranch Environmental Impact Report. The ultimate extension of Prado Road east to Broad Street was contemplated when evaluating future traffic needs for the U.S. 101/Prado Road Interchange Project and San Luis Obispo Creek Bridge Widening Project, but is not proposed at this time and not evaluated in detail as part of the environmental review for the U.S. 101/Prado Road Interchange Project and San Luis Obispo Creek Bridge Widening Project, as those two projects have separate purpose and need and independent utility.

The City has evaluated the extension of Prado Road to Broad Street as part of the Land Use and Circulation Element (LUCE) of the General Plan and associated Environmental Impact Report, but does not currently have ownership of the required right-of-way, and as a result has no action plan or proposed timeframe to initiate detailed planning or design. As a result, the potential Prado Road extension to Broad Street remains in the concept phase. Therefore, the extension of Prado Road to Broad Street is not considered reasonably foreseeable, and is not included in the cumulative setting for this project. Until the City has a reasonable level of assurance the project will commence, and has an understanding of the timing for construction and implementation of the project, the project limits, and project features, staff cannot begin to pursue the technical studies needed to prepare a CEQA document. There is no timeline for the extension of Prado Road to Broad Street and City staff believe the project as described is reasonably scoped.

Prado Road between U.S. 101 and South Higuera Street is currently identified as a Parkway Arterial Road, featuring design speeds of approximately 45 miles per hour, two lanes of traffic in each direction as well as two-way-left-turn-lane/median. The road will require curb and gutter, as well as bike lanes and sidewalks. The segment of Prado Road between U.S. 101 and South Higuera Street and the segment of Dalidio north of U.S. 101 are already designated as truck routes. Per the General Plan Circulation Element, Prado Road between South Higuera Street and Broad Street would be a truck route as well and constructed to the same standards whenever the roadway extension project moves forward.

While this is an important road for regional and truck traffic, the City is committed to making Prado Road a multi-modal corridor, and has dedicated a significant portion of the bridge and roadway to cyclist and pedestrian

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facilities, which will be physically separated from vehicular traffic. There will also be landscaping along the roadways and a median to help calm traffic and ensure pedestrians and cyclists feel comfortable accessing the services located along the road.

Prado Road as it extends across U.S. 101 to the future Prado Road/Elks Lane Intersection (at the current 40 Prado driveway) will be 101.75’ wide, and divided as follows:
(5) 12’ wide vehicular lanes
(2) 5’ wide vehicular shoulders
(2) 6’ wide protected bike lanes
(2) 6’ wide separated sidewalks
(2) 2’ wide barriers between cyclists and vehicles
(2) 1.25’ wide bridge rails
Along Prado Road from the future Prado Road/Elks Lane Intersection to South Higuera Street, the section will change slightly to 91’:
(4) 11’ + (1) 10’ wide vehicular lanes
(2) 3.5’ wide landscaped buffers
(2) 6’ wide protected bike lanes
(2) 6’ wide separated sidewalks
(2) 2’ wide landscaped buffers at back of sidewalk
This will require widening Prado Road both north towards the existing buildings and south towards the Wastewater Treatment Plant. There will be sufficient right-of-way for both roadway sections.

The scope of the current Prado Interchange project does not include the southbound ramps. For a discussion of the rationale for not including the southbound on and off ramps in the Project Description and Project Alternatives evaluated in this Initial Study-Mitigated Negative Declaration, refer to Response to Comment 1.1.

Comment 8.2: Additionally, the proposed intersection of a future Prado Road at Broad Street has long been a concern of mine. Having a four-lane truck highway adjacent to the Damon-Garcia Sports Fields will create environmental hazards for sports enthusiasts and add an additional stop light at Prado Road along Broad Street.

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The late Mayor Dave Romero and I, as well as other concerned citizens including Eugene Jud and the late Jamie Lopes, long advocated for the fact that that the “extension of Prado Road” should go south to Santa Fe Road at a widened Tank Farm Road to protect the integrity of the Damon-Garcia Sports Fields and to benefit traffic circulation.

Also, the land that was designated for the "extension of Prado Road” adjacent to the playing fields was purchased with City money. The purchase contract and verbiage in City documents state that it was “$2 million for 24 acres to be used for recreation”. There has never been an EIR conducted for putting a road at that location. Ever. The land was purchased for recreation. The Army Corps of Engineers supported the construction of the Damon-Garcia Sports Fields for recreation - not the construction of the road - at that location due to that very fact.

Response to Comment 8.2: As discussed in Response to Comment 8.1, the future extension of Prado Road to Broad Street remains in the concept planning phase and is not part of the current project scope or San Luis Obispo Creek Bridge Widening Project scope. There is no advanced planning or design in progress for this project and it is not currently identified in the City’s current five-year Capital Improvement Program. Detailed planning, environmental review, design drawings, and updated cost estimates will be prepared for this project when it is prioritized at a future date in the City’s Capital Improvement Program work program.

Comment 8.3: My other concern as a citizen is the recent figures that show the citizens will bear any cost of this interchange. Originally, during City planning discussions for the last 20 years, City employees and developers have stated that the developers of Serra Meadows, Avila Ranch, Righetti Ranch, and San Luis Ranch homes would be contributing a substantial portion of the needed funds.

The most recent reports make it appear that the cost for this interchange and overpass will be passed on to the residents of San Luis Obispo.

Be logical. Please delay any additional approval of this project and demand that a comprehensive Environmental Impact Report of Prado Road from Madonna Road to Broad Street be executed.

Response to Comment 8.3: The City plans to assist with project funding through a combination of impact fees, debt financing, and the San Luis Obispo Council of Governments Regional Transportation Improvement Program. The Project Approval and Environmental Document, Preparation of Plans, Specifications, and Estimates, and Right-of-Way Support phases are programmed with 100% local funds. The construction phase has nearly $64 million currently programmed from a combination of Regional Transportation Improvement Program and local funding sources.

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The funding plan for the Prado Interchange was conceived in 2017 when project development began. The estimated project cost at that time was $26 million and the project envisioned cost sharing based on the proportions of traffic anticipated to use it. The San Luis Ranch development west of U.S. 101 is required as part of their Development Agreement to contribute 28% of the total construction costs. San Luis Obispo County and the San Luis Obispo Council of Governments have also committed approximately $7.4 million towards the project, and the City remains in negotiations with these agencies to maximize their contributions.

In addition, some portions of the City funding will also be generated through Traffic Impact Fees, which are paid by all new development in the City. The City is currently updating the Traffic Impact Fee program to reflect the current cost of construction.

The City has determined that this project is eligible for federal-aid funding. As a result, City staff are also pursuing State and federal grant funding opportunities to cover as much of the remaining project cost as possible.

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Comment Letter 9 from Ellen Morrison
Comment 9.1: I am writing to state my great concern about the current plans for the long-awaited overpass of Prado Road over Highway 101 in San Luis Obispo. My particular concern is the decision not to include a southbound entrance or exit. There are currently two large communities being constructed on either side of 101, Avila Ranch and San Luis Ranch. There is ample land on both sides of 101 for future development. The need for a southbound entrance and exit to the freeway will undeniably grow even before the overpass is completed and for years into the future.

Without a southbound exit, residents of those communities returning from San Luis Obispo's downtown area, Cal Poly, and all points north will have to choose between exiting at Madonna Road or Los Osos Valley Road. Both of those southbound exits are already impacted. During rush hour it is not uncommon for the southbound exit to Los Osos Valley Road to back up onto the freeway, resulting in traffic snarls and safety hazards. When the two communities are fully occupied, these conditions will worsen dramatically.

Without an option for a southbound entrance, residents of San Luis Ranch will once again be forced to use Madonna or Los Osos Valley, both of which are already impacted. The Los Osos Valley Road southbound entrance to 101 is already harrowing, given the short exit-only lane and the fact that the northbound entrance is so soon after the southbound entrance. Drivers planning to travel northbound on 101 or to turn right on Higuera a few blocks away are understandably frustrated to sit through two traffic light cycles, so often use the left lane, then dart into the right lane at the last minute, endangering themselves and all other drivers on the Los Osos Valley Road overpass.

The decision not to include southbound entrance and exit from Prado Road is astoundingly short-sighted. The possibility of adding these options in the future, you must know, is highly unlikely. The current and future members of our community residing in this section of San Luis Obispo deserve a complete solution.

Response to Comment 9.1: For a discussion of the rationale for not including the southbound on and off ramps in the Project Description and Project Alternatives evaluated in this Initial Study-Mitigated Negative Declaration, refer to Response to Comment 1.1.

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Comment Letter 10 from San Luis Obispo County Air Pollution Control District
Comment 10.1: Thank you for including the San Luis Obispo County Air Pollution Control District (APCD) in the environmental review process. We have completed our review of the Initial Study and Proposed Mitigated Negative Declaration for the Prado Road Interchange located at Highway 101 at Prado Road in San Luis Obispo (Proposed MND).

The City of San Luis Obispo proposes to extend Prado Road over U.S. 101 to connect Prado Road with Dalidio Drive and rebuild the existing U.S. 101 northbound on- and off-ramp connections to Prado Road. The interchange is in the City of San Luis Obispo at post mile 26.8 on U.S. 101. The project limits extend from post mile 26.5 to post mile 27.3. U.S. 101 through the study area is currently a four-lane divided freeway with auxiliary lanes provided between Madonna Road and Marsh Street.

The project is included in the 2020 State Transportation Improvement Program. Project construction is expected to start in 2026 and span approximately three years. The current programmed cost for construction is approximately $58,700,000.

The following comments are formatted into 3 sections. The (1) General Comments section states information pertinent to the applicant, lead agency, and/or public. The (2) Air Quality and (3) Greenhouse Gas Emissions sections may state mitigation measures and/or rules and requirements which the APCD recommends be set as conditions of approval for the project.

The applicant or agent should contact the APCD Engineering & Compliance Division about permitting requirements stated in the (1) General Comments section. The lead agency may contact the APCD Planning Division for questions and comments related to proposed conditions of approval in the (2) Air Quality and (3) Greenhouse Gas Emission sections. Both Divisions can be reached at 805-781-5912.
(1) General Comments
Section 2.1.3 (Air Quality) of the Proposed MND characterizes the APCD as having jurisdiction over the South Central Coast Air Basin. Please note that the South Central Coast Air Basin encompasses San Luis Obispo, Santa Barbara & Ventura counties, while the San Luis Obispo County APCD has jurisdiction only in San Luis Obispo County.

Construction Permit Requirements
Based on the information provided, we are unsure of the types of equipment that may be present during the project’s construction phase. Portable equipment, 50 horsepower (hp) or greater, used during construction activities

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may require a California statewide portable equipment registration (issued by the California Air Resources Board) or an APCD permit. The following list is provided as a guide to equipment and operations that may have permitting requirements but should not be viewed as exclusive:
 Power screens, conveyors, diesel engines, and/or crushers;  Portable generators and equipment with engines that are 50 hp or greater;
 Electrical generation plants or the use of standby generators;  Internal combustion engines;
 Rock and pavement crushing; and
 Portable plants (e.g. aggregate plant, asphalt batch plant, concrete batch plant, etc).

For a more detailed listing, refer to the Technical Appendices, page 4-4, in the APCD's CEQA Air Quality Handbook (April 2012).

Response to Comment 10.1: (1) General Comments
Caltrans acknowledges receipt of these comments on this Initial StudyMitigated Negative Declaration and the organization of comments into (1) General Comments, (2) Air Quality, and (3) Greenhouse Gas Emissions. For responses to (2) Air Quality refer to Response to Comment 10.2. For responses to (3) Greenhouse Gas Emissions refer to Response to Comment

10.3. Responses to (1) General Comments follow.

Caltrans acknowledges that the APCD Engineering and Compliance Division should be contacted about permitting requirements, and the APCD Planning Division should be contacted about conditions of approval.

Caltrans acknowledges that portable equipment 50 horsepower or greater used during construction activities may require a California statewide portable equipment registration or APCD permit. Consultants and contractors would be required to secure required permits for all construction equipment and activities pursuant to the proposed project.

Comment 10.2: (2) Air Quality

CONSTRUCTION PHASE
Construction Phase Impacts - Below Threshold(s)
The Project Proponent evaluated the construction impacts of this project using the most recent CalEEMod computer model. The modeling results indicate that the construction phase impacts will likely be less than the

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APCD’s significance threshold values identified in Table 2-1 of the CEQA Air Quality Handbook (April 2012).

To manage fugitive dust emissions, minimize toxic air pollution impacts from idling diesel engines, and address potential naturally occurring asbestos impacts the APCD recommends the following mitigation measures for this project.

Fugitive Dust Mitigation Measures
The Proposed MND includes Mitigation Measure AQ-1 to mitigate fugitive dust. The APCD recommends replacing the language in Mitigation Measure AQ-1 with the following updated list of mitigation measures to reduce fugitive dust, which could be a nuisance to residents and businesses in close proximity to the proposed construction site. Projects with grading areas more than 4 acres and/or within 1,000 feet of any sensitive receptor shall implement the following mitigation measures to manage fugitive dust emissions such that they do not exceed the APCD 20% opacity limit (APCD Rule 401) and minimize nuisance (APCD Rule 402) impacts:
a. Reduce the amount of the disturbed area where possible; b. Use of water trucks or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site and from exceeding the APCD’s limit of 20% opacity for greater than 3 minutes in any 60-minute period. Increased watering frequency would be required whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water should be used whenever possible.

When drought conditions exist and water use is a concern, the contractor or builder should consider use of a dust suppressant that is effective for the specific site conditions to reduce the amount of water used for dust control. Please refer to the following link from the San Joaquin Valley Air District for a list of potential dust suppressants: Products Available for Controlling Dust;
c. All stockpiled dirt should be sprayed daily and covered with tarps or other dust barriers as needed;
d. All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible, and building pads should be laid as soon as possible after grading unless seeding, soil binders or other dust controls are used; e. All trucks hauling dirt, sand, soil, or other loose materials are to be covered or should maintain at least two feet of freeboard (minimum vertical distance between top of load and top of trailer) or otherwise comply with California Vehicle Code (CVC) Section 23114; f. “Track-Out” is defined as sand or soil that adheres to and/or agglomerates on the exterior surfaces of motor vehicles and/or equipment (including

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tires) that may then fall onto any highway or street as described in CVC Section 23113 and California Water Code 13304. To prevent ‘track out’, designate access points and require all employees, subcontractors, and others to use them. Install and operate a ‘track-out prevention device’ where vehicles enter and exit unpaved roads onto paved streets. The ‘track-out prevention device’ can be any device or combination of devices that are effective at preventing track out, located at the point of intersection of an unpaved area and a paved road. Rumble strips or steel plate devices need periodic cleaning to be effective. If paved roadways accumulate tracked out soils, the track-out prevention device may need to be modified;
g. All fugitive dust mitigation measures shall be shown on grading and building plans;
h. The contractor or builder shall designate a person or persons whose responsibility is to ensure any fugitive dust emissions do not result in a nuisance and to enhance the implementation of the mitigation measures as necessary to minimize dust complaints and reduce visible emissions below the APCD’s limit of 20% opacity for greater than 3 minutes in any 60-minute period. Their duties shall include holidays and weekend periods when work may not be in progress (for example, wind-blown dust could be generated on an open dirt lot). The name and telephone number of such persons shall be provided to the APCD Compliance Division prior to the start of any grading, earthwork, or demolition (Contact the Compliance Division at 805-781-5912).
i. Permanent dust control measures identified in the approved project revegetation and landscape plans should be implemented as soon as possible, following completion of any soil disturbing activities; j. Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading should be sown with a fast germinating, non-invasive grass seed and watered until vegetation is established;
k. All disturbed soil areas not subject to revegetation should be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the APCD;
l. Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site;
m. Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers shall be used with reclaimed water where feasible. Roads shall be pre-wetted prior to sweeping when feasible; and

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n. Take additional measures as needed to ensure dust from the project site is not impacting areas outside the project boundary.

Limits of Idling During Construction Phase
State law prohibits idling diesel engines for more than 5 minutes. All projects with diesel-powered construction activity shall comply with Section 2485 of Title 13 of the California Code of Regulations and the 5-minute idling restriction identified in Section 2449(d)(2) of the California Air Resources Board’s In-Use Off-Road Diesel regulation to minimize toxic air pollution impacts from idling diesel engines. The specific requirements and exceptions for the on-road and off-road regulations can be reviewed at the following web sites: arb.ca.gov/sites/default/files/classic/msprog/truck-idling and arb.ca.gov/regact/2007/ordiesl07/frooal.pdf.

In addition, because this project is within 1,000 feet of sensitive receptors (existing residences), the project applicant shall comply with the following more restrictive requirements to minimize impacts to nearby sensitive receptors.

1. Staging and queuing areas shall not be located within 1,000 feet of sensitive receptors;

2. Diesel idling within 1,000 feet of sensitive receptors shall not be permitted;

3. Use of alternative fueled equipment is recommended; and

4. Signs that specify no idling areas must be posted and enforced at the site.

Naturally Occurring Asbestos on Site
Naturally occurring asbestos (NOA) has been identified by the California Air Resources Board as a toxic air contaminant. Serpentine and ultramafic rocks are very common throughout California and may contain NOA, which may be released when land is graded for building purposes, or at quarrying operations. The APCD has identified areas throughout the county where NOA may be present (NOA Map). Because the project site is in a candidate area for NOA, a geologic evaluation must be conducted by a registered geologist to determine if the area disturbed is or is not exempt from the CARB Asbestos Air Toxics Control Measure (NOA ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations (Title 17 CCR Section 93105) regulation. The geologic evaluation must be submitted to the APCD Engineering Division prior to any grading activities at the site, with the following documents:
 For grading projects qualifying for NOA ATCM exemption:

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o Submit a completed APCD NOA Exemption Form with the geologic evaluation.
 For grading projects in serpentine rock less than 1 acre:
o Submit a completed APCD Project Form with the geologic evaluation; and
o Mini Dust Control Measures (93105.e.(A-F) as a condition of approval.  For grading projects in serpentine rock greater than 1 acre:
o Submit a completed Project Form with the geologic evaluation; and o An Asbestos Dust Mitigation Plan as a condition of approval.

When submitting the Project or Exemption Form, please fill in all applicable contact information. More information on NOA can be found on the APCD website at slocleanair.org/rulesregulations/noa.php, on the California Geological Survey website at
https://www.conservation.ca.gov/cgs/minerals/hazardous_mi nerals/asbestos, or from CARB at
https://ww2.arb.ca.gov/sites/default/files/classic/toxics/asbestos/asbestos.htm .

Response to Comment 10.2: Caltrans acknowledges the APCD recommended mitigation measures to manage fugitive dust emissions, minimize toxic air pollution, and address potential naturally occurring asbestos impacts from the project. APCD’s recommendations do not identify new or substantially more severe impacts than identified in Section 2.1.3, Air Quality, of the Draft Initial Study-Mitigated Negative Declaration. Rather APCD’s recommendations note requirements and appropriate construction management practices for projects with grading areas more than 4 acres and/or located within 1,000 feet of sensitive receptors. The text of Mitigation Measure AQ-1 has been revised to use APCD’s updated list of mitigation measures to reduce fugitive dust and toxic air pollution for projects with grading areas more than 4 acres and/or within 1,000 feet of any sensitive receptor.

APCD notes that the project is in a candidate area for naturally occurring asbestos (NOA), and that a geologic evaluation must be prepared to determine if the area disturbed is or is not exempt from the CARB Asbestos Air Toxics Control Measure (NOA ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations (Title 17 CCR Section 93105) regulation. Grading and structural refinements during final design will include preparation of the required geologic evaluation, as well as identification of any required construction best management practices, to meet the requirements of the CARB NOA ATCM for Construction, Grading, Quarrying, and Surface Mining Operations. Compliance with these requirements will ensure the project would not result in any significant impacts associated with the potential to encounter NOA during construction.

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Comment 10.3:
(3) Greenhouse Gas Emissions
The City of San Luis Obispo Climate Action Plan serves as the city’s qualified greenhouse gas (GHG) reduction strategy and the Climate Action Plan Consistency Checklist was used to demonstrate project consistency and tier from the Climate Action Plan per CEQA Guidelines Section 15183.5. The Proposed MND includes project GHG emission calculations for informational purposes.

Response to Comment 10.3: Caltrans acknowledges that the Climate Action Plan Consistency Checklist was used to demonstrate project consistency and tier from the Climate Action Plan per CEQA Guidelines Section 15183.5.

Section Error! Reference source not found., Error! Reference source not found., describes the available pathways to determining a project’s consistency with the Climate Action Plan, described in Appendix C to the Climate Action Plan (Greenhouse Gas Emissions Thresholds and Quantification Consistency Review for New Development). A project is considered consistent with the city’s Climate Action Plan if it includes provisions to further the emissions reduction goals in the Plan. The proposed project would provide congestion relief, operational efficiency, and multimodal connectivity, which would result in a reduction in greenhouse gas emissions.

The project would not conflict with any of the foundational actions of the Climate Action Plan. Therefore, the project would be consistent with the Climate Action Plan.

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Comment Letter 11 from Paula H
Comment 11.1: First let me note that there was not sufficient notification of the availability of this document or of the public hearing. Did Caltrans only post the notice in the newspaper? No one reads the newspaper anymore.

Please join the 21st century and post notices where the people are. I receive between three and five e-mails per week from the City and yet there wasn’t a single mention of this project. Not even in the City Council meeting summaries that preceded and followed the public meeting. There was also no mention on Nextdoor, where the City often makes announcements. Please don’t assume the poor attendance at the public meeting is indicative of a lack of public interest in this project; I didn’t hear about it until the day after, on KSBY. Consequently, my comments are not as thorough as I would have liked.

Furthermore, thorough review of this project also requires review of the other documents, such as the San Luis Ranch Specific Plan and city land use planning documents that reference this location and its vicinity. Presumably there is an Environmental Impact Report that addresses the change in land use for this area that the Prado Road Interchange Initial Study is relying upon.

Please identify the relevant planning documents, both Caltrans and City, that relate to this location and the surrounding projects.

Response to Comment 11.1: Noticing for the Draft Initial Study-Mitigated Negative Declaration was posted on the City website, Caltrans website, and State Clearinghouse. The Notice of Intent was published in the New Times on February 2, 2023, at the start of the advertising period. A social media post for the public meeting was shared on the Caltrans Twitter profile and sent to local outlets. Flyers for the public meeting were mailed to property owners within a 0.5-mile radius of the project area.

The Draft Initial Study-Mitigated Negative Declaration references (Appendix C in the Final Initial Study-Mitigated Negative Declaration) include website addresses for the San Luis Ranch Specific Plan, Final Environmental Impact Report, and other City land use planning documents that are referenced in the Initial Study-Mitigated Negative Declaration.

Comment 11.2: The Proposed Mitigated Negative Declaration does not include all the mitigation required to support the statements made for no significant impacts as a result of the project.

Response to Comment 11.2: The commenter does not disclose which statements they believe should include additional mitigation to support the finding of no significant impact. Potentially significant impacts were identified in Section 2.1.1, Aesthetics; Section 2.1.2, Agriculture and Forest Resources; Section 2.1.3, Air Quality; Section 2.1.4, Biological Resources; Section 2.1.5, Cultural Resources; Section 2.1.7, Geology and Soils; and Section 2.1.9,

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Hazards and Hazardous Materials of the Draft Initial Study-Mitigated Negative Declaration. Appropriate mitigation measures were included in each pertinent section to ensure the impacts to each resource would be less than significant.

Comment 11.3: The Proposed MND fails to address cumulative impacts from this project along with past and future projects, which are likely significant.

