The draft Environmental Impact Report is deficient, inadequate, misleading, and in many areas just plain wrong.
“I am appalled by the general sloppiness, the errors, the omissions, the lack of cohesiveness, and actual misstatement of facts contained in this document.”
Comments from Fred Weis on the draft Environmental Impact Report
- Table of Contents for these comments — 88 pages of comments.
- Introduction
- How to find the sections of the comments that interest you
- Specific areas of interest in these comments
- The Table of Contents and the Comments
- The Comments in a PDF viewer
Introduction
The 1,990-page draft Environmental Impact Report for Arcata’s General Plan Update was released to the public on January 29, 2024. The period for submitting written comments ended March 18.
As stated in the official “Notice of Availability” (highlighting added):
“The purpose of public review of the DEIR includes: sharing expertise, disclosing agency analysis, checking for accuracy, detecting omissions, discovering public concerns, and soliciting counter proposals (CEQA Guidelines Sec 15200).”
This article contains the comments submitted by me, Fred Weis. It is included here as it was submitted, formatted to be displayed on a web page. The actual PDF submission in its original format is included below also.
Related articles on Arcata1.com include:
The Documents of the General Plan Draft Environmental Impact Report
This is the original EIR document
An annotated Table of Contents for the Draft Environmental Impact Report
The Gish Gallop — and Brandolini’s Law
While the full draft EIR document is 1,990 pages, if we take out the 1,173 pages of Appendix E, the Environmental Database, because it’s really just a list, that makes “only” 817 pages.
The draft EIR includes one page of Contents and one page of the listings of the Figures (with no page numbers) and the Appendices — that’s all. This is considered insufficient for looking things up in such a large document. The annotated Table of Contents has 23 pages of a more detailed table of contents along with notes and commentary. If you are going to do any real reading of the draft EIR, it is suggested that the annotated Table of Contents be printed out and used as a guide.
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How to find the sections that interest you
As a suggestion:
- Skim through the Table of Contents.
- Skim or read through the 3-page Introduction.
- See what interests you and read those sections.
- You can refer to the full 1,990-page draft Environmental Impact Report document here. Clicking on that will open it up in a new tab. The Comments all include the PDF page number — you can easily get to that page number in the document by entering it in the page number box on the viewer and pressing Enter.
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Specific areas of interest in these comments:
- There’s not much on the impacts of Sea Level Rise, as this EIR is meant to address changes in Arcata only up through 2045, about 20 years from now. There is an obvious omission of King tide / Storm Events.
- Cal Poly Humboldt will be constructing more dorms for housing as part of the expansion. But the number of dorms they intend to build will be far fewer than the need for student and staff housing. New construction in the City of Arcata will be expected to pick up the short-fall. Of all the new construction in the entire City over the next 20 years, perhaps 40% or 50% or 60% or close to 70% may be occupied by students and staff. See Misstatement of Cal Poly Humboldt’s off-campus housing needs.
- Arcata was the location of many lumber mills and other industrial uses in the past. As stated on page 2-6.3 (PDGF page 178), there are 11 active hazardous materials sites and 92 “closed” or inactive sites within the City limits. The “closed” sites may have been deemed okay for an industrial-use parcel, but may not be okay for residential use — which is what is going on throughout the Gateway area. See: “Inactive” status is not permission to build housing and other comments.
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The Noise study is based on “modeling” of 27-year-old sound measurements. And it is likely wrong. What’s more, as the “Elephant in the room” — Arcata’s traffic noise level may require substantial mitigation, with costs to be paid by the builders.
- The draft EIR shows a projected number of apartments build in the Gateway area at 500. In what appears as a way of “fudging” the numbers to make everything fit, it shows 1,340 apartments built in the Downtown, Craftsman Mall, and Valley West “infill opportunity zones” — even though there’s about 1/4 as much vacant and re-developable land in those zones. See here.
- It suggests that in the next 20 years that the Uniontown (Safeway) shopping center will be torn down and reconstructed with apartments on top of the stores. And that the Northcoast Co-op building may be torn down and reconstructed too.
- There may be 7,000 or 8,000 new residents in Arcata in the next 20 years, including “an estimated 700-1,200 new kindergarten through twelfth grade students” — but as for the expansion of police services, fire and emergency protection, city parks, and school facilities, they are pretty much on their own. Starts here and onward.
There’s more
In the comments that I submitted, not everything is included that I wanted to include. You can see the annotated Table of Contents for more.
For other people who submitted written comments on the draft EIR, with their permission I will be posting their comments here on Arcata1.com.
It’s required that all comments be responded to in writing. Those responses may or may not adequately answer the issues brought up. The official responses and any corrections to the draft EIR will be incorporated into a Final Environmental Impact Report, and that will be released to the public. There will be a Planning Commission meeting at which the final EIR will be reviewed, and a City Council meeting for its adoption.
No changes were made in what is below other than a spelling correction: The word “assert” was spelled as “asset” in the original.
To use the Table of Contents
Each item in blue in the Table of Contents will skip directly to that section. You can use your browser’s back-arrow to return to the Table of Contents, or use the ^ icon at the lower right corner of the page to go to the top.
Comments submitted on the
Draft Environmental Impact Report
Arcata General Plan Update
Dated: January 26, 2024
by Fred Weis
March 18, 2024
Instructions:
This comment document contains a Table of Contents.
Every bulleted item on this Table of Contents requires one or more statements as a written response.
Table of Contents
Introduction
Among what we see in this draft Environmental Impact Report includes the following deficiencies. This list is part of what’s wrong or missing. There’s more than what’s on this list.
- When evaluating the impact on the scenic view of the proposed tall buildings, it tells us that the views are acceptable – if we allow our views to be “altered to include buildings…as part of the viewscape in the urbanized foreground.”
- We are given an image that’s described as purporting to “depict what a full build out scenario in the Gateway Area could look like” – only it shows a total of five buildings. That’s not a full build-out. It’s a partial build-out.
- It shows the Gateway area with a projected 500 units built over the next 20 years, and shows 1,340 units to be built in the Valley West, Craftsman Mall, and Downtown infill opportunity zone areas – even though the acres available for redevelopment in those three zones are in the order of one-quarter the amount of land slated for redevelopment in the Gateway area. And even though 1,340 units just wouldn’t fit in the Downtown, Valley West, and Craftsman Mall space. Even if the Valley West and the Uniontown Safeway shopping centers were demolished.
- It tells us that Cal Poly Humboldt’s off-campus housing needs may amount to either 40%, or 50%, or even 60% of the total projected growth of Arcata over the next 20 years. That is, what’s left over for non-Cal Poly people will be 60% or 50% or 40% of what’s built. And then gives figures for Cal Poly’s needs that add up to taking up almost 70% of Arcata’s growth in housing. Yes, students and staff are people and they are or can be Arcata residents – that we understand. But we may see all this growth in our town and then just have 30% or so of all new construction available for the non-university people who want to live here.
- The draft EIR has a traffic noise study that’s based on the modeling and projections of measurements that were actually taken in 1997. That was 27 years ago. Is the modeling complete or accurate? We don’t know. Then it shows maps of the sound levels in Arcata that would seem to indicate that large parts of the areas slated for redevelopment may be not be suitable for residential use – unless the builder puts in a central air-conditioning system and the tenants keep their windows closed to shield against the road noise.
- It informs us that the remediation that was required to clean up contamination sites that were in industrially-zoned areas won’t likely be sufficient, now that we want to build residences there. But doesn’t tell us what we might do about this situation, or give us information or maps that might be helpful in determining if this will be an environmental impact situation. It says that if an individual project requires specific mitigation measures, it also may require an additional CEQA review. This effectively defeats the time-saving aspects of streamlined ministerial review.
- The EIR is required to provide alternatives to the Proposed Project. What we see here are alternatives that are not feasible, could never exist in Arcata, and should not have been included in this draft EIR in the first place. And an absence of alternatives that are reasonable, feasible, and rational.
An Environmental Impact Report is required to evaluate “reasonably foreseeable” direct and indirect physical changes in the environment that may be caused by the project. Changes to the environment that are speculative or unlikely to occur are not considered “reasonably foreseeable.”
On pages 3.10-46 and 47 (PDF pages 313 and 314), highlighting added, we see:
“However, with an estimated 700-1,200 new kindergarten through twelfth grade students over the planning horizon, it is likely that new or expanded school facilities or staff within the City would be needed.”
We know we’ll need new or expanded schools. But since we cannot “reasonably foresee” just where those schools might be built, then the need for schools is considered speculative.
In this way, something that is real very quickly becomes something that’s speculative, and as such does not have to be taken into consideration.
In my opinion, this draft EIR is filled with speculative, unrealistic, and unscientific content. It has assumptions that are presented as though they were facts. It draws conclusions based on data that was collected 27 years ago (the Noise study). It mixes up important designations — such as, with the dorms that Cal Poly Humboldt is building, confusing the number of beds being built with the number of units. It provides figures that, when used to calculate important conclusions, provide results that are different from the conclusions stated in the EIR.
In this report I refer to page numbers both by the Draft EIR section/page (such as “4.2-25”) and by the PDF page number (“382”). I find it far more helpful to navigate through the draft EIR by using the PDF page number, by scrolling through the thumbnail images on the left side of most PDF viewers. In addition, not all pages in the draft EIR have section/page numbers on them.
The document’s “Figures” do not have page numbers. The page numbers in the appendices do not use the section/page number format that is used in the main section of the document.
Outside the scope of these Comments on the draft EIR, but pertinent to the adopting this draft EIR by the City Council:
Because of State law requiring the recusal of two of Arcata’s five City Council members, the Gateway Area Plan has been kept as a separate document so that it can be approved by the three eligible City Council members, separate from the General Plan 2045 document. However, in this draft Environmental Impact Report, Gateway Area Plan issues are intermingled throughout the document. The word “Gateway” – referencing either the Gateway area or the Gateway plan, occurs 650 times. The phrase “Gateway Area Plan” occurs 155 times.
Perhaps the process will be:
- First the 3-member City Council will vote to adopt the Gateway Area Plan.
- Then, after that is adopted, then the 5-member City Council will vote to adopt the General Plan 2045. The Gateway Area Plan will already have been adopted, so the two recused councilmembers would not be voting Yea or Nay on that, in essence.
- Then, the 3-member City Council will vote to adopt the Gateway-specific portions of the Environmental Impact Report.
- Then, the 5-member City Council will vote to adopt the entirety of the Environmental Impact Report General Plan 2045. The Gateway-specific portions of the Environmental Impact Report will already have been adopted, so the two recused councilmembers would not be voting on that.
The question is: Is that how the process will go?
If not, perhaps it could be explained just how this will work. The Gateway-specific portions of the draft Environmental Impact Report cannot possibly be separated from the whole of the report.
Consistency and editing errors to be corrected
This is not the entirety of the typographical errors. Others are noted below. There are more that are not noted in these comments.
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- Appendix G, page 10 (PDF page 1967)
“Figure 6 graphs the Smart Growth Score against the average VMT per capita for the seven six”
It should be “seven cities plus the unincorporated areas of the County.” - Pages 3.4-21 and 3.4-22 (PDF pages 141 and 142) are about the cumulative impacts to cultural resources. There are four references to a “Table 1-1” – What is likely meant is the “Table 1-10-1” in this draft EIR document.
“Future projects considered for cumulative impacts are identified in Table 1-1.”Page 3.10-47 (PDF page 314) - “PF-4a” needs to be updated to “PF-5a” – two locations.
“New school facilities would be primarily provided as expansions to existing facilities or on infill sites with land use designations that allow such uses, such as Public Facilities or Gateway Area residential zones (PF4a). Public Facility Element Policy PF-4a requires the City to coordinate with local school districts….”In general, it would be better to write out the name of the Policy and not just refer to it by its abbreviated policy number. That is, to say “Public Facility Element Policy PF-4a Educational Facilities requires the City….”
- In Section 2.6.2 Land Use Element, under Infill and Density, the Gateway area is included in two places on the list. It is the first item on the list, on page 2.0-18 (PDF page 52) as “Gateway Area Infill Opportunity Zone” and then it is the last item on the same list on page 2.0-20 (PDF page 54) as “Gateway Area.”
- The segment of this draft Environmental Impact Report that discusses alternatives to the proposed project – the General Plan 2045, with its included Gateway Area Plan – is in Chapter 7, “Alternatives.” The 23 pages are found at page 7.0-1 through 7-23 (PDF pages 565 through 587). The document lost its proper page numbering system; it should show “7.4-1” rather than “ 7-21” as an example.
- Appendix G, page 10 (PDF page 1967)
Location: Throughout the document.
Remedy: Edit document as required, for consistency.
The designation “State Route 101” appears in this draft EIR document at least 34 times and “SR 101” is there 31 times. There is no such road as “State Route 101” or “SR 101” – for verification, please consult the CalTrans website and other sources.
“Highway 101” appears in the document 18 times (plus in the Environmental Database mapped sites appendix). Ten of those 18 are from insertions of General Plan 2045 policies – and are correctly designated as “Highway 101.”
For clarity, the full correct name of the highway is “U.S. Highway 101” or “U.S. 101” with “Highway 101” being acceptable.
No page number. After page 4.2-25 (PDF page 381)
This Proposed Vehicular Circulation map is dated 1/26/2024.
It shows roads through the Gateway area Barrel District as “New Local Road Connection.” The placement of these roads is subject to the future Barrel District master plan, which does not currently exit. Therefore, these roads should not be depicted on this map – or there should be a written caveat that explains the situation. The map shows the main entrance for the Barrel District as intersecting with the L Street linear park. That situation is unlikely to exist. Map should be corrected.
The map shows a road in the L Street corridor, as it exists prior to adoption of the General Plan 2045. That adoption includes designating the L Street corridor as a full-width linear park. This map should not show a road there, as this right-of-way is for the L Street corridor full-width linear park.
The map shows a “Proposed Traffic Signal” at L Street and Samoa Boulevard. This should be removed from the map, unless it is intended as a pedestrian/bike traffic signal.
Page 2.0-11 (PDF page 45), Page 2.0-18 (PDF page 52), 3.2-2 (PDF page 71) and other locations.
Remedy: Edit document as required, for consistency.
In at least 18 instances, “Craftsman’s Mall” is used in the draft EIR document. The designated name, “Craftman Mall” appears 17 times.
The correct name is “Craftman Mall.”
Page 1.0-7 (PDF page 13). Pages 2.0-7 and 3.7-11 (PDF pages 41 and 213).
Remedy: Check for actual APNs, and edit document as required.
On page 1.0-7 (PDF page 13) there is list of APNs for the parcels that are part of the Cal Poly Humboldt Craftsman Mall dormitories. This shows 12 parcels.
On pages 2.0-7 and 3.7-11 (PDF pages 41 and 213), the list has 7 parcels.
It is believed that the list of 7 parcels is correct. This would have to be checked, and the change made to the draft EIR document.
- Includes out-of-business company and likely soon-to-be gone companies in the description of the Gateway area.
Page 3.2-2 (PDF page 71)
As stated in the draft EIR, the Gateway area “…continues to be the location of various industrial companies such as Industrial Electric, Humboldt Wholesale, Wing Inflatables, AmeriGas, and numerous auto repair and detailing shops.”
The general definition of an industrial company is one that manufactures or produces goods. Wing Inflatables is an industrial company. Humboldt Wholesale, Industrial Electric, and AmeriGas are not industrial companies. They are distributors. Auto repair and detailing shops are also not industrial companies. Those businesses are in the service industry.
Humboldt Wholesale is out of business and its location has been vacant and for lease for a couple of years. The locations of Wing Inflatables and AmeriGas are targeted sites for development as outlined in the Gateway Area Plan and numerous illustrative plans for development. Auto repair and detailing shops are also not likely to maintain business operations if the Gateway projected development is successful.
It is suggested that this part of the description of the Gateway area be revised for accuracy.
Page 3.2-2 (PDF page 71)
“However, interspersed with these industrial uses are historic homes, boutique shops, condominiums, theaters, gyms, pubs, and restaurants.”
This needs to be revised and improved. It is a thoroughly inadequate description of the Gateway area. The one-paragraph descriptions of the three other infill opportunity zones are reasonably accurate. The paragraph describing the Gateway area is not accurate.
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- This description omits mention of the Creamery building and the surrounding area – which most people regard as the central highlight of what the draft EIR is describing as the “visual character of the Gateway Area.”
