Response to Initial Study of Calle Joaquin Hotel Development


The signatories of this letter, consisting of all of the Board Members of the licensed non-profit, Central Coast Grown ( urge the San Luis Obispo Architectural Review Commission not to grant a Mitigated Negative Declaration for the Calle Joaquin Hotel Development at its meeting of October 5, 2015.

This Declaration was recommended by the contract planner hired by the City of San Luis Obispo in an “Initial Study” dated July 31 2015, but we oppose it for the reasons detailed below.

We also request that 1)the project be either rejected or thoroughly scaled back and redesigned and 2)the project be required to submit for public review and comment a full EIR with sufficient time for consideration and response.

Neighbors of the project and members of the public did not receive adequate notice to fully respond, solicit technical expertise, and reach those people who would most be affected or concerned.Central Coast Grown, the primary tenant of the adjoining and nearby property, was never informed of this pending project.  Rather, the City sent a notice to Nico Allegretta, a former sublessee of Central Coast Grown, whose business was dissolved in late 2014.

Notice was also not given to San Luis Ranch, owner of the large property near the project, whose pending development plans will be affected by it. The project was first brought to the attention of both neighbors by a community member who saw the public notice in the classified ads of the Tribune in late August 2015. (See attachment 1: list of parties who received the notice.)

The proposal has serious environmental impacts that are either under-reported or ignored in the Initial Study. This violates the requirement of the California Environmental Quality Act:

“All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.”

The recommended “Negative Declaration: Less Than Significant With Mitigation Incorporated,” only

“applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level¦”

This requirement has not been met.

The project also does not comply with multiple San Luis Obispo City policies, most notably with the recently adopted LUCE update dealing with this property and adjoining properties, section 8.11.  Calle Joaquin Auto Sales Area:

These four vacant lots are suitable for commercial mixed use and other uses described under the Tourist Commercial designations. Portions of the site may be appropriate for use as auto sales, depending on market demand. Development of this area must address preservation of and transition to the agricultural parcels/uses to the northwest; connectivity to the Dalidio Ranch area; viewshed preservation; and treatment as a gateway to the City visible from Highway 101.

The project property shares a narrow border to the west with City Farm San Luis Obispo, a 20-acre parcel owned by the City of San Luis Obispo and managed by the 501(c)3 non-profit Central Coast Grown. The long northeast property line is separated from City Farm by only 211 feet, occupied by another as yet undeveloped lot. City Farm is a part of the Calle Joaquin Agricultural Open Space Preserve, which also includes approximately 140 acres of adjacent working agricultural land to its northeast, now owned by San Luis Ranch.  Half of this land plus City Farm have been designated by the City’s General Plan to remain in agricultural production and to serve as educational as well as tourist-serving facilities in order to acknowledge and strengthen the City and County’s agricultural heritage and to provide residents and visitors the opportunity to learn about, appreciate and participate in local farming activities.

Aesthetic Impacts (Item 1)

The first significant impacts not mitigated are aesthetic, 1a and 1c in the Initial Study prepared by the City: “Would the project have a substantial adverse effect on a scenic vista?” “Would the project substantially degrade the existing visual character or quality of the site and its surroundings?”

The Study mentions that “U.S. 101 and Los Osos Valley Road are designated in the Conservation and Open Space Element (COE) as having view corridors of “high scenic value” southwest of the site, and “moderate scenic value” northeast of the site (Figure 11: Scenic Roadways and Vistas).”

As highlighted in the preface to the Master Plan for the Calle Joaquin Agricultural Open Space Preserve, ˜”the 1994 update of the General Plan states that it was the City of San Luis Obispo’s intention to preserve significant parts of “this signature working agricultural landscape” at the city’s southern gateway.'(16)
Nevertheless, the Initial Study concludes “Based on the size and location of the proposed structure, a majority of existing views of prominent hillsides would be retained as viewers travel along U.S. 101.”