Response to Comment 11.3: As discussed in in Section 2.1.21, Mandatory Findings of Significance, the cumulative analysis considers the potential impact of past, present, and reasonably foreseeable future actions, combined with the potential impacts of the proposed project. Although incremental changes in certain issue areas would occur as a result of the proposed project, the project would be consistent with existing general plan goals, programs, policies, and zoning ordinance requirements for the transportation improvements. Cumulative impacts of several resource areas have been addressed in the individual resource sections, including Section 2.1.3, Air Quality, Section 2.1.8, Greenhouse Gas Emissions, Section 2.1.13, Noise, Section 2.1.17, Transportation, and Section 2.1.19, Utilities and Service Systems. Other issues (e.g., Geology/Soils, Hazards and Hazardous Materials) are by their nature project-specific, and impacts at one location do not add to impacts at other locations or create additive impacts. Cumulative environmental impacts that could occur as a result of project implementation would be reduced to a less than significant level through compliance with existing regulations and applicable General Plan policies and Municipal Code, and through implementation of required mitigation. Therefore, the impacts of the project were found to be individually limited and not cumulatively considerable.

Comment 11.4: Who is the CEQA lead agency on this project? Caltrans is claiming it’s Caltrans, but the City of SLO issued the Notice of Intent. CEQA states that the lead agency is to issue the NOI.

Response to Comment 11.4: Caltrans is the CEQA lead agency. However, the City of San Luis Obispo was responsible for assisting Caltrans with public noticing tasks, including creation and mailing of noticing flyers. As described in detail in Response to Comment 11.1, the Notice of Intent was provided to the public, responsible agencies, trustee agencies, and the State Clearinghouse, consistent with CEQA Guidelines Section 15072.

Comment 11.5: Both the Proposed MND and the City’s Notice of Intent state, “the project would have no significantly adverse effect on …hazards and hazardous materials.” That doesn’t make sense. My concern isn’t with the project having an effect on hazardous materials. Will the hazardous materials have an effect on the public? In the same paragraph of the NOI, it states, “A petroleum pipeline from a Unocal site is present at the intersection of Elks Lane and Prado Road, and potential aerially deposited lead, pesticides and herbicides could result in hazards to the public or the environment during

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construction of the project.” In light of the recent train derailment and resultant public hazards in Ohio, attention to potential hazards is especially heightened and should not be discounted. The illogical statement indicates this is being prepared with boilerplate language and is not being fully considered. (The same illogical statements are made regarding noise.)
Response to Comment 11.5: Impacts related to hazardous materials are evaluated in Section 2.1.9, Hazards and Hazardous Materials. As discussed therein, the potential aerially deposited lead, pesticides, and herbicides, and the existing petroleum pipeline, could result in hazards to the public or to the environment. However, implementation of Mitigation Measure HAZ-1 will require a preconstruction investigation of surface soils be completed to identify the presence of aerially deposited lead, and a workplan will be developed detailing the management and disposal of any contaminated soils if aerially deposited lead is detected above acceptable levels. Similarly, implementation of Mitigation Measure HAZ-2 will require the testing of surface soils in the proposed right-of-way to determine the presence or absence of pesticides, herbicides, and arsenic, and a workplan will be developed detailing the proper removal, transportation, and disposal of any impacted soils, if detected. It is anticipated that the project will avoid the existing petroleum pipeline at the intersection of Elks Lane and Prado Road; Mitigation Measure HAZ-3 requires the pipeline be marked prior to construction and a contingency plan be developed in the event contaminated soil is discovered. The nearest rail line is approximately 1.6 miles from the project site, and an incident along the rail line would not impact the project location in terms of hazardous waste issues. With implementation of the required mitigation measures, hazards or hazardous materials associated with the project would not have a significantly adverse effect on the public or the environment.

Impacts related to noise are evaluated in Section 2.1.13, Noise, which concludes that potential noise impacts associated with the project would result in less than significant impacts. Also refer to Response to Comment

11.44 for a detailed response to specific comments related to construction noise effects.

Comment 11.6: The document states, “The purpose of the project is to improve overall circulation and accessibility in the project area for all transportation modes.” In that case, why does the NOI and Proposed MND state there will be no significant effect on transportation? Isn’t a significant effect on transportation the whole point of the project? Response to Comment 11.6: Pursuant to California Public Resources Code 21068, a “significant effect on the environment” means a substantial, or potentially substantial, adverse change in the environment. Therefore, a significant effect on transportation would mean a substantial adverse change on transportation. Transportation impacts are evaluated in Section 2.1.17,

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Transportation. As determined therein, the project would not have a significant effect on transportation because substantial adverse changes would not occur.

Comment 11.7: One of the project’s needs is “a need to provide better community connectivity between the existing and planned neighborhoods.” Yet there is no discussion in the document to support this. In fact, there is nothing about traffic circulation.

Response to Comment 11.7: As described in the CEQA Guidelines and in Public Resources Code 21099(b)(2), “automobile delay, as described solely by the level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment pursuant to this division, except in locations specifically identified in the guidelines, if any.” Rather, a project’s potential to conflict with a program, plan, ordinance or policy addressing the circulation system is considered an environmental impact, as described in Section 2.1.17, Transportation. As determined therein, the project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, and bicycle and pedestrian facilities, and no impact would occur.

For information related to the project’s potential to improve connectivity and circulation, refer to the Traffic Operations Analysis Report (May 2019).

Comment 11.8: There is no clear purpose or need explained for this project.

The need statement exactly repeats the purpose, and neither addresses traffic circulation. There is no explanation of how this project will “Improve Overall Operations of U.S. 101 and Adjacent Interchanges.” There is no explanation of how this project will “Improve Safety and Mobility for Bicyclists and Pedestrians”. There is no explanation of how this project will “Improve Transit Performance and Enhance Transit Opportunities.” These are buzz words used to improve chances for funding. No attempt has been made to explain why the city is pursuing this project. This is insulting to the public.

Response to Comment 11.8: The commenter’s statements regarding the purpose and need for the project do not pertain to the adequacy of the Draft Initial Study-Mitigated Negative Declaration or the CEQA process. As the comment is not related to the potential environmental effects of the project, no further response is required. For informational purposes, the Project Study Report-Project Development Support (April 2018) describes the purpose of the project as to improve overall circulation and accessibility in the project area for all transportation modes. The need for the project involves providing better community connectivity between the existing and planned neighborhoods east and west of the U.S. 101 freeway by improving current and future operations on U.S. 101 and nearby interchanges, improving safety and mobility for bicyclists and pedestrians, improving transit performance, and enhancing transit opportunities. These connectivity needs extend to all transportation modes, including bicyclists and pedestrians. As a result of

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these needs, the goals and objectives of the project include: 1) improve overall operations of U.S. 101 and adjacent interchanges; 2) improve mobility for bicyclists and pedestrians; 3) improve transit performance and enhance transit opportunities; and 4) achieve consistency with local, regional and state planning.

Comment 11.9: How is this project being funded? Why isn’t this addressed in the document?
Response to Comment 11.9: This comment does not pertain to the adequacy of the Draft Initial Study-Mitigated Negative Declaration or the CEQA process. As the comment is not related to the potential environmental effects of the project, no further response is required.

For informational purposes, refer to Response to Comment 8.3, which includes a discussion of the project’s anticipated funding sources.

Comment 11.10: What are “Caltrans’ level of service targets”? Per CEQA, level of service is not to be used as a parameter for evaluating need or project success when addressing congestion. Statements to this effect need to be removed from the analysis and supporting discussion. They should be provided only for reference.

Response to Comment 11.10: As described in the CEQA Guidelines and in Public Resources Code 21099, Level of Service is no longer considered an environmental impact under CEQA. For informational purposes pertaining to existing traffic conditions, Level of Service standards and targets are provided in Section 2.1.17, Transportation. The project’s Traffic Operations Analysis Report (May 2019) concluded that no study area intersections would exceed the target Level of Service without the project or with the construction of any of the project alternatives, and the project would not conflict with plans or policies related to Level of Service standards.

Comment 11.11: The document identifies a need “on U.S. 101 between the interchange with Los Osos Valley Road and the interchange with Marsh Street”, and yet then gives a vague reference to traffic studies on the congestion on “several intersections and freeway segments in the vicinity of the project site.” Which? How are these related to the expressed need? And how does the project address this need? It’s not explained.

Response to Comment 11.11: The commenter’s statements regarding the purpose and need for the project do not pertain to the adequacy of the Draft Initial Study-Mitigated Negative Declaration or the CEQA process. As described in Response to Comment 11.7, a project’s effect on circulation is no longer considered an environmental impact in the CEQA Guidelines and in Public Resources Code 21099(b)(2). As discussed in Response to Comment

11.10, Level of Service standards and targets are provided in Section 2.1.17,

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Transportation, for informational purposes pertaining to existing traffic conditions. As the comment is not related to the potential environmental effects of the project, no further response is required.

For informational purposes, the following intersections and freeway segments in the vicinity of the project site were studied in the project’s Traffic Operations Analysis Report (May 2019):
 Intersections:
o Los Osos Valley Road NB and SB ramps
o Prado Road NB ramp
o Madonna Road NB and SB ramps
 Freeway Segments:
o US 101 south of Los Osos Valley Road
o US 101 north of Los Osos Valley Road
o US 101 north of Prado Road
o US 101 north of Madonna Road
For information related to the project’s potential to improve connectivity and circulation, refer to the Traffic Operations Analysis Report and Intersection Control Evaluation.

Comment 11.12: The real intent of this project is “to extend Prado Road over U.S. 101 to provide connectivity from Madonna Road east to the planned Prado Road east extension to Broad Street as a main east/west connector.” Why is this buried under a heading about improving mobility for bicyclists and pedestrians? The planned bike paths (which aren’t mentioned in the project description) aren’t necessary unless the project is built. You’re trying to use circular logic to defend your project. If you don’t build the multi-lane overpass, you won’t need the bike lanes. You haven’t shown bike lanes are an existing need – it will be a need only if the project is built. You can’t argue for a project that way. You have not shown a need related to cyclists or pedestrians that this overpass would address. Where is the multimodal mobility support for this project?
Response to Comment 11.12: The commenter’s statements regarding the purpose and need for the project do not pertain to the adequacy of the Draft Initial Study-Mitigated Negative Declaration or the CEQA process. Refer to Response to Comment 11.8 for a discussion of the purpose and need for the project, referencing the Project Study Report-Project Development Support (April 2018).

Comment 11.13: “Class 1 bike paths and Class 2 bike lanes are proposed along Prado Road from the western boundary of the Margarita Area Specific

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Plan, continuing to the proposed Prado Road grade-separated crossing of U.S. 101, and then continuing on Dalidio Road to Laguna Lake Park.” This is a key feature of the proposal that needs to be up front in the project description, not buried under the need. You have not shown a need for this feature or local support.

Response to Comment 11.13: The project’s proposed bike lanes are described in the Draft Initial Study-Mitigated Negative Declaration under Section 1.4.1, Build Alternatives, Common Design Features of the Build Alternative. Specifically, all build alternatives would extend Prado Road (Dalidio Drive) west of U.S. 101 to the intersection with Froom Ranch Road/Dalidio Drive and would include a separate sidewalk/Class 4 bikeway.

The language quoted by the commenter is from Section 1.2.2, Need. This language refers to the Class 1 bike paths and Class 2 bike lanes envisioned in the Margarita Area Specific Plan, which are not included as part of the project’s proposed action. The 2021 Active Transportation Plan envisions the project area and vicinity being improved with Class 4 facilities. The cited text in Section 1.2.2, Need, was revised to clarify that the Class 1 bike paths and Class 2 bike lanes in the Margarita Area Specific Plan are envisioned, rather than proposed.

Comment 11.14: “Transit Authority is in the process of developing administrative and operations office space and maintenance and storage facilities.” How does moving the office space improve “Improve Transit Performance and Enhance Transit Opportunities”? How will connectivity be improved between the east and west sides of 101 as stated? Will there be added bus routes? Is there funding for that? These are a bunch of disconnected statements about the local transit authority with nothing to support them. You have not shown a need that this overpass would address.

Response to Comment 11.14: The language quoted by the commenter references the Transit Authority’s recent relocation to new administrative and operations office space, maintenance, and storage facilities located adjacent to the northwest corner of the existing northbound ramp intersection with Prado Road, Elks Lane, and U.S. 101. The Transit Authority’s relocation provided improved regional accessibility due to its proximity to U.S. 101. The proposed project would further facilitate accessibility by providing connectivity from the east side of U.S. 101 to the west side of the City of San Luis Obispo through a new grade-separated crossing of U.S. 101 where no connection between the east side and west side currently exists. The project does not propose changes to existing transit service. However, the grade-separated crossing of U.S. 101 and the proposed northbound ramps would improve accessibility from the east side of U.S. 101 to the west side of the City of San Luis Obispo and to U.S. 101 as described above, improving the local and regional connectivity for transit providers.

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Comment 11.15: Figure 1-2 is worthless. It doesn’t show the place names or use areas that were used to describe the project (so we can’t identify anything) and it doesn’t show a project area that would complete the stated intent. Further, it doesn’t actually show the project, only an outline.

Response to Comment 11.15: Figure 1-2 depicts the general location of the proposed project in its local context relative to the surrounding transportation facilities it would connect to, including U.S. 101, Prado Road, Madonna Road, South Higuera Street, and Elks Lane. The Project Site Boundary shown in Figure 1-2 is a maximal disturbance boundary that encompasses the combined area of direct physical impacts for all evaluated build alternatives.

The individual concepts for each build alternative are depicted in Figure 1-3 through Figure 1-6 and are described in detail in Section 1.4.1, Build Alternatives, Unique Features of the Build Alternatives.

Comment 11.16: This IS is outdated. “...San Luis Obispo Creek Bridge Widening Project, which has independent utility from the proposed project and is being reviewed by the City of San Luis Obispo as of spring 2022.” The public deserves better than material that hasn’t been updated in nearly a year. Did Jason Wilkinson read this before signing it, or does he just not care? Further indication that this document is being pushed through the system without actual analysis and consideration.

Response to Comment 11.16: The status of the San Luis Obispo Creek Bridge Widening Project was accurately described at the time that the Draft Initial Study-Mitigated Negative Declaration was released for public review.

The San Luis Obispo Creek Bridge Widening Project remains in the design phase and has independent utility from the proposed project (i.e., each project has a unique purpose and need and could function with or without the other project).

Comment 11.17: “...a new continuous northbound U.S. 101 auxiliary lane between the Prado Road northbound on-ramp and the Madonna Road northbound off-ramp.” This is widening 101 to three lanes in the northbound direction and is a MAJOR project feature that should have been identified up front in the Notice of Intent, the Proposed MND, and the initial project description. You’ve buried it in the hopes that no one will notice.

Response to Comment 11.17: The northbound U.S. 101 auxiliary lane between the Prado Road northbound on-ramp and the Madonna Road northbound off-ramp is described in the Draft Initial Study-Mitigated Negative Declaration under Section 1.4.1, Build Alternatives, Common Design Features of the Build Alternatives. The Notice of Intent provides a summary of the project description, and indicates where copies of the Draft Initial StudyMitigated Negative Declaration and the related technical studies are available for review, including a link to the Draft Initial Study-Mitigated Negative

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Declaration, which was posted on the City website, Caltrans website, and State Clearinghouse.

Comment 11.18: What is a “four-lane divided arterial section through and next to the interchange”? That sounds like Prado will be four lanes, which seems excessive and out of proportion for the neighborhood.

Response to Comment 11.18: The commenter’s statements regarding the proportionality of the project to the neighborhood do not pertain to the adequacy of the Draft Initial Study-Mitigated Negative Declaration or the CEQA process. For informational purposes, as shown in the Alternative Concept figures (Figures 1-3 through 1-6), the proposed project envisions Prado Road as a four-lane facility from the Froom Ranch Road/Dalidio Drive intersection to the west through to the Prado Road/ South Higuera Street intersection to the east. The proposed improvements to Prado Road are based on programmed transportation improvements identified in the City’s Circulation Element to improve mobility and circulation and relieve congestion with the project study area by 2035, which include:
 Dalidio Drive widened to 4 lanes between Madonna Road and Froom Ranch Way (completed in 2021);
 Prado Road widened to 4 lanes between U.S. 101 and South Higuera Street; and
 Prado Road extended to Broad Street.

Comment 11.19: “Improvements to reduce this encroachment include placing a portion of the U.S. 101 northbound off-ramp and northbound on-ramp and most of the Prado Road (Dalidio Drive) extension west of U.S. 101 to the intersection with the future Froom Ranch Road/Dalidio Drive intersection on structures raised above the floodplain.” This is so badly worded I can’t even figure out what it’s trying to describe. Try again.

Response to Comment 11.19: The language referenced by the commenter describes the manner in which the grade-separated crossing of U.S. 101 would be elevated on column structures to minimize encroachment into the existing floodplain.

Comment 11.20: “...which would result in the need for the city to relocate some or all operations from this facility to another location.” This, and the impact to the yard’s operations, are secondary impacts that you need to quantify in this document, for this project, and possibly include mitigation for before this document can be considered adequate.

Response to Comment 11.20: As described in Section 1.4.1, Build Alternatives, the potential effect of the project on the corporation yard’s operations would vary based on the area of take required for each project alternative (described under Unique Features of the Build Alternatives). The

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City is required to consider the potential costs and secondary effects of relocating corporation yard operations as part of the Project Development Team selection of the preferred alternative. However, no offsite relocation of corporation yard buildings is currently proposed as part of this action, and no location(s) for such a project has been identified. The City has previously evaluated potential locations for relocating corporation yard operations, but none of the previously evaluated locations remain feasible options. Therefore, attempting to evaluate the potential environmental effects of relocating corporation yard operations would be speculative at this time.

Development of any future physical facilities to support corporation yard operations would be subject to a separate City-led planning process and applicable environmental review requirements under CEQA at the time sufficient project details could be known, or appropriate assumptions made, to support the required environmental review. As part of this requirement, mitigation would be incorporated as necessary to reduce any potentially significant environmental impacts associated with relocating corporation yard operations.

Comment 11.21: “The project would require realigning Elks Lane east of U.S. 101.” It’s already east of 101– it makes no sense. Impacts from any realignment have to be described, quantified, and possibly mitigated before this document can be considered adequate.

Response to Comment 11.21: The cited text in Section 1.4.1, Build Alternatives, was revised to clarify that the project would require realigning Elks Lane, which is located east of U.S. 101. The proposed realignment of Elks Lane is described qualitatively and shown in the Alternative Concept figures (Figures 1-3 through 1-6). The potential environmental impacts of the proposed realignment of Elks Lane are discussed in the impact analysis throughout Chapter 2 of the Draft Initial Study-Mitigated Negative Declaration.

Comment 11.22: This project must consider, and this document must describe, cumulative impacts from the “project to widen Prado Road from the planned Elks Lane realignment connection with Prado Road east to the western limits of the San Luis Obispo Creek Bridge Widening Project.” Response to Comment 11.22: As described in detail in Response to Comment 11.3, the project-level and cumulative impacts of the project, including the proposed realignment of Elks Lane, are discussed under threshold (b) in Section 2.1.3, Air Quality, thresholds (a) and (b) in Section

2.1.8, Greenhouse Gas Emissions, and threshold (b) in Section 2.1.21, Mandatory Findings of Significance, of the Initial Study-Mitigated Negative Declaration.

Comment 11.23: Figure 1-3, how are we to distinguish “Elks Lane Realignment Option 2” or Option 1? All options are grey. Why does Prado

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westbound flare out and curve back in as it approaches the circle? This is a poor representation of the proposal.

Response to Comment 11.23: The realignment options for the proposed Elks Lane Realignment are identified with arrows pointing to each option on Figure 1-3. The “flare out and curve back” design of the approach to the roundabout is used to slow traffic speeds. As vehicles approach, they would travel more slowly to be ready to merge into the roundabout with other vehicles.

Comment 11.24: What is a “Type L-1 tight diamond configuration”? Response to Comment 11.24: A Type L-1 interchange is defined in the Caltrans Highway Design Manual as a “Compact Diamond Interchange.” This refers to an interchange where the physical, geometric, or right-of-way restrictions require the on- and off- ramps be placed close to the freeway alignment. This interchange designation is applicable for Alternatives A1R and A3, which are depicted in Figures 1-3 and 1-4.

Comment 11.25: In the first 3 alternative diagrams, there is a second intersection on Prado that is not identified and not described. What is happening there?
Response to Comment 11.25: The second intersection referred to in the comment is the proposed location of the entrance to the city-owned corporation yard and the proposed realignment of Elks Lane. The corporation yard entrance and Elks Lane are proposed to be relocated to accommodate the Prado Road Bridge over U.S. 101 and the increased distance needed for the bridge to connect to Prado Road at existing ground elevation.

Comment 11.26: What is a “Type L-6 configuration” and why is it meaningful information?
Response to Comment 11.26: A Type L-6 interchange is defined in the Caltrans Highway Design Manual as an “Interchange with Parallel Street Systems.” This refers to an interchange where the freeway ramps connect with two-way parallel streets. This interchange designation is applicable to Alternative A7, which would connect the northbound on- and off- ramps directly to Prado Road, and is depicted in Figure 1-6.

Comment 11.27: What is this remnant road piece that’s showing on 2 of the 4 alternatives?

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Response to Comment 11.27: The comment refers to Figures 1-3 and 1-4.

The “remnant road piece” referred to in the comment is the line denoting the right hand edge of the outermost travel lane of U.S. 101 northbound, which is depicted in the figure to indicate the connection point for the northbound ramp and auxiliary lane.

Comment 11.28: The No-Build scenario discussion states the obvious. It addresses only the build itself and not what affect the No-build will have on environmental and social resources. The No Build is a viable alternative and must be discussed with the same detail and depth of analysis as the built alternatives. This section is not adequate per CEQA.

Response to Comment 11.28: The Initial Study-Mitigated Negative Declaration includes the required analysis of potential environmental impacts of the proposed project. While an Environmental Impact Report requires an alternatives analysis and a discussion of the potential impacts of a no-build or no-project alternative, a Mitigated Negative Declaration does not require an alternatives analysis or a discussion of a no-build alternative. Per CEQA Guidelines, Section 15071, the required content for a Negative Declaration (including Mitigated Negative Declarations) is as follows:
a) A brief description of the project, including a commonly used name for the project, if any;
b) The location of the project, preferably shown on a map, and the name of the project proponent;
c) A proposed finding that the project will not have a significant effect on the environment;
d) An attached copy of the Initial Study documenting reasons to support the finding; and
e) Mitigation measures, if any, included in the project to avoid potentially significant effects.

As part of the project evaluation Caltrans also examines the potential environmental effects of alternatives being considered for the proposed project. As a result, the Draft Initial Study-Mitigated Negative Declaration explains why the project is being proposed, the alternatives being considered

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for the project, the existing environment that could be affected by the project, potential impacts of each of the alternatives, and proposed avoidance, minimization, and/or mitigation measures. Therefore, the Initial StudyMitigated Negative Declaration includes the required content listed in CEQA Guidelines, Section 15071. A detailed environmental analysis of the No-Build Alternative is not required for compliance with CEQA.

Comment 11.29: 1.5.3 simply states alternatives were eliminated but doesn’t state why. This is not adequate– it must explain the alternatives and why they were rejected. Furthermore, it appears the contents of Volume II is being incorporated by reference, as relevant information within it is not covered in this document, Volume I. Therefore, pre CEQA, Volume II must have been made available during the same public comment period and in the same locations at Volume I, including on-line, which it has not been. The public must have the same opportunity to review Volume II before closing the comment period.

Response to Comment 11.29: As discussed in Section 1.5, Alternatives Considered but Eliminated from Further Discussion, of the Draft Initial StudyMitigated Negative Declaration (Section 1.6 of this Final Initial Study-Mitigated Negative Declaration), the Project Study Report-Project Development Support evaluated (April 2018) project alternatives A2, A5, and A6 and included a detailed discussion on the reasons that alternatives were eliminated from further consideration. In addition, several alternatives were evaluated in the Project Approval and Environmental Document phase, including additional Build Alternatives—A1 and A4—and a side slope option for all Build Alternatives.

Section 1.5, Alternatives Considered but Eliminated from Further Discussion, included a summary of the alternatives considered but eliminated as part of the Project Study Report-Project Development Support and Project Approval and Environmental Document phases, and the reasons they were eliminated.

These alternatives considered were eliminated for the following reasons:
 Alternative A2 (Partial Cloverleaf Configuration): Alternative A2 was eliminated from further consideration due to the loss of a transportation asset (San Luis Obispo Regional Transit Authority’s new facility) in the northwest quadrant of the interchange and the less than standard weave length between Prado Road northbound on-ramp and Madonna Road northbound off-ramp.
 Alternative A5 (Single-Point Interchange): Only the northbound ramp configurations to and from Prado Road was determined to be viable for this project; therefore Alternative A5 was removed from further consideration because it could not be built as two separate projects.

