October 1, 2001

Jean Pare
Planning and Development
County of Santa Barbara
123 E. Anapamu Street
Santa Barbara, CA

Dear Mr. Pare:

I appreciate the opportunity to make the following comments concerning the draft initial study for the ARCO Mini-Mart and Gas Station 99-DP-052. This proposed project is the gateway to the Patterson Ave. north neighborhoods. As such, its design, both architectural and landscape, and the pollution the station generates from noise, light, and noxious fumes, along with increased traffic, will unmistakably have a significant impact on the surrounding residential neighborhoods.

Section 4.1 Aesthetics/Visual Resources:

The draft report is in error when it describes the visual character of the area as being dominated by Highway 101 and Patterson Ave. interchange. If you look northward from either the top of the Patterson Ave. overpass or from the proposed station, what you see are tree tops or hills with mountains in the background. While Patterson Ave. is clearly visible, what you don’t see, with the exception of a few second story homes rising above the trees, are houses to the north, the almost completed 40 homes of Orchard Park northwest of this site and the soon-to-be built 500 plus residential senior community west of Orchard Park. This information was omitted in the draft report and should be included in the final report.

The proposed design to reflect the historic nature of the adjacent historic stagecoach has no relevance to this neighborhood. What is missing from this draft report is that the proposed storage facility across the street and the fire station not too far down Calle Real are being/have been designed with the architectural heritage of Goleta as a theme. Lastly, while the draft report discusses compatibility with other uses adjacent to the site, it fails to discuss how the 18+foot, 3,300 square foot proposed canopy over the gas pumps, a 20-foot freestanding sign, and a 3+ foot product pricing monument sign have any relationship either to the architectural style of the station itself or with the architectural elements of adjacent uses, particularly the residential neighborhood. I believe the draft report needs to reveal this information as potentially significant but mitigatible, rather than "not significant."

Lighting in excess of the standard street lights will have an impact on the residential character of this neighborhood. Especially at night, this proposed station will be a beacon of light in a neighborhood otherwise punctuated only by streetlights and stoplights. The canopy over the gas pumps will have lights which will not be shielded and the illuminated station sign, product pricing monument sign and light from the min-mart will generate light at night. All this will have an impact on the nearby homes. This light pollution needs to be discussed in the final report.

Section 4.1 D. mentions that the proposed structures is compatible with ". . . the abandoned gas station" (across the street). This abandoned gas station across the street is scheduled for demolition once the Carey Group develops the property. The final report needs to reflect this.

The draft report is in error when it describes a State of California marker identifying the route of the historic California stagecaoch trail. The marker was placed there by Wells Fargo Bank, the county of Santa Barbara and various civic organizations.

4.3 Air Quality

Reactive organic compound (ROC) air quality Class I issue is avoided by less than .36 percent. Factors used to determine (ROC), which are only .09 pounds below the country’s thresholds for ROC, do not provide enough assurance that ROC standards will be met. The estimates provided by ATE are just that, estimates and further evaluative study needs to be undertaken to ensure that ROC falls well under the county standards. Otherwise, this project will have significant impact on air quality with no mitigation possible.

4.4 Biologic Resources

The draft report only describes the myoporum shrubs on the site and the eucalyptus trees. It fails to include the junipers and the one native plant (rhus integrifolia) located at the southwestern corner of the property and the juniper at the eastern edge of the property. Therefore, it is not clear what the intention is concerning this vegetation. If these plants remain, pruning this mature vegetation will reduce the effectiveness it provides as screening devices. The final report needs to address the fact the eucalyptus trees are located on the proposed Calle Real extension and if removed for completion of this extension will others replace them on the proposed project’s property?. Will the final report explain why herbicides and pesticides are needed to maintain the myoporum bushes when they have thrived on neglect for many years and will provide the only screening for the adjacent property? Lastly, because the site has been vacant for many years, landscaping will be an important element in replacing the vegetation that is scheduled for removal, if any, and for beautifying the area surrounding the station. Information thus needs to be provided as to what size (e.g., one gallon container, five gallon container, boxed trees, etc.) the additional vegetation is going to be to ensure that it is appropriate as a mitigation for the removed vegetation/change in aesthetic character of the site.

4.10 Historic Resources

Again, the draft report mistakenly identifies the stagecoach trail marker as a State of California historic marker. The marker was provided by Wells Fargo Bank, the county of Santa Barbara and various civic organizations. The sign is currently located next to the sidewalk and any relocation from its current position would not make it as accessible as it is now to both bicyclists and pedestrian. If this sign is intended for the community, then accessibility is important.

4.11 Land Use

The report wrongly characterizes the land uses immediately surrounding the proposed site as largely car oriented. The land to the north, northwest, and south across the freeway is residential. Additionally, the self-storage facility is not largely car oriented for it has the lowest traffic use of any commercial enterprise. If the Carey Group develops the property across the street as planned, this will be another storage facility. Again, this would not be a use that is largely car oriented. There should be a recognition of these facts in the final report.

4.12 Noise

Operation of the proposed project 24 hours a day is not appropriate for this residential area. Five service stations located in a commercial area about one mile to the west, operate on a 6 AM to 10, 11 or 12 PM schedule. Since this project is only 100 feet from four residences and adjacent to another, operation of this facility for 24 hours will significantly impact the lives of the people residing nearby. There is no mitigation for the noise-generating sound of car engines starting-up and car radios blaring throughout the late evening and early morning hours. Also, the noise generated by delivery truck back-up devices at 7AM (the first hour available for deliveries) or any hour, for that matter, will be intrusive for the neighbors. Consideration of beginning delivery at 8:00AM versus 7:00 AM would help somewhat. (It is noted that construction work is only allowed to begin at 8:00 AM.) Omitted from the draft is a discussion of the enforcement mechanism for mitigating these noise problems

4.15 Transportation/Circulation

The final report will need to address the extension of the Calle Real since the developer across the street (The Carey Group) has been required to address it in their development plans previously presented to the Planning Commission. The fact that no timeline for construction has been identified is not a sufficient reason to dismiss how this proposed extension will impact this project.

The report fails to address turning movements of cars exiting the station intending to return to south Patterson Ave. To do this, they will need to traverse three lanes of traffic, in a very short distance, to reach the left-hand turning lane in order to make a u-turn onto Patterson southbound. The final report needs to address the impact of this fact upon traffic congestion and safety.

There is no mention of how construction traffic will impact this neighborhood, where construction workers will park and where construction traffic might be limited. Recommend the final report include information that there is to be no construction worker parking in the any of the neighborhoods adjacent to or north of this project and that all construction traffic be limited to roadways south of Calle Real.

Lastly, this project will have the most impact on the people living at the adjacent storage facility will who have to endure noise and light pollution as well environmental pollution from reactive organic compounds that are within a hair’s breadth of exceeding standards, 24 hours a day, 7 days a week, 365 days a year. Also, the fact that a health risk assessment consultant identified excess cancer risk at approximately 8.8 in 1,000,000 persons with a threshold of significance for emissions as being 10 is also not sufficient to ensure that these will not be in harm’s way because of the pollutants generated by this gas station. Surely, with these factors in mind, for at least these people, there are many significant and detrimental environmental impacts which may well make their residence uninhabitable. What is the mitigation for this?

Sincerely,
Cecilia M. Brown