Callender Commercial, LLC for a Development Plan/Coastal Development Permit/ DRC2017-00016/ ED23-173

2024010535

San Luis Obispo County

NOE - Notice of Exemption

1/19/2024

1/19/2024

Jeremy Freund

County of San Luis Obispo

Senior Planner

Lead/Public Agency

976 Osos Street, Room 300
San Luis Obispo, CA 93408

(805) 781-5621

jfreund@co.slo.ca.us

091-152-004, 091-152-006

Categorical Exemption

Section 15061 (b)(3)

Aesthetic and Visual Resources. The project site is located in an established commercial park east of State Route 1, a designated Scenic Highway, and adjacent to Manadella Street. The project site and subsequent development will be effectively screened from view of SR 1 by the intervening topography and existing buildings. Views of the project site from Manadella Street will be screened by a dense grove of eucalyptus trees that has been established along the east property line. Agricultural Resources. The site is located within an established commercial business park and surrounded by urban development where soil-based agricultural activities would be infeasible. Air Quality. As discussed in the project description, the area of disturbance is estimated to be about 36,934 square feet (0.84 acres) and will include an estimated 813 cubic yards of excavation to replace the existing septic system and construct the new collection system and leach field. Based on the SLOAPCD’s CEQA Air Quality Handbook (2012) and Clarification Memorandum (2017), estimated construction-related emissions were calculated and are shown in Table 1 below. As shown in Table 1 the project is not expected to exceed the daily thresholds for ROG and NOx combined and diesel particulates. The project is also not expected to exceed the quarterly threshold for fugitive particulate matter. Table 1 -- Estimated Construction-Related Emissions, SLO Cal East (DRC2019-00051) Pollutant / Total Est Project Emissions / APCD Emissions Threshold / Mitigate Rqrd? (ROG) + (NOx) (combined) / 9.19 lbs. (1) / 137 lbs. per day / No (ROG) + (NOx) (combined) / 0.045 tons (1) / 2.5 tons per quarter / No Diesel Particulate Matter (DPM) / 0.40 lbs. (2) / 7 lbs. per day / No Diesel Particulate Matter (DPM) / 0.0019 tons (2) / 0.13 tons per quarter / No Fugitive Particulate Matter (PM10) / 0.63 tons (3) / 2.5 tons per quarter / No Notes: (1) Based on 813 cubic yards of material moved and 0.113 pounds of combined ROG and NOx emissions per cubic yard of material moved and 10 construction days. (2) Based 813 cubic yards of material moved and 0.0049 pounds of diesel particulate emissions per cubic yard of material moved. (3) Based on 0.82 acres of disturbance and 0.75 tons of PM10 generated per acre of disturbance per month and 10 days of construction. Operational impacts are focused primarily on the indirect emissions associated with motor vehicle trips generated by new development. Table 1-1 of the SLOAPCD’s CEQA Handbook provides screening criteria based on the size of different types of projects that would normally exceed the SLOAPCD’s operational thresholds of significance for greenhouse gases and ozone precursors. For example, a project consisting of 99 single family residences generating 970 average daily vehicle trips would be expected to exceed the 25 Ibs/day operational threshold for ozone precursors. As discussed in the project description, the range of uses for the new shell building could include warehousing, storage, vehicle storage, and agricultural processing as allowed within the Industrial land use category. A trip generation study prepared for the project (OEG Engineering Group, 2022) provides an estimate of afternoon peak hour trips associated with the range of uses likely to occupy the new building as summarized in Table 2, below. Table 2 – Estimated Trip Generation Land Use / Quantity / PM Peak Hour Trip Rate / PM Peak Hour Trips Light Industrial / 6,603 sq.ft. / 0.65 peak hour trips per 1,000 sq.ft. / 4 Residential / 1 / 0.44 peak hour trips per dwelling unit / 0 Total: / - / - / 4 Source: Orosz Engineering Group As shown in Table 2, the new building could generate as many as 4 vehicle trips during the PM peak hour which would translate to about 40 trips per day which is well below the 970 average daily trips that would exceed the operational threshold for daily emissions. The project site is located within 500 feet of a neighborhood of single family residences which may be occupied by sensitive receptors such as the elderly, children, people with asthma or other respiratory illnesses, and others who are at a heightened risk of negative health outcomes due to exposure to air pollution. However, construction of the proposed shell industrial building and associated parking is not expected to require the use of large earth moving equipment that would produce emissions that would adversely impact sensitive receptors. Naturally Occurring Asbestos (NOA) is identified as a toxic air contaminant by the California Air Resources Board (CARB). Based on SLOAPCD’s map, the project site is not located in a candidate area for soils containing NOA. Biological Resources. As discussed in the baseline conditions, the project site is covered with an existing building and compacted all-weather gravel surfaces; construction of the proposed shell building will not require the removal of any natural vegetation. A dense grove of eucalyptus trees has been established along the eastern property line outside the area of disturbance. There are no USGS blue line features within or immediately adjacent to the project site and no drainages. The project site does not contain any Environmentally Sensitive Habitat Areas as defined by the Coastal Act, nor does it contain suitable habitat for sensitive plants or animals. However, according to a biological assessment of the Callender Business Park (including the project site) prepared in 2021 (David Wolff Environmental, LLC, 2021), portions of the Business Park containing undisturbed coastal dune scrub is within the designated critical habitat of the La Graciosa thistle. However, none of these areas are within or adjacent to the project site or within the area of disturbance and the project will have no impact on these resources. In addition, the Business Park and the area along the east property line of the project site contains dense stands of eucalyptus trees which may provide roosting habitat for monarch butterflies. A field survey conducted in November 21,2021 provided ideal conditions for observing monarch butterflies (sunny, little wind, temperatures in the 60’s Fahrenheit). During that survey scanning all the trees in the vicinity of the Business Park with binoculars revealed less than about 25 monarch butterflies in flight and not all in one place. Typically, monarch butterflies are readily observable flying in and out of roost aggregations under these ideal conditions where they do occur. But as stated, no roost activities