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 Alternative A6 (Compact Diamond Configuration): Only the northbound ramps to and from Prado Road were determined to be viable; therefore, the southbound partial cloverleaf ramps were eliminated and only the northbound compact diamond ramps remained. This northbound ramp configuration was the same as provided with Alternative A3; therefore Alternative A6 was not longer applicable and was removed from further consideration.
 Alternative B (Prado Road Overcrossing Only): Alternative B would not meet the project’s purpose and need. Building the Prado Road Overcrossing over U.S. 101 was determined to be inconsistent with city planning, and removing the U.S. 101 northbound ramps from Prado Road was determined to negatively impact the overall operations at nearby interchanges north and south of the project site.  Alternatives A1 and A4 (Signalized Control at the U.S. 101 Northbound Ramp Intersection with Prado Road): Based on the conclusions of the final U.S. 101/Prado Road Interchange Traffic Operations Analysis Report and Intersection Control Evaluation, these alternatives were determined to not be viable due to higher mobility and environmental costs, higher life cycle costs, and a lower benefit to cost ratio and were therefore eliminated from further analysis.  Side Slope Option: Based on the findings of the Two-Dimensional Hydraulic Model Update Final Report, fill embankments were found to be hydrologically infeasible and were therefore eliminated from further analysis.

As specified on page 139 of the publicly available Draft Initial Study-Mitigated Negative Declaration (which was made available on-line during the public review period from February 2, 2023 through March 6, 2023 at https://dot.ca.gov/-/media/dot-media/district-5/documents/us101-prado-rd-intd-051h640-0123-a11y.pdf), the technical studies bound separately in Volume 2 were available to the public upon request. The following contact information was provided for the public to request any of the technical studies in Volume 2:

To obtain a copy of one or more of these technical studies/reports or the Initial Study, please send your request to: Dianna Beck Associate Environmental Planner, District 5 California Department of Transportation, CEQA Lead Agency 50 Higuera Street, San Luis Obispo, California 93401
Or send your request via email to: [email protected] Or call: 805- 459-9406

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In addition to being available from Caltrans upon request, these documents were made available on the City’s website at:
https://www.slocity.org/government/department-directory/communitydevelopment/documents-online/environmental-review-documents/-fsiteid-1/- folder-2306.

The link to the location of technical studies on the City’s website was included on the Notice of Intent circulated by the City.

Comment 11.30: Preparation of a NEPA categorical exclusion is not appropriate under 23 CFR 771.117(b). Encroachment into a floodplain and inclusion of minimization and avoidance measures indicates “unusual circumstances,” which precludes the use of a NEPA CE for this project. An environmental assessment, at minimum, must be prepared that includes a full discussion of impacts to the 100-year floodplain. Exactly which CE category was Caltrans intending to apply to this project?
Response to Comment 11.30: The NEPA evaluation being prepared by Caltrans is not required for documents prepared pursuant to CEQA. The project is anticipated to meet the categorical exclusion category specified in 23 Code of Federal Regulations Section 771.117(d)(13). The project overpass was designed to be supported on piers rather than fill embankments in order to minimize impacts to the 100-year floodplain. According to the 2- Dimensional Hydraulic Model Update (October 2019) prepared for the project, grading and structural refinements during final design would ensure that any floodplain water surface elevation and velocity changes are below the City’s Drainage Design Manual thresholds and meet the requirements of the Federal Emergency Management Agency. In addition, the categorical exclusion is supported by a Location Hydraulic Study, which demonstrates that any changes in floodplain elevation and velocity comply with Federal Emergency Management Agency requirements and would not pose a significant encroachment as defined by 23 Code of Federal Regulations 650.105. Because the floodplain encroachment would result in a minimal encroachment to floodplains, as demonstrated by the required Location Hydraulic Study, the location of the project within the 100-year floodplain does not preclude the use of a categorical exclusion.

Comment 11.31: Will the State Historic Preservation Officer be reviewing and approving the mitigation measures included in the project? It’s not listed in the approvals. While perhaps not approving the project as a whole, the project can’t be approved by either Caltrans or the City without approval of the mitigation measures by the SHPO.

Response to Comment 11.31: The State Historic Preservation Officer review and concurrence is not required for documents prepared pursuant to CEQA. Therefore, there is no requirement for the State Historic Preservation Officer to review the analysis or mitigation measures included in this Initial

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Study-Mitigated Negative Declaration. However, the Draft Initial StudyMitigated Negative Declaration was submitted to the State Clearinghouse, who submits the document to State Agencies during the public review period.

As part of the public review process, the State Clearinghouse provided the Draft Initial Study-Mitigated Negative Declaration to the Office of Historic Preservation, which is managed by the State Historic Preservation Officer, for review and comment. The Office of Historic Preservation and the State Historic Preservation Officer did not provide public comments on the Draft Initial Study-Mitigated Negative Declaration.

For informational purposes, the State Historic Preservation Officer is responsible for review pursuant to Section 106 of the National Historic Preservation Act which is applicable to environmental documents prepared pursuant to NEPA. The cultural studies for the proposed project were carried out in a manner consistent with Caltrans’ regulatory responsibilities under Section 106 of the National Historic Preservation Act (36 Code of Federal Regulations Part 800) and pursuant to the January 2014 First Amended Programmatic Agreement among the Federal Highway Administration, the Advisory Council on Historic Preservation, the California State Historic Preservation Officer, and the California Department of Transportation Regarding Compliance with Section 106 of the National Historic Preservation Act (Section 106 Preservation Act). The Section 106 Preservation Act requires that Caltrans submit determinations of National Register of Historic Places eligibility and supporting documentation to the State Historic Preservation Officer for comment in accordance with 36 Code of Federal Regulations Section 800.4(c)(2).

The Historic Property Survey Report, Historic Resources Evaluation Report, and Finding of No Adverse Effect (without Standard Conditions) were submitted to the State Historic Preservation Officer in January 2020. The State Historic Preservation Officer’s concurrence was received on April 6, 2020. No further State Historic Preservation Officer review is required.

Comment 11.32: The determinations that the project would have “less than significant” impacts on aesthetics, even with your plans for “plantings that offer a variety of colors, shapes, and species” is inappropriate. “The project is in an area of the City of San Luis Obispo that is largely built” is a false statement. The project is on the edge of the city, adjacent to designated open space. Furthermore, the project would forever block views of the distant hills, particularly impactful because it’s the gateway to the city. This is a significant adverse impact. The city “policies” are quaint but meaningless in this expansive freeway setting. Meanwhile, the project violates 9.2.1: “The city will preserve and improve views of important scenic resources from public places.”
Response to Comment 11.32: The commenter incorrectly states that the project site is on the edge of the city and adjacent to open space. The project

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location is shown in Figure 1-2. The project site is located in the southwestern portion of the city and is not located on the edge of the City limit or any other applicable City boundary. The area surrounding the project location is developed and includes commercial use northwest of the intersection of Prado Road and U.S. 101, commercial and residential uses northeast of said intersection, the city-owned corporation yard and Water Resource Recovery Facility southeast of the intersection, and the San Luis Ranch property west of U.S. 101. The San Luis Ranch property is currently in the initial phases of development, with approved commercial, residential, recreational, and agricultural land uses under the San Luis Ranch Specific Plan adopted by the City in 2017. 53 acres of agricultural land on the San Luis Ranch property, which is next to U.S. 101 and the western portion of the project site, are planned to remain in agricultural production.

As discussed in Section 2.1.1, Aesthetics, the project site is outside the cone of view for each of the City’s designated vistas. The site is approximately 1.5 miles from the vista point located at the southeastern edge of the Irish Hills Natural Reserve; however, views of the site from this point are partially obstructed by intervening vegetation and the existing Los Osos Valley Road/U.S. 101 interchange. Visual renderings of the project from the east, west, south, and north are shown in Figures 2-1 through 2-4. The project’s proposed overcrossing and additional traffic signal or roundabout would be of similar height and visual dominance as existing buildings, infrastructure, and urban vegetation in and around the project area. As shown in Figures 2-3 and 2-4, the proposed bridge structure would partially obscure views of the hillsides from U.S. 101. However, the project would result in moderate to moderate-to-low visual impacts along U.S. 101 because the proposed overcrossing would be of a similar scale as other overcrossing structures along U.S. 101, and viewers (motorists on U. S. 101) would pass the overcrossing at a high rate of speed, minimizing visual exposure to the structure. Therefore, the project would not have a substantial adverse effect on a scenic vista, including the Irish Hills Natural Reserve, and this impact would be less than significant.

Comment 11.33: Figure 2-2 is terrible. The perspective is way off – the road appears to be unrealistically steep and ends abruptly mid-air. It’s unclear what any of those components are. With the well-developed trees, it appears to show a time well into the future, which does not give us any idea what the project will look like for the first 10-20 years we have to live with it. Figure 2-1 also shows a skewed perspective, with the distant figures being much smaller than they would actually appear. It minimizes the impression of this overpass.

Response to Comment 11.33: The renderings included in the Draft Initial Study-Mitigated Negative Declaration are conceptual for the purpose of supporting the environmental analysis and do not depict final landscaping or design of the project. The renderings are provided to give the public and reviewing agencies a conceptual understanding of the general appearance,

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height, and scale of the proposed interchange. As specified in Mitigation Measures AES-1 through AES-3, the final landscaping will be determined during final project design. As specified in these required mitigation measures, a landscape plan will be developed by the City and approved by the Caltrans’ District Landscape Architect. Existing trees will be protected in place as feasible. Any trees that cannot be feasibly protected in place will be replaced with a minimum ratio of three new trees for each tree removed.

Comment 11.34: Figure 2-3: frankly, that’s a hideous monstrosity. THIS is what you want people to see as they enter the city? Blocking our beautiful vista of the local hillsides? And what is that giant tree canopy ghosted into the background? There won’t be any trees like that there at any time in the future, and the project will take out any that exist there now. Figure 2-4 is nearly as bad, and what a parting view for visitors who are leaving. It looks like something from a Texas oilfield.

Response to Comment 11.34: As discussed in Response to Comment

11.33, the renderings included in this Initial Study-Mitigated Negative Declaration are conceptual for the purpose of supporting the environmental analysis. As discussed in Response to Comment 6.1, and Section 2.1.1, Aesthetics, auxiliary structures would be required to be designed and built consistent with the City of San Luis Obispo Community Design Guidelines and will be reviewed and approved by the City Architectural Review Commission. As a result, these elements are expected to be of the same quality in design and materials as surrounding infrastructure. In addition, aesthetic treatments within the State Right-of-Way would be required to be reviewed and approved by Caltrans. During the design phase, the consultant structural designer will coordinate with the Caltrans Office of Structures Design, Caltrans Bridge Architecture, and Caltrans Landscape Architecture to determine any required aesthetic treatment for bridge structures. Refer to Response to Comment 11.33 for a discussion of the proposed landscaping.

As discussed in Response to Comment 11.32, the proposed overcrossing and additional traffic signal or roundabout would be of similar dominance as the buildings, infrastructure, and urban vegetation in and around the project area. Refer to Response to Comment 11.35 for a discussion of the height of proposed project structures in comparison to existing land uses in the project vicinity.

Comment 11.35: Aesthetics, question a): you’ve addressed only the city’s designated vistas. That’s not what the question is asking about. You have not addressed the question. “The project’s proposed overcrossing and additional traffic signal or roundabout would be of similar dominance as the buildings, infrastructure, and urban vegetation in and around the project area.” This is a FALSE statement.

Response to Comment 11.35: Section 2.1.1, Aesthetics, identifies the project’s location approximately 1.5 miles from the nearest city-designated

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vista point at the southeastern edge of the Irish Hills Natural Reserve, including that views of the site from this point are partially obstructed by intervening vegetation and the existing Los Osos Valley Road/U.S. 101 interchange. Section 2.1.1, Aesthetics, also notes that the project site is not visible from a designated state scenic highway, and acknowledges that the project would change views from Prado Road and U.S. 101, which are designated under the city’s General Plan Circulation Element as having moderate and high scenic value, respectively. The analysis discuss the visual dominance of the proposed overcrossing and additional traffic signal or roundabout as compared to the buildings, infrastructure, and urban vegetation in and around the project area. The tallest proposed structure would be the proposed bridges, with the top of the bridge railing being approximately 28 feet above ground level. The existing buildings surrounding the proposed interchange include 40 Prado Road, which is 29 feet tall, the San Luis Obispo Regional Transit Authority, which is 23 feet tall, the city-owned corporation yard, which includes structures up to 30.5 feet tall, and the Water Resource and Recovery Facility, which includes structures up to 35 feet tall. Visual renderings of the project from the east, west, south, and north (Figures 2-1 through 2-4) show that the project would include similar visual elements – including infrastructure and urban vegetation – as the existing visual environment in the project vicinity.

Based on this information, the analysis concludes that the project would result in a moderate-to-low resource change for viewers along Prado Road because it would generally be consistent with the scale of urban vegetation and agricultural land that contribute to the visual character. Similarly, the project would result in moderate to moderate-to-low visual impacts along U.S. 101 because the proposed overcrossing would be of a similar scale as other overcrossing structures along U.S. 101, and viewers would pass the overcrossing at a high rate of speed, minimizing exposure to the structure.

The project would have a moderate-to-high level of resource change in areas along Dalidio Drive due to the construction of a new dominant infrastructural feature in a primarily agricultural location. However, Dalidio Drive is not designated as having moderate or high scenic value under the city’s General Plan.

Comment 11.36: Aesthetics, question c): explaining your determination by discussing city plans for commercial development is avoiding the question.

Furthermore, stating that “The project would not involve construction in visually prominent locations” and would not “substantially degrade the visual character of the site or its surroundings” is FALSE. Stating that the project would “generally be consistent with the scale of urban vegetation and agricultural land that contribute to the visual character” is FALSE. Stating that “viewers would pass the overcrossing at a high rate of speed, minimizing exposure to the structure” is FALSE. (Drivers can see these structures long before they arrive, and this is the city gateway.)

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Response to Comment 11.36: Section 2.1.1, Aesthetics, accurately discusses the proposed overcrossing and additional traffic signal or roundabout as compared to the visual character and quality of public views of the site and its surroundings. The project site is located in a developed area of San Luis Obispo. Specifically, the area surrounding the project is developed and includes commercial use northwest of the intersection of Prado Road and U.S. 101, commercial and residential uses northeast of said intersection, the city-owned corporation yard and Water Resource Recovery Facility southeast of the intersection, and the San Luis Ranch property west of U.S. 101. The San Luis Ranch property is currently in the initial phases of development, with approved commercial, residential, recreational, and agricultural land uses under the San Luis Ranch Specific Plan adopted by the City in 2017.

As discussed in Response to Comment 11.32, the project site is not located on the edge of the City limit or any other applicable City boundary. The project site is also relatively flat. Therefore, Section 2.1.1, Aesthetics, accurately states that the project would not involve construction in visually prominent locations, such as ridgelines, hillslopes, or visual gateways to the City. Refer to Response to Comment 11.36 for a discussion of the project’s consistency with the scale of the surrounding development. The speed limit on U.S. 101 is 65 mph; therefore, Section 2.1.1, Aesthetics, accurately states that drivers would pass the overcrossing at a high rate of speed, minimizing exposure to the proposed bridge structures.

Comment 11.37: The renderings do not show any retaining walls and they are not described other than in passing. Retaining walls are cold, urbanizing structures and will degrade the visual quality.

Response to Comment 11.37: The project design does not include any retaining walls. Therefore, it is appropriate for retaining walls to not be depicted in the visual renderings. The text of Section 2.1.1, Aesthetics, has been revised to clarify that retaining walls are not proposed as part of the project design.

Comment 11.38: There is no mitigation included to address all the hardscape, the structure itself, any fencing, walls, supports, etc. You have determined that you can build this huge, elevated structure with all its urbanizing components on the edge of the city, next to open space, and that the visual impact will be “low to moderate”. This is an improper and unrealistic determination.

Response to Comment 11.38: As discussed in Response to Comment

11.31, the project site is not located on the edge of the city or located next to open space. As discussed in Response to Comment 11.35, the proposed overcrossing and additional traffic signal or roundabout would be of similar dominance as the buildings, infrastructure, and urban vegetation in and

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around the project area. The proposed bridge structures will be similar in size and scale to the other bridge structures along the U.S. 101 corridor through San Luis Obispo, such as the overcrossings at Los Osos Valley Road and Madonna Road. As discussed in Response to Comment 6.1, and Section

2.1.1, Aesthetics, auxiliary structures would be required to be designed and built consistent with the City of San Luis Obispo Community Design Guidelines and will be reviewed and approved by the City Architectural Review Commission. Concrete barriers would be consistent with the Aesthetic Barrier Design guidance and the California Highway Barrier Aesthetics Report (Caltrans 2002). As a result, these elements are expected to be of the same quality in design and materials as the surrounding infrastructure. In addition, aesthetic treatments within the State Right-of-Way would be required to be reviewed and approved by Caltrans. During the design phase, the consultant structural designer will coordinate with the Caltrans Office of Structures Design, Caltrans Bridge Architecture, and Caltrans Landscape Architecture to determine any required aesthetic treatment for bridge structures.

Comment 11.39: What was the Department of Conservation’s assessment results for the reduction in agricultural land?
Response to Comment 11.39: A formal Department of Conservation assessment was not required for the project. The Preliminary Environmental Analysis Report (January 2018) identified no farmlands in the project area beyond those already evaluated and mitigated for in the San Luis Ranch Project Final Environmental Impact Report. Due to the proximity of agricultural land to the project, a Form AD-1006 (Farmland Conversion Impact Rating analysis) prepared in coordination with the Natural Resource Conservation Service (NRCS) was identified as the appropriate evaluation of agricultural resources.

The project’s potential effects on agricultural lands, and specifically the findings of the Farmland Conversion Impact Rating analysis (September 2021), are described in Section 2.1.2, Agriculture and Forest Resources. The Draft Initial Study-Mitigated Negative Declaration concludes that the Prado Road extension portion of this project would be required to comply with Mitigation Measure AG-1 from the San Luis Ranch Project Final Environmental Impact Report, which requires 1 acre of agricultural land of comparable productivity to be preserved in perpetuity for every acre of Important Farmland on the San Luis Ranch property that would be permanently converted to nonagricultural use (City of San Luis Obispo 2017b). Additionally, this Draft Initial Study-Mitigated Negative Declaration includes similar language for impacts to farmland as a result of the Elks Lane realignment in Mitigation Measure AG-1.

The Department of Conservation did not provide comments on the Draft Initial Study-Mitigated Negative Declaration. As described in detail in Response to

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Comment 11.1, the Notice of Intent was provided to the public, responsible agencies, trustee agencies, and the State Clearinghouse, consistent with CEQA Guidelines, Section 15072.

Comment 11.40: “Native American outreach conducted for this project and nearby projects indicated that the general project vicinity is sensitive for archaeological resources. Sixteen previously recorded cultural resources were identified within a 1-mile radius of the Area of Potential Effect…. [D]ue to the known sensitivity of the project area, there is potential for grounddisturbing activities in and in the vicinity of the Area of Potential Effect to uncover previously undiscovered human remains.” This would constitute “unusual circumstances” under 23 CFR 771.117(b), precluding preparation of a NEPA categorical exclusion, therefore an environmental assessment must be prepared.

Response to Comment 11.40: As discussed in Section 2.1.5, Cultural Resources, no archaeological resources were identified within or next to the Area of Potential Effect. As with all ground disturbance, there is a potential for previously unknown archaeological resources or human remains to be encountered during project construction. This is not an unusual circumstance as this is typical for any project that requires ground disturbance or excavation.

Comment 11.41: “The project would result in an overall increase in impervious surface of up to 2 acres on the project site.” How much of this is within the 100-year floodplain?
Response to Comment 11.41: As stated in Section 2.1.10, Hydrology and Water Quality, the floodplains within the project site are depicted in the Water Quality Assessment Report prepared for the project. As shown in Figure 3-4 of the Water Quality Assessment Report, the majority of the project site is located within the 100-year floodplain, with a portion of the western, southern, and eastern portion of the site within the 500-year floodplain. Based on the location of the floodplains within the project site, a majority (approximately 80 percent) of the increase in impervious surface area would be within a 100- year floodplain. The project will be designed such that water that falls on impervious surfaces will drain via pipes or ditches to natural outlets into the surrounding area, which would not exacerbate existing flood risks. The description of the floodplains in the project site has been revised in Section

2.1.10, Hydrology and Water Quality, to clarify the consistency with the floodplains depicted in Figure 3-4 of the Water Quality Assessment Report.

Comment 11.42: Considering the rains received this year and the unexpected extensive and expensive flood damage within the city, the discussion on flood prevention should be expanded. Indications are that the city’s “flood damage prevention regulations” are no longer adequate in this time of extreme climate events and simply stating that adherence to them

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“would ensure that the proposed new roadway facilities would not substantially impede flood flows or otherwise result in adverse effects associated with the 100-year and 500-year floodplains that extend onto the project site” is not adequate insurance. Again, these are “unusual circumstances” under 23 CFR 771.117(b) and a NEPA CE is not appropriate.

Response to Comment 11.42: City hydrologic models for precipitation and flood modeling follow the Federal Emergency Management Agency (FEMA) standard. The recent 25-year storm event confirmed the City’s models to be accurate. Refer to response to comment 11.30 for a discussion of potential floodplain impacts and the appropriateness of a NEPA categorical exclusion.

Comment 11.43: Referring to the potential (and likely) relocation of the corporation yard, it is not sufficient under CEQA to defer the analysis of this component of the Prado Road Interchange project. “Any subsequent relocation or alteration of these facilities would be subject to applicable environmental review requirements under CEQA, with mitigation incorporated as necessary to reduce any potentially significant environmental impacts”; this is deferring the study and possible required mitigation, which is unlawful. It is a known impact and must be addressed with this project.

Response to Comment 11.43: Refer to Response to Comment 11.20 for a discussion of the potential effects of the project on the city-owned corporation yard’s operations and the manner in which future physical facilities to support corporation yard operations would be subject to a separate planning process and applicable environmental review requirements.

Comment 11.44: “[C]onstruction noise shall not exceed 86 A-weighted decibels Lmax at 50 feet from the job site activities from 9:00 p.m. to 6:00 a.m.” What is A-weighted decibels Lmax in plain language? How will that be monitored and regulated during construction? What happens if it’s exceeded? Response to Comment 11.44: A-weighted decibels are defined in Section

2.1.13, Noise: “The A-weighting scale is an adjustment to the actual sound pressure levels so they are consistent with the human hearing response.” The identified noise level of 86 A-weighted decibels Lmax at 50 feet from the project site is used as a threshold of significance for the purpose of the noise analysis, and noise analysis indicates that this level is not reasonably anticipated to be exceeded at nearby noise receptors. Specifically, as discussed in Section 2.1.13, Noise, construction noise levels were determined to potentially reach up to 77 dBA Leq at the Prado Day Center; 72 dBA Leq at the Mobile Home Park on Elks Lane; and 67 dBA Leq at the Embassy Suites Hotel. Therefore, the impact is classified as less than significant and no mitigation is required.

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Comment 11.45: “[N]oise intrusive to interior habitable space of residential units from exterior sources should not exceed 45 CNEL. The General Plan Noise Element restricts noise in outdoor living areas due to transportation noise sources to 60 CNEL.” What is CNEL? How will these levels be monitored and regulated? What happens if they’re exceeded? Response to Comment 11.45: Community Noise Equivalent Level (CNEL) is a weighted average of noise level over time and a description is provided in the Affected Environment of Section 2.1.13 Noise. CNEL noise levels are not used as a threshold of significance in the Draft Initial Study-Mitigated Negative Declaration. CNEL noise levels are described in the discussion of City of San Luis Obispo General Plan and State of California Noise Standards for informational purposes. The description of the City of San Luis Obispo General Plan and State of California Noise Standards has been revised in Section 2.1.13, Noise, to include a definition of the term CNEL.