- The second large aspect of the visual character of the Gateway area is the large industrial area located along Samoa Boulevard. This is not mentioned.
- Other than the one large industrial area, the remaining portion is a mixed-use area. There are some manufacturers in the Gateway area outside of the large industrial area. Most are in the area of the Creamery building.
- It is not that the historic homes, boutiques, etc. are interspersed with the industrial uses. It is the other way around.
- The description says there are “… historic homes, boutique shops, condominiums, theaters, gyms, pubs, and restaurants.” I know of one pub and one theater – not plural.
Page 2.0-10 (PDF page 44)
Remedy: Check for actual area of the Gateway Area Plan; check for actual total of the parcels in the Plan; edit the EIR document to correct the existing error.
From the draft EIR:
“The Gateway Area is composed of 189 parcels totaling 139 acres adjacent to and west of the Downtown area.”
Correct to this or similar:
“The Gateway Area is approximately 139 acres adjacent to and west of the Downtown area, and is composed of 189 parcels totaling approximately 118 acres.”
It is incorrect to say that the 189 parcels total to 139 acres. This should be corrected.
The 139-acre figure is the gross size of the Gateway area – the entire land between the borders of the area. This includes roads, rights-of-ways, pathways, and so forth.
The 189 parcels total to 118.21 acres, by my calculations of adding up the parcel sizes. The GIS mapping systems and City parcel size database can provide the exact number.
Categories: Incorrect information. Outdated information.
Page 3.7-3 (PDF page 205)
Table 3.7-2 shows the Gateway districts as Land Use Designations G-C, G-B, G-H, G-N, and G-OS (Corridor, Barrel, Hub, Neighborhood, and Open Space).
The table shows G-C, G-B, G-H, G-N and G-OS as land use categories. They are not land use categories. G-C, G-B, G-H, and G-N are districts.
“Gateway Open Space” and “G-OS” are not phrases found in the Gateway Area Plan.
The Gateway area has now been proposed as C-M land use — Commercial – Mixed Use.
The acreages could be added to the C-M acres, or for clarity could be kept as something like “Gateway Barrel C-M” and “Gateway Corridor C-M.”
The number of acres shown for each of the districts does not correspond with the current Gateway Area Plan.
It is possible that these numbers come from an earlier (pre-December 2021) version of the Gateway area. This table shows what is in the draft EIR versus the figures obtained from adding up the parcel lot sizes.
|
Draft EIR |
Adding up the parcel acres |
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Gateway Barrel District |
28.9 |
28.90 |
(same) |
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Gateway Corridor |
17.3 |
41.27 |
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Gateway Hub |
32.0 |
16.37 |
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Gateway Neighborhood |
19.2 |
31.77 |
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Gateway Open Space |
6.9 |
— |
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Totals: |
104.3 acres |
118.31 acres |
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At one point, the Gateway area was smaller, and did not include the parcels along Samoa Boulevard, extending to F Street. The area at that time was 103.86 acres, which is similar to the 104.3 acres shown in the Draft EIR. It is possible that the acres figures that were used to make this table came from that pre-December 2021 Gateway area map. |
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Note: Totals do not include acres for roads and other rights-of-ways. |
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- Housing Estimate confuses Cal Poly Humboldt “beds” with “units”
Page 3.9-2 (PDF page 245).
Remedies: Correct Replace “1,550 units” with “1,550 beds.”
From the draft EIR, highlighting added:
“Assuming the total resident maximum population in 2045 will be 27,000, a total of 2,791 additional dwelling units and 1,550 net additional dorm beds would be developed to accommodate that growth.”
Further in the paragraph, highlighting added:
“Cal Poly Humboldt Campus Housing – 1,550 units”
Page 2.0-6 (PDF page 40).
Remedy: “4,340 additional dwelling units would be developed” is incorrect. Revise.
Page 2.0-6 (PDF page 40), highlighting added:
“It is assumed that the total resident maximum population in 2045 will be up to 27,000 (as stated above), and that 4,340 additional dwelling units would be developed to accommodate that growth.”
This figure of 4,340 is incorrect. It is likely based on the figures on Page 3.9-2 (PDF page 245) and the confusion over dorm beds and units (see above).
This figure likely came from multiplying the 1,550 dorm bed figure by the 2.36 persons per household figure
The draft EIR consistently uses “Average household size ranging between 2.2 and 2.5.” (3.9-1, PDF page 244; 7-10, PDF page 574) and “2.36 persons per household” (3.9-2, PDF page 245).
If the 4,340 figure were used, the result would be:
At 2.36 = 10,150 persons. Between 2.2 and 2.5: 9,460 to 10,750.
All these figures are in excess of the projected population growth of about 8,140 from the 2020 census figure, to reach 27,000.
Here are the figures on Page 3.9-2 (PDF page 245), with “beds” inserted where the document has “units” for the dorm housing:
The total of the non-dorm housing is 2,791. Multiply this by 2.36 and the result is 6,587. Adding the 1,550 dorm bed figure to that and the result is 8,137 – equivalent to the 8,140 figure to achieve the 27,000 population number.
Page 3.10-6 (PDF page 273)
Remedy: Establish correct figures and edit the table.
Table 3.10-5 shows a change in acres from 2010 to 2023 of Natural Areas of -3,621.5 acres – that is, a LOSS of -3,621.5 acres. This is incorrect, as the text states. Why not update this table and make it right?
The total number of acres shown do not match a sum of the contents of the table. The arithmetic is not correct.
A footnote says: “Note: Negative changes in acres are due to recategorization of parkland types since the adoption of the Parks & Recreation Master Plan in 2010, not a loss of parkland. Overall, a net gain in parkland occurred between 2010 and 2023.”
This table requires updating to show reality. It would be a simple matter. If the totals shown do not correspond to the contents of the table, the table cannot be considered to be trustworthy.
Page 3.2-2 (PDF page 71).
Remedy: Correct the draft EIR to include existence of Cal Poly dorms under construction.
Page 3.2-2 (PDF page 71), highlighting added:
“The Craftsman’s Mall / St. Louis Opportunity Zone is approximately 41.8 acres, of which 10.5 acres are owned by Cal Poly Humboldt and are planned to contain new student housing and amenities.”
In actuality, the Craftsman Mall dorms are not just “planned” – they are being constructed at this time. The dorms will have a significant impact on housing in Arcata by the end of this year – 2024.
The draft EIR includes many mentions of Cal Poly’s housing requirements and Cal Poly’s construction of housing. The quantity of housing that Cal Poly is planning to construct is a key element throughout the draft EIR. Many calculations and assumptions within this draft EIR are based upon the figures presented in the Cal Poly prospectus.
The draft EIR needs to be corrected here.
- The Humboldt County Climate Action Plan is referred to in the document but is not listed in the References. Page 6.2-21 (PDF page 563).
- It seems that acronyms that are used in Appendix G are not included in the draft EIR’s “Acronym list.” (Page iii, PDF page 5). Examples: “MPO” and “TAZ” are in the document, but not in the acronym list.
Appendix G – Vehicle Miles Traveled Analysis, Pages 5, 30, 32. PDF pages 1962, 1987, 1989.
An “MPO” is a Metropolitan Planning Organization.“TAZ” from Wikipedia: “A traffic analysis zone or transportation analysis zone (TAZ) is the unit of geography most commonly used in conventional transportation planning models. The size of a zone varies, but for a typical metropolitan planning software, a zone of under 3,000 people is common.”
- Appendix G, page 3 (PDF page 1960). Makes a statement “Data shows that when housing is in close proximity….” with a footnote. The footnote reference does not relate to the statement. Rather it is a reference to State law that describes a requirement for evaluating a project’s transportation impacts.
This footnote does not support the “Data shows” statement. This is careless and sloppy writing. It is considered a “false reference.” In an academic paper, it would be cause for returning the entire document for update and revision, and cause also for suspicion. If a reference is in the document that is not in support of the statement, what else is there that is, shall we say, made up?
Page 2.0-14. PDF page 48.
Remedy: Remove this illustration and its reference. It has no purpose in this EIR.
This illustrative plan is on page 2.0-14 (PDF page 48) of the draft EIR. The document states (highlight added): “See Image 2-2 for the Gateway-Barrel District illustrative plan.”
First of all, it should say “a” illustrative plan, not “the” illustrative plan. Second, this illustrative plan should not be in this document at all. It is not in accord with the Gateway Area Plan policies, and it is not in accord with the 20-year build-out figures that are in this draft EIR.
There is no date on this illustration. It’s my guess that this illustration was made before the Planning Commission started their discussions on the Gateway Area Plan, that is, perhaps from prior to December 2021, or over two years ago.
In white letters, too small to read unless the image is expanded, it says “Drawing is for illustrative purposes only and does not reflect a concrete development proposal.”
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- It shows 1,500 dwelling units for the Barrel District. The projected 20-year build-out figure for the entire Gateway area (not just the Barrel District) is 500.
- It shows a parking rate of 1.25 spaces per dwelling unit. The Gateway Code for Barrel district parking is 0.5 spaces per dwelling unit.
- It shows commercial parking at 5 spaces per 1,000 square feet. The Gateway Code for Barrel district commercial parking is 1 space per 500 to 1,000 square feet.
- The Gateway Plan calls for a park with a minimum size of 1.0 acres, located in the Barrel District. There’s no park in this drawing.
- “L Street” is depicted as a road — not as a Linear Park. It’s been declared as a full-width linear park since August, 2023.
- From the roundabout in the center, the curved road that goes to the left (west) looks to be about 3-1/2 blocks long, or over 1,000 feet with no intersecting streets or woonerfs. This is not proper for a walkable or bikeable neighborhood. In Arcata, we want the maximum block length to be 300 feet.
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As shown, it portrays the Barrel District as having 1,500 dwelling units. The information in the inset (upper left) calls for 1.25 parking spaces per dwelling unit. That would be 1,875 parking spaces. The 150,000 square feet of commercial space calls for 5 parking spaces per 1,000 square feet, for an additional 750 spaces. Total parking spaces required, per this illustration, is 2,625 parking spaces.
This amounts to approximately 18 to 20 acres of parking. To put this in perspective, the entire Barrel District is said to be about 35 acres. The number of parking spaces at the Bayshore Mall is in the vicinity of 1,200 spaces. Uniontown Shopping Center, with Safeway and CVS, has about 250 parking spaces.
And yet this “illustrative plan” shows what looks to be zero parking spaces. It’s hard to say, as the drawing isn’t clear. Possibly the parking could be in the lower levels of the buildings — but it would require about two floors of parking in each building to amount to that 2,625 number.
If you’re interested in seeing more on this unrealistic “illustrative plan” see:
arcata1.com/gateway-barrel-district-illustrative-plan-1500-units
The issue here is not just that this “illustrative plan” is false, misleading, bogus, and unrealistic. The larger issue is that the inclusion of this plan into the draft EIR seems to reflect upon the people who created this draft EIR.
This “illustrative plan” can easily be deleted from this draft EIR (as far as I know, there are no references to it) and it likely will be removed. Other examples of false and misleading information may be more difficult to set straight.
The image below was modified from the original — colors were changed. The roofs are made to be the same hue, so we can more easily view the sizes and shapes of the buildings.
Follow page 3.2-26. (Figures pages are not numbered.) PDF pages 99 and 101.)
Remedy: Change wording. See below.
The draft EIR states (highlighting added):
“Figures 3.2-1 (A&B), and 3.2-2 (A&B) depict what a full build out scenario in the Gateway Area could look like from two locations located at the top of the hill.”
Should be changed to this or similar:
“Figures 3.2-1 (A&B), and 3.2-2 (A&B) depict what a build-out scenario in the Gateway Area could look like over the 20-year period, showing an approximate build-out of a projected 500 units. Shown from two locations located at the top of the hill.”
This is NOT a full build-out scenario. These images do NOT “depict what a full build out scenario” would be. The images show a total of FIVE buildings. It could theoretically be a potential build-out in the Gateway area over the duration of the General Plan (20 years, through 2045). But that is not what this draft EIR states. It states that this is a “full build out scenario.” This is false and misleading to the reader.
Figure 3.2-2B. View of Gateway Area. Looking south from K Street. 100 feet above the ground. (Following Page 3.2-26. PDF page 99)
Page 3.10-6 (PDF 273)
Remedy: States there 10 parks. In actuality there are 4. Correct and re-word.
The draft EIR states, highlighting added:
“Approximately 10 parks are located within 0.25 miles from the Gateway Area. Arcata Plaza is three blocks from the eastern boundary. Shay Park and Stewart Park are located to the north, and the Janes Creek Linear Park is west. South of Samoa Boulevard is the Arcata Marsh and Wildlife Sanctuary.”
First, this should be re-worded as this or similar:
“Approximately 10 parks are located within 0.25 miles from the boundaries of the Gateway Area.”
Or replace “boundaries” with “borders” or “edges.”
It is an invalid statement to assert that there are parks that are 0.25 miles from the Gateway area. The Gateway Area is large. The parks are not 0.25 miles from the whole of the Gateway area. They would be 0.25 miles from the edge of the Gateway area.
The draft EIR states that there are “Approximately 10 parks” and then just lists five parks. In reality there are four parks.
Where is Janes Creek Linear Park, and how do I get there? Does anyone know?
Janes Creek Linear Park is a non-existent City park that exists only on paper. In theory, it runs close to McDaniel Slough, behind some houses on the east side of the southern portion of Villa Way. There is no access to this theoretical park except by going over privately-owned fences and walking through private property – and there is serious doubt as to whether this park exists at all. McDaniel Slough will wander and change course.
To claim that this “park” exists and is located within a quarter-mile of the Gateway area – from its westernmost edge – is a severe misrepresentation of reality.
Infill Opportunity Zone issues
Page 2.0-18 (PDF page 52).
Remedy: Correct the draft EIR to include existence of Cal Poly dorms under construction.
From Page 2.0-18 (PDF page 52), highlighting added:
“This area will likely take longer to have a significant impact on housing.”
“The specific visioning has not been initiated in this Infill Opportunity Zone, but this Draft EIR anticipates potential minimum development at Residential High and Medium Densities.”
In actuality, the Craftsman Mall dorms are currently being developed – they are being constructed at this time. The dorms will have a significant impact on housing in Arcata by the end of this year – 2024.
While “specific visioning has not been initiated,” it is incorrect to state that “this Draft EIR anticipates potential minimum development at Residential High and Medium Densities.” High density development is already taking place.
This statement is incorrect: “This area will likely take longer to have a significant impact on housing.”
By the end of 2024 there will already be a “a significant impact on housing.” The impact of the dorms on the Craftman Mall Infill Opportunity Zone cannot be ignored.
The draft EIR includes many mentions of Cal Poly’s housing requirements and Cal Poly’s construction of housing. The quantity of housing that Cal Poly is planning to construct is a key element throughout the draft EIR. Many calculations and assumptions within this draft EIR are based upon the figures presented in the Cal Poly prospectus.
Page 3.9-2 (PDF page 245).
Remedies: 1,340 figure for housing units for the on-Gateway Infill Opportunity Zones is a virtual impossibility. Establish reasonably correct figures. Revise and correct.
Summary
- Cal Poly Humboldt housing is shown as 1,550 units – this should be 1,550 beds.
- The assumptions show Gateway area housing as 500 units. The assumptions show the other three Infill Opportunity Zones housing as 1,340 units combined. The three Infill Opportunity Zones have a smaller combined total area that’s less than the Gateway area, that have a smaller realistically developable area, and that have a stated lower likely level of redevelopment.
Background information
There are four Infill Opportunity Zones: The Gateway area, Downtown, Craftsman Mall, and Valley West.
The draft EIR states on page 2.0-18 (PDF page 52), highlighting added:
“…this Draft EIR anticipates potential minimum development at the proposed Residential High Density” for Valley West;
“…but this Draft EIR anticipates potential minimum development at Residential High and Medium Densities” for Craftsman Mall;
“The redevelopment within this area over the planning period is anticipated to produce 60 units, though the number could be much higher if either the Northcoast Co-op or Union Town Shopping Center are redeveloped.” for the Downtown zone.
The Gateway area is the predominate zone. It is listed as 139 acres, of which about 118 acres are parcels (balance are roads and rights-of-way). Of that amount, based on evaluating each parcel, about 46 to 51 acres could be available for redevelopment.
