January 10, 2002

John Patton
Director, Planning and Development
County of Santa Barbara
Attn: Jean Pare
123 E. Anapamu Street
Santa Barbara, CA 93101

RE: ARCO AM/PM Mini Mart New Gas Station 99-DP 052

Dear Mr. Patton:

Patterson Area Neighborhoods Association appreciates the opportunity to present additional testimony regarding the above project.

The hearing day (October 1^st) to receive testimony was very poorly attended by the community because the notice date of the hearing was September 11, 2001 when the community’s’ hearts and minds were elsewhere. Regrettably, this hearing provided no opportunity to ask questions or to receive answers that the community might have had about the project. Because of this, PANA requested that ARCO Products Co. hold a community meeting to address the neighbors’ concerns. This was done on October 29^th with about 25 interested neighbors (and Mr. Pare of your staff). Unfortunately, as informative as this meeting was, it failed to provide many assurances to the neighbors on issues of air quality, traffic, and the 24-hour operation of the gas station and mini-mart.

There is one issue not addressed at all in the negative declaration and that is the planned 24-hour operation of the gas station and mini-mart and the questions that it raises for the safety of the neighborhood. There was considerable anecdotal evidence presented by neighbors in the aforementioned October 29^th meeting that the 24-hour operation of the previous gas station fostered an increase in the nuisance/crime rate in the adjacent neighborhoods. ARCO representatives had little response to the neighbors’ concerns about the potential for increased crime with this 24-hour operation. PANA believes that such an operation in the middle of an entirely residential neighborhood is not only inappropriate but inimical to the safety and well-being of the residents and the surrounding neighborhoods.

In addition to the testimony we gave at your October 1^st hearing, the following information represents our concerns which have not fully or adequately been addressed in the revised draft negative declaration.

I appreciate the responsiveness of your staff in answering my several phone inquiries since the initial notice of this project. Lastly, because this project is of vital interest to the community, would you please notify me at the above address/numbers once you have made your decision. Thank you.

Sincerely,
Cecilia Brown
President, Patterson Area Neighborhoods Association

ARCO AM/PM Mini Mart New Gas Station 99-DP 052 (page 2)

Section 4.0 Aesthetics/Visual Resources: The proposed 3,300 square fueling canopy will be aesthetically offensive to the character of this area. It was a former planning commissioner, Colleen Beal, who described this locale as the "gateway" to the Goleta neighborhoods north of the freeway. (See exhibit ) In recognition of this fact, we believe that the fueling canopy and other elements traditionally associated with service station architecture will not be an attractive addition to the neighborhood.

Section 4.3 Air quality: This project is in a CH- Highway Commercial zone. Article III, Inland Zoning Ordinance states that the "purpose and intent of this district is to provide areas adjacent and accessible to highways or freeways exclusively for uses which serve the highway traveler." Yet, inexplicably, Mr. Schell, from Associated Transportation Engineers, concludes that the figure (to be used in calculating an average urban trip length) is approximately 2 miles based on the nature of the road system. . . " rather than the 10.2 miles for the average urban trip length. The convenience of using this smaller number is that county’s thresholds for reactive organic compounds (ROC) is avoided. Any trip, even slightly exceeding this standard, will result in the ROC threshold being exceeded.

Section 4.4: Biological Resources: The negative declaration states the following: "The myoporum shrubs would be pruned and maintained . . . as a natural screen between the proposed service station and the Allstore facility." The myoporum shrubs (exhibit ) are the only screening device to the adjacent neighbors and it is imperative that they be carefully maintained to ensure their screening capacity. Any reduction in their height or size through pruning would severely affect this ability. The applicant reported at the community meeting that an arborist would be reporting on the condition of the myoporums. If an aborist’s report was completed, it should have been included in this report.

Also, the report states that the proposed project will not result in the removal. . .(of) other significant vegetation." There are several large junipers in the rear and a lemonade berry at the front property line (exhibit ). The negative declaration fails to mention these plants. Will they be maintained? We are for retaining as much of the mature vegetation as possible.

Section 4.10 Historic Resources: The negative declaration is in error when it states that the site of the current marker is not easily accessible by either pedestrians or cyclists. The marker is now adjacent to the sidewalk and the bicycle path! The applicants intention of moving it to the rear of the property will result in less accessibility by pedestrians and bicyclists, not more. (Exhibit.)

Section 4.11 Land Use: The negative declaration describes the property directly across from the gas station as being zoned Highway Commercial. The July 11, 2001 zoning map from the county indicates that this property is zoned C-1.

RE: ARCO AM/PM Mini Mart New Gas Station 99-DP 052 (page 3)

Section 4.12 Noise: Five neighbors live within 130 feet of this project. They will bear the full brunt of all noise emanating from this project, from the intrusive back-up warning device (BUWD) sound to that of car radios at high volume. At the community meeting, the public was assured that turning movements within the station were sufficient so that the fuel delivery trucks would not have to back up. If this is the case, then there should be no noise generated by the BUWDs of any delivery vehicle. But what is the mitigation for noise generated by truck and car engines and from car radios? Some drivers’ penchant for booming, blaring car sound systems is problematical at any hour. The negative declaration entirely fails to address these types of noise. And, how will the applicant mitigate these?

Section 4.15 Transportation/Circulation: This section discusses the Calle Real extension proposed in the GTIP. What this paragraph lacks is the information that anything built on this property will add to the problem of having Calle Real used, at some time in the future, as a freeway frontage road all the way from State St. through Goleta. 

The traffic study fails to address several traffic issues, which are ultimately safety-related ones. The first is that of cars exiting from the freeway westbound onto Patterson Ave. The close proximity of the first entrance to the gas station is very close to this exit. Congestion will be created by vehicles turning right getting "caught" behind a vehicle slowing to turn into the station. Also, vehicles from the station could be exiting from this same driveway as cars are trying to enter.

Secondly, the traffic study fails to address the turning movements of cars exiting the station intending to return to south Patterson Avenue. or to the 101 freeway. To do this, vehicles will have to cross three lanes of traffic in a very short distance to access the left hand turning lane to make the U-turn to return to south Patterson Avenue or to the 101 freeway. The increased traffic generated by this project as well as traffic from the newly completed 40-unit housing development of Orchard Park and the under-construction Maravilla senior resident community of 600 plus (residents plus employees) will further add to the congestion and complicate the ability of any motorist to negotiate their way into the left hand-turn lane. Should traffic prevent motorists from making this left-hand turn, they will be forced to travel north onto Patterson Ave. to make a U-turn. Since the intersections immediately north of the Calle Real/Patterson Avenue intersection, Parejo and University Avenues, prohibit U-turns, that essentially means that motorists will travel into the neighborhoods to make the U-turn necessary to return to Patterson Avenue. This is an unsatisfactory solution.

PANA has previously expressed concern regarding these issues. The community deserves a response on all traffic-related issues affecting this site and the adjacent intersections.