Comment 11.46: What are the “levels specified in Table 4.10-3”? How will they be monitored and regulated? What happens if they’re exceeded? Response to Comment 11.46: The language referenced by the commenter is originally from the City Noise Element, and refers to Table 1 in the Noise Element, Maximum Noise Exposure for Noise-Sensitive Uses Due to Transportation Noise Sources. The description of the City General Plan Noise Standards has been revised in Section 2.1.13, Noise, to remove the description of Policy 1.4. Policy 1.4 does not apply to modification of existing transportation noise sources, and the noise exposure levels in Table 1 of the Noise Element are not used as thresholds of significance in the Draft Initial Study-Mitigated Negative Declaration. As described in Section 2.1.13, Noise, traffic noise impacts occur when the predicted noise level approaches or exceeds the land-use-specific Noise Abatement Criteria specified in 23 Code of Federal Regulations 772 or a predicted noise level substantially exceeds the existing noise level (a “substantial” noise increase).

Section 2.1.13, Noise, evaluates the project’s potential to result in a substantial noise increase (defined as in Caltrans’ Traffic Noise Analysis Protocol [April 2020] as an increase of 12 A-weighted decibels from the existing noise level) or exceedance of Caltrans’ Noise Abatement Criteria. As described in the Traffic Noise Analysis Protocol, a 3 A-weighted decibels difference is generally the point at which the human ear will perceive a difference in noise level. Because this impact would not exceed the applicable threshold of significance, no mitigation, such as noise monitoring, is required.

Comment 11.47: Will there be any night construction? Have noise calculations been done to see if night levels will be exceeded? Response to Comment 11.47: Nighttime construction may be required and would be subject to applicable Caltrans and City requirements and limitations.

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During the Plans, Specifications, and Estimates Phase, Caltrans will evaluate the construction means and methods to determine if nighttime work is necessary and what activities would be needed. If necessary, a nonstandard special provision will be developed, reviewed, and approved by Caltrans Headquarters that would require the contractor to develop and implement a Noise Control Plan to ensure the 86 A-weighted decibels threshold is adhered to in Caltrans Standard Specification Section 14-8.02 “Noise Control”. The Noise Control Plan will be developed by a qualified individual and reviewed by Caltrans environmental engineering staff for approval. As described in Section 2.1.13, Noise, Caltrans Standard Specifications Section 14-8.02, “Noise Control” state that construction noise “shall not exceed 86 A-weighted decibels Lmax at 50 feet from the job site activities from 9:00 p.m. to 6:00 a.m.” The City Planning Department may issue a night work permit if night or weekend hours are required by the City Transportation Division. The Permit conditions would require the Transportation Division to identify why the night work is required, and any specific conditions and notification requirements that will apply. Refer to Response to Comment 11.44 for a discussion of anticipated construction noise levels in comparison to this requirement.

Comment 11.48: There is no information on how traffic was incorporated into the predicted noise and vibration levels (with or without the project). Where did that factor into the results? What percentage of trucks are anticipated, and how was that number generated? It also seems like levels for both day and night should be calculated. Based on the opening statement, “Considering the information in the U.S. 101/Prado Road Interchange Improvement Project Noise Study Report,” it’s evident the IS is incorporating that document by reference, however the Noise Report was not made available to review during the period and locations that the IS was available. This violated the requirements for CEQA public review.

Response to Comment 11.48: The details and assumptions of the traffic analysis and noise analysis are included in the Traffic Operations Analysis Report and Noise Study Report. As discussed in Response to Comment

11.29, the technical studies are available on the City’s website, or from Caltrans upon request.

Comment 11.49: Under 2.1.14, this document is making determinations of significance based on the determinations in the San Luis Ranch Specific Plan without explaining them. That is not adequate analysis or discussion. The Prado Road Interchange project is contributing to the growth of the city by a predicted 2.8 percent with no explanation on why that has been determined to be less than significant. Furthermore, the document has failed to discuss cumulative growth impacts from the other development projects within the city.

Response to Comment 11.49: The commenter refers to the Affected Environment discussion in Section 2.1.14, Population and Housing, which

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summarizes the population growth and conclusions of the San Luis Ranch Project Final Environmental Impact Report, certified by the City of San Luis Obispo in 2017. Section 2.1.14, Population and Housing, provides a projectlevel analysis of the U.S. 101/Prado Road Interchange Project’s impacts, concluding that the project does not include any housing or business development and would not directly induce population growth in the city.

While the project would indirectly facilitate population growth by facilitating the development of the San Luis Ranch Specific Plan Area, the growth associated with the San Luis Ranch Specific Plan Area was evaluated in the San Luis Ranch Project Final Environmental Impact Report and found to be consistent with the City’s General Plan projections. As described in detail in Response to Comment 11.3, the project-level and cumulative impacts of the project are discussed in Section 2.1.21, Mandatory Findings of Significance.

Comment 11.50: “The project would facilitate the development of the San Luis Ranch Specific Plan Area.” Therefore, you cannot make the statement that the project “would not directly induce population growth in the city.” It facilitates the development of housing, therefore it facilitates the development of population growth. Any statement to the contrary is FALSE. If there’s no place to live, people will not move here. Also, just because the project is consistent with the city’s General Plan projections doesn’t mean the impacts will be less than significant. This is a false assumption. This needs explanation.

Response to Comment 11.50: As discussed in Response to Comment

11.49, the growth associated with the San Luis Ranch Specific Plan was evaluated in the San Luis Ranch Project Final Environmental Impact Report, certified by the City of San Luis Obispo in 2017, and found to be consistent with the City’s General Plan projections. The U.S. 101/Prado Road Interchange Project is referenced in the San Luis Ranch Specific Plan Environmental Impact Report as mitigation required to support the San Luis Ranch Specific Plan. Therefore, Section 2.1.14, Population and Housing, appropriately concludes that, while the project would facilitate the development of the San Luis Ranch Specific Plan Area, growth would be consistent with the City’s General Plan projections and would not result in substantial new environmental impacts beyond those previously evaluated and found to be less than significant, for the General Plan and San Luis Ranch Specific Plan.

Comment 11.51: The response to question 2.1.15 a.5 doesn’t address the question. Under “other public services” the answer would be “YES”. One of the purported “needs” for this project is related to the City’s desire “to maintain acceptable service ratios, response times or other performance objectives for any of the public services,” specifically the Transit Authority.

See comment 13. Furthermore, once again, you cannot separate out the project to relocate the corporation yard that is necessitated by this project.

This is not a “less than significant” impact. At this point, it is an unknown

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impact; in that case, CEQA requires preparation of an environmental impact statement.

Response to Comment 11.51: The discussion of “other public facilities” in Section 2.1.15, Public Services, concludes that the proposed project does not involve the construction of housing or other development that would increase demand on any public facility in a manner that results in a physical environmental effect. Refer to Response to Comment 11.14, which discusses the Transit Authority’s relocation to new office, maintenance, and storage facilities located adjacent to the northwest corner of the existing northbound ramp intersection with Prado Road, Elks Lane, and U.S. 101. Also refer to Response to Comment 11.6, which explains that a “significant effect on the environment” means a substantial, or potentially substantial, adverse change in the environment in the context of the Draft Initial Study-Mitigated Negative Declaration.

Refer to Response to Comment 11.20 for a discussion of the potential effects of the project on the city-owned corporation yard’s operations and the manner in which future physical facilities to support corporation yard operations would be subject to a separate planning process and applicable environmental review requirements.

Comment 11.52: “The project would not involve the construction of additional vehicle lanes or increase the capacity of the existing interchange.” Please explain. The project DOES construct additional lanes, and there is NO existing interchange. (How did this document get approved???) Response to Comment 11.52: The project does not involve the construction of additional vehicle travel lanes with the potential to induce travel, or otherwise increase the capacity of the existing interchange. The text cited by the commenter has been revised in Section 2.1.17, Transportation, to clarify that the project would not involve the construction of additional vehicle travel lanes on U.S. 101 or increase the capacity of the existing northbound on- and off-ramps at the U.S. 101/Prado Road interchange. Caltrans has identified project types that typically do not increase vehicle miles traveled, which includes additions of auxiliary lanes less than 1 mile, addition of roadway capacity on local streets provided project substantially improves ped/bike conditions, and installation of roundabouts (Caltrans 2020b). The only additional lanes that would be constructed as part of the project include the short segment along Prado Road that would have four lanes and the weave lanes that would connect the new ramps to U.S. 101. Additional widening would occur along Prado Road after it returns to City right-of-way and connects with other local facilities.

Comment 11.53: There appears to be no explanation on how the project will address “the removal of existing biofiltration strips along the U.S. 101 northbound lane.” This is mitigation for a previous impact.

Appendix B  Comment Letters and Responses
U.S. 101/Prado Road Interchange Project  162
Response to Comment 11.53: As discussed in Section 2.1.10, Hydrology and Water Quality, the portions of the project within Caltrans right-of-way are subject to the National Pollutant Discharge Elimination System Statewide Stormwater Permit Waste Discharge Requirements for the State of California Department of Transportation (Order 2012-0011-DWQ and subsequent amendments). In addition, portions of the project site outside the State rightof-way are subject to the National Pollutant Discharge Elimination System Phase 2 Small MS4 General Permit (Order 2013-0001-DWQ). Both of these permits require post construction Treatment Best Management Practices to infiltrate and/or treat runoff from the project site. Post construction water quality Treatment Best Management Practices may include, but would not be limited to, Design Pollution Prevention Infiltration Area Treatment Best Management Practices, Biofiltration Strips/Swale Treatment Best Management Practices, or Detention Basins or other flow-through Treatment Best Management Practices. These Treatment Best Management Practices are required to treat stormwater runoff from 100 percent of the New Impervious Surface created by the project. The New Impervious Surface is the sum of all new and replaced impervious surfaces, plus any tributary areas from existing Treatment Best Management Practices removed by the project.

The existing biofiltration strips along the U.S. 101 northbound lane that will be removed as part of the project will be relocated in kind or added to the New Impervious Surface to be treated by the entire project. Stormwater regulations in California have continued to get more stringent; therefore, the project would include more Best Management Practices than are removed and those Best Management Practices would treat more runoff than the existing Best Management Practices.

Comment 11.54: A discussion on cumulative impacts is completely lacking.

The document claims to have discussed each section separately, but this is not the case. Most importantly, the document doesn’t even identify any other projects, past or future, aside from the San Luis Ranch development, in its analysis. It makes passing reference, however, to relocation of the corporation yard, extension of bike lanes to Laguna Lake Park, the “planned Elks Lane realignment connection with Prado Road east to the western limits of the San Luis Obispo Creek Bridge Widening Project”, the San Luis Obispo Creek Bridge Widening Project, and the “planned Prado Road east extension to Broad Street as a main east/west connector.” These projects will have impacts on the community, on visual quality, on noise receptors, on air quality, and more, and they’re all connected. Considering how these projects will affect traffic circulation patterns and consequently population or commercial development, there will likely be substantial associated secondary impacts. This document must contain an extensive discussion on how all these projects are going to tie together and what effect they’re going to have on the city, its residents, and the natural environment. This discussion is required under “mandatory findings of significance”; a thorough analysis will almost certainly necessitate the preparation of an environmental impact report.

Appendix B  Comment Letters and Responses
U.S. 101/Prado Road Interchange Project  163
Response to Comment 11.54: As described in Response to Comment 11.3, the cumulative analysis considers the potential impact of past, present, and reasonably foreseeable future actions, combined with the potential impacts of the proposed project. CEQA Guidelines Section 15130(b) describes the requirements for an adequate discussion of cumulative impacts in an Environmental Impact Report. The Draft Initial Study-Mitigated Negative Declaration generally follows a “plan” based approach to identifying the cumulative setting.

The project is included in the Transportation Capital Projects of the City of San Luis Obispo General Plan Circulation Element (City of San Luis Obispo 2014a). The project would implement improvements to the city’s circulation network identified in the Circulation Element, and would be consistent with applicable goals, policies, and programs contained in the Circulation Element.

Similarly, the project is included in the 2019 Regional Transportation Plan as an “unconstrained” project. The analysis in the Final Environmental Impact Report for the 2019 Regional Transportation Plan includes all projects from the constrained and unconstrained project lists. The project is also identified in the San Luis Ranch Specific Plan, and incorporates by reference the conclusions of the San Luis Ranch Project Final Environmental Impact Report, certified by the City of San Luis Obispo in 2017.

In addition to the “plan” based approach to identifying the cumulative setting, the Draft Initial Study-Mitigated Negative Declaration also provides discussion of specific past, present, and reasonably foreseeable future actions in the immediate project vicinity, where such actions may have specific impacts that could be cumulatively considerable when combined with the project’s impacts (e.g., drainage). Specific past, present, and reasonably foreseeable future actions discussed in the Draft Initial Study-Mitigated Negative Declaration include buildout of the San Luis Ranch Specific Plan, the San Luis Obispo Creek Bridge Widening Project, the city-owned corporation yard and Water Resource Recovery Facility, the San Luis Obispo Regional Transit Authority administrative and operations office space and maintenance and storage facilities, and the Prado Road shelter (40 Prado Road).

Refer to Response to Comment 11.20 for a discussion of the potential effects of the project on the city-owned corporation yard’s operations and the manner in which future physical facilities to support corporation yard operations would be subject to a separate planning process and applicable environmental review requirements.

U.S. 101/Prado Road Interchange Project  164
Appendix C References
Bibliography
Airport Land Use Commission of San Luis Obispo County. 2005. Airport Land Use Plan for the San Luis Obispo County Regional Airport. Amended May 18, 2005. Available at: https://www.sloairport.com/wpcontent/uploads/2016/10/alup_txt.pdf. Accessed February 2022.

California Air Resources Board. 2017. California 2017 Climate Change Scoping Plan. Available at:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scopin g_plan_2017.pdf. Accessed December 2021.

California Air Pollution Control Officers Association. 2008. CEQA and Climate Change whitepaper. January 2008. Available at: www.capcoa.org/wpcontent/uploads/2012/03/capcoa-white-paper.pdf. Accessed September 2021.

California Climate Action Registry. 2009. General Reporting Protocol.

Available at:
https://sfenvironment.org/sites/default/files/fliers/files/ccar_grp_3- 1_january2009_sfe-web.pdf. Accessed November 2021.

California Department of Conservation. 2009. Tsunami Inundation Maps. https://www.conservation.ca.gov/cgs/documents/tsunami/maps/tsunam i_inundation_pismobeach_quad_slo.pdf. Accessed December 2021. _____2016. California Important Farmland Finder Map. Available at:
https://maps.conservation.ca.gov/dlrp/ciff/. Accessed December 2021. _____2021. EQ Zapp: California Earthquake Hazards Zone Application.

Available at: https://www.conservation.ca.gov/cgs/geohazards/eqzapp. Accessed December 2021.

California Department of Finance. 2021.E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2021 with 2010 Census Benchmark. May 2021. Available at:
https://www.dof.ca.gov/forecasting/demographics/estimates/e-5/.

Accessed December 2021.

California Department of Forestry and Fire Protection. 2007. San Luis Obispo County Fire Hazard Severity Zone Map. State Responsibility Area.

Adopted November 2007. Available at:
https://osfm.fire.ca.gov/media/6795/fhszs_map40.pdf. Accessed December 2021.

Appendix C  References
U.S. 101/Prado Road Interchange Project  165
_____2009. San Luis Obispo County Fire Hazard Severity Zone Map. Local Responsibility Area. Recommended July 2009. Available at:
https://osfm.fire.ca.gov/media/5980/san_luis_obispo.pdf. Accessed December 2021.
_____2015. Cuesta Fire Incident. Available at:
https://www.fire.ca.gov/incidents/2015/8/16/cuesta-fire/. Accessed December 2021.
_____2021. Fire Hazard Severity Zone Viewer Map. Available at:
https://egis.fire.ca.gov/fhsz/. Accessed December 2021.

California Department of Transportation (Caltrans). 2002. California Highway Barrier Aesthetics. June 2002. Available at: https://dot.ca.gov/- /media/dot-media/programs/design/documents/barrier-aesth1finala11y.pdf. Accessed May 2022. _____2013a. Technical Noise Supplement to the Traffic Noise Analysis Protocol. Available at: https://dot.ca.gov/-/media/dotmedia/programs/environmental-analysis/documents/env/tens-sep2013- a11y.pdf. Accessed December 2021.
_____2013b. Transportation and Construction Vibration Guidance Manual.

September 2013. Available at:
https://www.contracosta.ca.gov/documentcenter/view/34120/caltrans2013-construction-vibration-pdf. Accessed December 2021. _____2015. Transportation Management Plan Guidelines. November 2015.

Available at: https://dot.ca.gov/-/media/dot-media/programs/trafficoperations/documents/tmp/tmp-guidelines-07202122763-rt1.pdf.

Accessed February 2022).
_____2018a. Scenic Highways. Available at:
http://www.dot.ca.gov/design/lap/livability/scenic-highways/. Accessed April 2019).
_____2018b. Standard Specifications. Available at:
http://ppmoe.dot.ca.gov/hq/esc/oe/construction_contract_standards/std _specs/2018_stdspecs/2018_stdspecs.pdf. Accessed September 2021.
_____2019. Seismic Design Criteria, Version 2.0, April 2019. Available at:
https://dot.ca.gov/-/media/dotmedia/programs/engineering/documents/seismicdesigncriteriasdc/202007-seismicdesigncriteria-v2-a11y.pdf. Accessed December 2021.

Appendix C  References
U.S. 101/Prado Road Interchange Project  166
_____2020a. Vehicle Miles Traveled-Focused Transportation Impact Study Guide. May 2020. Available at: https://dot.ca.gov/-/media/dotmedia/programs/transportation-planning/documents/sb-743/2020-05- 20-approved-vmt-focused-tisg-a11y.pdf. Accessed February 2022. _____2020b. Caltrans Policy on Transportation Impact Analysis and CEQA Significance Determinations for Projects on the State Highway System.

September 2020. Available at: https://dot.ca.gov/-/media/dotmedia/programs/transportation-planning/documents/sb-743/2020-09- 10-vmt-policy-memo-fnl-a11y.pdf. Accessed April 2023.
_____2021. California Scenic Highway Mapping System. Available at:
https://www.arcgis.com/apps/webappviewer/index.html?id=465dfd3d80 7c46cc8e8057116f1aacaa. Accessed November 2021.

California Department of Water Resources. 2004. San Luis Obispo Valley Groundwater Basin, Bulletin 118. Last Updated: February 27, 2004.

Available at: https://water.ca.gov/-/media/dwr-website/webpages/programs/groundwater-management/bulletin-118/files/2003- basin-descriptions/3_009_sanluisobispovalley.pdf (accessed February 2022)._____2019. Sustainable Groundwater Management Act 2019 Basin Prioritization. January 2019. Available at:
https://www.emwd.org/sites/default/files/fileattachments/sgma_basin_prioritization_2019_results.pdf?1559164669 Accessed February 2022.

California Emergency Management Agency, California Geological Survey, and University of Southern California. 2009. Tsunami Inundation for Emergency Planning. Pismo Beach Quadrangle. Scale 1:24,000. July 1, 2009. Available at:
https://www.conservation.ca.gov/cgs/documents/tsunami/maps/tsunam i_inundation_pismobeach_quad_slo.pdf. Accessed February 2009.

California Energy Commission. 2018. Revised Transportation Energy Demand Forecast 2018-2030. April 19, 2018. Available at:
https://efiling.energy.ca.gov/getdocument.aspx?tn=223244. Accessed November 2021.
_____2020a. Electricity Consumption by Entity. Available at:
http://ecdms.energy.ca.gov/elecbyutil.aspx. Accessed November 2021. _____2020b. Gas Consumption by County. Available at:
http://ecdms.energy.ca.gov/gasbycounty.aspxv. Accessed November 2021.
_____2021. “California Retail Fuel Outlet Annual Reporting (CEC-A15) Results.” Available at: https://www.energy.ca.gov/data-reports/energyPage 534 of 753 Appendix C  References
U.S. 101/Prado Road Interchange Project  167
almanac/transportation-energy/california-retail-fuel-outlet-annualreporting. Accessed November 2021.

California Geological Survey. 2002. California Geomorphic Provinces. Note

36. Available at:
https://www.conservation.ca.gov/cgs/documents/publications/cgsnotes/cgs-note-36.pdf. Accessed December 2021.

CalRecycle. 2021. Solid Waste Information System (SWIS). Cold Canyon Landfill, Inc. (40-AA-0004). Available at:
https://www2.calrecycle.ca.gov/solidwaste/siteactivity/details/1509?site id=3171. Accessed December 2021.

County of San Luis Obispo Board of Supervisors. 2018. Notification of Intent to Initiate Development of Groundwater Sustainability Plan for the San Luis Obispo Valley Groundwater Basin. Available at:
https://www.slocounty.ca.gov/departments/public-works/formsdocuments/committees-programs/sustainable-groundwatermanagement-act-(sgma)/san-luis-obispo-valley-groundwater-basin/slobasin-noi.aspx Accessed February 2022.

Crocker, Malcolm J. 2007. Handbook of Noise and Vibration Control, John Wiley & Sons.

Department of Toxic Substances Control. 2019a. EnviroStor database. https://www.envirostor.dtsc.ca.gov/public/. Accessed April 2019. _____2019b. DTSC's Hazardous Waste and Substances Site List - Site Cleanup (Cortese List).
https://www.dtsc.ca.gov/sitecleanup/cortese_list.cfm. Accessed April 2019.

Federal Emergency Management Agency. Flood Map Service Center. Map:
06079C1066G, effective November 16, 2012. Available at:
https://msc.fema.gov/portal/search?addressquery=san%20luis%20obis po%2c%20ca#searchresultsanchor
Federal Highway Administration. 2011. Highway Traffic Noise: Analysis and Abatement Guidance. FHWA-HEP-10-025. Available at:
https://www.fhwa.dot.gov/environment/noise/regulations_and_guidanc e/analysis_and_abatement_guidance/revguidance.pdf. Accessed December 2021.
_____2019. Sustainability.
https://www.fhwa.dot.gov/environment/sustainability/resilience/. Last updated February 7, 2019. Accessed: August 21, 2019.

Appendix C  References
U.S. 101/Prado Road Interchange Project  168
_____No date. Sustainable Highways Initiative.
https://www.sustainablehighways.dot.gov/overview.aspx. Accessed:

August 21, 2019.

Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual. September 2018. Available at:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/researchinnovation/118131/transit-noise-and-vibration-impact-assessmentmanual-fta-report-no-0123_0.pdf. Accessed January 6, 2022.

Governor’s Office of Planning and Research. 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. April 2018. Available at:
https://opr.ca.gov/docs/20180416-743_technical_advisory_4.16.18.pdf.

Accessed February 2022.

GSI Water Solutions, Inc. 2018. San Luis Obispo Valley Basin Characterization and Monitoring Well Installation. Available at:
https://www.slocounty.ca.gov/departments/public-works/formsdocuments/committees-programs/sustainable-groundwatermanagement-act-(sgma)/san-luis-obispo-valley-groundwater-basin/slobasin-characterization-report.aspx. Accessed February 2022.

Jennings, C. W. 1958. Geologic Map of California, San Luis Obispo Sheet.

Scale 1:250,000. Available at:
https://ngmdb.usgs.gov/prodesc/proddesc_328.htm. Accessed December 2021).

Intergovernmental Panel on Climate Change. 2007. Summary for Policymakers. In: Climate Change 2007: The Physical Science Basis.

Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M.

Marquis, K.B. Avery, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

Metz, Jennifer. 2020. Utilities Project Manager, City of San Luis Obispo.

Personal communication via email regarding City of San Luis Obispo Water Resource Recovery Facility operations with Chris Bersbach, Supervising Planner, Rincon Consultants, Inc. October 7, 2020.

Miller, R. V. 1989. Mineral Land Classification map. San Luis Obispo–Santa Barbara P-C Region, San Luis Obispo Quadrangle. Scale: Reduced from 1:24,000. Available at:
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html ?map=mlc. Accessed December 2021.

