To:         Dave Loya, Planning Commissioners and City Council members
From:     Andrea Tuttle    
RE:        Comments on the Draft EIR for the Arcata General Plan
Date:     March 18, 2024

Thank you for the opportunity to comment on the Draft EIR for the Arcata General Plan, which also contains assessments for the Gateway “targeted infill” area. 

General comments on document usability:

The document promotes major changes to Arcata’s urban form and density.   Unfortunately, within its 1990 (!!) pages it is very difficult to find consolidated responses to the top 5 issues that have been repeatedly raised throughout the public process, particularly regarding Gateway.  Section 1.9 is not a complete list of “areas of controversy,” nor does it take the next logical step to then summarize and provide transparency on what the significant environmental impacts actually are for those issues.  The reader is left to wade through the entire document to piece together the overall story for the impact they care about.

1) Highlight the most important: Although the document may legally need to follow a laundry-list format, it would benefit from an additional section that highlights and consolidates the impacts the public primarily cares about, namely: Urban character, Height and Density, Traffic and Parking, Dark canyons and solar shading, Service Capacity of the sewage treatment plant and Fire Department, and development in risky areas for sea level rise, Cascadia events and geologic instability. 

• For example, a search for “traffic” finds 226 hits and 305 for “parking” scattered throughout the document. But the reader must jump from one to the next in order to construct an overall picture of whether traffic and parking impacts will be significant or not. A consolidated, plain-English discussion at the head of the document for each of the top issues would more transparently disclose those impacts.
• Yes, all the other impacts must also be covered, but the current format buries the important among the trivial.

2) Identify what changes were made from the initial Gateway proposal with the intent of mitigating environmental impacts:  Although city staff, the Planning Commission and City Council have spent countless hours discussing the Gateway proposal over the past year, it appears practically unchanged from its first iteration, with only bits of cosmetic tinkering.  This CEQA document should disclose what changes have been made in response to the original public concerns expressed over a year ago and how they serve to mitigate impacts.

Specific points I find most distressing:

1)   Dodging the true impact: Community character.   The document does not frankly and honestly discuss the most significant change that Arcatans will actually feel when Gateway converts to an “urban sacrifice area,” with large blocks of tightly-packed tall buildings emerging in the northwest quarter of the city, visible from Eureka to Six Rivers Brewery.  Whether you like tall buildings or not, the EIR cannot just blithely dismiss this profound, utter change in community character and aesthetics that will result from full buildout of a plan that permits dense agglomerations of tall buildings.  Incredibly, the EIR identifies the aesthetic impacts on the community as having “No significant impact” or “Less than significant impact”, with “No mitigation required.”  (See Table 1-11 “Aesthetics”) . This is flatly, simply factually incorrect.

It is the underlying character of Arcata that is the reason most residents choose to live here.  Arcata’s town scale, environmental sensitivity, and the social blend of campus, residents and businesses are what distinguish this city from its neighbors.  Do we really aspire to physically look like Goleta? It is difficult to believe that most Arcatans truly endorse the magnitude of change that will occur and agree that the visual impacts are “less than significant.” 

Statement of Overriding Considerations : Yes, some may consider the impacts acceptable and be willing to accept “no feasible mitigation” for the creation of a massive new urban island.   But at least it should be honestly acknowledged that unmitigated visual impacts will fundamentally change the character and scale of Arcata. In this case a Statement of Overriding Considerations  is the proper CEQA recourse, not a false finding of “no impact”.    ( A Statement of Overriding Considerations is a written statement explaining the specific reasons why the social, economic, legal, technical, or other beneficial aspects of the proposed project outweigh the unavoidable adverse environmental impacts and why the Lead Agency is willing to accept such impacts.)

2)  Blithe dismissal of almost all other environmental impacts:  Table 1.11, the “Summary of Impacts and Mitigation Measures” requires 18 pages to list around 80 – 90 potential impacts.  Astonishingly, almost all are identified as having “No impact” or  “Less than significant impact”, with “No mitigation necessary”.

Really?? On a land-use plan providing for 4340 new dwelling units and up to 8000 new residents? This can only be interpreted as either hurried, careless, flagrantly dismissive of the intent of a serious CEQA analysis, or an attempt to dodge around making findings of overriding considerations.

• • The only impacts considered to have some potential impact include:

– vibration and noise from construction
– various air quality pollutants and greenhouse gases
– possible impacts to cultural resources and paleontological resources which have “no feasible mitigation”
– bats

• • Meanwhile, impacts from traffic and parking, for example, are not even listed in Table 1.11 as a category. A search for “sewage” does not take you to the discussion of whether there is adequate treatment capacity for planned growth (you have to scroll through to “UTL-c” (huh? who knew?) to find the discussion of treatment capacity). Providing for adequate fire protection is not considered relevant to a CEQA document (Section 3.10). Does conflagration of buildings and possible loss of human life from lack of capacity to respond not result in environmental impact?

It can only be charitably assumed that the impact analysis was a rush job that needs serious editing and re-consideration of impact significance. The most important focus should be on the issues that were repeatedly raised in public comment.

3)   Approving the application of Gateway standards to the rest of the city is seriously premature.  I seriously oppose the proposed expansion of the Gateway “targeted infill zoning ordinance for the Gateway Area using a form-based code” to virtually the entire city, including within designated neighborhood conservation areas.  We have zero experience with whether the Gateway experiment  and ministerial approvals will be successful or not, so how can we already approve its application everywhere?

• • The designated Neighborhood Conservation Areas, such as Bayview, were established by people who had the credentials to evaluate historic significance and cultural values. They seriously studied and debated the designation, and determined that the areas were worthy of recognition as having special character and significance to the fabric and historic resources of the city. Are we just tossing their informed deliberations out on a whim?  Are ministerial decisions by a city staff member to suddenly plunk tall buildings and retail establishments in the middle of a conservation district really what we want  — as allowed under a “form based code”?   Does this appropriately honor the integrity of the district and the reason it was designated?

    (Frankly, if the aesthetic impacts of Gateway are judged by the writers to have “no significant impact” as in this CEQA document, it is difficult to trust the judgment of city decisionmakers  who lack credentials in historic resources to honor the values intended within a Conservation Area).

  • If we really want to violate or de-designate the Neighborhood Conservation Areas, then a committee of interested, qualified individuals should be appointed to evaluate the issue and make recommendations to the Council, comparable to the quality of the appointees who established the areas in the first place.

In sum:

Although the Draft EIR is loaded with boilerplate and exhaustive lists, the document fails in its responsibility to address the environmental impacts that the public really cares about. The impacts that people have repeatedly testified about are brushed aside as either not relevant to a CEQA analysis or are deemed to not be significant.

The document needs serious editorial scrubbing and a more honest, transparent assessment of the impacts that will really occur from the planned development.  If unmitigated significant impacts will occur then the document should openly admit it, and make the required findings of Overriding Considerations.