As an example, the Barrel District is said to be 35 acres. A large amount of that is preserved as a natural area. The remaining parcels add up to 28.90 acres. The planned-for park is one acre, and the roads and trails and woonerfs will amount to 3 acres or so. That leaves ~25 acres in the Barrel District for actual potential redevelopment.
The draft EIR shows the Downtown area as being 53.3 acres. The draft EIR states: “The redevelopment within this area over the planning period is anticipated to produce 60 units, though the number could be much higher if either the Co-op or Union Town are redeveloped.”
The Northcoast Co-op site is 1.43 acres. The draft EIR considers that this site is a possibility for redevelopment in the next 20 years. That seems like an unlikely assumption.
The Uniontown Shopping Center is 6.47 acres. If the stores on this site were to torn down and the property redeveloped, with commercial on the ground floor and housing above, this could result in the creation of perhaps 200-250 units. To view the Humboldt State student report from 2020 with ideas on how this redevelopment might work, see “Uniontown Revisioning Project” at arcata1.com/uniontown-revisioning-put-housing-over-cvs-and-safeway
The Valley West zone is shown as 33.9 acres. (My figures show 36.34.) The draft EIR states “While the specific visioning and land use proposals for the area have not been initiated, this Draft EIR anticipates potential minimum development at the proposed Residential High Density.”
The Valley West zone is not large. It consists of the space between Valley West Boulevard and Valley East Boulevard (the loop) where Valley West Shopping Center and the Hampton House and Comfort Inn hotels are located, plus the strip along Guintoli Lane to the east from there to the Highway 299 on-ramp.
The shopping center site is 10.31 acres. There is 3.40 acres that are empty, and about 2.7 acres that seem appropriate for redevelopment – 6.1 acres in all.
The Craftsman Mall Infill Opportunity Zone is shown as 41.8 acres. The draft EIR states: “This Opportunity Zone has 37 parcels comprising 12.2 acres of Residential Low Density along Todd Court and Eye Street, 7 parcels comprising 12 acres of Industrial Limited zoning, 6 parcels comprising 4.9 acres of Industrial General zoning, and 4 parcels of 7 acres zoned Residential Medium Density.”
That adds up to 54 parcels, totaling 36.1 acres. My calculations show 57 parcels that add up to 36.34 acres. So to say it’s 41.8 acres is probably an error.
The draft EIR states: “This area will likely take longer to have a significant impact on housing due to ownership patterns and the relatively built-out and constrained nature of the area. Notwithstanding, there is significant long-term potential in the Craftsman’s Mall / St. Louis Opportunity Zone. The visioning and rezoning have not been initiated in this Opportunity Zone, but this Draft EIR anticipates the proposed Residential High Density zoning to be applied to the properties.”
Of the 36.34 acres of the Craftsman Mall area, the university has rights to 11.22 acres. There are about 9.0 acres that are vacant, including portions of larger lots where there is a building potential. In addition, if the Mad River Lumber mill were to cease operations, that is 2.87 acres for redevelopment. There is a railroad right-of-way of 2.70 acres that is slated to be the Annie and Mary Trail. The residential portion of the Craftsman Mall area is pretty much built-up. Areas where a 2nd house could be built are included in the 9.0-acre figure of vacant land, above.
In total, there’s about 12 acres of buildable property in the Craftsman Mall Area.
Buildable area:
Downtown is shown as 60 units. If the Northcoast Co-op or Uniontown Shopping Center were to be redeveloped, there is greater potential.
Valley West has about 6 acres that are open for development.
Craftsman Mall has about 12 acres, assuming the Mad River Lumber site gets redeveloped.
And the Gateway Area is 138 or 139 acres, of which about 50 acres is open for redevelopment.
What does the draft EIR say?
See the “Housing Estimates” on Page 3.9-2 ( PDF page 245), highlighting added:
It shows:
– Housing Element Vacant Parcels – 351 units
First, for the Cal Poly Humboldt Campus Housing – that should be 1,550 beds, not units. That is stated in the paragraph earlier on the draft EIR page.
Here is the question:
The Gateway Area is 138 or 139 acres, of which about 50 acres is open for redevelopment. The draft EIR shows the assumption of 500 units during 20 years — the timespan of General Plan 2045.
The other three infill opportunity zones combined add up to about 20 or 25 acres that seem open for redevelopment. And, combined, they are assumed to have 1,340 units built there.
How can it be that the Gateway Area is assumed to have 500 units built… and Valley West, Downtown, and the Craftsman Mall areas are assumed to have 1,340 units built?
Is it possible there is something invalid about these assumptions?
Yes.
Unless the Uniontown and the Valley West shopping centers are torn down and replaced with four- to six-story buildings that have the two supermarkets, the restaurants, the retail stores, and more on the ground floor, then this 1,340 figure is an impossibility.
That is to say: Unless the owners of those two shopping centers are willing to risk the investment of $50 million or $80 million – then redevelopment of those sites on a scale to produce 1,340 housing units is not going to happen.
In addition: There just is not enough land.
Suppose new construction were to be built at an average density of 50 units per acre. Keep in mind that the ground floors will likely be commercial, so there is one less floor of residential space than there’d be in an all-residential building.
This section of the draft EIR needs to be looked at and revised.
These numbers, which assumptions, need to be scrutinized.
- 500 units are projected for the Gateway area. For the smaller combined area of the infill opportunity zones of Valley West, Craftsman Mall, and Downtown, there are 1,340 units projected. This is actually impossible.
For an analysis of the sizes and capacities of the Valley West, Craftsman Mall, and Downtown infill opportunity zones, please see the previous comment.
At 50 units per acre average, it would take 27 acres to build for 1,340 units. Unless every single vacant and re-developable parcel in all three of those infill opportunity zones are utilized, then the 1,340 unit figure would not be attainable.
This would mean – over the next 20 years — tearing down the entire Valley West shopping center and replacing it with ground-level commercial, residential on upper floors style buildings. Ditto for Uniontown / Safeway shopping. Ditto for the Northcoast Co-op block.
Possibly those 1,340 units were to consist only of a blend of 200 square foot micro-studios and 320 square foot studio apartments. Then, perhaps, there could be sufficient density to construct 1,340 tiny units in the space that’s theoretically available.
Vehicles Miles Traveled Analysis issues
Appendix G. Appendix page numbers 1-32. (PDF pages 1957-1990)
Remedy: Re-write. The analysis does not provide the conclusions that it asserts to.
Note: For the response these comments, every bullet-point item should be addressed.
From the draft EIR, Appendix G page 1 (PDF page 1958). Highlighting added.
“1. Introduction
This memorandum describes the proposed methodology for assessing transportation impacts in the City of Arcata (City) consistent with SB-743 and current CEQA Guidelines. Validation, testing and limitations of the proposed methodology, and initial findings associated with the methodology are presented herein. Additionally, GHD recommends a baseline VMT metric to which the City’s average metrics will be compared and a percent reduction target for determining thresholds of significance. The methodology and guidance presented herein has been developed for use by the City in establishing an interim ordinance for SB 743 implementation in the City.”
- Summary
-
- The conclusions of this Vehicle Miles Traveled analysis may be agreeable. But that does not mean that the methodology for reaching those conclusions are proper or correct.
- There is a requirement for some kind of Vehicles Miles Travelled (VMT) assessment, and a means of tracking improvements to this. Among the intents are to measure and effect reductions in miles travelled and greenhouse gas emissions produced.
- The City of Arcata, as expressed in the General Plan 2045 and elsewhere, supports a lessening of the Vehicles Miles Travelled.
- The State of California is looking for a reduction in Vehicle Miles Travelled. According to the draft EIR, initially the required reduction was 15% over existing conditions. (The time-line for this reduction is not stated in the draft EIR.) This was made to require a greater (19%) reduction in the four largest metropolitan areas, and smaller (10%) for smaller city areas. Arcata is not designated in the State’s target-setting. This analysis suggests using a target of just a 4% reduction of average per-capita Vehicle Miles Traveled. In my view, this is unacceptably low, and easily attainable – and environmentally irresponsibly.
- Many people would agree with what is meant to be “proven” in this analysis: That if housing is in close proximity to shops/services, then people will tend to drive less and walk or bike more. However, the methodology and levels of assumptions in this report are, in my view, quite flawed.
- The analysis appears to have been developed for a larger city – Sacramento. Some of the methodology may apply to Arcata and some absolutely does not. The analysis states that it is built for small-town use, but that is not always evident. For example, the section on “Destinations” looks at trips to offices, shopping areas, schools, etc. that are over 16 miles. This does not apply to Arcata.
- A section of the analysis is for trips to shops, services, restaurants, and such. Trips to work, school, social activities, and recreation are excluded. It could be argued that in this location, it is precisely the trips to work, school, social activities, and recreation that make up the large component of vehicle miles driven and greenhouse gas emissions produced.
- The VMT Analysis contains nothing on the potential reduction of vehicle miles traveled resulting from improved bike and walking pathways, improved transit systems, and a decrease in available parking – all of which are a part of the General Plan 2045 policies. On a City-wide basis, the improvements to the safety and comfort of non-vehicular modes of transit will likely do as much or more than the creation of denser housing.
- The analysis makes a large assumption: That if there is dense housing close to where there are jobs, then people who live in those areas close to the jobs will be the people who work there. While it can be argued that having housing near jobs is better than not having housing near jobs, the analysis does not make an actual correlation that indicates that people who live close to where there are jobs are actually the people who work at those jobs. Using downtown Arcata and Cal Poly Humboldt as examples, do people who work downtown or at Cal Poly Humboldt in reality live near their jobs? It seems that experientially, in this area, that they do not.
- The final sentence of the analysis is an example of a made-up statement. It is not a summation of the analysis, as it perhaps intends to be. It is a sentence with little meaning.
-
The Vehicle Miles Traveled Analysis is in Appendix G of this draft EIR. It is composed of about 22 pages of text and 10 pages of diagrams or figures.
I am in agreement with the premise that it is desirable to lessened Arcata’s vehicle miles travelled. What I disagree with is how this premise is arrived at and supported in this draft EIR analysis. And I disagree with some of the methodologies and the degree and types of assumptions.
- The analysis does not include many important factors in reducing VMT: Improvements to bike and walking paths, improved transit, decrease in available parking, and more.
Remedy: Revise and rewrite.
The VMT Analysis is noticeably void of discussions of the potential for decreasing vehicle miles traveled from sources other than the proximity of jobs, service, stores, and housing. All that is good, but on a City-wide basis there may be more “bang for your buck” results that come from a variety of policies that are a part of the General Plan 2045.
The analysis contains nothing on the potential reduction of vehicle miles traveled resulting from improved bike and walking pathways, improved transit systems, and a decrease in available parking. On a City-wide basis, the improvements to the safety and comfort of non-vehicular modes of transit will likely do as much or more than the creation of denser housing.
The Shasta Regional Transportation Agency’s August 2023 report, 9 pages, “2022 RTP/SCS Off-Model Strategy Quantification for the Shasta Region” can be seen at: srta.ca.gov/DocumentCenter/View/9065/Off-Model-Strategy-Quantification. This document is useful to read because it contains many factors that are not incorporated into the Arcata draft EIR Vehicle Miles Traveled Analysis, including improvements to transit, bicycle and pedestrian improvements, EV charging stations as part of zero-emission vehicle promotion, car share facilities, and bike share facilities.
- The goal for reduction of Vehicle Miles Traveled is based on Redding / Shasta County’s goal of only a 4% improvement. This is not enough.
The Appendix G page 30 (PDF page 1987) has a section on the development of goals for the reduction of vehicle miles traveled (and resultant greenhouse gas reduction) as put forward by the State. The document writes “As with other aspects of SB-743, there is considerable uncertainty regarding how the thresholds should be set.
According to the draft EIR, initially the required reduction was 15% over existing conditions. (The time-line for this reduction is not stated in the draft EIR, but is believed to be by 2035.) This was made to require a greater (19%) reduction in the four largest metropolitan areas, and smaller (10%) for smaller city areas.
Arcata is not in a Metropolitan Planning Organization (MPO) area and is not designated in the State’s target-setting.
The draft EIR Vehicle Miles Traveled Analysis states:
“For that reason, we suggest using the targets for Shasta RTA, as it is both the geographically closest MPO and demographically most similar MPO to the City of Arcata. CARB set the target for Shasta RTA at a 4% reduction in average per-capita VMT.”
I see no valid reason to copy Arcata’s targets for the reduction of vehicle miles traveled and greenhouse gas production on that of Redding / Shasta County. To copy Redding / Shasta County’s 4% reduction figure because they are the closest and because they have somewhat similar demographics (central cities and widespread rural areas) is simply not a good enough reason.
There are 18 California Metropolitan Planning Organizations. The Shasta Regional Transportation Agency is centered in Redding, California. The 48-page October 2015 document, “Technical Evaluation of the Greenhouse Gas Emissions Reduction Quantification for the Shasta Regional Transportation Agency’s SB 375 Sustainable Communities Strategy,” can be found at ww2.arb.ca.gov/sites/default/files/2020-06/Technical_Evaluation_of_the_GHG_Emissions_Reduction_Quantification_for_the_SRTA_SB_375_SCS_October_2015.pdf
This report concludes, highlighting added:
“This report documents ARB staff’s technical evaluation of SRTA’s adopted 2015 RTP/SCS. This evaluation affirms that the SCS would, if implemented, meet the Board adopted per capita GHG emissions reduction targets of zero (0) percent reduction in 2020 and in 2035.”
[ARB = Air Resource Board; SRTA = Shasta Regional Transportation Agency; RTP = Regional Transportation Plan; SCS = Sustainable Communities Strategies]
The Shasta Regional Transportation Agency’s August 2023 report, 9 pages, “2022 RTP/SCS Off-Model Strategy Quantification for the Shasta Region” can be seen at: srta.ca.gov/DocumentCenter/View/9065/Off-Model-Strategy-Quantification
This document is useful to read because it contains many factors that are not incorporated into the Arcata draft EIR Vehicle Miles Traveled Analysis, including improvements to transit, bicycle and pedestrian improvements, EV charging stations as part of zero-emission vehicle promotion, car share facilities, and bike share facilities.
- This draft EIR is environmentally irresponsible. The reduction of Vehicle Miles Traveled by only 4% is insufficient.
Remedy: Revise and rewrite.
The suggestion in this draft EIR that the reduction in the average per-capita vehicle miles travelled of just 4% is complete unacceptable.
This is a very easily achieved. We can do better – much better. It is strongly recommended that this low figure of a 4% improvement to Arcata’s VMT figure be revisited. This is an environmentally irresponsible figure.
By my view, this draft EIR is deficient as long as this low 4% improvement figure is in place.
According to this draft EIR, this 4% reduction figure is based on the goal set by the Shasta Regional Transportation Authority. Shasta County includes the incorporated cities of Redding, Anderson, and Shasta Lake. To the extent that politics might be a factor in setting environmental goals, politically it is more or less the opposite of Arcata and Humboldt County:
|
2020 Presidential Election Results |
Biden |
Trump |
Other |
|
Arcata |
63.5% |
34.3% |
2.2% |
|
Humboldt County |
65.0% |
31.6% |
3.4% |
|
California |
65.2% |
32.9% |
1.9% |
|
Shasta County |
35.5% |
62.7% |
1.9% |
To reiterate: A target goal of only 4% reduction in Vehicle Miles Traveled is completely unacceptable. The reasons for this 4% figure as stated in this draft EIR are not valid. The analysis does not include many important factors in reducing VMT, including improvements to bike and walking paths, improved transit, decrease in available parking, and more.
The Vehicle Miles Traveled Analysis of the draft EIR needs to be revised and re-written.
“Based on the 4% threshold referenced above, an impact threshold could be established that aims to achieve a total smart growth score for the City that is at least four percent higher than existing regional averages for Humboldt County.”
“Additionally, the countywide average is important to consider when deciding upon a baseline to compare impacts against and whether to use a local or regional threshold, which is discussed in the following section.”
The existing “smart growth score” average for Humboldt County is shown in this draft EIR as being 75.4. The existing “smart growth score” for Arcata is shown in this draft EIR as being 81.5.