Appendix C  References
U.S. 101/Prado Road Interchange Project  169
Natural Resources Conservation Service. 2017. Web Soil Survey. Last Modified: August 21, 2017. Available at:
https://websoilsurvey.sc.egov.usda.gov/app/websoilsurvey.aspx.

Accessed March 2019.

San Luis Coastal Unified School District. 2021. Our Schools. Available at:
https://www.slcusd.org/our-schools. Accessed December 2021.

San Luis Obispo, City of. 2000. Safety Element. Available at:
http://www.slocity.org/home/showdocument?id=6645. Accessed December 2021.
_____2006. Conservation and Open Space Element. Available at:
https://www.slocity.org/home/showdocument?id=6651. Accessed December 2021.
_____2014a. Circulation Element. Available at:
https://www.slocity.org/home/showdocument?id=20412. Accessed December 2021.
_____2014b. Land Use and Circulation Element Update Draft Program EIR.

Available at: https://www.slocity.org/home/showdocument?id=6723.

Accessed December 2021.
_____2014c Land Use Element. Available at:
https://www.slocity.org/home/showdocument?id=6635. Accessed December 2021.
_____2016. Emergency Operations Plan. Available at:
https://www.slocounty.ca.gov/getattachment/40e9d234-8576-41a1- 82fe-a07f3b67a20a/county-emergency-operations-plan-(eop).aspx.

Accessed December 2021.
_____2017a. San Luis Ranch Specific Plan. Available at:
https://www.slocity.org/home/showpublisheddocument/24679/6371026 69193230000. Accessed December 2021.
_____2017b. San Luis Ranch Specific Plan Final EIR. Available at:
https://www.slocity.org/home/showdocument?id=15653. Accessed December 2021.
_____2019a. 2-Dimensional Hydraulic Model Update.
_____2019b. San Luis Obispo Parks and Recreation Master Plan – Community Needs Assessment. Available at:
https://www.slocity.org/home/showpublisheddocument/23356/6369586 60067030000. Accessed December 2021.

Appendix C  References
U.S. 101/Prado Road Interchange Project  170
_____2021a. Fire Department: Fire Stations and Training Grounds. Available at: https://www.slocity.org/government/department-directory/firedepartment/about-us/fire-stations-facilities. Accessed December 2021. _____2021b. Police Department.: About the Department Available at:
https://www.slocity.org/government/department-directory/policedepartment/about-the-department. Accessed December 2021. _____2021c. 2020 Urban Water Management Plan. Available at:
https://www.slocity.org/home/showpublisheddocument/31041/6376737 68464130000. Accessed December 2021.
_____2021e. Utilities Department: Construction & Demolition Recycling Program. Available at: https://www.slocity.org/government/departmentdirectory/utilities-department/garbage-recycling/constructiondemolition-recycling-program. Accessed December 2021. _____2022. Water Plus. Available at: https://www.slowrrfproject.org/about.

Accessed February 2022.

San Luis Obispo Council of Governments. 2019. Transition from LOS to VMT Staff Report. October 2019.

San Luis Obispo, County of. 1999. General Plan Safety Element. Available at:
https://www.slocounty.ca.gov/departments/planning-building/formsdocuments/plans-and-elements/elements/safety-element.pdf.

Accessed December 2021.
______2019. Community Wildfire Protection Plan. Available at:
https://www.slocounty.ca.gov/departments/county-firedepartment/publications/community-wildfire-protection-plan.pdf.

Accessed December 2021.

San Luis Obispo County Air Pollution Control District (District). 2001. Clean Air Plan. December 2001. Available at:
https://storage.googleapis.com/slocleanairorg/images/cms/upload/files/business/pdf/cap.pdf. Accessed February 2022.
______2012. CEQA Air Quality Handbook. April 2012. Available at:
https://www.prcity.com/documentcenter/view/14604/californiaenvironmental-quality-act-handbook---2012-volume-1-pdf. Accessed February 2022.
______2017. Clarification Memorandum for the San Luis Obispo County Air Pollution Control District’s 2012 CEQA Air Quality Handbook.

November 2017. Available at:
https://storage.googleapis.com/slocleanairPage 538 of 753 Appendix C  References
U.S. 101/Prado Road Interchange Project  171
org/images/cms/upload/files/final_clarification%20memorandum%2020 172.pdf. Accessed November 2021.

San Luis Obispo County Airport Land Use Commission. 2021. San Luis Obispo County Regional Airport Land Use Plan. Available at:
https://www.slocounty.ca.gov/departments/planning-building/formsdocuments/planning-projects/airport-land-use-plan-update/airport-landuse-plan-(amended-restated).pdf. Accessed December 2021.

San Luis Obispo Valley Basin Groundwater Sustainability Agencies. 2021.

San Luis Obispo Valley Basin Groundwater Sustainability Plan.

October 2021. Available at: https://02ee8e55-e735-4a38-bedf455049034f73.filesusr.com/ugd/3de50a_f330a123a74e4007a9cf6d027 961e1f2.pdf. Accessed February 2022.

State of California. 2018. California’s Fourth Climate Change Assessment. http://www.climateassessment.ca.gov/. Accessed: August 21, 2019. _____2019. California Climate Strategy. https://www.climatechange.ca.gov/.

Accessed: August 21, 2019.

State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State—January 1, 2011-2020.

Sacramento, California, May 2020.

State Water Resources Control Board. 2019a. GeoTracker database. https://geotracker.waterboards.ca.gov/. Accessed April 2019. _____2021. 2018 California Integrated Report (Clean Water Act Section 303(d) List and 305(b) Report).
https://www.waterboards.ca.gov/water_issues/programs/water_quality _assessment/2018_integrated_report.html. Accessed February 2022.

United States Department of Transportation. 2011. Policy Statement on Climate Change Adaptation. June. Available at:
https://www.fhwa.dot.gov/environment/sustainability/resilience/policy_a nd_guidance/usdot.cfm. Accessed August 2019.

U.S. Energy Information Administration. 2020.“California – State Profile and Energy Estimates.” Available at:
https://www.eia.gov/state/?sid=ca#tabs-2. Accessed November 2021.

U.S. Environmental Protection Agency. 2009. Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Section 202(a) of the Clean Air Act. https://www.epa.gov/ghgemissions/endangermentand-cause-or-contribute-findings-greenhouse-gases-under-section202a-clean. Accessed August 2019.

Appendix C  References
U.S. 101/Prado Road Interchange Project  172
_____2018. Inventory of U.S. Greenhouse Gas Emissions and Sinks. https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gasemissions-and-sinks. Accessed: August 21, 2019. _____2019. Envirofacts database. https://www3.epa.gov/enviro/. Accessed April 2019).

United States Forest Service. 2018. “Fire in chaparral ecosystems.” Last modified November 30, 2018.
https://www.fs.fed.us/psw/topics/fire_science/ecosystems/chaparral.sht ml. Accessed April 2019.

United States Geological Survey. 2018. Post-Fire Flooding and Debris Flow.

Last modified: October 31, 2018. Available at:
https://ca.water.usgs.gov/wildfires/wildfires-debris-flow.html. Accessed April 2019.

United States Global Change Research Program. 2018. Fourth National Climate Assessment. https://nca2018.globalchange.gov/. Accessed:

August 2019.

Wiegers, M.O. 2021. Preliminary geologic map of the west half of the San Luis Obispo 30’ x 60’ quadrangle, California, version 2.0: California Geological Survey. Scale 1:100,000. Available at:
https://filerequest.conservation.ca.gov/?q=preliminary-geologic-mapsanluisobispo-100k-west-v2-map.pdf. Accessed April 2022.

U.S. 101/Prado Road Interchange Project  174
Appendix D Energy Calculations

Appendix D  Energy Calculations
U.S. 101/Prado Road Interchange Project  175

U.S. 101/Prado Road Interchange Project  176
List of Technical Studies Bound Separately (Volume 2)
 Initial Environmental Site Assessment, August 2017
 Remedial Excavation Report, San Luis Obispo Regional Transit Authority Bus Maintenance Facility, 253 Elks Lane, San Luis Obispo, California, November 2020.
 Farmland Conversion Impact Rating Memorandum, September 2021  Moderate Level Visual Impact Assessment, September 2021  Air Quality Technical Study, September 2021
 Climate Action Plan Consistency Checklist, September 2020  Natural Environment Study, October 2021
 Archaeological Survey Report, January 2020
 Finding of No Adverse Effect without Standard Conditions, February 2020  Historic Property Survey Report, January 2020
 Historic Resources Evaluation Report, February 2020
 Supplemental Historic Properties Survey Report and Archeological Survey Report, January 2022
 Water Quality Assessment Report, November 2021
 Noise Study Report, October 2021
 U.S. 101/Prado Road Interchange Traffic Operations Analysis Report and Intersection Control Evaluation, May 2019
 U.S. 101/Prado Road Vehicle Miles Traveled Analysis, June 2020  Community Impact Assessment, September 2021
To obtain a copy of one or more of these technical studies/reports or the Initial Study, please send your request to:

Dianna Beck
Associate Environmental Planner, District 5
California Department of Transportation, CEQA Lead Agency 50 Higuera Street, San Luis Obispo, California 93401
Or send your request via email to: [email protected] Or call: 805-459-9406
Please provide the following information in your request:

Project title: U.S. 101/Prado Road Interchange Project
General location information: San Luis Obispo County, California District number-county code-route-post mile: District 5–SLO-101–PM 26.5-27.3 Project ID number: 0516000105

05 – SLO – 101 - 26.5/27.3
05-1H640 – 0516000105 PPNO-2831

20.XX.075.600 STIP RIP 20.XX.400.100 Local Funds
June 12, 2023
Project Report
For Project Approval
On Route 101
Between 0.3 mile south of Prado Road
And 0.2 mile south of Madonna Road Overcrossing
I have reviewed the right-of-way information contained in this report and the right-ofway data sheet attached hereto, and find the data to be complete, current and accurate:

Marshall Garcia, District Division Chief, Right of Way
APPROVAL RECOMMENDED:

Paul Valadao, Project Manager
APPROVED:

Scott Eades, District Director Date

05 – SLO – 101 - 26.5/27.3
Vicinity Map

05 – SLO – 101 - 26.5/27.3
This project report has been prepared under the direction of the following registered civil engineer. The registered civil engineer attests to the technical information contained herein and the engineering data upon which recommendations, conclusions, and decisions are based.

REGISTERED CIVIL ENGINEER DATE
03/31/25
C41227
Jay Walter

05 – SLO – 101 - 26.5/27.3
Table of Contents

1. INTRODUCTION .....................................................................................................................1

2. RECOMMENDATION .............................................................................................................2

3. BACKGROUND .......................................................................................................................2

4. PURPOSE AND NEED.............................................................................................................4 A. Problem, Deficiencies, Justification....................................................................................4 B. Regional and System Planning............................................................................................5 C. Traffic..................................................................................................................................8

5. ALTERNATIVES....................................................................................................................13 5A.Preferred Alternative .........................................................................................................14 Alternative 3......................................................................................................................14 5B. Rejected Alternatives ........................................................................................................18 No Build ............................................................................................................................18 Alternative A1 ...................................................................................................................18 Alternative A1R ................................................................................................................19 Alternative A2 ...................................................................................................................19 Alternative A4 ...................................................................................................................19 Alternative A4R ................................................................................................................20 Alternative A7 ...................................................................................................................20

6. CONSIDERATIONS REQUIRING DISCUSSION ...............................................................20 6A.Hazardous Waste...............................................................................................................20 6B. Value Analysis ..................................................................................................................21 6C. Resource Conservation......................................................................................................21 6D.Right of Way Issues ..........................................................................................................22 6E. Environmental Compliance...............................................................................................23 6F. Air Quality Conformity.....................................................................................................33 6G.Title VI Considerations.....................................................................................................34 6H.Noise Abatement Decision Report....................................................................................34 6I. Reversible Lanes...............................................................................................................35

7. OTHER CONSIDERATIONS AS APPROPRIATE...............................................................35 Public Hearing Process......................................................................................................35 Route Matters....................................................................................................................35 Permits...............................................................................................................................36 Cooperative Agreements...................................................................................................36 Other Agreements...........................................................................................................36 Report of Feasibility of Providing Access to Navigable Rivers........................................36 Public Boat Ramps............................................................................................................36 Transportation Management Plan......................................................................................36 Stage Construction ............................................................................................................37 Accommodation of Oversize Loads..................................................................................37 Graffiti Control..................................................................................................................37 Asset Management ............................................................................................................37 Complete Streets................................................................................................................37

05 – SLO – 101 - 26.5/27.3
Climate Change Considerations........................................................................................38 Broadband and Advance Technologies.............................................................................38

8. FUNDING, PROGRAMMING AND ESTIMATE.................................................................38 Funding..............................................................................................................................38 Programming.....................................................................................................................38 Estimate.............................................................................................................................39

9. DELIVERY SCHEDULE........................................................................................................39

10. RISKS ......................................................................................................................................39

11. EXTERNAL AGENCY COORDINATION ...........................................................................40

12. PROJECT REVIEWS..............................................................................................................40

13. PROJECT PERSONNEL.........................................................................................................40

14. ATTACHMENTS ...................................................................................................................41 A – ENVIRONMENTAL DOCUMENT
B – LOCATION MAP
C – TYPICAL SECTIONS AND LAYOTS
D – STRUCTURES ADVANCE PLANNING STUDY (APS)
E – PRELIMINARY COST ESTIMATES
F – RIGHT OF WAY DATA SHEETS AND UTILITY PLANS
G – STORM WATER DATA REPORT
H – RISK REGISTER

05 – SLO – 101 - 26.5/27.3
1 1. INTRODUCTION
Project Description
The proposed project includes improvements to extend Prado Road over U.S. Route 101 (US 101) to connect with Dalidio Drive, reconstruct the existing US 101 northbound (NB) off-ramp and on-ramp connections with Prado Road, and construct an auxiliary lane on northbound US 101 between the Prado Road and Madonna Road interchanges in order to provide congestion relief, operational efficiency and multimodal connectivity. The interchange is located in the City of San Luis Obispo in the County of San Luis Obispo at Post Mile (PM) 26.8 and improvements on northbound US 101 extend from PM 26.5 to PM 27.3. The preferred alternative includes a partial interchange with the proposed Prado Road overcrossing constructed over US 101, a new US 101 NB off-ramp to Prado Road, and a new NB on-ramp from Prado Road. Refer to Attachment B for the Location Map.

The preferred alternative considers multimodal components and does not preclude future widening of US 101. The preferred alternative also would not preclude completion of a future full access interchange at this location by adding SB on and offramps.

Project Limits 05-SLO-101, PM 26.5/27.3
Number of Alternatives One
Alternative A3 Current Cost
Estimate FY 2022:

Escalated Cost
Estimate FY 2025:

Capital Outlay Support $9,900,000 $10,900,000
Capital Outlay Construction $51,700,000 $56,500,000
Capital Outlay Right-of-Way $4,500,000 $5,400,000
Total $66,100,000.00 $72,800,000.00
Funding Source State Transportation Improvement Program (STIP), Regional Transportation Improvement
Program (RTIP) and Local Funds
STIP-RIP 20.xx.075.600 & Local

20.xx.400.100
Funding Year 2025/2026
Type of Facility Local Interchange
Number of Structures 3
Environmental Determination
or Document
California Environmental Quality Act
(CEQA) – Initial Study/Mitigated Negative
Declaration
National Environmental Policy Act (NEPA) –
Categorical Exclusion

05 – SLO – 101 - 26.5/27.3
2 Legal Description In San Luis Obispo County, on Route 101 between 0.3 mile south of Prado Road and 0.2
mile south of Madonna Road Overcrossing
Project Development Category 3

2. RECOMMENDATION
It is recommended that this Project Report be approved, and authorization be granted to proceed to the Plans, Specifications and Estimate phase.

3. BACKGROUND
Project History
A Freeway Agreement between the State of California (Caltrans) and the City of San Luis Obispo (City) is currently in place and is dated July 3, 1972. The Freeway Agreement includes the segment of US 101 between 0.5 mile south of Los Osos Valley Road overcrossing and 0.4 mile south of Madonna Road overcrossing and includes the proposed project area.

A Project Study Report (PSR) was previously prepared and approved in December 1996 (EA 41120K). Fact Sheet Exceptions to Mandatory Design Standards for non-standard interchange spacing between the proposed Prado Road interchange and the Madonna Road interchange were also prepared and approved in April 1996. Both the approved PSR and Fact Sheet Exceptions to Mandatory Design Standards were determined to be no longer valid.

Construction of the Los Osos Valley Road (LOVR) improvements at US 101 was completed in 2016 (EA 0H730). During the Project Approval & Environmental Documentation (PA/ED) phase for that project, the environmental document included the constructed Prado Road interchange in the future scenario.

The City of San Luis Obispo (City), Caltrans District 5 (Caltrans) and the San Luis Obispo Council of Governments (SLOCOG) signed a Caltrans Project Information Form in January 2016 and the City and Caltrans signed a Project Charter in July 2017.

The City and Caltrans entered into a Cooperative Agreement (No. 05-0313) in July 2017 in which the City agreed to prepare a Project Study Report – Project Development Support (PSR-PDS) for the proposed project. Caltrans agreed to provide project oversight and approvals. A PSR-PDS was developed for the project and approved on April 12, 2018. The current proposal does not differ from the approved PSR-PDS The City and Caltrans entered into a Cooperative Agreement (No. 05-0332) on April 12, 2018, in which the City agreed to initiate the PA&ED phase for the proposed project.

Caltrans agreed to perform Independent Quality Assurance (IQA), environmental document quality control and owner/operator approvals for the portions of the work within the existing and proposed State Highway System right-of-way. At this time no right of way has been acquired for the project.

05 – SLO – 101 - 26.5/27.3
3 Community Interaction
This project is sponsored by the City of San Luis Obispo and was recommended in SLOCOG’s 2014 US 101 Corridor Mobility Master Plan. This plan included extensive public involvement, including seven local workshops, 30 community presentations, two web-based interactive tools, numerous stakeholder meetings and several SLOCOG board presentations. The study team included representatives from SLOCOG, Caltrans, County of San Luis Obispo and the cities of San Luis Obispo, Arroyo Grande, Atascadero, Grover Beach, Paso Robles, Pismo Beach, SLO Regional Transit Authority and the County Air Pollution Control District.

The City has continued to support the project concepts from the PSR-PDS and into PA&ED. The City is committed to providing clear and consistent communication with the community on this project, and will continue the public outreach efforts through PA&ED, during final project design, and construction. At this time, no final commitments on any alternative have been made, but there is substantial support for the project from the community because of its transportation benefit. No contact has been initiated with any special interest groups, but that could change after circulation of the DED. A public meeting was held on March 6, 2023 during which the project alternatives and environmental impacts were shared.

Existing Facilities
US 101
US 101 is the principal north/south freeway/expressway on the Central Coast traversing the counties of Santa Barbara, San Luis Obispo, Monterey and San Benito within District 5. It serves local, regional and interregional travel needs, including business, recreation, tourism, journey-to-work, freight and goods movement, and national defense transport. The Pacific Coast Bicycle Route runs parallel to US 101 in this area along South Higuera Street.

Within the project limits, US 101 is a four-lane freeway with 12-foot-wide travel lanes, 5-foot-wide left shoulders, 10-foot-wide right shoulders, and a 27 foot wide median with thrie beam median barrier. Right-of-Way width varies but is generally 177 feet. The area along US 101 is generally flat, with San Luis Obispo Creek running parallel to the freeway. The project area is located within the FEMA 100-year floodplain, and as such, the alternatives reflect the need to not impact the floodplain with additional embankments. US 101 is designated on the National Network as a Surface Transportation Assistance Act (STAA) truck route and the posted speed limit is 65 miles per hour (mph). Bicycle, pedestrians, and motor driven cycles are prohibited on the freeway sections of US 101.

US 101/Prado Road Interchange
The US 101 interchange with Prado Road is located between 0.3 miles south of Prado Road and 0.2 mile south of Madonna Road Overcrossing. The interchange is a partial interchange with access between US 101 and Prado Road currently provided only by a

05 – SLO – 101 - 26.5/27.3
4 compact diamond NB off and a hook NB on-ramp. This configuration provides limited access to and from US 101 from the local street system at this location. All way stop control is provided at the NB ramps intersection with Prado Road/Elks Lane.

Prado Road
Prado Road is a 2-lane Minor Arterial roadway that extends in a northwest direction and has a speed limit of 40 mph within the project vicinity. Prado Road provides two 12- foot-wide travel lanes and Class II bike lanes and is designated as an STAA truck route.

Prado Road currently terminates at the US 101 NB Ramps/Prado Road/Elks Lane intersection.

Elks Lane
Elks Lane is a two-lane, 30 foot wide Local Road that extends in a northeast direction between Prado Road and South Higuera Street. Elks Lane currently terminates at the US 101 NB Ramps/Prado Road/Elks Lane intersection.

4. PURPOSE AND NEED
Purpose:

The purpose of the project is to improve overall circulation and accessibility in the project area for all transportation modes.

Need:

There is a need to provide better community connectivity between the existing and planned neighborhoods east and west of the US 101 freeway and resolve forecasted operational deficiencies on State and City facilities. These connectivity needs extend to all transportation modes.

Goals and objectives of the project include: 1) improve overall operations of US 101 and adjacent interchanges; 2) improve mobility for bicyclists and pedestrians; 3) improve transit performance and enhance transit opportunities; and 4) improve consistency with local, regional and state planning.

A. Problem, Deficiencies, Justification
The existing Prado Road interchange with US 101 consists only of NB off- and NB onramps. Prado Road presently has a compact diamond off-ramp and a hook on-ramp in the northbound direction. This configuration provides limited access to and from US 101 from the local street system at this location. The Prado Road extension over US 101 that this project proposes is needed to provide better community connectivity between the existing and planned neighborhoods and to support planned roadway improvements east and west of the US 101 freeway. Improvements to US 101 in the study area and the extension of Prado Road over US 101 are critical to the operations for all modes of travel, not only for regional traffic, but also for local traffic.

05 – SLO – 101 - 26.5/27.3
5 B. Regional and System Planning
Systems
US 101 is designated with the following state and federal classifications:
 Federal Aid Primary Route
 Freeway Expressway System (F&E)
 National Highway System (NHS)
 Strategic Highway Corridor Network (STRAHNET)
 Interregional Road System (IRRS)
 High Emphasis Route
 Eligible to be part of the Scenic Highway System
State Planning
The US 101/Prado Road interchange is located at PM 26.80 within Segment 5 in the US 101 Transportation Concept Report (TCR), approved in December 2014. Segment 5 extends from the South Higuera Street Interchange (PM 24.3) to the State Route 58 Interchange (PM 37.9). The route is a four-lane freeway through the City of San Luis Obispo and then transitions to a six-lane expressway and conventional highway over the Cuesta Grade.

Within Segment 5 the 2035 Corridor Concept is freeway with capacity of four to six lanes, and the Ultimate Corridor Concept (beyond 2035) is freeway with capacity of up to six lanes. US 101 near the study area is currently a four-lane divided freeway with auxiliary lanes provided between Madonna Road and Marsh Street. As noted, the Ultimate Corridor Concept is identified as freeway with capacity of up to six lanes though there is no funding currently identified for providing a six-lane freeway section.

The TCR identifies various Intelligent Transportation System (ITS) elements for implementation within Segment 5. These include closed circuit television cameras (CCTV), inductive loop type census station (LOOP), microwave vehicle detection system (MVDS), wireless access point bridge (WAPB), and wireless client bridge (WCB). Though these elements are noted, specific locations for implementation are not identified. The TCR also identifies potential locations for ramp meters in the US 101 corridor, but with no locations within Segment 5.

The District System Management Plan (DSMP), approved in August 2015 identifies the construction of a northbound US 101 auxiliary lane between Prado Road and Madonna Road (DSMP 2015 ID No. 2073).

