Public Comments may still be submitted to the CSU Board of Trustees

The Cal Poly CSU Board of Trustees will meet on Tuesday and Wednesday, January 24 and 25, 2023, to consider the Craftsman Mall Student Housing Project and the Final Environmental Impact Report (FEIR).

The Final Environmental Impact Report (FEIR) is flawed and inadequate per the Arcata Fire District Director’s presentation to the Arcata Planning Commission on January 10, 2023.

Section 3.1011, Cal Poly Humboldt Student Housing Project at Craftsman Mall – Final Environmental Impact Report (FEIR) incorrectly states that the CPH Craftsman Mall housing project would have less than significant impacts regarding the AFD:

“Therefore, no additional fire protection facilities are anticipated to be necessary for AFD to adequately serve the project site, and no significant decrease in response time is expected. Impacts would be less than significant.”

This is directly refuted by Director Loudenslager’s presentation summarizing why the Cal Poly Humboldt Student Housing Project at Craftsman Mall and any additional tall buildings in Arcata make the Final Environmental Impact Report (FEIR) incorrect. 

The AFD and the associated mutual-aid local fire districts cannot provide adequate fire protection and emergency services for even four-story buildings. For the existing taller buildings in Arcata — Sorrel Place, the Plaza Point (on 8th Street, 3 stories), the Behavioral & Social Sciences building at Cal Poly — the AFD currently relies on luck and good fortune. “We’ve basically been lucky,” he said. “We’re telling them not to build another four-story Sorrel until we have a bigger fire department.”

and:

Under more or less best-case conditions, the response time to assemble enough firefighters to deal with a four-story or higher building is in the order of 43 minutes. This involves the ladder truck from Humboldt Bay Fire District in Eureka, and multiple engines and staff from Eureka, Fortuna, Rio Dell, Westhaven, and more. A response time that long is 100% unacceptable, and could result in fatalities. If there were to be another incident at the time — another fire, another emergency response need, a storm or natural disaster, or even Highway 101 being slowed or blocked from rush-hour traffic or an accident — then the response time goes up and the possibility of a human unfortunate event rises.

I have a public comment urging the CSU Board to not approve or adopt the FEIR.

Following is the link to download the FEIR either as a single document, or as individual sections and appendices.  https://facilitymgmt.humboldt.edu/craftsman-student-housing

It is still possible to submit a public comment on the inadequacy of the FEIR either in writing or in person, up until noon on Monday, January 23. Instructions are included below on information relative to the meeting and commenting.
All public comment (for all committee and plenary sessions) will take place on Tuesday, January 24, at the start of the Board of Trustees’ open session (scheduled to begin at approximately 12:15 p.m.)
Written comments may be emailed in advance of the meeting by 12:00 p.m. on Monday, January 23, to trusteesecretariat@calstate.edu. To the extent possible, all written comments will be distributed to members of the board, or its appropriate committee, prior to the beginning of the board or committee meeting.
Members of the public who wish to offer public comment during the meeting may do so in-person or virtually/telephonically by providing a written request by 12:00 p.m. on Monday, January 23 to trusteesecretariat@calstate.edu. The request should also identify the agenda item the speaker wishes to address or the subject of the intended presentation if it is unrelated to an agenda item. Efforts will be made to accommodate each individual who has requested to speak.
Additional details on the upcoming meeting are here: https://www.calstate.edu/csu-system/board-of-trustees/Pages/default.aspx

The AFD is saying that no more taller buildings should be built until this situation is conclusively resolved.

The increase in property taxes that come from new construction, or any special districts created around the new buildings, would not come remotely close to covering the costs involved in expanding the AFD enough to supply protection.

The State of California and the CSU system must provide adequate and ONGOING funding to the Arcata Fire District to provide the additional personnel, equipment and facilities necessary to ensure acceptable response times and safety for both CPH students and Humboldt County residents served by the Arcata Fire District before building more tall buildings in the City of Arcata.

Respectfully,

Glen Colwell
Sunset neighborhood
Arcata

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Page 80.