The County overall average is greatly lowered by the rural nature of the unincorporated areas of the County, where the residential density is sparse and the distances travelled to a “regional destination” are greater. Not surprisingly, the weighed scores for the lower areas are:
-
- Unincorporated areas of the County: 58.7%
- Trinidad: 67.0%
- Rio Dell: 4%
- Blue Lake: 0%
That is to say, the areas that are farther away and have fewer job opportunities and require more driving for ordinary functions – these areas have a lower score. McKinleyville, as an unincorporated part of the County, is not broken out separately. Conceivably McKinleyville’s score helps to raise the figure for the unincorporated areas of the County – without McKinleyville’s input, the unincorporated portion of the County would be lower. The same would be the case for Cutten – it’s an unincorporated part of the County.
By the way, the “smart growth” score for Eureka is higher than Arcata’s, at 82.7. Presumably this is because there is more dense housing in Eureka, more jobs, and the capability of more short trips.
The draft EIR proposes:
“Using the land use diversity methodology described above, impacts associated with a city buildout scenario could be determined to be less than significant if the future citywide smart growth score performs at least 4% better than the existing countywide condition, meaning a future citywide score higher than 75.4 would be less than significant, while a lower score would indicate a significant impact.”
The County average is 74.3. The dubious math of this section shows a figure that would be 4% better than the County-wide average as 75.3.
Arcata’s current score is 81.5. According to what is said here, as long as a city build-out scenario does not negatively affect Arcata’s 81.5 score so as to reduce it to 75.4, then there is no significant impact. It is inconceivable and impossible for a project in Arcata to actually reduce the “smart grown” figure by such an amount.
The “Overall Smart Growth Score” is an “aggregate score, which consists of a weighted combination of the individual scores” and which is made up of “testable components [that] had been confirmed with independent substantial evidence.”
Here is the “Overall Smart Growth Score” table. Appendix G, page 28, PDF page 1985
How is the County Average computed?
It’s not a straight average. Nor is it a population-weighted average – I checked on that.
If it were a straight average – summing up the 8 components and then dividing by 8 – then the result would be 72.3, which is somewhat close but that isn’t the answer.
Below is the chart that compares Smart Growth scores to the County-wide average. It is based on an “ideal” Smart Growth score of 100. The math is as follows:
-
- Take the Smart Growth score, and subtract that from 100. That gives the points that are needed to get to the ideal score of 100.
- Take that figure for Arcata (it’s smaller) and divide it by the County-wide average (it’s larger).
- The result will be a percentage. In the case of Arcata, it’s 28%
- Since, according to this draft EIR, if a project does not reduce that figure from 28% to 4% then there is no significant impact caused by the project.
By this math, I think that even if Cal Poly Humboldt were to shut down and all the jobs there were to be replaced by a dozen security offices who each did put hundreds of miles a day on their trucks while driving around campus, this would not result in a negative impact.
There is something flawed with this math.
Appendix G, page 10 (PDF page 1967) shows “each city’s Destinations score against the share of trips originating in that city that are over 16 miles long.” The footnote states “The 16-mile distance was chosen based on the distance intervals available in Replica’s database.”
This is an absurd set of data to be using when evaluating the reduction of Vehicle Miles Travelled in Arcata. The distance of 16 miles is used because that’s what was in the database. That is not a reason to use it.
Here are some destinations that approximate a 16-mile trip from Arcata, as well as other typical lengthy trips:
-
- Trinidad: 16.4 miles
- College of the Redwoods: 16.9 miles
- Pierson’s Building Center: 10.9 miles
- Humboldt Hill Road: 13.8 miles
- Cutten: 9.3 miles
- Providence St. Joseph Hospital: 8.8 miles
The data confirms the fact that the Destinations score is strongly indicative of the propensity to make long trips; i.e. the higher the score, the fewer long trips are made.
The 16-mile distance was chosen based on the distance intervals available in Replica’s database.
This analysis is filled with a variety of assumptions. And yet these assumptions are stated as facts.
In “Analysis Steps” on Page 3 (PDF page 1960):
“Data shows that when housing is in close proximity to shops and services uses people will walk or bike to those uses at least some of the time, and even if they drive, the trips will be short (i.e., low VMT trips).
Similarly, the likelihood of people walking or biking to work, rather than driving, is influenced by the distance between their homes and workplaces. So, measures of proximity are also measures of the potential for VMT reduction.”
There is a footnote following that first sentence. But the footnote reference is for something else entirely, and does not reference the “data shows” of the statement. Rather it is a reference to State law that describes a requirement for evaluating a project’s transportation impacts. In other words, it is a false reference.
What makes these statements to be assumptions (although presented as facts) is this: There can be homes and workplaces and the proximity between them can be close. But it doesn’t mean that people who live in one location will have a job at that workplace location that’s close to them.
We see this all the time here in Humboldt. Someone who works in Arcata may work in Eureka. Someone who works in Eureka may work in Arcata. We can agree that it’s more desirable to have housing in locations near jobs than then not having housing near jobs, But the analysis does not make an actual correlation that indicates that people who live close to where there are jobs are actually the people who work at those jobs. Using downtown Arcata and Cal Poly Humboldt as examples, do people who work downtown or at Cal Poly Humboldt in reality live near their jobs? It seems that experientially, in this area, that in general they do not.
Page 4 (PDF page 1961), highlighting added:
“The hexagons are sized so that the distance from the center of any given hexagon to the opposite edge of a neighboring hexagon is 0.5 miles. The size of the hexagons was based on survey data of typical distances for walking trips by Americans. This means that all of the land uses in a given hexagon and its neighboring 6 hexagons are within comfortable walking and biking distance.”
The size of the hexagons are 0.5 miles from center of a central hexagon to the edge of the adjacent hexagon. For a group of 6 hexagons (7, including the center hexagon), it is 1.0 miles across.
This analysis is saying that 1.0 miles is a “comfortable walking and biking distance.” According the National Institutes of Health, 0.25 miles or a 5-minute walk has sometimes been assumed to be the distance that “the average American will walk rather than drive” and has been used as the value of acceptable walking distance in studies. However, that’s an average for all Americans. Younger people and people who do walk or bike (as opposed to those who do not) will walk or bike greater distances.
For the people who do walk, a figure of just over 0.6 miles is accepted. In general, these surveys are based on good weather and not having to carry anything.
In Arcata, we can visualize (or actually walk) these routes:
-
-
- From the Co-op to the Cal Poly University Center is about a 1.0 mile walk.
- From the Plaza to the parking lot at Klopp Lake at the Arcata Marsh is about 1.1 miles
- From the Creamery to the Arcata Community Center / HealthSport is about 0.9 miles.
- From Safeway to the Arcata United Methodist Church on 11th Street past Q Street is 1.0 miles.
- From Safeway to Arcata High School is 1.1 miles.
-
I am all in favor of more walking and biking. Providing housing that is closer to a store will likely result in more walking and biking trips to that store. I believe that this analysis tells us only what is possible – not what actually takes place.
“The data shows a very strong relationship between the two (the R-square is 0.94), which confirms that the underlying assumption is correct; when people live in close proximity to workplaces, they are more likely to have short work trips.”
What this wants to say, but does not explicitly say: Where there is housing near to where there are jobs, and if people choose to and are able to live in that housing that’s near to the jobs, then those people will have short work trips.
“Proximity to Regional Destinations: As shown, hexes in Arcata score high on its proximity to regional destinations because the city is a regional destination within Humboldt County.”
That is: Arcata scores high on its closeness to regional destinations because it is a regional destination.
Figure 4 shows the percentage of trips of all types under ½ mile in each of the cities that is made by walking or biking. In every case walking and biking accounted for more than half of short trips. This confirms the assumption that locally balanced land uses will not only reduce the length of auto trips but also reduce the number of auto trips made.”
What is odd about this graphic is the orange sliver on top of each blue bar. The blue represents walking trips of under 1/2 mile. The orange represents the biking trips.
What this graphic is telling us is that bike trips amount to a tiny fraction of overall under-half-mile trips – that biking amounts to under 4% of all under-half-mile trips and walking amounts to over 96% of these trips. This is obviously incorrect.
The charts show trip distances of 1/2 miles. In terms of the methodology, there would be far greater value if there were companion charts that showed the similar information using 1-mile trips. The analysis starts with the “fact” that 1.0 miles is a “comfortable walking and biking distance.” But it does not give us data that supports this.
This is the last sentence of the Vehicle Miles Traveled Analysis, and also the final sentence in this 1,990-page draft Environmental Impact Report. It is the conclusion of a paragraph about how the methodology presented here can be used on individual land use projects.
“The idea is to see whether the project moves the city or neighborhood it is in towards the ‘Goldilocks’ spot where the three main types of land uses are in perfect balance.”
The final sentence of the analysis is an example of a made-up statement. It is not a summation of the analysis, as it perhaps intends to be. It is a sentence with little meaning.
What are “the three main types of land uses”? We don’t know – this is not discussed in this analysis or in this draft EIR.
Sometimes there are said to be six types of land uses: Residential, Agricultural, Recreation, Transportation, and Commercial. Sometimes these five: Agricultural, Commercial, Recreation, Residential, and Transportation.
Could the writer of this sentence possibly have meant: Residential, Commercial, and Industrial — ?
Perhaps defining Industrial as the production of goods and Commercial as sales and services.
Or: Agricultural, Residential, Commercial / Industrial ?
What about schools, public facilities, and natural areas? Is the existence of Cal Poly Humboldt a part of this “Goldilocks” perfect balance?
What is the Goldilocks balance that we’re supposed to achieve?
We don’t know, because the draft EIR is not telling us.
Hazards and Hazardous Conditions section is incomplete, misleading, needs improvement
Category: Major omission in content. Absence of information is critical to the draft EIR. With this omission, the draft Environmental Impact Report is deficient. This section should be revised and Re-written.
Sections of the document includes 3.6 Hazards and Hazardous Conditions (Pages 3.6-1 through the unnumbered page after 3.6-27; PDF pages 175-202) and Appendix E – Environmental Database Review Data (Appendix E, pages 1 through 1934; PDF pages 761 through 1934).
The Hazards and Hazardous Conditions study is intended to be for the entire city area. Yet the level of detail in the study is inconsistent. It treats one area of the City of Arcata as requiring more study than other areas – and states that this was done “to facilitate ministerial permit review.” It is not the purpose of a city-wide Environmental Impact Report to “facilitate” the permitting process in one area of the city over any other area. The areas of the city are to be treated equally.
The entire City is said to be study area
Section 3.6.1 “Study Area” states (highlighting added):
“For impact assessment related to hazards and hazardous conditions, the City limits were used as the study area (see Figure 2-1 – City of Arcata Planning Areas).”
The start of Section 3.6 states (highlighting added):
“This section evaluates the potential impacts of the proposed General Plan 2045 on human health and the environment due to exposure to hazardous materials or conditions within the City.
A Technical Memorandum (Tech Memo) focused on the approximate 138-acre Gateway Area was prepared to assist the City as a component of their environmental due diligence.
The Gateway Area was prioritized for this Environmental Database Review search to facilitate ministerial permit review for high-density development in this area plan.”
Here are the issues:
As the document says, “The Gateway Area was prioritized for this Environmental Database Review search to facilitate ministerial permit review for high-density development in this area plan.”
Actually, the General Plan 2045 indicates other large areas of Arcata will have ministerial permit review for high-density development. These include the other three infill opportunity zones — Downtown, Craftsman Mall, and Valley West — and, through the GP 2045 an Implementation Measure, the entire neighborhoods of Bayview, Northtown and Arcata Heights, and Sunset.
What’s more, the actual working of the General Plan LU-9 Implementation Measure starts with “City shall consider a rezone to consider allowing mixed uses and more housing in current R-L neighborhoods within walking distance of the Plaza and Cal Poly Humboldt….” So essentially any neighborhood that is within “walking distance” of the Plaza and Cal Poly Humboldt is may be considered for higher density development.
The issue: Why is it that only the Gateway area was prioritized for an Environmental Database Review search? The Gateway area is an overlay zone within the area of the City of Arcata. The City has made it clear that the three other infill opportunity zones will be considered the same as the Gateway area. Each will have a form-based code, and each will be an overlay zone.
The Gateway area started out in the planning process as an Area Plan, but it evolved to become an overlay zone. In this way It is not different from the other infill opportunity zones. They all will have ministerial permit review, and they all will have higher density development. And so will the neighborhoods of the LU-9 implementation measure.
It is not the purpose of a city-wide Environmental Impact Report to “facilitate” the permitting process in one area of the city over any other area. The areas of the city are to be treated equally.
Why is the Gateway area treated differently in this draft EIR?
This is supposed to be the environmental impact report for the entire city.
The draft EIR states there are 11 active “Open Contamination Sites” and 92 “Closed” sites within the City limits. It lists the 11 active “Open Contamination Sites” (Table 3.6-1, page 3.6-4, PDF page 178) and has a map showing the 92 closed sites (Figure 3.6-1, no page number, located after page 3.6-27, PDF page 202).
The draft EIR lists 44 of the contamination sites (open and closed) as being in the Gateway area. It does not list the “Closed” sites by address in the other parts of the city area – again, treating the non-Gateway parts of the Arcata with less rigor.
Of the 11 active sites, three are located in the Gateway area and two are in the downtown area.
In the Gateway area, the three sites listed are:
Fisch Trust Property, 1461 M Street; Schmidbauer Arcata Mill (south), 901 O Street; and Arcata Community Recycling / former Standard Oil facility, 1380 Ninth Street.
The two downtown sites listed are: Ghera Property, 987 H Street (SW corner 10th & H, Humboldt Exchange); and the previous Northcoast Environmental Center site, 879 Ninth Street (vacant lot, south side of 9th Street, one lot east of the corner, across from Hensel’s Hardware).
Quite noticeably, there is only one identified contamination site in the Gateway area Barrel District on the clean-up site map. It is a closed case. That is at the previous Beaver Lumber Company site. The database shows the Wing Inflatables and FedEx sites were found to have no violations and don’t show up on the map. The Humboldt Waste Management site (the SoilScape) building shows environmental storage, and no notation – and it is not shown on the map. There may be a couple of identified Leaking Underground Storage Tank (LUST) sites in the Gateway area, with closed cases.
That there are no identified sites in this listing in the expanse of the Barrel District – a known area of decades of mill and industrial operations – shows a lack of scrutiny on the part of this draft EIR.
There is anecdotal information from “old timers” here in Arcata about open-pit wood preservative locations. The draft EIR says that aerial photographs were evaluated for evidence, and makes no note of anything that might bring an alert. It is generally the case that where there was a “teepee” beehive burner, there will be contamination around that location.
An environmental impact report isn’t required to be a thorough investigation – only to tell us what is known. This is similar to statements made in the Noise study: “At this time, it is not known if any of these facilities produce noise levels exceeding the standards….”
What does it take to know something?
How is it that this draft EIR can hide behind the shadow of “it is not known”?
Isn’t that the task of an environmental impact report – to research all available resources in order to find this out?
If all current resources are not researched, then the draft EIR is deficient.
Please note the following:
“Inactive site” status does not mean that the site is suitable for residential use.
From the draft EIR, page 3.6-3 ( PDF page 177), highlighting added.
“Inactive sites are defined as having been investigated and remediated to the satisfaction of the lead oversight agency.
Residual contamination at levels that do not pose significant health risks to the current land use may still be present at inactive sites.
However, inactive sites can be restricted for future land uses that require completely remediated conditions.
For example, an unauthorized release at an industrial property could be remediated to cleanup levels appropriate for future industrial land uses, but the residual levels of contamination after remediation may be too high and pose health risks for other types of future land uses such as residences, schools, or parks.”
In other words, the “case closed” sites located on properties that were formerly zoned “Industrial” may have been tested to a standard for future industrial use, but may not have been tested to a standard so that the property can be used for housing.
- The draft EIR states that building housing near contaminated former Industrial-zoned parcels is an issue, but includes no maps or recognition of this.
It is quite well-known that the industrial areas of the Gateway area are intended for the creation of housing. For the writers of this draft EIR to take the attitude of “At this time, it is not known” if the contamination sites are to a standard appropriate for residential use is disturbing.
- “Residual contamination at levels that do not pose significant health risks to the current land use [that is, the previous Industrial Use zoning] may still be present at inactive sites. However, inactive sites can be restricted for future land uses that require completely remediated conditions.”
Why are there no maps or information on inactive sites that indicate the level of health risks that might be present?