During the Project Initiation Development (PID) phase, the PDT recommended the initial project that provides the Prado Road overcrossing of US 101, reconfigured NB ramps only with Prado Road, and a northbound US 101 auxiliary lane between Prado Road and Madonna Road. Provision of US 101 southbound (SB) Prado Road ramps and southbound collector-distributor road between the Los Osos Valley Road (LOVR) and Madonna Road interchanges were also initially evaluated, however, the PDT recommended that these facilities not be considered within the PSR-PDS. Though not

05 – SLO – 101 - 26.5/27.3
6 considered within the PSR-PDS, the PDT directed that these facilities are still a component of long-range system planning. As such, the PDT also directed that the Prado Road structure should be designed in such a way as to accommodate the future southbound Prado Road ramps and collector-distributor road. The City is reserving right-of-way needed for the future southbound ramps based on the best information that is available at this time, and the Structures design for each alternative is providing sufficient vertical and horizontal clearance for the SB ramps and collector-distributor road system. The reservation of this right-of-way will not preclude future viable alternatives.

Regional Planning
The US 101 Corridor Mobility Master Plan (December 2014) evaluated potential corridor improvements within four (4) distinct US 101 focus segments within the county. Focus Segment 2 is located within the City of San Luis Obispo with the segment limits extending from Los Osos Valley Road to Monterey Street. The US 101/Prado Road interchange and US 101 northbound auxiliary lane between Prado Road and Madonna Road are identified as projects to be considered during future planning and programming cycles. Within Segment 2, the US 101 Corridor Mobility Master Plan also identified ramp meters on the northbound on-ramp from Madonna Road and on the southbound on-ramp from Los Osos Valley Road.

The SLOCOG 2017 Park & Ride (P&R) Lot Study (August 2017) notes that a major goal of SLOCOG is to help assure the development of an efficient, coordinated, integrated, and balanced transportation system including providing P&R lot locations throughout the County. The study identifies a P&R lot on Prado Road at or near the Prado Road/US 101 interchange as a potential P&R location.

The US 101/Prado Road interchange and US 101 northbound auxiliary lane between Prado Road and Madonna Road are identified in the SLOCOG 2019 Regional Transportation Plan (2019 RTP Project ID No. CEN-MHWY-1402). This project is identified as ‘Constrained’ in the 2019 RTP, Chapter 9, Figure 9-14.

Local Planning
The City’s General Plan (May 2015) is published in separately adopted sections, called elements, which address various topics. The City updated both the General Plan Land Use and Circulation elements (San Luis Obispo 2035 Land Use and Circulation Update) which was adopted in 2014. The Circulation element was subsequently amended in October 2017. While the Land Use Element describes the city’s desired character and size, the Circulation Element describes how transportation will be provided in the community described by the Land Use Element. A description of the transportation improvements is provided in Table 5 (Transportation Capital Projects) of the Circulation Element. The following roadway improvements which will improve mobility and circulation and relieve congestion with the project study area have been identified by the City as in place by the year 2035:
 Dalidio Drive widened to 4 lanes between Madonna Road and Froom Ranch Way (completed 2021)

05 – SLO – 101 - 26.5/27.3
7  Froom Ranch Way extended to Dalidio Drive (completed 2021)  Prado Road widened to 4 lanes between US 101 and S. Higuera Street  Horizon Lane extended between Avila Ranch and Suburban Drive  Buckley Road extended to South Higuera Street (completed 2022)  A new North/South Collector between Prado Road and Tank Farm Road  Prado Road extended to Broad Street
 Madonna Road at South Higuera Street realigned to Bridge Street The City of San Luis Obispo Active Transportation Plan (ATP), approved in 2021 identifies a need for a Bicycle/Pedestrian Grade Separated Crossing of US 101 between Los Osos Valley Road and Madonna Road which could be a Protected Bicycle Path, Bike Lanes, or Class IV Cycle Tracks as part of a Grade Crossing project.

The City’s General Plan and Circulation Element assume and reflect a future full interchange at US 101 and Prado Road. As these planning documents are updated, they will be revised to include a collector-distributor roadway for the southbound ramps as the ultimate facility (beyond 2050) and in the near term the partial interchange at Prado with the reconfigured northbound ramps and an auxiliary lane between the Prado northbound on and Madonna northbound off-ramp.

The project would require realignment of Elks Lane east of US 101. The specific future alignment of Elks Lane would depend on the requirements of the three build alternatives.

The City also has an independent project to widen Prado Road from the planned Elks Lane realignment connection with Prado Road east to the western limits of the San Luis Obispo Creek Bridge Widening Project. The project will widen Prado Road to four lanes between the proposed interchange and San Luis Obispo Creek Bridge project improvements.

Transit Operator Planning
Transit service is currently provided by San Luis Obispo Transit (SLO Transit). SLO Transit is operated by the City and currently offers eight fixed routes. Within the project area, only Route 2A would be directly impacted by the proposed closure of Prado Road and Elks Lane at US 101 during construction of the new Prado Road overcrossing. Route 2A currently provides one way service seven days a week from/to the City’s Transit Center located on Osos Street between Palm Street and Mill Street. Within the project vicinity, this route runs southbound along Elks Lane from the intersection with South Higuera Street to Prado Road then eastbound to a transit stop located on the south side of Prado Road. Route 2A then continues eastbound on Prado Road before turning southbound at the intersection with South Higuera Street. This area along Prado Road is a prominent services location for the City’s homeless population, and at minimum, consideration should be given to constructing the Elks Lane realignment as a first item of work to preserve Transit service here. Because of the new connection of Prado Road over the freeway, it may be possible to re-examine transit routing to take advantage of the new connection to save time.

05 – SLO – 101 - 26.5/27.3
8 SLO Transit will be notified in advance of the start of construction and provided road closure and/or detour information and schedules. Because of the proximity of the SLORTA Maintenance & Operations Facility, construction impacts will need to be closely coordinated.

C. Traffic
Current and Forecasted Traffic
US 101 just north of LOVR currently experiences over 60,000 vehicles per day on an average day with this volume projected to increase by almost 50% by the design year 2050. Continued growth in the use of US 101 for regional and interregional travel will contribute to this projected growth. Continued growth within the City of San Luis Obispo will result in an increase in local traffic to the projected growth in traffic on mainline US 101 and increases in traffic accessing US 101 from the LOVR interchange, the Prado Road NB off-ramp and NB on-ramps, and the Madonna Road interchange.

Table 4.1 shows the US 101 No-Build condition existing and forecasted design year freeway mainline and freeway on and off-ramp peak hour traffic volumes from south of the LOVR interchange north through the Madonna Road interchange, and on LOVR and Madonna Road on the respective overcrossing.

Table 4.1 – Existing and Forecasted Design Year Average Daily Traffic (No Build Condition)
US 101 Collision Analysis
Existing and Forecasted Average Daily Traffic (ADT) Volumes Los Osos Valley Road (LOVR) 22,600 37,400
Prado Road N/A N/A
Madonna Road 23,500 31,400
Mainline S. of LOVR 72,400 102,300
NB Off-Ramp to LOVR 8,600 11,390
NB On-Ramp from LOVR 5,000 6,500
SB On-Ramp from LOVR 9,100 12,340
SB Off-Ramp to LOVR 6,500 7,890
Mainline N. of LOVR 65,300 91,200
NB Off-Ramp to Prado Rd. 1,600 2,800
NB On-Ramp from Prado Rd. 3,770 5,290
Mainline N. of Prado Rd 65,300 90,300
SB On-Ramp from Madonna Rd. 5,540 8,130
NB Off-Ramp to Madonna Rd. 5,350 5,150
SB Off-Ramp to Madonna Rd. 8,630 11,890
NB On-Ramp from Madonna Rd. 3,500 4,010
Mainline N. of Madonna Rd. 65,300 89,700
Location Existing Design Year
Cross Streets (at US 101 O.C.)
US 101

05 – SLO – 101 - 26.5/27.3
9 Caltrans’ Highway Safety Improvement Program (HSIP) has been developed as a comprehensive effort to reduce the number and severity of collisions on State and Local roads. Monitoring systems are in place that identify collision concentrations where collision history may indicate a pattern susceptible to correction by a safety improvement project. Projects may be implemented at spot locations, or they may be system-wide improvements involving highway elements which are associated with collision frequency or severity.

US 101 NB Mainline between Los Osos Valley Road (LOVR) and Prado Road Interchanges
Collision rates for US 101 NB mainline between the LOVR interchange (PM 25.9) and the Prado Road interchange (PM 26.8) were obtained from Traffic Accident Surveillance and Analysis System (TASAS) – Transportation Systems Network (TSN) for the five-year period between July 1, 2015 and June 30, 2020. Table 4.2 summarizes the collision data for this five-year period.

4.2 - Table B Collision Data Summary (July 1, 2015 to June 30, 2020) US 101 Mainline
Segment (PM-PM)
Number of Collisions
Actual Collision Rate
(acc/million veh miles)
Average Collision Rate
(acc/million veh miles)
Total Fatal F + I Fatal F+I Total Fatal F+I Total
US 101 NB (25.991
-26.849)
19 0 7 0.000 .12 .34 0.006 .29 .83
Notes:

1. Collision Rates are measured in collisions per million vehicle miles As shown in Table 4.2, 19 collisions (0-Fatal, 7-Injury, 12-Property Damage Only (PDO)) were reported on US 101 NB between PM 25.9 and PM 26.8. Thirteen (13) of the collisions involved multiple vehicles. The reported collision types are as follows:

Type of Collision Number of Collisions
Hit Object 6
Rear End 7
Sideswipe 4
Other 2
The predominant vehicle direction of travel was NB (100%), and the vehicle movements preceding the collision are as follows:

Movement
Preceding Collision
Number
Proceeded Straight 13
Ran Off Road 2
Slowing, Stopping 5
Changing Lanes 5
Stopped 4
Other 2

05 – SLO – 101 - 26.5/27.3
10 The project is not anticipated to contribute to the collisions reported on NB US 101 between the two interchanges and no improvements are proposed to mainline US 101 with the project.

US 101 / Prado Road Interchange Ramps Collision Analysis Collision rates for both the US 101 NB off-ramp to, and on-ramp from Prado Road were obtained from Traffic Accident Surveillance and Analysis System (TASAS) – Transportation Systems Network (TSN) for the five-year period between July 1, 2015 and June 30, 2020. Table 4.3 summarizes the collision data for each ramp for this fiveyear period.

Table 4.3 -Table B Collision Data Summary (July 1, 2015 to June 30, 2020) Location (PM)
Number of Collisions
Actual Collision Rate
(acc/million veh)
Average Collision Rate
(acc/million veh)
Total Fatal F + I Fatal F+I Total Fatal F+I Total
US 101 NB Off to
Prado Road
(26.730)
0 0 0 0.000 .00 .00 0.026 .38 1.01
US 101 NB On
from Prado Road
(26.990)
2 0 0 0.000 .00 .26 0.007 .21 .61
Notes:

1. Collision Rates are measured in collisions per million vehicles As shown in the table, there were no collisions reported on the US 101 off-ramp to Prado Road during the five-year period. Two (2) collisions, all PDO, were reported on the NB US 101 on-ramp from Prado Road. Each of the collisions involved single vehicles and the reported collision type was Hit Object. One (1) collision was reported within the onramp entry from Prado Road and one (1) collision was reported within the on-ramp. The project includes reconstruction of the NB on-ramp from Prado Road and this improvement is anticipated to improve safety and not contribute to any increase in collision rates within the on-ramp.

US 101 NB Mainline between Prado Road and Madonna Road Interchanges Collision rates for US 101 NB mainline between the Prado Road interchange (PM 26.8) and the Madonna Road interchange (PM 27.5) were obtained from Caltrans TASAS – TSN for the five-year period between July 1, 2015 and June 30, 2020. Table 4.5 summarizes the collision data for this five-year period.

Table 4.4 -Table B Collision Data Summary (July 1, 2015 to June 30, 2020) US 101 Mainline
Segment (PM-PM)
Number of Collisions
Actual Collision Rate
(acc/million veh miles)
Average Collision Rate
(acc/million veh miles)
Total Fatal F + I Fatal F+I Total Fatal F+I Total
US 101 NB (26.850
-27.500) 25 0 4 0.000 .10 .65 0.006 .28 .83
Notes:

1. Collision Rates are measured in collisions per million vehicle miles

05 – SLO – 101 - 26.5/27.3
11 As shown in the table, 25 collisions (0-Fatal, 4-Injury, 21-PDO) were reported on US 101 NB between PM 26.8 and PM 27.5. Twelve (12) of the collisions involved multiple vehicles. The reported collision types are as follows:

Type of Collision Number of Collisions
Hit Object 14
Rear End 8
Sideswipe 2
Broadside 1
The predominant vehicle direction of travel was NB (100%), and the vehicle movements preceding the collision are as follows:

Movement
Preceding Collision
Number
Proceeded Straight 13
Ran Off Road 6
Slowing, Stopping 5
Changing Lanes 1
Other Unsafe Turn 2
Merging 3
Other 4
The project includes construction of a new NB US 101 auxiliary lane between the onramp from Prado Road and the off-ramp to Madonna Road to improve operations between the two closely spaced interchanges. These improvements are anticipated to improve safety and not contribute to any increase in collision rates on NB US101 between the two interchanges.

US 101 / NB Madonna Road Off-Ramp Collision Analysis
Collision rates for the US 101 NB off-ramp to Madonna Road were obtained from TASAS –TSN for the five-year period between July 1, 2015 and June 30, 2020. Table

4.6 summarizes the collision data for this ramp for this five-year period.

Table 4.5 - Table B Collision Data Summary (July 1, 2015 to June 30, 2020) Location (PM)
Number of Collisions
Actual Collision Rate
(acc/million veh)
Average Collision Rate
(acc/million veh)
Total Fatal F + I Fatal F+I Total Fatal F+I Total
US 101 NB Off to
Madonna Road
(27.400)
14 0 6 0.000 .69 1.61 0.008 .39 1.03
Notes:

1. Collision Rates are measured in collisions per million vehicles Fourteen (14) collisions, (0-Fatal, 6 -Injury, 8-PDO) were reported on the US 101 NB off-ramp to Madonna Road. Twelve (12) of the collisions involved multiple vehicles.

The reported collision types are as follows:

Type of Collision Number of Collisions
Broadside 2

05 – SLO – 101 - 26.5/27.3
12 Rear End 10
Hit Object 1
Seven (7) collisions were reported on the ramp exit to Madonna Road, six (6) collisions were reported in the ramp area on Madonna Road and one (1) collision was reported within the off-ramp. There were no collisions reported within the ramp entry from NB US 101.

The predominant vehicle direction of travel was NB (63%), EB (26%) and WB (7%) and SB (4%). The vehicle movements preceding the collision are as follows:

Movement
Preceding Collision
Number
Proceeded Straight 12
Making Left Turn 3
Backing 1
Stopped 7
Slowing, Stopping 1
The project includes construction of a new NB US 101 auxiliary lane between the onramp from Prado Road and the off-ramp to Madonna Road to improve operations between the two closely spaced interchanges. Construction of the auxiliary will also require reconstruction of the ramp entry from NB US 101 to the off-ramp to Madonna Road. These improvements are anticipated to improve safety and not contribute to any increase in collision rates on the ramp entry. The project does not propose any improvements within the ramp, at the ramp exit to Madonna Road or within the Madonna Road intersection.

Highway Safety Manual (HSM) Predictive Collision Analysis The collision analysis was performed for the study area using the Enhanced Interchange Safety Analysis Tool (ISATe) per National Cooperative Highway Research Program (NCHRP) Project 17-45, May 31, 2012. This safety prediction methodology for freeways and interchanges is consistent with the Highway Safety Manual (HSM) 2014 Supplement, Chapters 18 and 19. ISATe uses the HSM Predictive Method (Part C and D) to estimate the expected average collision frequency (in total, or by collision type or severity) for a freeway with known characteristics. The predictive analysis results include predicted mainline, ramp, and ramp terminal collisions. The overall collision frequency is predicted based on the relationship of roadway geometric design features and safety. Since collisions are random in nature, safety is predicted based on adopted safety performance functions and collision modification factors (CMFs) developed from several studies of similar freeway facilities with different geometric characteristics. The predictive methodology can be used to make informed decisions about different build alternatives in the project development process in quantifying substantive safety.

All Build alternatives are very close in comparison, but Alternative A1R predicts the least collisions among the build alternatives in the design year 2050. Also, all alternatives show a slight increase in expected annual crash frequency when compared to the No Build alternative. This is due to the minor volume changes on US 101 mainline

05 – SLO – 101 - 26.5/27.3
13 within the project limits and increase in traffic volumes at Prado Road interchange with the Build alternatives. In addition, ISATe was not able to model a roundabout at the Prado Road ramp terminal. The roundabout intersection control was instead modelled as an all-way stop with a right turn yield control. The results of the predictive model distribute around 33% of the predicted crashes to the terminal component of the highway facility in the four alternatives analyzed. Therefore, as ISATe does not have the ability to correctly model a roundabout intersection treatment, there would be an impact to the roundabout alternative results. The 2022 Caltrans Local Roadway Safety Manual (LRSM) notes that converting an intersection with all way stop control to a roundabout (Countermeasure NS04) has a varied Crash Reduction Factor between 12%-78%. Thus, the results from the ISATe prediction may be overestimating the results of the roundabout alternatives slightly (Alt 1R & Alt 4R).

5. ALTERNATIVES
In addition to the No Build alternative, four (4) viable build alternatives were identified in the approved PSR-PDS. These include Alternative A1R, Alternative A3, Alternative A4R and Alternative A7. All except Alternative A7 continue to be considered during the environmental document circulation. Each of the viable build alternatives include a partial interchange with the proposed Prado Road overcrossing constructed over US 101 and new US 101 NB off-ramp to and on-ramp from Prado Road (these new ramps replace US 101 NB off and on-ramps that currently connect with Prado Road). The viable build alternatives would not preclude widening US 101 up to a six-lane facility (Ultimate Corridor Concept) with a collector distributor roadway and southbound ramp connections.

Within the approved PSR-PDS, each viable build alternative proposed retaining walls on the inside of the NB US 101 off and on-ramps with fill embankments (side slopes) proposed on the outside of the ramps and along Prado Road. After approval of the PSRPDS, the City of San Luis Obispo developed a two-dimensional (2D) hydraulic model to evaluate potential hydraulic impacts associated with the proposed Prado Road overcrossing and modified US 101 NB ramps. Two options were evaluated, the first option placing Prado Road and the US 101 NB off and on-ramps primarily on fill embankment (side slopes) generally consistent the PSR-PDS and, the second option placing Prado Road and the US 101 NB off and on-ramps primarily on piers (structure).

The results of the 2D hydraulic modeling was presented in the 2-Dimensional Hydraulic Model Update Final Report (October 2019). This report concluded that the fill embankments option was not a hydraulically feasible alternative as this alternative exceeds the City’s Drainage Design Manual (DDM) criteria since the import of fill becomes a barrier resulting in restriction of flood waters. A memorandum was prepared and submitted to Caltrans on February 11, 2022 recommending that, based on the report’s conclusions, the project’s viable build alternatives proceed only with placement of the majority of Prado Road and the US 101 NB off and on-ramps on structures.

Caltrans concurred with this recommendation on February 25, 2022.

Each viable build alternative would also encroach into the current floodplain located both to the east and west of U.S. 101. Improvements to reduce this encroachment include

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14 placing a portion of both the U.S. 101 northbound off-ramp and northbound on-ramp and a majority of the Prado Road (Dalidio Drive) extension west of U.S. 101 to the intersection with the future Froom Ranch Road/Dalidio Drive intersection on structures raised above the floodplain.
5A. Preferred Alternative
Alternative A3
Proposed Engineering Features
Alternative A3 is consistent with a Type L-1 tight diamond interchange configuration to the east of US 101. The proposed Alternative A3 design year improvements are shown in Attachments C & D. Interchange improvements associated with Alternative A3 include the following:
 construct a new four-legged traffic signal controlled intersection at the Prado Road intersection with the US 101 NB Ramps;
 construct a new single-lane NB US 101 off-ramp to Prado Road;  construct a new single-lane on-ramp from Prado Road to NB US 101;  construct a portion of both the US 101 NB off-ramp and NB on-ramp on structures;
 construct a majority of the Prado Road (Dalidio Drive) extension on structures from the intersection with the future Elks Lane east of US 101 to the intersection with the Froom Ranch Road/Dalidio Drive west of US 101;  construct Prado Road with a minimum 4-lane divided arterial section through and adjacent to the interchange with a separate 14.75-foot wide sidewalk/Class IV bikeway and 5-foot wide shoulder;
 provide crosswalks and Americans with Disabilities Act (ADA) accessible ramps along pedestrian facilities;
 construct an approximately 1,060-foot long auxiliary lane with a 12-foot paved width and 10-foot paved shoulder provided between the Prado Road NB onramp and the Madonna Road NB off-ramp; and  construct Maintenance Vehicle Pullout (MVPs) in appropriate locations as determined during District Maintenance and Safety review; and  construct new Midwest Guardrail System placed adjacent to the proposed northbound U.S. 101 auxiliary lanes outside shoulder.

Traffic Forecasts
Traffic forecasts and projected traffic operations for this alternative are provided in the TOAR and ICE. The TOAR provided projected design year (2050) AM and PM peak hour operations for Alternative A3. Table 5.4 provides the projected US 101 mainline, ramp merge and diverge, and weaving section peak levels of service (LOS) from south of the LOVR interchange north to the Marsh Street interchange.

Table 5.1 – Alternative A3 Design Year (2050) Peak Hour Mainline, Ramps and Weaving Section Operation

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15 The TOAR also provided projected 2050 AM and PM peak hour weave section operations using the Leisch Method with the results shown in Table 5.5. As shown in this table, the peak hour weaving LOS on the proposed NB auxiliary lane between the Prado Road and Madonna Road interchanges are projected to be LOS D or better.

Though LOS D does not meet the target LOS, HDM Index 504.7 notes that weaving sections in urban areas should be designed for LOS C or D.

Table 5.2 – Alternative A3 Design Year (2050) Peak Hour Weaving Sections Operations – Leisch Method
Finally, the TOAR provided projected 2050 AM and PM peak hour intersection operations for this alternative. Table 5.6 provides the projected LOS at the US 101 ramp intersections with LOVR, Prado Road and Madonna Road.

AM
LOS
PM
LOS
US 101 Northbound
US 101 South of LOVR C Freeway 2 E C
Off Ramp to LOVR C Diverge 1 E D
On Ramp from LOVR C Merge 1 D D
US 101 South of Prado Road C Freeway 2 D C
Off Ramp to Prado Road C Diverge 1 E D
US 101 North of Prado Road C Weave 3 C C
US 101 North of Madonna Road C Weave 3 C C
US 101 Southbound
US 101 South of Marsh Street C Weave 3 C D
On Ramp from Madonna Road C Merge 1 C F
US 101 South of Madonna Road C Freeway 2 C E
Off-Ramp to LOVR C Diverge 1 C F
On Ramp from LOVR C Merge 1 C F
US 101 South of LOVR C Freeway 2 B F
BOLD - LOS worse than Target LOS
Segment
Type
Target
LOS
Alternative A3
Interchange Location
No. of
Lanes
AM
LOS
PM
LOS
US 101 Northbound
US 101 North of Prado Road C Weave 3 C C
US 101 North of Madonna Road C Weave 3 D D
US 101 Southbound
US 101 South of Marsh Street C Weave 3 C D
BOLD - LOS worse than Target LOS
Alternative A3
Interchange Location
Target
LOS
Segment
Type
No. of
Lanes

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16 Table 5.3 – Alternative A3 Design Year (2050) Peak Hour Intersection Operations
BOLD – LOS worse than Target LOS
Proposed Nonstandard Design Features
Design Standards Risk Assessment
Alternative
Highway
Design
Manual Index
Type Highway
Design
Manual
Standard
Probability of
Design
Exception
Approval
Justification for Probability
Rating
A3
501.3, M
Interchange
Spacing
(1.0 mile
minimum in
Urban Areas)
B Interchange
Spacing
High
Existing roadway connections to
US 101, cannot be feasibly
relocated
A3
502.2 M
Partial
Interchange
B Partial
Interchange High
Existing partial interchange to be
maintained, plus City is reserving
R/W for future conversion to full
interchange.

A3
504.7 M
Minimum
Weave Length
(2000 feet
Urban Areas)
B Weaving
Length High
Project includes addition of an
auxiliary lane to connect the
interchange ramps.

