October 1, 2001

Planning and Development Department
County of Santa Barbara
123 East Anapamu Street
Santa Barbara, CA 93110

Jean Pare RE: 01-ND-37, 00-DP-052, ARCO

PANA is deeply concerned at the use of a Negative Declaration for this project. Our concerns are focused on the areas of traffic safety, air quality, and enforcement.

Traffic safety

The project is expected to attract 161 PM peak hour trips. This would result in a vehicle exiting the site every 22 seconds during the peak hour. According to the supporting traffic studies, about half (80) of the northbound trips on Patterson Avenue will turn left onto Calle Real. This means that every 44 seconds during the PM peak hour, a car exiting the site will attempt to cross at least three lanes of traffic to the Calle Real left turn lanes - blocking northbound traffic on Patterson Avenue. The statement that the project will only generate 29 left and U-turns at Patterson/Calle Real is misleading, since these are only new trips, not the total including pass-by and diverted trips.

The only way we can imagine that the project could avoid this traffic safety issue would be to force all exiting cars onto or next to the northbound off-ramp from the freeway, providing the same distance to cross into the Calle Real turn lanes.

Air Quality

The air quality analysis avoids a Class I ROC impact by 0.09 pounds per day. The method by which this is accomplished is amazing.

Stationary emissions are estimated at 14.96 pounds per day, based upon an annual throughput of 4.3 million gallons per year. The first page of this Initial Study refers to this 4.3 million gallons per day as a "maximum." This does not appear to be true. The project will attract 1953 trips per day with a fuel tank of up to 18 gallons. Assuming that this service station is "average" in trip generation, this offers a maximum fueling of 35,000 gallons per day, and a maximum annual throughput of 12.8 million gallons - 3 times higher. Stationary ROC emissions are likely to be up to 45 pounds per day.

Mobile emissions are estimated at only 9.95 pounds per day - only 1% less than a Class I threshold when added to the lowered stationary impacts. Yet the analysis was based upon an arbitrary decision that the average trip length would exactly 2 miles instead of the standard 10.2 miles. If the arbitrary trip length were chosen as 2.2 miles, the 859 additional project generated trips would generate 10.95 pounds per day of ROG instead of 9.95 pounds per day. Added to the low estimate of 14.96 pounds per day from stationary sources, this produces a Class I impact of 25.9 pounds per day.

Even if all assumptions regarding stationary sources and trip lengths are accepted, a mere 9 additional trips exceeds the county threshold for ROG.

Any reasonable estimate of air quality parameters - trip length, length of diverted trips, or stationary emission - leads to exceeding the County threshold.

Enforcement

The Initial Study states that all deliveries of fuel and merchandise shall occur between the hours of 7 AM and 5 PM Monday through Friday - yet there is no mechanism for enforcement of such a provision.

PANA does not believe this Negative Declaration will stand reasonable scrutiny.

Sincerely,
Jack Hawxhurst, PANA President