When the draft EIR says “at levels that do not pose significant health risks to the current land use” – isn’t this a bit disingenuous? At the moment that the General Plan 2045 is passed, these formerly-Industrial-Use zoned parcels will become Commercial-Mixed Use, and intended for residential development. What is the schedule here? Is the draft EIR to be certified or adopted prior to the General Plan 2045, or after?
This EIR is an evaluation of the impacts from the policies in the General Plan 2045. These policies specify residential use in formerly Industrial-Use zoned areas.
The Environmental Impact Report need to be far more forthcoming on this. A detailed analysis is warranted on this.
- Level of Significance is “Less than significant impact”
This doesn’t mean that it’s okay to build there.
As the draft EIR states on Page 3.6-23 and 24 (PDF pages 197-198), highlighting added:
“Impact HAZ-d:
Would adoption and implementation of the General Plan include site(s) which are included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Mitigation Measures: No mitigation is necessary
Level of Significance: Less than significant impact
“If no new potentially significant project-level hazards or hazardous materials are identified during the environmental screening, and the project otherwise qualifies for ministerial streamlining per the Gateway Code, then the project is ministerial per Arcata development code and qualifies for a CEQA Statutory Exemption per Section 15268.
If new or existing potential significant project-level hazards or hazardous materials impacts are identified as compared to the existing database review and/or GeoTracker investigation, the proposed project would require specific mitigation measures prior to being eligible for streamlined ministerial review.”
If a project requires specific mitigation measures, it also may require an additional CEQA review. This effectively defeats the time-saving aspects of streamlined ministerial review.
- Sanborn Fire Insurance maps are said to be used for identification
in this draft EIR. But the maps were hardly used, really.
The Sanborn Fire Insurance maps were used to evaluate a very small portion of the Gateway area. It is disingenuous to pretend that the Sanborn maps added anything of significance to the findings.
The draft EIR utilizes “Sanborn Fire Insurance” maps as a means of evaluating potential hazardous sites. The document states on page 3.6-10 (PDF page 184):
“Additionally, Sanborn Fire Insurance maps of the Gateway Area assisted in the identification of historical land uses and commonly illustrate the existence and location of underground and aboveground storage tanks, structures, improvements, and facility operations.”
This statement is highly disingenuous. The Sanborn Fire Insurance maps could hardly have been used to identify much at all.
The Sanborn Fire Insurance maps are located on pages 2 – 12 of Appendix E – Environmental Database Review Data. (PDF pages 762-772).
There are seven maps in total. Each map shows about eight or nine or so city blocks. There is one map each from the years 1961, 1951, 1941, 1928, 1919, 1908, and 1900 (the 1900 map covers very little area – about two blocks at 8th and K Streets).
The maps are for just a portion of the Barrel District – mostly between N and K Streets (2-1/2 blocks wide), between 7th and 10th Streets (3-1/2 blocks high). It’s mostly of the old Arcata Barrel factory – where the Wing Inflatables building (the long building) now is.
The four historic “Devlin Cottages” (located on 7th Street, between K and L Streets, to the north of the current AmeriGas site) appear on all the images except for the partial 1900 map that only shows two blocks.
“Additionally, Sanborn Fire Insurance maps of the Gateway Area assisted in the identification of historical land uses and commonly illustrate the existence and location of underground and aboveground storage tanks, structures, improvements, and facility operations.”
I say that is a false statement. The Gateway area is about 70 blocks. These maps show 8 or 9 blocks, total. It’s such a small portion of the Gateway area. The maps are of little useful value.
The draft EIR does not say whether anything of any significance was identified using these maps. There are no results indicated.
Throughout the draft EIR, it seems that a primary intent was just to “check the box” to say that the authors did this or that task. In terms of creating useable information, the authors do not seem to be concerned with that task.
Aerial photographs
The draft EIR contains 13 aerial photos from 1941 through 2016 – all of them covering just the Gateway area, not of the whole city — to help identify possible sources of hazardous contamination.
The locations of “teepee” beehive burners at lumber mills may be a spot where toxic waste accumulated.
The draft EIR contains the photos, but does not state whether the aerial photos were used to obtain any useable information. Conceivably each lumber mill would have had a teepee burner. The aerial photos are fun to look at, but the detail is such that it may not be possible to identify much of any use. I am not trained at identifying teepee burners, however I believe I can see two of them.
There are two types of aerial photographs: Vertical and Oblique. Vertical (straight down) aerial photographs are used to show streets and placement of buildings and open space. The resulting photographs look like a map – just flat image. Oblique aerial photos are taken at an angle. They show the appearance of buildings and structures, as there is a sense of perspective in the photograph.
The aerial photographs in the draft EIR are all vertical. They show where the buildings and structures are, but there is no sense of the shape or height of the structures.
Oblique photos of portions of the Gateway area are available. It is too bad that the authors of the draft EIR chose not to include them. They would have been valuable in accomplishing the document’s stated goal.
City directories (i.e. phone book, address listing, business directory) from past decades can be useful in identifying hazardous material sites. For example, a city directory might show the existence of a dry cleaner (there was one at 879 9th Street, the vacant lot where the Northcoast Environmental Center was located — Appendix summary page 43, PDF page 908) or a gas station or facility (there were 10).
The City Directory Image Report is included in Appendix E. (The page numbering system isn’t useful. It’s on PDF pages 788-849.)
The draft EIR includes small portions of directories for: 2017. 2014, 2010, 2005, 2000, 1995, 1992, 1982, 1977, 1972, 1968, 1964, 1958.
The directories shown are centered around 9th Street from 900 to the 1300 blocks (roughly I to N Streets); 10th Street from the 900 block to the 1600 block (roughly I to Q Streets; and L Street from 700 to 1300 blocks (7th to 13th).
The entries show are often just a few actual listings per block — that is, the entries might be a small portion of what was on that block. What is shown is perhaps 25% of the businesses/persons on the blocks shown.
What is the purpose of such a small sampling of Arcata’s directory?
Once again, it seems that a primary intent was just to “check the box” to say that the authors did this or that task. In terms of creating useable information, the authors do not seem to be concerned with that task.
Appendix E contains a detail map of contaminated sites. (No page number. In the “Executive Summary” section, after page 44. PDF page 911.)
Sensitive Receptors” are persons who are deemed to be especially sensitive to chemical or audio pollution sources. This group includes children, the elderly, and those who are infirm. Schools, daycare centers, hospitals, medical centers, nursing homes, etc. need to be noted and marked on maps. For noise, churches, parks, and play areas are also included.
The map shows the Little Learners Center on 11th Street and the Little Learners site on 10th Street. It shows “Northcoast Preparatory and Performing Arts Academy” (the school’s previous name) on 11th & Q. It does NOT show the Redwood Coast Montessori 6th through 12th school facility at 8th and K Streets.
The map is dated 2022 — the school started there in 2018.
Often when one error is found, there are other errors. The contact person shown on the map lives locally. He should know better.
Other omissions and empty references
Category: Omission of information. If the public cannot view it, the draft EIR is deficient.
Appendix B, pages 24 and 33. (PDF pages 626 and 635)
The letter from Arcata Fire District Chief Justin McDonald is missing or incomplete, and not readable. He wrote “Here is the letter from the Fire District.” but there is no letter there. He refers to four images, but the images are not there.
Note the name of Arcata Fire District Board Member Eric Loudenslager is misspelled, page 4.
Category: Omission of information. The full list of “Historic Resources in the Study Area” should be included in this EIR document.
Page 3.4-2 ( PDF page 122)
The draft EIR has a listing of the “Historic Resources of the Gateway Area.” It has a 19-page appendix (Appendix D, PDF page 741) of “City of Arcata Gateway Area Historic Resources Inventory.”
For the City-wide list of “Historic Resources in the Study Area” shows a list of the nine National Register buildings and then says:
“There are 96 local historic landmarks within the study area which are listed in Table HP-1 of the Arcata General Plan 2020.”
First, this appears to be a typo – Likely should be “Table HP-1 of the Arcata General Plan 2045.” I do not believe that Table HP-1 is in the General Plan 2020.
Table HP-1 is in the General Plan 2045 on page 5-31 in the Design and Historic Preservation Element, along with two maps. The 96-entry listing is on 4 pages.
This draft EIR is 1,990 pages long. Why not include another four pages? Or six pages with the maps.
To omit this important City-wide list of designated historical sites is irresponsible for what is supposed to be an inclusive.
Category: Omission of information.
Page 5.5-30 ( PDF page 510)
While there is a discussion of Sea Level Rise issues, there is almost no mention of King tide / Storm Events. The draft EIR states: “Projected to occur after the planning horizon, 3.3 feet of sea level rise could reach very minor areas along the very southern edge of the Gateway Area during high tides.” and “None of the development allowed under the General Plan 2045 would exacerbate sea level rise within the areas that are vulnerable to 3.3 feet of sea level rise, therefore sea level rise is not discussed further in this analysis.”
The King tide / storm event of New Years Eve 2005 and the event of January 11-12, 2020, brought tide levels of 8.5-9 feet. In 2005, sections of Highway 101 were covered with water. Noted local sea level rise expert Aldaron Laird has discussed the King tide / storm event situation on numerous occasions, including at a presentation to the Arcata City Council on March 28, 2023. For a video of this presentation and more discussion on King tide events, see:
- arcata1.com/sea-level-rise-presentation-on-march-28th-to-pc-and-cc/com/sea-level-rise-presentation-on-march-28th-to-pc-and-cc
- arcata1.com/olli-presentation-on-sea-level-rise-aldaron-laird-march-16-2023
- arcata1.com/sea-level-rise-selected
A sea level rise amount of just one or two feet – which is predicted to occur within the timeframe of this General Plan 2045 period, when coupled with a King time / storm event, is likely to affect sections of Arcata that are considered appropriate for development.
This potential is not discussed in the draft EIR. This is an omission of a necessary consideration.
- Rising Groundwater
There is no mention of rising groundwater in this draft EIR. Yet this is a very real consideration as a part of climate change. Rising groundwater will affect road construction, underground utility lines, and foundation engineering.
Alameda, Marin, San Francisco, and San Mateo Counties recognize the impacts of rising groundwater. They issued a study on this in 2022. The study focused on the San Francisco Bay side of each county and does not include the Pacific coastline of Marin, San Francisco, or San Mateo Counties. That is, the report deals with bay issues, not with ocean issues – just as we have here in the city of Arcata.
This report can be seen at:
arcata1.com/emerging-groundwater-report-from-the-sf-bay-area
Among what is in their report:
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- Low-lying inland areas could flood from below by emergent groundwater long before coastal floodwaters overtop the shoreline.
- Rising groundwater can destabilize foundations, flood basements and other underground structure, and increase infiltration into sewers.
- Contaminated Sites: The interaction of rising groundwater and contaminated sites could pose challenges for public health and the environment.
- The California Toxic Tides study significantly underestimates the number of sites located in low-lying coastal communities that contain legacy contamination from past military, industrial, manufacturing, or other purposes and does not consider sites that will be impacted by groundwater rise.
- Current remediation regulations consider a static climate, meaning they do not consider a rising groundwater table.
- Liquefaction: The areas most at risk of liquefaction are generally located along the Bay shoreline and Bay tributaries in former floodplains, marshplains, wetlands, mudflats, and open water areas that were filled for development. These same areas are at risk of rising groundwater, and as the groundwater table rises, the liquefaction risk is likely to increase.
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Misstatement of Cal Poly Humboldt’s off-campus housing needs
- Cal Poly’s off-campus proportion taken from Arcata’s newly constructed housing will not be 40% or 50% — it may be closer to 70%
Page 2.0-5 (PDF page 39)
Remedy: Revise with valid information. As it is the figures are misleading.
At different spots within the draft EIR, it is estimated that the City of Arcata is expected by Cal Poly Humboldt to take of 40%, 50%, or 60% of its housing needs for students and staff.
Page 2.0-5 (PDF page 39), highlighting added:
“Cal-Poly Humboldt plans to develop and maintain housing to accommodate approximately 50% of its planned 2030 resident student population.”
On the same page, Table 2.4-1. Shows a 40% prospectus and a 60% prospectus for Cal Poly’s proportion of the total population growth.
The Cal Poly prospectus shows an increase of 5,500 “full time equivalency students” (FTES) or about 6,200 persons. Added dorm beds shown in the prospectus (page 76) are 2,050 to 2,250. At best, the dorm beds that are planned to be added amount to just 37% to 41% of expected increase of “full time equivalency students” or just 33% to 36% of the number of persons. Clearly Cal Poly Humboldt is looking to the community to supply housing.
Cal Poly’s prospectus shows they will rely on Arcata for 64% to 66% of the need for housing — not 50% as the draft EIR states.
In terms of numbers, if Cal Poly were planning on housing 50% of the increased, that would result in an off-campus housing requirement for about 3,100 people. But that is not their plan. Their plan is to supply 2,250 beds (that’s the high side), and have the off-campus housing requirement be about 3,950 people.
Table 2.4-1 (see above) shows “Population Scenarios with Various Average Annual Growth Rates.” This shows a 2045 growth of 7,543 people, and lists two possibilities for how much of the increase in student population that would be required for off-campus housing: 40% and 60%.
Based on the Cal Poly Humboldt prospectus, they are not calling for 40% or 50% or even 60%. They are calling for about 64% of the increase in student population to be housed off-campus.
This does not include faculty / staff housing needs — which likely will be entirely in the community. Cal Poly estimates are 625 staff – which with family members could be 1,200 or more. This staff would not necessarily live in the City of Arcata. If the 2,791 new dwelling units figure is used, as put forth in this the draft EIR, this could bes over 22% of Arcata’s growth projections for these 625 persons for Cal Poly’s staff needs, if they were to want to live in Arcata.
Adding the 1,200 staff and family figure to the 3,950 off-campus student housing requirement figure yields a requirement for housing for over 5,150 people.
The figures imply Arcata will be expected to accommodate close to 70% of Cal Poly’s future student, staff, and family housing needs.
The population increase shown in the draft EIR is around 7,500. See Table 2.4-1, shown on page 2.0-5 (PDF page 39). If over 5,100 people from the expansion of Cal Poly Humboldt are going to be housed off-campus, and if all those people were to live in Arcata, then the Cal Poly requirements would take over ~69% of the new housing built in Arcata.
This is what this draft EIR is saying.
We can acknowledge that students, staff, and family will also be living in the surrounding areas, including McKinleyville, Manila, and Eureka. When the student population was close to 9,000, about seven years ago, that is what we saw.
Regardless, the increase in student, staff, and family puts a tremendous pressure on housing availability and rental costs.
Noise study is based on “modeling” of 27-year-old sound measurements. And it is likely wrong.
- No new sound measurements were made for this EIR. The modeling is based on theory, speculation, and assumptions.
Section 3.3 “Noise” – pages 3.8-1 – 3.8-26 (PDF pages 216 – 243)
Appendix F – Noise Study Technical Memo (PDF pages 1,935 – 1,990)
Note: The phrase “sensitive receptor” is used to refer to a person who is sensitive to such environmental issues as air pollution, odors, dust, chemical pollution, noise, etc. This group includes children, the elderly, and those who are infirm. Uses that are considered “sensitive receptors” include schools, daycare centers, hospitals, medical centers, nursing homes, etc. When evaluating noise levels, the proximity of churches, parks, and play areas is also taken into consideration. There can be “interior sensitive receptors” (sensitive people or children who are inside) and “exterior sensitive receptors” (sensitive people or children who are outside). The phrase “sensitive receptors” is in the draft EIR a total of 94 times,
First, we will note that there was not an actual survey of noise level measurements in Arcata that was done as part of this Environmental Impact Report. Rather, this draft EIR utilized measurements that were conducted in 1997 – that is, 27 years ago. These measurements were “modeled” to account for (in theory, that is) population growth and other factors.
The factors that were used in this modeling likely did not include the real-world considerations that we’ve seen from changes over these past 27 years. These changes include:
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- Diesel pickup trucks in far greater numbers: Louder
- Greater use of off-road or aggressive tread tires: Louder
- On an average basis, vehicles are larger than they were 27 years ago. Larger and heavier vehicles generally produce more tire noise.
- Proliferation of modified muffler systems: Louder
Even though not allowed by law, there is little enforcement. This is a major issue in Arcata. - Vehicles traveling faster on City roads. An increase in speed results in a large increase in noise from tires.