A3
202.5(2) A
Superelevation
Runoff
U Superelevation
Runoff
High
Providing the standard
superelevation runoff length
would result in additional right of
way impacts to the adjacent RTA
facility and Sunset Drive-In
property.

A3
304.1 A
Embankment
Slopes
U Embankment
Slopes High
Most of Interchange will be built
on structures over freeway, with
steeper side slopes to minimize
AM
LOS
PM
LOS
Los Osos Valley Road/US 101 SB
Ramps
Signal C C B
Los Osos Valley Road/US 101 NB
Ramps
Signal C C B
Prado Road/US 101 NB Ramps Signal C B A
Madonna Road/US 101 NB Ramps Signal C B C
Madonna Road/US 101 SB
Ramps/Madonna Inn Signal C D C
Alternative A3
Control Type Target
LOS
Intersection

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17 impacts to environmentally
sensitive areas.

Interim Features
There are no interim features associated with this alternative.

High Occupancy Vehicle Lanes
There are no high occupancy vehicle lanes associated with this alternative.

Ramp Metering
The US 101/Prado Road interchange is not currently listed in the District 5 TCR as a potential location for ramp meters and provisions are not being made for future ramp metering with this alternative.

California Highway Patrol (CHP) Enforcement Activities
CHP enforcement areas are not included with this alternative. CHP enforcement activities will be required during construction.

Park and Ride Facilities
There are no Park and Ride facilities currently located at or immediately adjacent to the US 101/Prado Road interchange. Provision of a new Park and Ride facility is not considered with this alternative.

Utility Involvement
A Utility Information Sheet has been prepared for Alternative A3 and is included with the Right of Way Data Sheets in Attachment F. The following is a preliminary list of known utilities with potential longitudinal encroachment in existing or proposed access controlled right of way:
 Pacific Gas & Electric Company (PG&E) - overhead electric transmission lines;  AT&T - overhead and underground cables;
 Southern California Gas (SoCalGas) - 2-inch and 10-inch high pressure underground gas lines;
 Phillips Petroleum - two 8-inch underground petroleum pipelines;  Caltrans – two (2) recycled water distribution lines; and  City of San Luis Obispo - underground communications, sewer, water, recycled water, water well and fiber optic line.

At this time, it is not known which, if any utilities will need to be relocated. Refer to section 6d for further information.

Noise Barriers
The Noise Study Report (NSR- also reference section 6H, Noise Abatement Decision Report Section of this DPR) concluded that noise abatement was not required and noise barriers are not proposed as a project feature.

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18 Nonmotorized and Pedestrian Features
The City of San Luis Obispo Active Transportation Plan (ATP), approved in 2021 identifies a need for a Bicycle/Pedestrian Grade Separated Crossing of US 101 between Los Osos Valley Road and Madonna Road which could be a Protected Bicycle Path, Bike Lanes, or Class IV Cycle Tracks as part of a Grade Crossing project. With Alternative A3, a 14.75-foot wide sidewalk/Class IV bikeway and 5-foot wide shoulder will be provided along both the north and south sides of Prado Road through the project area.

Construction and Right of Way Cost Estimates
Capital cost estimates for construction and right of way were prepared for Alternative A3 with copies of the preliminary cost estimates included in Attachment E. The estimated capital cost to acquire the right of way and construct the full improvements of this alternative is $61,900,000 in the year 2025. A cost breakdown by major project elements is as follows. Capital outlay support costs are not included in the estimates.  Roadway/Roadside Item $ 10,500,000
 Structural Items $46,000,000
 Right of Way $ 5,400,000
 Total Capital Construction Costs $61,900,000
Effect of Alternative Proposal on Operations
The potential effects Alternative A3 will have on the design year capacity/operating characteristics of US 101 were analyzed in the TOAR. Based on the results of this analysis, Alternative A3 is projected to operate at a LOS D on the NB US 101 mainline between the LOVR and Prado Road interchanges during the AM peak hour. The respective projected No Build design year LOS at this location is LOS C. Alternative A3 is also projected to operate at LOS E on the SB US 101 off-ramp diverge to LOVR during the PM peak hour. The respective projected No Build design year LOS at this location is LOS D.
5B. Rejected Alternatives
No Build Alternative
The No-Build Alternative assumes no improvements to existing US 101 or the northbound off and on-ramps to/from Prado Road. This alternative also assumes that Prado Road also terminates at the northbound ramps/Elks Lane intersection as is the current condition. No construction activities would occur, and there would be no change in the operations of the existing interchange. This alternative does not meet the need and purpose of the proposed project.

Alternative A1
Alternative A1 was identified as a viable build alternative in the PSR-PDS. Alternative A1 was a Type L-1 tight diamond interchange configuration to the east of US 101.

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19 Interchange improvements associated with this alternative were similar to Alternative A1R, except that traffic signal control was provided at the Prado Road intersection with the US 101 NB ramps instead of a roundabout. The Final ICE was prepared subsequent to the PSR-PDS which provided a comprehensive evaluation of both the traffic signal control alternative and the roundabout alternative. Based on these evaluations, the Final ICE concluded that the roundabout alternative, Alternative A1R, represented the preferred intersection control. Caltrans reviewed the Final ICE and concurred with the findings. A memorandum was prepared and submitted to Caltrans on February 11, 2022 recommending that, based on the findings of the Final ICE, the roundabout alternative represented the preferred intersection control and Caltrans concurrence with this finding, Alternative A1 be no longer considered as a viable build alternative moving forward. Caltrans concurred with this recommendation on February 25, 2022.

Alternative A1R
Alternative A1R is similar in concept to a Type L-1 tight diamond interchange configuration to the east of US 101. The NB on and NB off-ramps meet in a roundabout intersection with Prado Road. Alternative A1R was identified as a viable alternative in the PSR-PDS but was rejected by the PDT. A meeting was held with City staff and Caltrans Design staff recommending that, due to the more complex structure design Alternative A1R be no longer considered as a viable build alternative moving forward.

Caltrans and the City concurred with this recommendation on April 24, 2023.

Alternative A2
Alternative A2 was a Type L-8 configuration (partial cloverleaf) with proposed loop NB off-ramp to and direct on-ramp from Prado Road located on the north side of Prado Road. Alternative A2 was identified as a viable alternative in the PSR-PDS that was rejected by the PDT due to the loss of a transportation asset, San Luis Obispo Regional Transit Authority’s (SLORTA) new facility, located in the northwest quadrant of the interchange and the less than standard weave length between Prado Road northbound on-ramp and Madonna Road northbound off-ramp. As a result, the PDT determined that Alternative 2 did not meet the project’s purpose and need and it was removed from further consideration.

Alternative A4
Alternative A4 was identified as a viable build alternative in the PSR-PDS. Alternative A4 was a Type L-7 partial cloverleaf interchange configuration to the east of US 101.

Interchange improvements associated with this alternative were similar to Alternative A4R except traffic signal control instead of a roundabout was provided at the Prado Road intersection with the US 101 NB ramps. The Final ICE was prepared subsequent to the PSR-PDS which provided a comprehensive evaluation of both the traffic signal control alternative and the roundabout alternative. Based on these evaluations, the Final ICE concluded that the roundabout alternative, Alternative A4R, represented the preferred intersection control. Caltrans reviewed the Final ICE and concurred with the findings. A memorandum was prepared and submitted to Caltrans on February 11, 2022 recommending that, based on the findings of the Final ICE that the roundabout

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20 alternative represented the preferred intersection control and Caltrans concurrence with this finding, Alternative A4 be no longer considered as a viable build alternative moving forward. Caltrans concurred with this recommendation on February 25, 2022.

Alternative A4R
Alternative A4R is similar in concept to a Type L-7 partial cloverleaf interchange configuration to the east of US 101. The NB on and NB off-ramps have sweeping curves and merge with Prado Road near the intersection with Elks Lane. Alternative A4R was identified as a viable alternative in the PSR-PDS but was rejected by the PDT. A meeting was held with City staff and Caltrans Design staff recommending that, due to the significant right of way needed from the City Corporation Yard, Alternative A4R be no longer considered as a viable build alternative moving forward. Caltrans concurred with this recommendation on April 24, 2023.

Alternative A7
Alternative A7 is similar in concept to a Type L-6 interchange configuration to the east of US 101. The NB on and NB off-ramps have sweeping curves and merge with Prado Road near the intersection with Elks Lane. Alternative A7 was identified as a viable alternative in the PSR-PDS but was rejected by the PDT. A meeting was held with City staff and Caltrans Design staff recommending that, due to the significant number of design exceptions and safety concerns that were identified after further study and Caltrans review, Alternative A7 be no longer considered as a viable build alternative moving forward. Caltrans and the City concurred with this recommendation on September 16, 2022.

6. CONSIDERATIONS REQUIRING DISCUSSION
6A. Hazardous Waste
An Initial Environmental Site Assessment was prepared for this project during the PID phase and provided to Caltrans for review. The initial conclusions from this study included the following:
 The properties along the proposed right of way have been in agricultural use as early as the 1930s and it is likely for the soil within the proposed project site to have been impacted with hazardous levels of pesticides, herbicides and arsenic (used as an herbicide in the early 20th century).
 The nearby roadways have supported vehicular activity since the middle of 20th century and it is likely that the surface soils are affected by deposition of aerial lead.  The roadway was built prior to the 1980s and it is likely that the surface markings and signs may contain asbestos-containing materials (ACM) and lead-based paint (LBP) in their construction materials.
 A petroleum pipeline is present within the project limits.

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21 The study recommended that additional studies and investigations will be required during PS&E to determine if hazardous waste/materials contamination is present within the project site.
6B. Value Analysis
A hybrid Value Analysis (VA) study, sponsored by the City of San Luis Obispo and the California Department of Transportation (Caltrans) District 5 and facilitated by Value Management Strategies, Inc. (VMS), was conducted for the Prado Interchange Project located in San Luis Obispo, California. The workshop was facilitated March 20-24, 2023, in-person and online using the WebEx virtual meeting platform. The document, VA Study Summary Report – Final Results provides an overview of the project, key findings, the alternatives developed by the VA team, and the decisions of the project stakeholders from the implementation meeting held April 24, 2023.

The VA team recommended six alternatives to be considered for implementation:

VA Alternative 1.0 – Reduce the maximum speed on structure to 35 mph; VA Alternative 2.0 – Reduce lane and shoulder widths where practical; VA Alternative 3.0 – Use CIDH columns in lieu of driven piles and pile caps; VA Alternative 4.0 – Use longer spans and fewer columns with precast I girders in lieu of CIP girders;
VA Alternative 5.0 – Leave existing sewer main on current Elks Lane alignment in lieu of relocation;
VA Alternative 6.0 – Utilize recycled and/or reclaimed materials in project.

The project stakeholders rejected one of the six developed VA study alternatives (5.0) and accepted two of the alternatives (2.0 & 6.0) for inclusion into the project design.

The remaining alternatives (1.0, 3.0 & 4.0) require significant additional analysis and investigation to determine if they are feasible alternatives to the current design. A decision was made by the PDT to defer the in-depth investigation of the remaining VA study alternatives to early in the PS&E phase. Caltrans Management staff has been briefed and there is concurrence with this approach. Deferring the further study is a strategy that is prudent to the current project schedule yet holds fast the intentions of the VA recommendations to determine if significantly changing the design will result in the cost and time savings that have been identified. 6C. Resource Conservation
Where feasible, existing materials and facilities would be preserved, either through salvaging and/or incorporating previously salvaged material from existing roadway facilities, such as signs, light standards, guardrails, and other associated hardware.

This approach would minimize the consumption, destruction, and disposal of nonrenewable resources. VA Recommendation 6.0, “Utilizing recycled and/or reclaimed materials in project” was agreed to by the PDT at the implementation meeting.

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22 6D. Right-of-Way Issues
Right of Way Required
A Right of Way Data Sheet for the preferred alternative is included in Attachment F.

Implementing this alternative will require acquiring approximately 0.6 acres of additional right of way from nine (9) parcels with no excess parcels. The project would require take of a portion of the City-owned Corporation Yard located south of Prado Road and east of US 101 (APN 053-051-045), which would result in the need for the City to relocate some operations from this facility to another location. No off-site relocation of corporation yard buildings is currently proposed as part of this action.

The preferred alternative also has right-of-way impacts to the planned SLORTA administration, operations, and bus maintenance facility located north of and adjacent to Prado Road and east of and adjacent to Elks Lane. Final alignment of Elks Lane will be determined in consultation with the owners of the SLORTA Facility & the 40 Prado Homeless Services Center.

Relocation Impact Studies
Relocations are not anticipated with the preferred alternative.

Railroad
Railroad involvement is not required for this project.

Utilities
Verification of utilities would be performed as an initial phase of PS&E. Each utility agency, with utilities in the project limits, would be notified and allocated time to respond to potential concerns. Utilities shown to be High Risk would be positively located in accordance with Caltrans Policy and the results would be plotted on the PS&E utility sheets. Relocation of the utilities would be coordinated with each agency or company to ensure standard requirements are met.

The following is the list of known utilities with potential longitudinal encroachment in existing or proposed access controlled right of way:
 Pacific Gas & Electric Company (PG&E) - overhead electric transmission lines;  AT&T - overhead and underground cables;
 Southern California Gas (SoCalGas) - 2-inch and 10-inch high pressure underground gas lines;
 Phillips Petroleum - two 8-inch underground petroleum pipelines;  Caltrans – two (2) recycled water distribution lines; and  City of San Luis Obispo - underground communications, sewer, water, recycled water, and water well.

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23 Based on the design of the preferred alternative and the observed location of the various utilities, it is assumed that utility relocations will be required. It is unknown at this time who will be responsible (project or provider) for utility relocations that will be required with the proposed project. The preliminary utility plans prepared for the project are included as Attachment F.

Airspace Lease Areas
Airspace leases are not within the project limits.
6E. Environmental Compliance
Caltrans is the lead agency under the California Environmental Quality Act (CEQA), and is the National Environmental Policy Act (NEPA) lead as assigned by the Federal Highway Administration (FHWA). The City, in coordination with Caltrans, has prepared an Initial Study (IS) for this project and, pending public review, expects to determine from this study that the proposed project would not have a significant effect on the environment. The Mitigated Negative Declaration (MND) has been prepared in accordance with Caltrans’ environmental procedures, as well as State and federal environmental regulations. The Draft IS/MND (Attachment A) is the appropriate document for the proposal.

The project would have no significant effect on forest resources; energy; greenhouse gas emissions; land use and planning; mineral resources; noise; population and housing; public services; recreation; transportation; utilities and service systems; and wildfire.

The project would have no significantly adverse effect on aesthetics; agricultural resources; air quality; biological resources; cultural resources; geology and soils; hazards and hazardous materials; hydrology and water quality; and tribal cultural resources because mitigation measures would reduce potential effects to insignificance.

Aesthetics
Mitigation Measure AES-1. Tree Protection and Replacement Plan. Before issuing grading or building permits, a Tree Protection and Replacement Plan will be prepared for the project based on the final grading and building plans. The Tree Protection and Replacement Plan will identify all trees within the project limits. The Tree Protection and Replacement Plan will stipulate that all trees not proposed for removal will be preserved and protected from harm during project construction activities (consistent with requirements of Mitigation Measure AES-2).

If, during the preparation of the Tree Protection and Replacement Plan, it is discovered that trees within the project study area must be removed, the Caltrans Design Engineer and District Landscape Architect will agree that tree removal is necessary before final approval of the project plans. Where trees are authorized by Caltrans for removal, they will be replaced with native or other horticulturally appropriate species suitable for the area at a minimum ratio of three new trees for each tree removed, as directed by the

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24 Caltrans District Landscape Architect. All replacement planting will include a minimum three-year plant establishment period.

The project specifications will include provisions requiring the protection of all trees as directed in this measure, and the cost estimate will include adequate funds for identified tree protection measures and tree replacement and maintenance measures, if necessary.

Mitigation Measure AES-2. Tree Protection. All qualifying trees within 25 feet of proposed ground disturbances that will be retained will be temporarily fenced with chain-link or other material throughout all grading and construction activities. The fencing shall be installed outside the dripline of each tree or as far from the trunk as is feasible while accommodating project construction and be shown in the Tree Protection and Replacement Plan. No construction equipment shall be staged, parked, or stored within the dripline of any qualifying tree. If project construction requires activities within the dripline of a tree that is proposed to be retained, an arborist shall be present during ground-disturbing work under the dripline.

Mitigation Measure AES-3. Landscape Plan. A landscape plan shall be developed by the city and approved by the District Landscape Architect before project approval. The landscape plan shall consist of plantings that offer a variety of colors, shapes, and species with an emphasis on drought-tolerant, native plant materials. The landscape plan shall include plantings along constructed walls and structures as well as benched and graded areas within the project corridor to soften visual changes and reduce the visual scale of new project features. Landscaping shall be overseen for a minimum period of two years or as determined by the District Landscape Architect.

Agricultural Resources
Mitigation Measure AG-1. Agricultural Conservation. The city shall provide that for every 1 acre of Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) on the site that is permanently converted to nonagricultural use as a result of the Elks Lane realignment, one (1) acre of comparable land in agricultural production shall be preserved in perpetuity. The land dedicated to agriculture pursuant to this measure shall be of the size, location, and configuration appropriate to maintain a viable, working agricultural operation. Said mitigation shall be satisfied through:
 Granting a perpetual conservation easement(s), deed restriction(s), or other farmland conservation mechanism(s) to a qualified conservation organization that has been approved by the city, or establishing a perpetual conservation easement(s) or deed restriction(s) held by the city or other farmland conservation mechanism(s), for the purpose of permanently preserving agricultural land. The land covered by said onsite and/or offsite easement(s) or deed restriction(s) shall be located within or contiguous to the city’s Urban Reserve Line or Greenbelt, subject to review and approval of the city’s Natural Resources Manager; or  Making an in-lieu payment to the City of San Luis Obispo’s Open Space Fund to be applied toward the future purchase of a perpetual conservation easement(s) or deed restriction(s) held by the city or other farmland conservation

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25 mechanism(s), for the purpose of permanently preserving agricultural land. The land covered by said onsite and/or offsite easement(s) or deed restriction(s) shall be located within or contiguous to the city’s Urban Reserve Line or Greenbelt, subject to review and approval of the city’s Natural Resources Manager. The amount of the payment shall be sufficient to conserve similar land on a per acre basis, as determined by a licensed appraiser; or
 Making an in-lieu payment to a qualified conservation organization that has been approved by the city and that is organized for conservation purposes, to be applied toward a future purchase of comparable agricultural land, or a perpetual conservation easement, deed restriction, or other farmland conservation mechanism to preserve the required amount of agricultural land in San Luis Obispo County. The amount of the payment shall be sufficient to conserve similar land on a per acre basis, as determined by the qualifying entity or a licensed appraiser; or
 Any combination of the above.

Air Quality
Mitigation Measure AQ-1. Fugitive Dust and Emissions Control Measures.

Construction projects shall implement the following dust control measures to reduce fugitive particulate matter emissions in accordance with District requirements. All fugitive dust mitigation measures shall be shown on grading and building plans:
 Reduce the amount of the disturbed area where possible;  Use of water trucks or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site and from exceeding the APCD’s limit of 20% opacity for greater than 3 minutes in any 60-minute period. Increased watering frequency would be required whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water should be used whenever possible. When drought conditions exist and water use is a concern, the contractor or builder should consider use of a dust suppressant that is effective for the specific site conditions to reduce the amount of water used for dust control. Please refer to the following link from the San Joaquin Valley Air District for a list of potential dust suppressants: Products Available for Controlling Dust;
 All stockpiled dirt should be sprayed daily and covered with tarps or other dust barriers as needed;
 All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible, and building pads should be laid as soon as possible after grading unless seeding, soil binders or other dust controls are used;  All trucks hauling dirt, sand, soil, or other loose materials are to be covered or should maintain at least two feet of freeboard (minimum vertical distance between top of load and top of trailer) or otherwise comply with California Vehicle Code (CVC) Section 23114;
 “Track-Out” is defined as sand or soil that adheres to and/or agglomerates on the exterior surfaces of motor vehicles and/or equipment (including tires) that may then fall onto any highway or street as described in CVC Section 23113 and California Water Code 13304. To prevent ‘track out’, designate access points

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26 and require all employees, subcontractors, and others to use them. Install and operate a ‘track-out prevention device’ where vehicles enter and exit unpaved roads onto paved streets. The ‘track-out prevention device’ can be any device or combination of devices that are effective at preventing track out, located at the point of intersection of an unpaved area and a paved road. Rumble strips or steel plate devices need periodic cleaning to be effective. If paved roadways accumulate tracked out soils, the track-out prevention device may need to be modified;
 All fugitive dust mitigation measures shall be shown on grading and building plans;
 The contractor or builder shall designate a person or persons whose responsibility is to ensure any fugitive dust emissions do not result in a nuisance and to enhance the implementation of the mitigation measures as necessary to minimize dust complaints and reduce visible emissions below the APCD’s limit of 20% opacity for greater than 3 minutes in any 60-minute period. Their duties shall include holidays and weekend periods when work may not be in progress (for example, wind-blown dust could be generated on an open dirt lot). The name and telephone number of such persons shall be provided to the APCD Compliance Division prior to the start of any grading, earthwork, or demolition (Contact the Compliance Division at 805-781-5912).
 Permanent dust control measures identified in the approved project revegetation and landscape plans should be implemented as soon as possible, following completion of any soil disturbing activities;
 Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading should be sown with a fast germinating, non-invasive grass seed and watered until vegetation is established;  All disturbed soil areas not subject to revegetation should be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the APCD;
 Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site;
 Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers shall be used with reclaimed water where feasible. Roads shall be pre-wetted prior to sweeping when feasible; and  Take additional measures as needed to ensure dust from the project site is not impacting areas outside the project boundary.

Construction projects shall implement the following emission control measures to reduce particulate matter and toxic air contaminant emissions from idling diesel engines.

All emission control measures shall be shown on grading and building plans.  Staging and queuing areas shall not be located within 1,000 feet of sensitive receptors;
 Diesel idling within 1,000 feet of sensitive receptors shall not be permitted;  Use of alternative fueled equipment is recommended; and  Signs that specify no idling areas must be posted and enforced at the site.

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27 Biological Resources
Mitigation Measure BIO-1. California Red-Legged Frog and Coast Range Newt. The city shall implement the following to avoid and minimize potential impacts to California red-legged frog and Coast Range newt. Because these species utilize similar habitats, the implementation of the following measures shall be implemented for both species.  A qualified biologist(s) shall conduct a preconstruction survey within 48 hours before the start of any work activities within and around the project disturbance footprint. If the preconstruction survey identifies the presence of individuals of California red-legged frog or Coast Range newt, or if individuals of these species are encountered during construction, then work shall stop work and comply with all relevant requirements of the Federal Endangered Species Act before resuming project activities.
 No motorized equipment shall enter riparian areas. Arroyo willow tree removal shall be performed with hand tools only.
 Before trimming or removing trees within riparian areas, a qualified biologist shall conduct a training session for the tree removal crew. At a minimum, the training shall include a description of the California red-legged frog and its habitat and Coast Range newt and its habitat, the specific measures that are being implemented to conserve the California red-legged frog and Coast Range newt for the project, and the boundaries within which the project may be accomplished.
 A biological monitor familiar with semi-aquatic species that have the potential to occur shall monitor the trimming or removal of trees within riparian areas. If California red-legged frog or Coast Range newt are observed in the work area, all shall stop work until all relevant requirements of the federal Endangered Species Act have been implemented.
 All areas of the project site disturbed by activities associated with the project shall be re-vegetated with an assemblage of native riparian, wetland, and upland vegetation suitable for the area as detailed in the Landscape Plan and approved by the District Landscape Architect. Locally collected plant materials shall be used to the extent practicable.