Impact 3.10-1: 

Result in Substantial Adverse Physical Construction-Related Impacts Associated with the Provision of or the Need for New or Physically Altered Fire Facilities to Maintain Acceptable Service Ratios 

 

The project would result in an increase in on-site population and the density of development on-site, which could result in additional calls for service to the project site. However, the project site is located within the current service area of the AFD and would be designed and constructed in accordance with applicable requirements, including the California Fire Code. Therefore, no additional fire protection facilities are anticipated to be necessary for AFD to adequately serve the project site, and no significant decrease in response time is expected. 

LTS     No mitigation measures are required.

 

 

Page 254

 

  The project would result in an increase in on-site population and the density of development on-site, which could result in additional calls for service to the project site. However, the project site is located within the current service area of the AFD and would be designed and constructed in accordance with applicable requirements, including the California Fire Code. Therefore, no additional fire protection facilities are anticipated to be necessary for AFD to adequately serve the project site, and no significant decrease in response time is expected. Impacts would be less than significant. 
[Bold in the original in those 3 words.]

Although the project would increase the on-site population, an increase in population by itself would not increase demand for fire protection services. Typically, an expansion of geographic distribution, not simply an increase in population, impairs emergency response times and therefore potentially requires additional services and facilities. As noted above, the project would not result in an expansion of the current service area of the AFD. All new on-site buildings would be designed to meet minimum fire and emergency safety requirements identified in the California Building Code and California Fire Code and would include appropriate fire safety measures and equipment, including the use of fire-retardant building materials, inclusion of emergency water infrastructure (fire hydrants and sprinkler systems), installation of smoke detectors and fire extinguishers, emergency response notification systems, and provision of adequate emergency access ways for emergency vehicles. Further, adequate right-of-way for emergency vehicles would be provided around the proposed on-site structure with hydrants spaced according to applicable requirements. As a result, development under the project would be adequately serviced by existing fire stations and facilities, and the project is not anticipated to result in a substantial increase in service calls that would require new or expanded fire protection employees or facilities. Additionally, due to the improvements in on-site circulation, including the provision of dedicated emergency access from the project site to Eye Street, the ability for AFD to respond to emergency calls for service to and through the project site may improve. Therefore, although the project may result in an incremental increase in the number of service calls and place a greater demand on fire protection services, it would not result in the need for the construction of new fire protection facilities to maintain acceptable service ratios. AFD currently has sufficient facilities to adequately serve the population within its service area. Impacts would be less than significant.   
[Bold in the original in those 3 words.]

Page 36

 

  Response L1-15 AFD identifies current staffing needs and indicates that automatic and mutual aid assistance from neighboring fire departments allows for a sufficient response (see Comment L1-11). Comment L1-11 also indicates that the Mad River Fire Station is at capacity, but a facility currently being at capacity does not necessitate expansion of the facility due to construction of the proposed project. While a ladder truck may be necessary to serve the project, the Mad River Fire Station was able to house one in the past and could therefore accommodate one in the future (see Response L1-11). Although the Comment L1-11 indicates that the Mad River Fire Station is at capacity, that does not mean that acquisition of a ladder truck would require a remodel. Rather, it could be that an existing apparatus is replaced with the ladder truck. For these reasons, impact discussions presented in the Draft EIR remain valid, because, “although the project may result in an incremental increase in the number of service calls and place a greater demand on fire protection services, it would not result in the need for the construction of new fire protection facilities to maintain acceptable service ratios. AFD currently has sufficient facilities to adequately serve the population within its service area. Impacts would be less than significant,” as stated in the second to last paragraph on page 3.10-2 of the Draft EIR. This analysis is based on the fact that the project site is within the existing service area and would be designed and constructed in accordance with applicable requirements, including the California Fire Code. In contrast and as clarified in the responses above, no additional fire protection facilities are anticipated to be necessary for AFD to adequately serve the project site, and no significant decrease in response time is expected (see Impact 3.10-1). Because no substantial evidence has been provided to support the need for new or modified facilities, the construction of which could result in significant environmental impacts, no changes to the document are necessary.