- While the modeling may account for increased traffic based on increased population, it may not be accounting for changes in traffic patterns. As one example, the increased traffic on Alliance Road and around Arcata High School at drop-off and pick-up times. A greater percentage of students do not walk to school now, relative to 27 years ago.
- Compared to 27 years ago (1997 – prior to the Dot.com expansion), a vast increase in home deliveries from on-line shopping. UPS, FedEx, USPS, etc. trucks all add to the noise.
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Since so much in the EIR and mitigations depends on actual noise measurements, I find it irresponsible to not have conducted at least a sampling of noise measurements.
As an example of how the modeling of 27-year-old data might not be working as planned, the draft EIR charts show Alliance Road as being less noisy than K Street. This depends on where the measurements are taken, of course. But in general we find Alliance Road to be much louder than K Street.
Under some conditions – situations that may already exist in Arcata – the developer of an apartment building may be required to install an air conditioning system, so that residents can keep their windows closed… to keep out excessive street noise.
Examples of mitigation that could be required:
Appendix F – Page 14 (PDF page 1949)
“Thus, for potential developments where exterior road traffic sound levels exceed the indoor sound level criteria of Table 6 by more than 10 dBA (rounded down from 12 dBA), central air conditioning systems will be required to allow occupants to close their windows to achieve acceptable indoor noise levels.”
Appendix F – Page 18 (PDF page 1953)
“GHD has quantitatively assessed the transportation noise impacts projected inside the City and established a land use compatibility plan for new development projects in the City. Mitigation measures for developments located in heightened acoustic conditions have been recommended to ensure compliance with the existing Municipal Code sound level exposure limits, and include central air conditioning, acoustic barriers, and/or upgraded building exterior construction.”
Appendix F – Page 13 (PDF page 1948)
“Projected growth during the General Plan Update planning period (up to 2045) is expected to result in development of noise-sensitive uses in the Gateway Area where noise levels may exceed applicable standards for sensitive interior and outdoor areas. Transportation noise levels exceeding standards contained in Table 6 of this report would represent a significant impact.”
In addition to mitigation requirements of possible noise barriers and central air conditioning, there is also the question of how close to acknowledged sources of traffic noise a building that’s planned for construction will be.
Table 3.8-8, “Setback Distances to Noise Prediction Thresholds (Page 3.8-19, PDF page 234), we see that some form of mitigation may be required for residential construction along K Street, Alliance Road, and Samoa Boulevard if noise levels are greater than certain standards. The table shown has been modified with the red boxes and blue arrows. This table is also found in Appendix F Noise Study Technical Memo, page 15 (PDF page 1,950).
The noise levels are expressed in “dBA Ldn” – an industry standard measurement that is time-weighted for measurements taken after 10 PM and before 7 AM, the times when the background noise is quieter and people are more sensitive to noise.
What this table is telling is that at certain noise levels, for setback distances along K Street, Alliance Road, and Samoa Boulevard, sound mitigation may be required.
- Based on the “Transportation Noise Contour” map in the draft EIR, the noise levels of large areas of Arcata already exceed the City’s standards.
Based on the “Transportation Noise Contour” map in the draft EIR, the noise levels of large areas of Arcata already exceed the City’s standards. The draft EIR alludes to this, but does not specifically point this out. This is irresponsible.
The “Transportation Noise Contour” map in the draft EIR is found on an unnumbered page, after page 3.8-26 (PDF page 243). An almost identical map called Figure 2 is located in the Noise Study, Appendix F, no page number, after page 19, (PDF page 1,956). That map is included here, below.
What we can see is that areas that are two or three blocks on either side of Highway 101 are in the tan color, representing a sound level of 65 to 70 dBA Ldn. This corresponds to about H Street on the downtown side, and about to Union Street in the Bayview neighborhood on the east side of 101. The light green color is 60 to 65 dBA Ldn. That extends from about L Street on the west to around Bayview Street (a block or two past Union Street) on the east side.
Appendix F, page 11 (PDF page 1946), highlighting added:
“A community noise survey conducted in 1997 as part of background studies for the General Plan showed that typical noise levels in noise-sensitive areas of the City ranged from 46 dB to 63 dB Ldn.”
“Based on projected 2020 noise contours presented in the Arcata General Plan: 2020 as well as the noise survey results referenced above, GHD estimates that existing road traffic noise levels within the City are generally in the range of 50 dB to 65 dB Ldn. At locations in close proximity to major roads and highways there is potential for existing noise levels exceeding 65 dB Ldn.”
Appendix F, page 15 (PDF page 1950), highlighting added:
“As seen in Figure 2, projected 2045 road traffic noise levels in the Development Areas exceed 55 dBA Ldn, such that noise mitigation is expected to be required. For any planned sensitive uses within the corresponding roadway setbacks noted above, mitigation will be required as described below.”
Table 6 shows the maximum allowable transportation noise exposure. (Appendix F, page 7, PDF page 1942.) This is “Table 3-3” of the Arcata Municipal Code. It is shown here below.
This table shows that “Noise Sensitive Land Use” – which includes Residential – shall have a maximum sound level for outdoor activities of 60 dBA LDN.
What this means
What this is indicating is that there are areas in Arcata that will require the mitigation described in Table 3.8-8 (shown above) which are:
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- Central air conditioning
- Acoustic barriers for Outdoor Activity Areas
- Possibly upgraded building exterior construction.
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As the draft EIR states, Appendix page 8 (PDF page 1953), highlights added:
E. Standards for sensitive receptors. New noise sensitive land uses as identified in [Table 6] shall not be allowed where the noise level from existing non-transportation noise generators will exceed the noise level standards in [Table 5], or where projected levels of transportation noise will exceed the levels specified in [Table 6], unless effective noise mitigation measures are incorporated into project design to maintain outdoor and indoor noise levels on the receptor site in compliance with [Tables 5], and [6].
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- New noise-sensitive uses. New construction and retrofits at existing buildings shall include appropriate insulation, glazing, and other sound attenuation measures so that they comply with standards in [Table 6].
- Mitigation required. Noise that may affect a proposed noise sensitive land use shall be mitigated to not exceed the noise level standards in [Table 5] at the property line of any noise-sensitive land use identified in [Table 6]. Appropriate mitigation measures include:
a. Noise attenuation measures, and stationary noise source controls shall include the use of barriers, setbacks, site design, baffles, enclosures, silencers, and improved facade construction techniques.
b. Where noise mitigation measures are required, mitigation shall occur primarily through site planning and project design, where feasible. The use of noise barriers shall be considered a means of achieving the noise standards only after all other practical design-related noise mitigation measures have been integrated into the project.
F. Acoustical analysis. Where the Director determines that a proposed project is a noise sensitive land use (such as hospitals, schools, and health care facilities), or may generate noise in excess of any limit established by [Tables 5] or [6], and/or where the use may generate noise in outdoor areas in excess of 60 dBA, the planning permit application for the use shall include an acoustical analysis, which shall:
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- Be the financial responsibility of the applicant;
- Be prepared by a qualified person experienced in the fields of environmental noise assessment and architectural acoustics;
- Include noise level measurements, with sufficient sampling periods and locations, to adequately describe local conditions and the predominant noise sources;
- Estimate existing and projected cumulative (20-year) noise levels in terms of Ldn or CNEL and/or the standards of [Table 5], and compare those levels to the requirements of this Section and the policies of the Noise Element;
- Recommend appropriate mitigation to achieve compliance with this Section and the policies and standards of the Noise Element, giving preference to proper site planning and design over mitigation measures which require the construction of noise barriers or structural modifications to buildings that contain noise-sensitive land uses;
- Estimate noise exposure after prescribed mitigation measures are implemented; and
- Describe a post-project assessment program that may be used to evaluate the effectiveness of the proposed mitigation measures.
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- The “Elephant in the Room” = Arcata’s traffic noise level may require substantial mitigation, with costs to be paid by the builders.
But we don’t really know what will happen. The draft EIR is relying on projections of sound levels made by modeling the actual sound measurements that were done in 1997 – 27 years ago.
After new, current sound level measurements are done, we’ll know more.
Odd proposed mitigation measures, requirements, exclusions
- Mitigation for excess noise: Require central air conditioning, so people can leave their windows closed.
Appendix F – Noise Study Technical Memo.
Page 14 (PDF page 1949)
Noise chapter, page 3.8-19 (PDF page 234)
See the section above:
Noise study is based on “modeling” of 27-year-old sound measurements. And it is likely wrong.
No new sound measurements were made for this EIR. The modeling is based on theory, speculation, and assumptions.
Issues with the Impact assessments
Would adoption and implementation of the General Plan contribute to a cumulatively significant impact to cultural resources?
Pages 3.4-21 and 3.4-22 (PDF pages 141 and 142)
Remedy: Typographical errors on the table of future projects. Repair the typographical errors.
From the draft EIR document, pages 3.4-21 and 3.4-22 (PDF pages 141 and 142), highlighting added:
“The cumulative effects analysis examines the current Project effects taken together with effects of past projects and known projects in the foreseeable future. Future projects considered for cumulative impacts are identified in Table 1-1.”
There are four references in the paragraph with “Table 1-1” that require repair. What is likely meant is the “Table 1-10-1” in this draft EIR document.
Would adoption and implementation of the General Plan result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools?
Page 3.10-46, PDF page 313
Remedy: Reassess this Impact. The draft EIR assessment is inaccurate and inconsistent, based on its own supplied information.
From the draft EIR:
“The growth anticipated in the General Plan 2045 could potentially result in the need for new or expanded school facilities. The location and extent of new or expanded facilities to serve additional students in is not known at this time. Therefore, the significance of physical impacts on the environment that could result from the construction and operation of future school facilities cannot be evaluated.”
Level of Significance: Less than significant
I disagree with the logic and the results. We can understand that the location and extent of new or expanded facilities are unknown at this time. But the draft EIR clearly presents the viewpoint that new facilities will be required to accommodate and expanding population.
Pages 3.10-46 and 47 (PDF pages 313 and 314), highlighting added:
“However, with an estimated 700-1,200 new kindergarten through twelfth grade students over the planning horizon, it is likely that new or expanded school facilities or staff within the City would be needed.”
The “physical impacts on the environment” that will result from “construction and operation of future school facilities” perhaps cannot evaluated with exactness. But as the draft EIR states, that expansion will take place. Just because it cannot be determined with precision at the current time does not mean that it is less than significant.
Throughout the draft EIR document there are effects which are not specifically measured, but, rather, are projected or modelled. It is not necessary to have precise measurements in order to evaluate the impacts; in fact, it is often the case that precise measurements are not available. One example is in the Noise study, in which impacts are assessed based on the modeling of data that is 27 years old.
Seeing as the draft EIR itself says “it is likely that new or expanded school facilities or staff within the City would be needed” it would not be proper to ignore this environmental assessment requirement.
The draft EIR states “The location and extent of new or expanded facilities to serve additional students in is not known at this time.”
By a similar logic, the “location and extent” of new apartment buildings to house the population growth is not known at this time. But we do not need to know the “location and extent” of new facilities in order to project their quantity and impact.
Page 3.10-47 (PDF page 314), highlighting added:
“New school facilities would be primarily provided as expansions to existing facilities or on infill sites with land use designations that allow such uses, such as Public Facilities or Gateway Area residential zones (PF4a). Public Facility Element Policy PF-4a requires the City to coordinate with local school districts regarding expected growth and encourages the districts to expand existing schools rather than designating new sites to serve future student enrollment needs; thus, reducing potential impact by focusing development on property previously disturbed or developed. Additionally, new or expanded facilities would require adherence to all applicable building and zoning codes, and if relevant, additional CEQA review to analyze project and location specific impacts.”
To state that “New school facilities would be primarily provided as expansions to existing facilities or on infill sites with land use designations that allow such uses….” is an assumption that this draft EIR cannot possibly foresee. This is encouraged, but it is not a foregone conclusion, as the word “would” defines.
The language of General Plan PF-5 “Educational Facilities” Policy PF-5a reads “The City shall encourage the school districts and charter schools to expand existing schools rather than designating new sites for this purpose.”
I ask this: “with an estimated 700-1,200 new kindergarten through twelfth grade students over the planning horizon” – plus pre-school and daycare facilities – is it not likely that one or more new facilities will be built over the 20-year planning horizon?
In Arcata we have seen multiple new school facilities over the past ten years – and this is during a period of lower growth than is projected for the future.
The draft EIR is projecting a 40% increase in population. It is false to assume that the new student-age population will be served in existing facilities. The reality of the past 10 years has shown otherwise.
In this way, this section of the Impact assessment is deficient. It requires expansion of the environmental impacts if it is to make a “Less than significant” determination.
Small update needed on Page 3.10-47 (PDF page 314).
“PF-4a” needs to be updated to “PF-5a” – two locations.
“New school facilities would be primarily provided as expansions to existing facilities or on infill sites with land use designations that allow such uses, such as Public Facilities or Gateway Area residential zones (PF4a). Public Facility Element Policy PF-4a requires the City to coordinate with local school districts….”
In general, it would be better to write out the name of the Policy and not just refer to it by its abbreviated policy number. That is, to say “Public Facility Element Policy PF-4a Educational Facilities requires the City….”
Would adoption and implementation of the General Plan 2045 contribute to a cumulatively significant impact to Public Services?
Page 3.10-52 (PDF page 319)
Remedy: Reassess this Impact. The draft EIR assessment is inaccurate, based on a misinterpretation of State law.
From the draft EIR:
“Projects located in areas subject to school district development impact fees would be required to pay the adopted fees to ensure the adequate provision of schools in the future. Per SB 50, these development fees are deemed to be “full and complete school facilities mitigation” and therefore a less than significant cumulative impact would occur.
Projects located in areas that are not subject to school district impact fees would either not result in significant impacts or the districts will adopt development impact fee programs. The process for adopting impact fees is subject to the various school districts’ concerns for impacts to their facilities. The districts are able to adopt the fees unilaterally when they find that there are impacts related to new development. For this reason, any impact associated with a district that does not currently have an adopted fee would remedy the impact by adopting a fee.”
This is incorrect. It is not the case the adopted fee would remedy the impact. The adopted fee may lessen the impact – but is not intended or guaranteed to remedy the impact, as the draft EIR states.
The writers of the draft EIR need to get advice from an attorney on this, or read the statute. The depiction here of SB 50 is vastly misinterpreted.
When in SB 50 it says that the development fees are “full and complete school facilities mitigation” this does not mean that those fees are all it takes to operate the schools for the number of children that will be added by the development.
Rather it means if the development fees are imposed, then the jurisdiction (the city, county, etc.) cannot deny the project. The theoretical increase in school expenses coming as a result of the development are said to be mitigated. This does not imply that the actual costs are taken care of – only that the development cannot be denied on the basis of school expansion expenses if those fees are imposed.
Similarly, the draft EIR states “For this reason, any impact associated with a district that does not currently have an adopted fee would remedy the impact by adopting a fee.” This also is false. The costs of the impact are not “remedied” by adopting the fee, resulting in no impact on the school system. The fee is the maximum that can be assessed.
The maximum fee is $4.79 per square foot of development. So a 1,000 square foot apartment – perhaps three bedrooms, for a family with, say, two children – would require the developer to pay $4,790 as fees – on a one-time basis.
The draft EIR can state that the imposition of this fee will “remedy” the impacts, but that is not true.
Would adoption and implementation of the General Plan result in substantial adverse physical impacts associated with the provision or new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks?
Page 3.10-47 (PDF page 314)
Remedy: Reassess this Impact. The draft EIR assessment is inaccurate, based on a misinterpretation of State law.
The impact question can be shortened as: Would adoption and implementation of the General Plan result in … need for new … facilities … in order to maintain acceptable service ratios … for parks?
In response to the impact question in the draft EIR is: Mitigation Measures: No mitigation is necessary. Level of Significance: No impact.
I disagree with the reasoning of this section, and I disagree with the response.
The discussion in the draft EIR contains information that is irrelevant. While true, is not pertinent to the discussion at hand.
Note on definitions: The use of the word “developed” as in a “developed park” does not refer to that the park already exists, i.e. has already been developed. The word “developed” is to distinguish that park design from that of an “undeveloped” park. An “undeveloped” park can have trails and other facilities – the phrase does not mean that the park is untouched.
As stated in the General Plan 2045, “More than 97% of the City’s parks and recreation acreage is provided as Natural Areas or undeveloped park reserves and a relatively small proportion of the park system is devoted to developed parks.”