Mitigation Measure BIO-2. Southwestern Pond Turtle. The city shall ensure the following actions are implemented to avoid and minimize potential impacts to the southwestern pond turtle :
 Qualified biologist(s) shall conduct a preconstruction survey within 48 hours before the start of work activities within and around areas that may serve as potential habitat for the southwestern pond turtle, including guard rail and erosion control installation. If individuals of the southwestern pond turtle are found, the approved biologist shall be allowed sufficient time to move them from the project site before work activities begin. The biologist(s) shall relocate any individual southwestern pond turtle the shortest distance possible to a location that contains suitable habitat that is not likely to be affected by activities associated with the project.

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28  Access routes, staging, and construction areas shall be limited to the minimum area necessary to achieve the project goal and minimize potential impacts to southwestern pond turtle habitat, including locating access routes and construction staging areas outside of wetlands and riparian areas to the maximum extent practicable.
 Before the start of construction activities, high-visibility orange construction fencing shall be installed along the perimeter of the area of disturbance and construction access routes to ensure avoidance of sensitive habitat.  Before starting construction activities, a qualified biologist(s) shall conduct a training session for all construction personnel conducting vegetation removal activities, including a description of the southwestern pond turtle, its habitat and legal status, and the need for conservation of the species.

Mitigation Measure BIO-3. South-Central California Coast steelhead trout. The applicant shall ensure the following actions are undertaken to avoid and minimize potential impacts to steelhead :
 Before any activities begin on the project, a qualified biologist shall conduct a training session for all construction personnel. The training shall include a description of the steelhead and its habitat, the specific measures that are being implemented to conserve this species for the current project, and the boundaries within which the project may be accomplished.
 Before starting construction activities, high-visibility orange construction fencing shall be installed outside of the tops of the banks of San Luis Obispo Creek along the limits of the proposed disturbance to avoid disturbance to steelhead and its federally designated critical habitat. Fencing shall be located a minimum of 20 feet from the edge of the riparian canopy or top of the bank and shall be maintained throughout the construction period. Once construction in this area is complete, the fencing may be removed.
 During the duration of project activities, waste shall be properly contained and secured, promptly removed from the work site, and disposed of regularly.

Following construction, all trash and construction debris shall be removed from the work areas.
 Project construction activities within 50 feet from the edge of the riparian canopy or top of the bank of San Luis Obispo Creek shall only occur during the dry season (e.g., between May 1 and November 1) in any given year, when potential effects to steelhead would be minimal.
 To control sedimentation during and after project implementation, the following Best Management Practices shall be implemented for the project. It shall be the city’s responsibility to maintain control of construction operations and to keep the entire site in compliance with required Best Management Practices. o Erosion shall be controlled by covering stockpiled construction materials (i.e., soil, spoils, aggregate, fly ash, stucco, hydrated lime, etc.) over 2.0 cubic yards that are not actively being used, consistent with the applicable construction general permit, or through other means of erosion control approved by the city (e.g., temporary erosion and sediment control). The site shall be maintained to minimize sedimentPage 577 of 753 05 – SLO – 101 - 26.5/27.3
29 laden runoff to any storm drainage system, including existing drainage swales and/or sand watercourses.
o If grading operations are expected to denude slopes, the slopes shall be protected with erosion control measures immediately following grading on the slopes.
o During construction, to prevent sedimentation and debris from entering San Luis Obispo Creek during construction, a temporary large sediment barrier shall be installed along the top of the banks of the channel before the start of construction activities planned for the project. o Equipment will be checked daily for leaks before the start of construction activities. A spill kit will be placed near the creek and will remain readily available during construction if any contaminant is accidentally released. o The project biologist will monitor construction activities, in-stream habitat, and overall performance of Best Management Practices and sediment controls to identify and reconcile any condition that could adversely affect steelhead or their habitat. The biologist will stop work if necessary and will recommend site-specific measures to avoid adverse effects to steelhead and their habitat.
o The city shall be responsible for monitoring erosion and sediment control measures (including but not limited to fiber rolls, inlet protections, and gravel bags) before, during, and after storm events. Monitoring includes maintaining a file documenting onsite inspections, problems encountered, corrective actions, notes, and a map of remedial implementation measures.

Mitigation Measure BIO-4. Nesting Birds. The city shall ensure the following actions are undertaken to avoid and minimize potential impacts to nesting birds :
 For construction activities occurring during the nesting season (generally February 1 to September 15), surveys for nesting birds covered by the California Fish and Game Code and/or Migratory Bird Treaty Act shall be conducted by a qualified biologist no more than 3 days before vegetation removal or initial construction activities. The surveys shall include the disturbance area plus a 500- foot buffer around the site, where feasible, accounting for private property rightof-entry constraints. If active nests are located, all construction work shall be conducted outside a buffer zone from the nest to be determined by the qualified biologist. The buffer shall be a minimum of 250 feet for non-raptor bird species and 500 feet for raptor species unless there is a compelling biologically valid reason for a smaller buffer (e.g., a physical barrier, such as a hill or large building, between the nest and the site, blocks line of sight and reduces noise).

Larger buffers may be required depending upon the status of the nest and the construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and the young have fledged the nest before removal of the buffer. Readily visible exclusion zones shall be established in areas where nests must be avoided.

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30  Removal of vegetation within suitable nesting bird habitats shall be scheduled to occur in the fall and winter (between September 16 and January 31), after fledging and before the initiation of the nesting season.  If active white-tailed kite nests are located during surveys, all construction work shall be conducted outside a buffer zone from the nest to be determined by the qualified biologist. The buffer shall be a minimum of 300 feet for raptor species, including white-tailed kites. Larger buffers may be required depending upon the status of the nest and the construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and the young have fledged the nest before the buffer is removed.

Mitigation Measure BIO-5. Invasive Species. The city shall ensure the following actions are undertaken to avoid and minimize potential impacts associated with invasive species in the project area :
 Before construction, a qualified botanist/biologist shall provide invasive plant prevention training and an appropriate identification/instruction guide to staff and contractors. A list of target species shall be included, along with measures for early detection and eradication.
 Before construction, specific areas shall be designated for cleaning tools, vehicles, equipment, clothing, footwear, and other gear.  Before entering and exiting the work site, all tools, equipment, vehicles, clothing and footwear, and other gear shall be cleaned to remove soil, seeds, and other plant parts.
 The reproductive parts of any invasive plants, such as seeds, mature flowers, and roots/shoots of species that can reproduce vegetatively, shall be contained in sealed containers and removed from the project site and disposed of at a licensed landfill/disposal site. Before transporting invasive plant materials, the receiving areas of the landfill/disposal site shall be confirmed by the city as designated for invasive plant waste disposal. The city shall ensure that 100 percent containment of invasive plant materials is enforced during the transport of invasive plants to the disposal site.
 All disturbed areas that are not converted to hardscape or formally landscaped shall be hydroseeded with a mix of locally native species upon completion of work in those areas. In areas where construction is ongoing, hydroseeding shall occur where no construction activities have occurred before winter rains. If exotic species invade these areas before hydroseeding, weed removal shall occur in consultation with a qualified botanist/biologist. Alternatively, in areas not suitable for hydroseeding, areas that are not hardscaped and are planned for formal landscaping shall be mulched to reduce the potential for invasive species to colonize. Mulch shall be at least four inches thick and shall be weed free.

Mitigation Measure BIO-6. Riparian Habitat. The city shall ensure the following actions are undertaken to avoid and minimize potential impacts to riparian habitat and jurisdictional areas :

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31  All refueling, maintenance, and staging of equipment and vehicles shall occur at least 100 feet from riparian habitat or bodies of water and in a location where a potential spill would not drain directly toward aquatic habitat (e.g., on a slope that drains away from the water source). Before the start of work activities, a plan must be in place for a prompt and effective response to any accidental spills.

All workers shall be informed of the importance of preventing spills and of the appropriate measures to take should an accidental spill occur.  Raw cement, concrete or washings thereof, asphalt, paint or other coating material, oil or other petroleum products, or any other substances that could be hazardous to aquatic species resulting from project-related activities shall be prevented from contaminating the soil and/or entering jurisdictional areas.  To control sedimentation during and after project implementation, appropriate erosion control Best Management Practices (e.g., temporary erosion and sediment control) shall be implemented to minimize adverse effects on San Luis Obispo Creek. Plastic monofilament erosion control matting shall not be implemented onsite.
 Before the start of construction activities, high-visibility orange construction fencing shall be installed along the limits of the proposed disturbance outside of the top of the western bank of San Luis Obispo Creek and its associated riparian habitat to minimize the potential for disturbance of this area.  Project activities within 60 50 feet of San Luis Obispo Creek shall occur during the dry season (e.g., between May 1 and November 1) in any given year.

Mitigation Measure BIO-7. Habitat Mitigation and Monitoring Plan. A Habitat Mitigation and Monitoring Plan shall be prepared, which will provide a minimum 2-to1 restoration ratio (replaced to removed) for permanent impacts to riparian habitat unless otherwise directed by pertinent regulatory agencies. Mitigation activities associated with the replacement of riparian habitat shall occur in the designated sensitive habitat mitigation portion of the Biological Study Area and shall avoid additional impacts to sensitive plant or wildlife species. All areas of temporary disturbance shall be stabilized and revegetated with an assemblage of native vegetation suitable for the area. Examples of activities associated with the implementation of the Habitat Mitigation and Monitoring Plan include the application of native willow/ riparian seed mix and the removal of non-native weedy species within the habitat mitigation area. The final Habitat Mitigation and Monitoring Plan will be implemented immediately after project completion.

Cultural Resources
Mitigation Measure CR-1 Unidentified Cultural Materials. If archaeological resources are exposed during construction, all work shall be halted within 50 feet of the exposed resource until a qualified archaeologist can visit the site of discovery and assess the significance of the find(see 36 Code of Federal Regulations 800.11.1 and California Code of Regulations, Title 14, Section 15064.5[f]).

Examples of cultural materials that could be exposed during construction include ground stone tools such as mortars, bowls, pestles, and manos; chipped stone tools such as

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32 projectile points or choppers; flakes of stone not consistent with the immediate geology such as obsidian or fused shale; historic trash pits containing bottles and/or ceramics; or structural remains. If the resources are found to be significant, they must be avoided or will be mitigated consistent with State Historic Preservation Officer Guidelines.

Geology and Soils
Mitigation Measures GEO-1 Paleontological Resources. If paleontological resources are exposed during construction, all work shall be halted within 100 feet of the exposed resource until a qualified paleontologist can visit the site of discovery and assess the significance of the find. Caltrans shall be informed of the discovery immediately. If the paleontological resource is determined to be significant, the paleontologist shall have the authority to salvage and remove the fossil from its locality, as appropriate, before ground-disturbing or other construction activities resume in the area. Any fossils recovered during the development, along with their contextual stratigraphic data, shall be offered to the City of San Luis Obispo or other appropriate institution with an educational and research interest in the materials. The paleontologist shall prepare a report of the results of any findings as part of a testing or mitigation plan following an accepted professional practice.

Hazards and Hazardous Materials
HAZ-1 Aerially-Deposited Lead. A workplan shall be developed for aerially deposited lead sampling for the area of the selected project alternative. Surficial soil samples shall be collected and analyzed for total lead in areas that are to be disturbed for the project. The workplan shall require the investigation of surface soils to be conducted before construction. The workplan shall include all required measures for proper management and disposal of contaminated soils in accordance with the U.S.

Toxic Substances Control Act, California Health and Safety Code, and California Occupational Safety and Health Act if the total lead is detected above acceptable levels in the project site soils. The workplan shall require that investigation and/or remediation of soil contamination be performed in accordance with Department of Toxic Substances Control procedures and requirements and require Department of Toxic Substances Control approval before recommencing construction or demolition work.

HAZ-2 Pesticides and Herbicides. Surface soils shall be tested by a professional geologist or environmental professional to determine the presence or absence of pesticides, herbicides, and arsenic along proposed rights-of-way. A workplan describing sampling locations and sampling and analytical methods shall be prepared by the project developer before the start of work. The workplan shall include laboratory data for the impacted soils to profile excavated soil before transport, treatment, and recycling at a licensed treatment facility. The workplan shall also detail the requirements for removal, transportation, and disposal of impacted soil in accordance with applicable federal, state, and local laws, regulations, and ordinances. The workplan shall require that investigation and/or remediation of soil contamination be performed in accordance with Department of Toxic Substances Control procedures and requirements and require Department of Toxic Substances Control approval before recommencing construction or demolition work.

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33 HAZ-3 Petroleum Pipelines. The petroleum pipeline at the intersection of Elks Lane and Prado Road shall be properly marked by the developer before the start of any project construction activities. A contingency plan shall be developed by the developer and include all applicable federal, state, and local regulatory requirements for soil handling and/or remediation if contaminated soil from the petroleum pipeline is encountered during construction activities. All other known pipelines in the project area shall be identified and marked by the developer before the start of any construction activities.

Hydrology and Water Quality
Implementation of Avoidance, Minimization, and/or Mitigation Measure BIO-3 would reduce impacts to hydrological resources to a less than significant level.

Tribal Cultural Resources
Implementation of Avoidance, Minimization, and/or Mitigation Measure CR-1 would reduce impacts to tribal cultural resources to a less than significant level.

Mandatory Findings of Significance
Implementation of Avoidance, Minimization, and/or Mitigation Measures AG-1, AQ-1, BIO-1 through BIO-7, CR-1, GEO-1, and HAZ-1 through HAZ-3 would reduce impacts to tribal cultural resources to a less than significant level. 6F. Air Quality Conformity
The Project has been designed to improve roadway operations and would not interfere with timely implementation of Transportation Control Measures (TCMs) identified in the State Implementation Plan (SIP) and regional conformity analysis. Typical TCMs, such as improved public transit, traffic flow improvements, and pedestrian/bicycle facilities, would be implemented by the Project. Because the Project would improve long-term roadway operations in the vicinity of the project, the improvements proposed by the Project would reduce the need for additional TCMs.

Conformity at the Project-level requires “hot spot” analysis if an area is classified as federal “nonattainment” or “maintenance” for CO and/or PM2.5 or PM10. On March 10, 2006, the USEPA published a final rule that establishes the transportation conformity criteria and procedures for determining which transportation projects must be analyzed for local air quality impacts in PM2.5 and PM10 non-attainment and maintenance areas. The Project is located in the City of San Luis Obispo in the Basin, which is classified as a non-attainment-transitional area for the State standard for PM10.

The San Luis Obispo County portion of the Basin is in attainment for the State standards for CO and is unclassified for the State standard for PM2.5. According to the USEPA Transportation Conformity Guidance, PM2.5 hot-spot analysis is required for Projects of Air Quality Concern (POAQC) in non-attainment areas for federal PM10 and PM2.5 standards (40CFR 93.123 [b][1]). Projects that are exempt or not POAQC do not require hotspot analyses. As a result, the Project does not require a hot spot analysis. In addition,

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34 the Project is exempt from regional conformity requirements pursuant to 40 CFR

93.127.

The project proposes to extend Prado Road over US 101 to connect with Dalidio Drive and reconstruct the existing US 101 NB on- and off-ramp connections to Prado Road.

The preferred alternative includes a partial interchange with the proposed Prado Road overcrossing. The preferred alternative considers a traffic signal control design option for the interchange intended to reduce congestion. Therefore, the Project constitutes an interchange configuration project that is designed to improve traffic flow and vehicle speeds and would not involve increases in idling. As a result, the Project is not of Air Quality Concern under 40 CFR 93.123(b)(1)(i) and (ii) and does not require a hot spot analysis. In addition, the Project is exempt from regional conformity requirements pursuant to 40 CFR 93.127.

The Project is included in the San Luis Obispo Council of Governments’ (SLOCOG) 2019 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) project list (SLOCOG 2019). The project is listed as a “constrained” project; therefore, it is a fundable improvement project that is within the 2019 RTP 25-year planning horizon.
6G. Title VI Considerations
The purpose of the project is to efficiently convey traffic safely through the Prado Road at US 101 interchange as well as enhance mobility for all travel modes. Bicycle and pedestrian facilities would be provided by a new sidewalk/Class IV bikeway provided along both the north and south sides of Prado Road through the project area, which would make the interchange more accessible and safer for users. The changes to access in the immediate area of the project would not adversely affect the community, as the improvements would enhance circulation and access in the area.

During construction, temporary roadway closures might disrupt routines of community members for a short period of time. Residents and businesses whose access may be impacted would be notified in advance of construction activity and a Transportation Management Plan (TMP) would be in place to manage construction, detours, etc.

The proposed project has no potential to cause disproportionately high and adverse effects on any minority or low-income populations. No division of existing neighborhoods or disruption of routines would result from implementation of the project. Transportation benefits of the proposed project would accrue to all area residents.
6H. Noise Abatement Decision Report
No significant changes in noise levels are expected within the proposed project area and therefore, there is no noise abatement required. The Noise Study Report (NSR) identified that design year traffic conditions noise impacts from the project would not result in a significant noise impact. Traffic noise impacts from the project

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35 would not approach or exceed the noise abatement criteria (NAC) for Activity Category B (residential) or for Activities C or E.

The NSR also identified that no adverse noise impacts from construction are anticipated because temporary construction would be conducted in accordance with Caltrans Standard Specifications Section 14.8-02, limiting nighttime construction activities.

Additionally, construction noise would be short-term in duration and intermittent.

As noise abatement was found not to be required, noise barriers are not proposed as a project feature. However, the preliminary noise abatement decision presented in this report is based on preliminary project alignments and profiles, which may be subject to change. As such, the physical characteristics of noise abatement described herein also may be subject to change. If pertinent parameters change substantially during the final project design, the preliminary noise abatement decision may be changed or eliminated from the final project design. A final decision to construct noise abatement will be made upon completion of the project design. The preliminary noise abatement decision presented here will be included in the draft environmental document, which will be circulated for public review.
6I. Reversible Lanes
Reversible lanes have not been considered.

7. OTHER CONSIDERATIONS AS APPROPRIATE
Public Hearing Process
A public hearing was held on March 6, 2023 at the City’s Corporation Yard.

Approximately 30 people attended and were provided with a presentation of the project features and the Environmental Approval process, and allowed to ask questions of City, Caltrans and consultant staff who were present. Comment cards were provided so those interested could submit comments on the circulating Draft Environmental Document.

Route Matters
There is an existing Freeway Agreement between the State of California (Caltrans) and the City of San Luis Obispo dated July 3, 1972. The Freeway Agreement includes the segment of US 101 between 0.5-mile south of Los Osos Valley Road overcrossing and

0.4-mile south of Madonna Road overcrossing and encompasses the existing US 101 northbound off-ramp and on-ramp connections with Prado Road. According to Caltrans Project Development Procedures Manual, Chapter 24 – Freeway Agreements, Article 8 – Resolutions of Change, and based on Caltrans opinion of this project’s impacts, the proposed project would be considered a “Major Change” which will require a superseding Freeway Agreement prior to construction and California Transportation Commission (CTC) approval.

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36 Permits
The City of San Luis Obispo will be responsible for obtaining an encroachment permit from Caltrans for all work within State Right of Way. The following additional permits will also be required:
 National Pollution Discharge Elimination System (NPDES) Permit – California Regional Water Quality Control Board
 California Fish and Game Code Section 1602 Streambed Alteration Agreement  Encroachment Permit – City of San Luis Obispo
Cooperative Agreements
A Cooperative Agreement (05-0332) between Caltrans and the City was approved on April 12, 2018. The Cooperative Agreement is for the PA&ED phase, and states that the City will prepare PA&ED and will fund 100% of all costs. Caltrans will perform Independent Quality Assurance (IQA), environmental document quality control and owner/operator approvals for the portions of the work within the existing and proposed State Highway System right-of-way. The State will fund 100% of all costs of IQA.

A separate Cooperative Agreement will be executed between Caltrans and the City for the following subsequent distinct Project Components as defined in the Caltrans Workplan Standards Guide:
 Phase 1 – Plans, Specifications and Estimate
 Phase 2 – Right of Way Support
 Phase 3 – Construction Support
Other Agreements
A Maintenance Agreement will be executed between Caltrans and the City which, at a minimum, will identify City maintenance responsibilities for the Prado Road overcrossing and any other City-maintained features in the Caltrans R/W. The agreement will be formally initiated during PS&E and must be executed prior to the beginning of construction.

Report on Feasibility of Providing Access to Navigable Rivers There are no navigable rivers located within the project limits.

Public Boat Ramps
There are no boat ramps located within the project limits.

Transportation Management Plan
For construction of the proposed Prado Road overcrossing (OC), full freeway closures will be required for falsework erection and removal. This may call for detours and/or median crossovers which will be addressed in the PS&E phase. It will also need to be determined whether the current ramp configuration at Prado Road will remain open during construction, and if they can be used for the northbound detour. Southbound

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37 closure will be more complicated, possibly requiring use of a median crossover, or detour via Madonna Road and LOVR. Mainline closures of US 101 will be allowed at night only.

A preliminary Transportation Management Plan (TMP) Data Sheet/Checklist has been prepared (provided in Attachment I) which identifies strategies that should be included in the project. Major strategies are listed below:
• Public Awareness Campaign
• Portable Changeable Message Signs
• Construction Area Signs
• Planned Lane Closure Web Site
• Construction Zone Enhanced Enforcement Program (COZEEP) • Lane/Ramp Closures Charts
• Contingency Plan
• Special Days (to be determined)
• Liquidated Damages Penalty
• Maintain Traffic
Stage Construction
Stage construction exhibits will be developed for the preferred alternative, which will identify the number of project stages and potential detours that will be required.

Individual stage descriptions will be developed during the PS&E phase.

Accommodation of Oversize Loads
US 101 accommodates oversized loads. No permanent restriction to the movement of oversized loads would result from this project. The new Prado Road overcrossing structure over US 101 will be constructed to meet current State standards for vertical clearance.

Graffiti Control
Standard anti-graffiti measures would be used for the surfaces prone to graffiti installed forthe project. The only surfaces anticipated to require anti-graffiti measures (e.g. antigraffiti sign and wall coatings) are the structures, roadside/overhead signs and highway lighting poles.

Asset Management
There are no outstanding issues carried over from the project initiation phase of the project.

Complete Streets
The proposed improvements would be developed in compliance with Deputy Directive 64-R1 to provide safe mobility for all users, including bicyclists, pedestrians, transit riders, and motorists appropriate to the function and context of the facility. The proposed improvements would be developed in compliance with Policy 9.1.4

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38 Streetscapes and major roadways, of the City of San Luis Obispo General Plan Conservation and Open Space Element, to include street furniture, decorative lighting and paving, arcaded walkways, public art, and other pedestrian-oriented features to enhance the streetscape appearance, comfort, and safety.

The City of San Luis Obispo Active Transportation Plan (ATP), approved in 2021 identifies a need for a Bicycle/Pedestrian Grade Separated Crossing of US 101 between Los Osos Valley Road and Madonna Road which could be a Protected Bicycle Path, Bike Lanes, or Class IV Cycle Tracks as part of a Grade Crossing project. The proposed project would benefit pedestrian and bicyclists by providing a new sidewalk/Class IV bikeway along both the north and south sides of Prado Road through the project area.

The new sidewalk/Class IV bikeway will also provide connections to existing/planned Class I shared use paths located to either side of the project area.

Climate Change Considerations
A Climate Change Technical Memorandum (July 2022) was prepared for the project which evaluated climate change and greenhouse gas (GHG) emissions. The report is included as an attachment to the Environmental Document.

Broadband and Advance Technologies
As part of the utility coordination processes, utility purveyors would be given the opportunity to upgrade their facilities within the project limits to accommodate existing or future proposed installation of broadband and advance technology. No improvements have been identified at this time.

8. FUNDING, PROGRAMMING AND ESTIMATE
Funding
It has been determined that this project is eligible for Federal-aid funding. The City plans to fund the project with a combination of impact fees, debt financing and the SLOCOG Regional Transportation Improvement Program (RTIP). The PA&ED, PS&E, and Right of Way support phases are programmed with 100% local funds. The Construction phase has nearly $64 million currently programmed from a combination of RIP and local funding sources. The City will continue to pursue additional funds through other state and federal grants.

Programming
Fund Source Fiscal Year Estimate
Local/RIP Prior 22/23 23/24 24/25 25/26 26/27 Future Total Component In thousands of dollars ($1,000)
PA&ED 1,500 1,500
PS&E Support 2,500 2,500
Right-of-Way
Support