were observed. Given the Pismo monarch butterfly preserve recorded over 22,000 monarch butterflies in November 2021, it would be expected that a roost site would have been readily noticeable during the November 21st field survey. Therefore, the project is expected to have no impact to potential monarch butterfly habitat. It should also be noted that no eucalyptus trees will be removed or otherwise impacted by the project. Cultural Resources. The project site does not contain a site under the Historic Site (H) combining designation and does not contain other structures of historic age (50 years or older) that could be potentially significant as a historical resource. The project site is not subject to the Archaeologically Sensitive combining designation and does not contain any known archeological resources. The site has been developed with a building and all-weather parking and access areas. Subsurface excavation for the proposed septic leach field will be confined to an area that was previously graded and covered with decomposed granite. Energy. During construction activities, fossil fuels, electricity, and natural gas would be used by construction vehicles and equipment. The energy consumed during construction would be temporary in nature and would be typical of other similar construction activities in the county. Based on the size and scope of proposed earthwork and building construction, the project is not expected to result in adverse environmental impacts through its use of diesel fuel for construction equipment. During operation, the project would rely on electricity provided by PG&E, which is fully compliant with state renewable energy regulations. PG&E utilizes clean energy sources, including 50% from renewable energy sources and 43% from other GHG-free energy sources (PG&E 2021). Operational energy use would include interior and exterior lighting and could include machinery used for light industrial operations, as well as natural gas for heating. However, energy demand from these sources would not be more intensive than other typical light industrial activities. Geology and Soils. The project site is flat and has been previously graded. Soils consist of coastal dune sands of the Oceano Series. The project site is not located within the Geologic Study Area designation. The site’s potential for liquefaction and landslide hazard is considered low. The project site is not located in an Alquist Priolo Fault Zone, and no active fault lines cross the project site (CGS 2018). Based on the Safety Element Landslide Hazards Map, proposed components are located in an area with a low potential for landslide risk. The project site is not located within a 100-year flood hazard area. Drainage, sedimentation and erosion control plans are required for all construction and grading projects (LUO Sec. 22.52.100 and 22.52.110) to ensure there are no post-construction drainage impacts. Proposed development on the project site will be served by a new septic system. According to an onsite sewage disposal site evaluation prepared for the site in 2021 (Nexgen, 2021), the Oceano Series soils of the project site do not present significant limitations for the use of septic leach fields. The project site contains ample area for the location of a septic leach field if additional disposal area is needed to meet County and RWQCB standards. Greenhouse Gas Emissions. Assuming the new shell building contains one single family residence (caretakers quarters) and 6,603 sq.ft, of industrial floor space the project would produce about 50 metric tons C02 equivalent (MTC02e) each year which is well below the interim working threshold of 690 MTC02e. Hazards and Hazardous Materials. Future tenents will be required to comply with all relevant regulations relating to the use, handling and storage of hazardous materials. The project is located within a State Responsibility Area for fire protection but is not located within a "very high” severity risk area which could present a significant fire safety risk. The proposed project will be required to prepare a fire safety plan for review and approval prior to occupancy. Hydrology and Water Quality. The project will result in an area disturbance area of about 0.84 acres. Accordingly, a sedimentation and erosion control plan will be required subject to the review and approval of the County Building Division in accordance with LUO Section 22.52.120. The project is served by the Callender Grove Mutual Water Company. An e-mail from Mr. Rob Miller on behalf of the Water Company (January 11, 2018) states that the water company has capacity to serve the project, assuming 1 acre-foot of water per year. The project would be required to comply with all National Pollution Discharge Elimination System (NPDES) requirements and prepare a SWPPP that incorporates BMPs during construction. Based on the Safety Element Flood Hazard Map, the area of disturbance is not located within a 100-year flood zone (County of San Luis Obispo 2013). Noise. Project construction would result in a temporary increase in noise levels associated with construction activities, equipment, and vehicle trips. Construction noise would be variable, temporary, and limited in nature and duration. The County LUO requires that construction activities be conducted during daytime hours to be able to utilize County construction noise exception standards and that construction equipment be equipped with appropriate mufflers recommended by the manufacturer. Transportation. As discussed above under Air Quality, the project may be expected to generate as many as 4 afternoon peak hour trips. Based on the referral response from the Department of Public Works (David Grimm, May 9, 2023) the project is not expected to result in adverse impacts associated with roadway safety or capacity. In addition, based on the project description and the baseline conditions provided above, the project will have no impacts relating to the following: Land Use and Planning Mineral Resources Population and Housing Public Services Recreation Tribal Cultural Resources Utilities and Service Systems Wildfire Conclusions The project site is within an established commercial business park which is served by a community water system, paved access and parking. The site is partially developed with an existing building and the remainder is covered with an all-weather parking surface; the site contains no biological or archaeological resources and is not visible from State Route 1 or the surrounding residential neighborhood. In sum it can be seen with certainty that there is no possibility that the activity in question may have a significant effect and the project is exempt from CEQA. The project will conform to the applicable General Plan and Area Plan standards, and no measures beyond those required by County Code are necessary to address the environmental impacts associated with the proposed project.