The draft EIR mixes up the need for developed parks that are close to where a person lives, and brings in the large areas of Arcata’s undeveloped parks (i.e. nature and trails) that may be located some distance away. Those undeveloped parks are great – but their quantity is not a substitute for neighborhood-oriented developed parks. What’s more, travelling to Arcata’s undeveloped parks often involves a vehicle trip, which is counter to the General Plan 2045 emphasis on reducing vehicle miles traveled.
The draft EIR has a discussion of the Quimby Act (State law) which allows for parkland of three to five acres per 1,000 residents, and states that the City will be within this 3 to 5 range. The Quimby Act is for the creation of sub-divisions. As a law, it is not applicable to expansion of a city as the General Plan 2045 describes.
The draft EIR states that, based on public outreach, Arcata residents value a park system that emphasizes natural areas and trails. We can accept all this as true. Arcata has over 4,000 acres of what are called “undeveloped” parks.
Arcata residents value a park system that emphasizes natural areas and trails. It is the developed parks that are the concern of this section. These would be parks that are ideally within close walking distance of where the new construction will take place and where people will live.
The draft EIR states: “Considering the large expanse of natural area and undeveloped parks, the City will exceed well past the Quimby Act maximum dedication ratio when considering the projected population and existing undeveloped parkland.”
No, we are not considering the “large expanse of natural area and undeveloped parks.” We are considering the near-neighborhood construction of what will be called “developed” parks.
On page Page 3.10-52, PDF page 319, the logic is similar:
“Arcata currently has approximately 4,200 acres of parkland. Development proposed by cumulative projects could increase the use of City parks, however Arcata would still maintain a high ratio of parks to population. Cumulative project development would not result in the need for new or expanded parks and recreation facilities.”
The ratio that the City of Arcata wants to maintain is 5 acres of developed parks per 1,000 residents. This is for developed parks. Arcata currently has 88.8 acres or 95.9 acres of developed parks (depending on the information source). A population of 27,000 residents would involve about 135 acres.
If the backwards logic of the draft EIR were to be taken as truth, the City would not be maintaining a 5 acre to 1,000 resident parkland ratio, but rather it would be a 210 acre per 1,000 resident ratio – based over 4,100 acres of parkland. This is laughably not the case. The type of parks being considered in the Arcata ratio is developed parks.
From the draft EIR:
“In Arcata, the current area of developed parks is 95.9 acres and undeveloped parks is 4,006.8 acres. The City currently maintains a parkland to population ratio of approximately five acres per 1,000 residents. [Note: This should say developed parkland.]
The General Plan 2045 assumes a total resident maximum population of 27,000 in 2045. Based on this population, 135 acres of total parkland would be required to maintain a ratio of five acres per 1,000 residents.
Therefore, without the Public Services and Recreation addition of new parkland, the ratio of developed parks and undeveloped parks to residents in 2045 would be approximately 4.3 acres and 147 acres per 1,000 residents, respectfully.”
The section concludes:
“Based on the range of Quimby Act parkland dedication….”
“Even with the projected population growth, the City would maintain a ratio of greater than 3 acres per 1,000 residents based on existing parkland. No impact would occur.”
The draft EIR is missing the point here.
Let’s start with: “The City currently maintains a parkland to population ratio of approximately five acres per 1,000 residents.”
The Quimby Act’s ration range of 3 to 5 acres per 1,000 residents is not at all relevant. That’s what the Quimby Act is – for sub-divisions. In Arcata, the standard is five acres per 1,000.
The draft EIR states: “Based on this population, 135 acres of total parkland would be required to maintain a ratio of five acres per 1,000 residents.”
In other words, if roughly 40 acres of dedicated developed parkland are not added to the City of Arcata, ideally in walkable distances from population centers, then the people of the City of Arcata are adversely affected.
Would adoption and implementation of the General Plan 2045 contribute to a cumulatively significant impact to Public Services?
Page 3.10-52 (PDF page 319)
Remedy: Reassess this Impact.
From the draft EIR Page 3.10-52 (PDF page 319), highlighting added:
“The Cal Poly Humboldt Police Department would continue to provide services to Cal Poly properties as well as student and employees. Development outside the City limits would continue to be served by Humboldt County Sherriff’s Office and California Highway Patrol. Projects considered for cumulative impacts would not contribute to increased calls for service within the City limits. Impacts from housing projects are evaluated in this EIR. Proposed trail and roadway improvements could improve transportation safety. Many of the considered projects are located outside the City limits and would not contribute to cumulatively significant impacts to police protection services provided by APD. A less than significant impact would occur.”
Extremely disingenuous, or could be considered to be false.
Taking this section one sentence at a time:
“The Cal Poly Humboldt Police Department would continue to provide services to Cal Poly properties as well as student and employees.”
Only for students and employees who live on campus or while on campus. For those students and employees who live in residences off-campus, it is the Arcata Police Department who responds to those calls.
“Development outside the City limits would continue to be served by Humboldt County Sherriff’s Office and California Highway Patrol.”
That statement has nothing to do with the General Plan 2045, which deals with development within the City limits. We are not considering development outside of the City limits.
“Projects considered for cumulative impacts would not contribute to increased calls for service within the City limits.”
What is this saying here – that there will be no increase in service calls from a 40% increase in the population?
The project considered for cumulative impacts is, in this case, the General Plan 2045 plans for an increased population in Arcata. Or does this statement use “projects” to mean the individual buildings, as projects.
The draft EIR is stating that the increased population would not result in increased calls for service within the City limits.
This is a false statement. It needs to be corrected or removed.
“Impacts from housing projects are evaluated in this EIR.”
Yes, that’s certainly what we are doing here. This sentence can be removed.
“Proposed trail and roadway improvements could improve transportation safety.”
Yes, this could happen. Lots of things “could” happen. There is no modeling to back this up – it is speculation. We’d like to think that it is true, but the opposite could be true as well. There could be more bicycling, and more bicycle accidents. The improved trails could become filled with speeding electric motorbikes. The increased population could cause traffic jams on City streets, and an increase in road-rage incidences. All of these speculative notions would cause an increase in police service calls.
Although we may agree that “Proposed trail and roadway improvements could improve transportation safety” – the amount that this may lower the number of service calls will not offset the increase in service calls that are the result of a 40% greater population.
“Many of the considered projects are located outside the City limits and would not contribute to cumulatively significant impacts to police protection services provided by APD.”
Where does this sentence come from? It is false.
No. NONE of the considered projects are located outside the City limits. All of the considered projects would contribute to cumulative impacts of services provide by APD.
“A less than significant impact would occur.”
What – because of the false assertion that “Many of the considered projects are located outside the City limits and would not contribute to cumulatively significant impacts to police protection services provided by APD.” ?
This is truly a garbage in / garbage out situation. The statement in this paragraph of the draft EIR do not make sense. Therefore, the conclusion of these false statements is also false.
Impact PSR-C-1 states: Would adoption and implementation of the General Plan 2045 contribute to a cumulatively significant impact to Public Services?
I say: Yes, it would. The adoption and implementation of the General Plan 2045 contribute to a cumulatively significant impact to Public Services. It is not a less than significant impact.
What’s written on Page 3.10-52 (PDF page 319) does not show that there is a less than significant impact.
This draft EIR is based on a proposed 40% increase to the population of the City of Arcata. How in the world can it be said that “Projects considered for cumulative impacts would not contribute to increased calls for service within the City limits” ?
Regardless of whether the proposed 40% increase in population is regarded for EIR purposes as having an impact or not, this section should be re-written to reflect the real-life situation.
Would adoption and implementation of the General Plan 2045 contribute to a cumulatively significant impact to Public Services?
Page 3.10-52 (PDF page 319)
Remedy: The report is minimal and omits important information. Ignores actual impacts on the AFD. Re-write as required.
The page of information “Fire Protection within the Study Area” is found on page 3.10-1 and 3.10-2 (PDF pages 268 and 269) in the draft EIR. This page is entirely about the description and statistics for the Arcata Fire District (AFD).
The text of this passage includes: “In 2022, the Arcata Fire Protection District responded to approximately 3,750 calls within the District. Of those calls, 1,747 were within the City limits; an approximate 50% increase since 2004.”
From the figures shown in Table 3.10-2, the number of calls within Arcata in 2022 were 1,747. The average between 2013 to 2017 was 1,377, and the average between 2008 to 2012 was 1,094.
Based on those numbers, the increase from the 2013-2017 average to the 2022 figure was 27%.
The increase from the 2008-2012 average to the 2022 figure was 60%.
So it is unlikely that the increase from 2004 was 50%, as stated. It is likely it was considerably higher.
The entire text for Impact PSR-C-1 that deals with the Arcata Fire District is this — Page 3.10-52 (PDF page 319):
“Arcata Fire Protection District (AFPD) extends beyond the City limits into unincorporated areas of Humboldt County and one of the District’s three stations are located outside the City limits. Therefore, growth outside of the City would impact District services; potentially slowing response times to City properties. Likewise, increased growth within the City would impact AFPD services in areas of the District that are outside of the City.
Cumulative projects could require the development of a new fire station if call volume and distribution change significantly due to development patterns and population growth. The City and AFPD would continue to monitor annual call metrics and plan for facilities as needed. Cumulative impacts would be less than significant.”
As stated for the Arcata Police Department above, regardless of whether the proposed 40% increase in population is regarded for EIR purposes as having an impact or not, this section should be re-written to reflect the real-life situation.
The draft EIR glosses over important factors and omits the obvious. “Cumulative projects could require the development of a new fire station if call volume and distribution change significantly due to development patterns and population growth.” No, the draft EIR has already indicated that the call volume will change significantly with population growth.
As written on page 3.10-2 (PDF page 269), “Almost 50% of the Fire District’s calls were related to rescue or emergency medical services.”
The factors that affect the performance of the Arcata Fire District will be impacted by an increase in population. That is a fact. An increase in population will result in an increase in service calls. That is a fact.
The draft EIR seems to minimize or omit this part of the impacts of population growth.
The text of this impact is simple:
“Would adoption and implementation of the General Plan 2045 contribute to a cumulatively significant impact to Public Services?”
The question does not refer to the environmental impacts – say, if the Arcata Fire District had a lot they wanted to build on that was next to a frog pond, perhaps.
The question only asks if the implementation of the General Plan 2045 – that is, the 40% proposed population increase – will contribute to a significant impact on public service. It doesn’t say “which might have an adverse physical effect on the environment” or “which could cause significant environmental impacts” as do other Impact questions. It is a very simple question.
Of course a 40% proposed population increase will impact public service.
My suggestion is that the title of this Impact should be re-written, and the text should be re-written as well. That way, the draft EIR can do a better task of minimizing and hiding the actual impacts here.
Would the Project contribute to a cumulatively significant impact to Energy Resources?
Categories: Disputed argument, misleading conclusion.
Page 6.2-21 (PDF page 563)
First, a small factual error:
The draft EIR states: “Executive Order N-79-20, which requires all new passenger vehicles sales to be zero-emission by 2035”
Executive Order N-79-20 does not say — as this EIR states — that it “requires all new passenger vehicles sales to be zero-emission by 2035.”
The Executive Order says this is a GOAL – not a requirement. However, steps are being taken to have all new vehicle sales to be zero-emission.
The draft EIR states: “Impact ER-C-1: Would the Project contribute to a cumulatively significant impact to Energy Resources?”
This section in the Draft EIR states: “As growth occurs throughout Humboldt County, there would be an increase in electricity and natural gas demand.”The draft EIR makes the argument that compliance with state regulations and the draft Humboldt County Climate Action Plan will reduce greenhouse gas emissions. Further, that energy in the future will come more from renewable and zero-carbon sources.
The section concludes: “As a result of these regional and state regulations and commitments, the General Plan 2045 would not significantly contribute to a cumulatively considerable impact for wasteful, inefficient, or unnecessary energy use.”
The argument presented in the text is for “wasteful, inefficient, or unnecessary energy use.” The impact that is under discussion is for the cumulative impact on all energy use – not whether the energy usage is wasteful, inefficient, or unnecessary.
“Electricity and natural gas demand would increase compared to existing conditions due to the anticipated growth accommodated under the General Plan 2045. However, the General Plan 2045 includes policies and measures to implement an electric-only ordinance.”
An electric-only ordinance does not decrease energy usage. There is no logic to the draft EIR statements.
It can be anticipated that the per-person energy usage will be lower in the years to come. But even if the per-person amount is smaller, the overall energy consumption associated with a 40% population increase is larger.
Even if the energy that is used is produced and used with greater efficiency, it is still an increase in the amount of energy used. The question is: “Would the Project contribute to a cumulatively significant impact to Energy Resources?” That question is not addressed in the text.
The argument presented in the draft EIR does not relate to or prove or disprove the correctness of the Impact. Thus, to say that there is a less than significant impact is a false statement.
“Would adoption and implementation of the General Plan 2045 have a substantial adverse effect on a scenic vista?
Page 3.2-19 (PDF page 88)
The reference is shown at: 3.2.6 Impacts and Mitigation Measures
“Impact AES-a: Would adoption and implementation of the General Plan 2045 have a substantial adverse effect on a scenic vista?
Starting at page 3.2.6 (PDF page 88) we have “Impacts and Mitigation Measures.” The draft EIR document continues for 1-1/2 pages of text, including these statements (highlighting added):
“As shown between existing conditions and the schematic, views of Humboldt Bay and the mountains could be altered to include buildings within the Gateway Area as part of the viewscape in the urbanized foreground.”
“Views of the Bay and mountains would still be visible around the buildings and would still be visible from other locations throughout the City.”
To say that the views “could be altered to include buildings” “in the viewscape” and “Views of the Bay and mountains would still be visible around the buildings” is extreme ‘engineering-speak’ using a passive voice.
It’s similar to saying “mistakes were made” – or worse. As commentator William Safire said, this is “a passive-evasive way of acknowledging error while distancing the speaker from responsibility for it.”
It is not that the view could be altered to include buildings. “Views” don’t do anything. A “view” cannot create an action.
The construction of the buildings is what alters the views.
And it’s not that “Views of the Bay and mountains would still be visible around the buildings” – No, it’s the views of the bay and mountains are blocked by the buildings – partially blocked or greatly blocked, depending on where the person is standing.
Speaking in English, the Bay and mountains would still be visible except where the view is blocked.
Whether or not this is acceptable is a separate question.
The impact question is:
Would adoption and implementation of the General Plan 2045 have a substantial adverse effect on a scenic vista?
The answer is Yes. The new buildings would have a substantial adverse effect on a scenic vista. That effect may be acceptable, but it is adverse.
- Impact AES-a: Impact on the scenic views. The images of the scenic views in this EIR document do not represent actual viewscapes of normal people in typical locations.
“Would adoption and implementation of the General Plan 2045 have a substantial adverse effect on a scenic vista?
Page 3.2-66.2-21 (PDF page 88)
Remedy: Supply images that show the perspective of people in downtown Arcata.
The draft EIR has supplied six images that seem intended to show an assessment of an adverse effect on a scenic vista. Unfortunately, these images do not represent actual viewscapes of normal people in typical locations.
This is a false presentation.
The images that are from a viewpoint that is 100 feet above the ground do not adequately show the impact on the scenic view. An appropriate scenic view would be from the perspective of the height of a human being, or from the height of a window of a one-story house.
From a higher perspective, there is less impact against the horizon caused by a taller building. The perspectives from 100 feet above the ground are invalid for people living in the downtown area – the people who would be most affected by taller buildings.
Similarly, the perspective from above 14th Street, as is shown in Figure 3.2-2a, is not going to show a valid viewscape relative to that of people who live closer to the Plaza, or the Co-op, or the Creamery. The elevation at 14th and K is about 70 feet higher than the elevation at 8th or 9th or 10th street – plus the perspective in the image is from 10 feet above that.
The images of buildings shown in this figure are depicted as being about 70 or 80 feet high – and as you can see in the image we are looking slightly down at this building. That is, we are located above the roof of this building.
The same depiction taken from 10th Street would show a far different view. From the homes and streets there, a person would be looking up a the building.
It’s very simple: From a hill, you’ll be looking over a building. From the flats, you’ll be looking up at the building. If you’re looking up at a building, it’s going to affect your scenic view.
The draft EIR contains six images that depict views of a partial build-out scenario for the Gateway area. These are located following page 3.2.26 (PDF page 95). They are:
Figure 3.2-1a View of Arcata Plaza – Looking South from H Street – 10-ft above ground
Figure 3.2-1b View of Arcata Plaza – Looking South from H Street – 100-ft above ground
Figure 3.2-2a View of Gateway Area – Looking South from K Street – 10-ft above ground
Figure 3.2-2b View of Gateway Area – Looking South from K Street – 100-ft above ground
Figure 3.2-3a View of Gateway Area – Looking Northwest from Samoa Blvd – 10-ft above ground
Figure 3.2-3b View of Gateway Area – Looking Northwest from Samoa Blvd – 100-ft above ground
Below is “Figure 3.2-1a –View of Arcata Plaza – Looking South from H Street – 10-ft above ground.” The full page from the General Plan 2045 is below.
Clearly the image is not from a viewpoint that is 10 feet off the ground. Notice the cars on the street. The viewpoint of this image is much higher than the roofs of the cars.
This is the intersection of H Street and 12th Street. I am friends with the owners of the house that is shown at the mid-right side of this image, and with the owners of the house that is next up the street on H Street. I have been on their back decks (west-facing) and looked at the view toward the Creamery building and Arcata Bay.
What is shown is nothing like what the impact on their view of what a 6-story or 7-story would have.
This perspective is substantially above the viewpoint of an actual person.
Clearly this image is not from a viewpoint that is 10 feet off the ground. Notice the cars on the street. The viewpoint of this image is much higher than the roofs of the cars.
This is the intersection of H Street and 12th Street. I am familiar with the house that is shown at the mid-right side of this image and with the house that is next up the street on H Street. I have been on their back decks (west-facing) and looked at the view toward the Creamery building and Arcata Bay.
What is shown is nothing like what the impact on the view of what a 6-story or 7-story would have. This perspective is substantially above the viewpoint of an actual person.
This image better shows how a tall building would appear on the horizon. There should be more perspectives like this. The point-of-view is at an elevation that is similar to the elevation of where the buildings are located.
Figure 3.2-3A. View of Gateway Area. Looking northwest from Samoa Boulevard. 10 feet above the ground. Following Page 3.2-26 (PDF page 100).
Note that this image shows just two of the four potential buildings that are shown in other images.
This is Figure 3.2-2A. View of Gateway Area. Looking south from K Street. The elevation of 14th Street is more than 80 feet above where the buildings are located, so we are looking approximately even with the tops of the buildings. The perspective is from 10 feet above the ground. Following Page 3.2-26 (PDF page 98).
- Impact AES-a: Impact on the scenic views – Remaining Study Area. False statements in the impact analysis.
“Would adoption and implementation of the General Plan 2045 have a substantial adverse effect on a scenic vista?
Page 3.2-19 (PDF page 88)
The draft EIR states, highlighting added:
“Remaining Study Area
Development outside of the Infill Opportunity Zones is not anticipated to be substantially different from existing development. The most significant changes to land use code are within the Gateway Area with minimal changes to development standards outside of the Gateway Area. Therefore, development outside of the Gateway Area is anticipated to resemble existing development and it is unlikely that future proposed development under the General Plan 2045 outside the Gateway Area would adversely affect a scenic vista. A less than significant impact would occur.”
This paragraph is false on a number of levels. We’ll take it one sentence at a time.
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- “Development outside of the Infill Opportunity Zones is not anticipated to be substantially different from existing development.”
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The General Plan 2045 Implementation Measure LU-9 anticipates a re-zoning of existing R-L residential neighborhoods to Mixed Use and R-H zoning. The projection is for 4-story buildings which, with State density bonus additions, could be six stories.
This is substantially different from existing development, unlike what is stated.
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- “Therefore, development outside of the Gateway Area is anticipated to resemble existing development and it is unlikely that future proposed development under the General Plan 2045 outside the Gateway Area would adversely affect a scenic vista.”
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No, development outside of the Gateway Area is NOT anticipated to resemble existing development. Conceivably this sentence is meant to say “Therefore, development outside of the Gateway Area and the other Infill Opportunity Zones is anticipated to resemble existing development…” but that’s not what it says.
Proposed development under the General Plan 2045 is very likely to result in construction that does NOT resemble existing development.
Whether or not the anticipated development outside of the four Infill Opportunity Zones will affect the scenic views is a question to be looked at. But it is NOT true that “Development outside of the Infill Opportunity Zones is not anticipated to be substantially different from existing development” as is stated here.
- Impact AES-c: In non-urbanized areas, would adoption and implementation of the General Plan substantially degrade the existing visual character or quality of public view of the site and its surroundings?
In non-urbanized areas, would adoption and implementation of the General Plan substantially degrade the existing visual character or quality of public view of the site and its surroundings? (Public Views are those that are experienced from publicly accessible vantage point).
If the General Plan applies to an urbanized area, would the adoption and implementation of the General Plan conflict with applicable zoning and other regulations governing scenic quality?
Page 3.2-24 (PDF page 93)
This is really two different questions. The questions should be separated to have a meaningful dialogue on each.
As stated in the draft EIR:
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- This intentional plan to build upwards, as opposed to outwards;
- This is desired by the City to promote conservation of natural resources, such as agricultural land and wetlands that surround the City limits;
- This priority is reinforced in both current and proposed zoning.
The conclusion is that since this is what is wanted, and all development would be in compliance with applicable zoning, then this is okay and there is a less than significant impact.
As stated:
“The adoption and implementation of the General Plan 2045 is the overarching guidance for the implementation of zoning and other regulations governing scenic quality and would, therefore, not constitute a conflict. All development would be in compliance with applicable zoning and other regulations governing scenic quality, which are designed to enhance the architectural environment of the City.”
This does not answer the question. To say that if everything is done according the zoning codes, then therefore there is no environmental impact – This is NOT an argument that can be use in an EIR.
There can be an argument made as to why Impact AES-c is okay, but this is not it.
This needs to be revised.
Also, similar to what was covered in discussion of Impact AES-a above, I take issue with the statement:
“Development in other Infill Opportunity Zones would not include multi-story buildings (greater than 70 feet) and would, therefore, resemble existing development throughout City limits.”
Development in other Infill Opportunity Zones would not necessarily resemble existing development throughout City limits. This is a false statement.
A discussion on the Alternative Analysis presented in this Draft EIR
The segment of this draft Environmental Impact Report that discusses alternatives to the proposed project – the General Plan 2045, with its included Gateway Area Plan – is in Chapter 7, “Alternatives.” The 23 pages are found at page 7.0-1 through 7-23 (PDF pages 565 through 587). The document lost its proper page numbering system; it should show “7.4-1” rather than “ 7-21” as an example.
As the draft EIR tells us, highlighting added:
“An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation.”
“The lead agency [i.e. the City of Arcata] is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives.”
The document lists the General Plan objectives and the Gateway Area Plan objectives. In doing so, it perpetuates the written myth that the objectives of the General Plan and the Gateway Area Plan will have “a variety of housing types and designs.” There are no intentions for allowing the development of single-family residential land-use areas in Arcata. The Gateway area redevelopment is entirely apartments and townhouses.
I’ll take issue with this line:
“Promote thoughtful development through form-based and streamlined development standards.”
Thoughtful development can come through objective form-based code building standards. But utilizing a streamlined approval process has nothing to do with promoting thoughtful design.
Our experience has shown it to be the opposite: That the streamline approval process can accomplish many things, but good and thoughtful design is not one of them.
As the draft EIR informs us, it is the City of Arcata that selects the quantity and the range of project alternatives.
Six alternatives are presented. This includes the required “No Project” alternative, which would essentially continue with the growth rate that was a part of the General Plan 2020 document, that was adopted by Arcata in October, 2000.
The six Alternatives and the Proposed Project are:
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- A. Development in Hillsides and/or Arcata Bottoms (Urban Sprawl)
- B. Four Story Alternative
- C. Infill Agricultural Sites
- 1. No Project
- 2. Upzoning Single-Family Zoning Districts (Dispersed Development)
- 3. Reduced Population Estimate
- The Proposed Project
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Of these six alternatives, I propose that three of them are inherently unfeasible and should never have been included here.
Three alternatives – A, B, and C — were “considered but rejected” and I believe “B. Four Story Alternative” was rejected without proper consideration.
As mentioned, the City of Arcata was responsible for choosing these alternatives.
Based on long-standing City policies, the City is not going to expand into the hillsides or into the Arcata Bottoms. So “A. Development in Hillsides and/or Arcata Bottoms” is already a non-starter.
Similarly, “C. Infill Agricultural Sites” also is counter to long-standing City policies. Both the people and the government have spoke to this and made this City policy clear, again and again. And so this alternative is also a non-starter.
We’ve told that the City must present alternatives that are in a “a reasonable range of potentially feasible alternatives.” Alternatives A and C fail this criteria. They are not potentially feasible alternatives, in the sense that they never would be approved by the City Council or okayed by the public. They should not have been included among the EIR’s alternatives.
The stated reason why the “Four Story Alternative was rejected is:
“The potential for meeting the City’s residential development needs is lower with this alternative. In addition, this alternative is effectively the same as the reduced population alternative.”
First of all, this alternative is NOT “effectively the same as the reduced population alternative.” To say it is does not make it so. The two alternatives are different.
“The potential for meeting the City’s residential development needs is lower with this alternative” is a disputable statement. The theoretical potential is lower, in the sense that a single building might have fewer apartments and thus fewer residents. But there might be more buildings built that are four stories. And even with a higher maximum height limit, there is no guarantee whatsoever that builders will want to build taller than four stories – it’s less economical, on a per-floor basis to do so. Testimony from Chris Dart, the president of Danco, Arcata’s major builder, reinforces this.
To reject this alternative outright is an indicator that the EIR is doing its due diligence on these alternatives.
- Why was the Upzoning Single-Family Zoning Districts (Dispersed Development) NOT rejected outright? Why is it being considered at all?
The Upzoning Single-Family Zoning Districts (Dispersed Development) is what might be considered an absurd alternative. It is counter to very much of the clear guidelines and objectives of the people of Arcata, as stated many times in many ways. This alternative involves the rezoning of 61 acres of Residential Low and Residential Very Low Density parcels, and then proposing the construction of four-story buildings (or higher, with the State density bonus law) on the parcels.
The Residential Very Low zoned parcels are located around the perimeters of Arcata and on land that is hilly, difficult to access, forested hillside, prime agricultural soil, or other such constraints. If located on the perimeters of the City limits, building apartments there would negate the reduction of vehicle miles traveled and greenhouse gas emission goals.
The City must present alternatives that are in a “a reasonable range of potentially feasible alternatives.” Upzoning Single-Family Zoning Districts (Dispersed Development) fails this criteria. It is not a potentially feasible alternative, in the sense that it never would be approved by the City Council or okayed by the public. Buildings could never be constructed on these properties in the density and numbers that the draft EIR proposes. It is impossible. It should not have been included among the EIR’s alternatives.
The description of the “Upzoning Single-Family Zoning Districts (Dispersed Development)” alternative is on page 7-10 (PDF page 574). I consider it to be laughable in its explanation of how it could reasonably produce housing for 7,625 people. This is such a completely unreasonable alternative. Its inclusion does not comply with EIR requirements.
This alternative proposes a growth rate of 0.65% to 0.73%, as opposed to the 1.0% to 1.4% growth rate that is in the Proposed Project.
The description of this alternative, staring on Page 7-15 (PDF page 579), is incomplete and lacking. It does not describe the alternative. Rather, it describes what steps the author of these paragraphs believes would be necessary in order to put this alternative into effect.
There are four paragraphs in this “description.” Paragraphs #3 and #4 speak to procedures the City could use to deny or defer housing production.
The problem with what is written is that existing State law would not allow these procedures to be take place. If the City did what is described here, they would be sued.
The author of this document knows better than this. What is here are essentially “scare tactics” – it is meaningless, because it could not happen.
It is possible that the Reduced Population Estimate alternative may not be acceptable for Arcata, but not for the reasons given.
Below, the offensive paragraphs, from page 7-16 (PDF page 580). Highlighting added. As mentioned above, cities are not allowed to do much of what is proposed, by State law. These kinds of housing-limiting procedures could be used 30 years ago, but they cannot be utilized now. It would be against the law.
“To implement this option, the City could set lower allowed residential densities and adopt measures to increase discretionary decision making in development proposals. Policies could be established that set low targets for housing production and provide increased protection for existing residents. These polices could then be cited to deny or defer projects if housing targets are met.”
“In addition, the City could adopt stringent design policies. The state laws regulating housing production generally allow jurisdictions to regulate based on objective standards. The City could adopt objective standards that limit production of lower cost designs and require larger areas of each parcel to be set aside for onsite amenities, such as open space or parking. This would decrease the number of projects that are proposed, and the number of units that could be constructed. Together with a more complex development approval process, these measures would assist in implementing the reduced population estimate alternative. The mitigation measures presented in this Draft EIR would be active under this alternative.”
Reiterating what was said above. This is a missing, deficient aspect of this draft EIR.
Reiterating what was said above. This is a missing, deficient aspect of this draft EIR. It is not acceptable to provide an Alternative and then not describe it.
These sentences do not describe the Alternative. They describe what the plan would be if this alternative were to be used.
“An alternative to the proposed 1.0% to 1.4% average annual growth rate is to reduce growth estimates and impose reductions in reduced development potential. Policies aimed at reversing streamlining could be implemented to slow development, which would decelerate population growth.”
- There are two submitted alternatives, plus the “No Project” alternative. Both of the two proposed alternatives are not valid alternatives
For reasons stated above, neither the “Upzoning Single-Family Zoning Districts (Dispersed Development)” alternative nor the “Reduced Population Estimate” alternative – as it is described here – are rational or feasible as alternatives. Therefore, they fail to meet the standards of alternatives for an Environmental Impact Report.
An actual, feasible example of a valid alternative would be one that was closer to the Proposed Project – not so ridiculously different that it would just be rejected right off the bat.
The Proposed Project is listed as 1.0% to 1.4% growth – resulting in a population increase of (at the higher end) of about 7,500 persons.
The “Reduced Population Estimate” alternative is proposed as 0.65% to 0.73% growth. That might result in a population growth of about 3,750 persons – that is, about half as many new people here in Arcata.
A suitable alternative would be similar to the Proposed Project, but with a growth rate of, say, 0.9% to 1.1%. Or one with a lower maximum growth rate – say, with a growth rate from 1.0% to 1.2%.
These increments may not sound like much. But as described below, the difference between 1.0% and 1.4%, when compounded, amounts to a total population growth of 30% versus 40% over the course of 25 years.
What would happen if, say, on a particular year, the annual growth percentage came in higher than the 1.4% maximum that was listed for the Proposed Project. Supposed it was 1.6% that year – or 2%?
The procedures that are outlined in the critique that rejected the Reduced Population Estimate alternative – the procedures for slowing down growth. Would these slowing-down-construction procedures be used here if growth was too great?
I don’t think they would. Can growth be limited to be not greater than 1.4% per year? Probably not.
The rate of growth is the selected alternative is stated as 1.0% to 1.4% annual growth rate. This is misleading and duplicitous. While the range of “1.0% to 1.4%” is what is called for, the figures that are discussed are based only on the higher figure of 1.4% annual growth.
The discussion surrounding the General Plan has the population growth at around 7,000 – that is, from about 20,000 to about 27,000 in 20 years. Other tables show the growth starting from 18,857 in 2020.
No discussion has taken place using the 1.0% figure. It’s always the 1.4% figure – or even slightly higher.
The difference between 1.0% and 1.4%, when compounded, amounts to 30% versus 40% over the course of 25 years.
There is a significant difference between 30% growth and 40% growth – and it is the higher figure that is referred to.
It is duplicitous to say that this plan is a “1.0% to 1.4%” plan. Actually, it’s a 1.4% plan.
When looking at any of these increase in population figures, please keep in mind that the Cal Poly university-provided housing – on-campus housing, Craftsman Mall dorms, possible Creekside expansion, etc. – will result in new persons added to Arcata that count in addition to the City growth figures.
When the City says a 40% increase over 20 years, when Cal Poly’s non-Arcata housing needs are added to that, we are looking at 53% or 55% growth. To me, that’s a lot.
This is on page 2.0-5 of the draft EIR:
— End —
PDF of the original Comments as submitted on March 18, 2024
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