However this conclusion is not supported either by a visit to the site, driving by it on Highway 101, or even by the Study’s own visual representations of before and after:

northboundafterThis structure would completely block the background views of San Luis Mountain for travellers entering the City before they reached the viewpoint of this picture.  From the point the picture was taken, it would hide Bishop Peak and the adjacent middle distance view of the Eucalyptus grove which has been an iconic feature of this critical City gateway.

More significantly, what is not shown by the picture is that the foreground of the “signature landscape” consists of the rowcrops of vegetables and flowers and of the farmers and volunteers and farm equipment engaged in agricultural activity.  All of this is completely obstructed by what could be described as a four-story “big box” vastly out of scale vertically and horizontally with its agricultural surroundings. Taken together, these effects constitute Class 1 impacts to Aesthetics.

Although Aesthetic Impacts, particularly in this signature gateway context, need to be reconsidered, other impacts “including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts,” as specified by the Initial Study, are just as important in this case, despite not being mentioned there.

Because of its height and monolithic mass, this project would dominate views from anywhere on City Farm, views to the south and southwest that now open to the hills in the distance.


View from northern (most distant) border of City Farm [CCG rendering]


View from middle of City Farm field [CCG rendering]

This massive structure is inconsistent with the agricultural operations to the North, and will undermine City Farm and San Luis Ranch’s outreach and educational efforts.

Impacts on neighbors (not considered)

The EIR we request needs to thoroughly examine the project’s impacts, not only for aesthetics but for its long-range negative consequence for the tourist-serving and commercial facilities already approved by the City in the form of 1) a farmstand and parking area to be constructed on City Farm at the end of the present Calle Joaquin as soon as the present temporary off-ramp from the freeway is relocated and 2) a Pergola serving as a meeting place and educational center now nearing the end of the City’s approval process.
Were this hotel project redesigned to be compatible with the Agricultural Preserve, it could enhance views both of and from it with tourist serving facilities that would benefit from the proximity.
Examples of such compatible projects are readily available, e.g. San Luis Obispo’s Apple Farm:



applefarmimage2The consequences of the project’s incompatibility with its neighborhood will be intensified as plans unfold for the development of San Luis Ranch within the Calle Joaquin Agricultural Preserve.  This development will continue agricultural activities on a large portion of its acreage and will integrate design elements including agriculturally themed housing, commercial structures and tourist facilities in what is planned as as a “farm-to-table community.” Examples of this progressive up-and-coming approach is afforded by the Cannery Development in Davis, California ( and by the twelve more described here:

In contrast to such visionary projects, the Calle Joaquin Hotel Development is outmoded in style as well as function.  Its cookie cutter design may be suitable for generic freeway exit locations in “anywhere U.S.A.,” but not for the scenic gateway and stunning natural resources of our signature landscape.  Its towering presence will draw the attention of passers-by away from the agriculturally centered businesses and activities at the Calle Joaquin Preserve and will reduce their appeal to those on site.

Guidelines not followed in Initial Study

Specifically the project violates multiple and overlapping City Policies for development in this area. Relevant key terms are highlighted

From the current LUCE update: 8.11.  Calle Joaquin Auto Sales Area:

These four vacant lots are suitable for commercial mixed use and other uses described under the Tourist Commercial designations. Portions of the site may be appropriate for use as auto sales, depending on market demand. Development of this area must address preservation of and transition to the agricultural parcels/uses to the northwest; connectivity to the Dalidio Ranch area; viewshed preservation; and treatment as a gateway to the City visible from Highway 101.

From Agricultural Master Plan for the City of San Luis Obispo’s Calle Joaquin Agricultural Reserve:

“This approximately 180-acre area of prime farm land bounded by Madonna Road, Highway 101, Central Coast Plaza, and Prefumo Creek is in three ownerships. The City intends to preserve at least one-half of this signature working agricultural landscape at the southern gateway to San Luis Obispo as it existed in 1994.” —City of San Luis Obispo General Plan, Land Use Element, Policy 8.8

The proposed project violates multiple “Community Design Guidelines” mandated by the Architectural Review Commission, for example:

Chapter 1 – Introduction and Applicability
San Luis Obispo is a vital community located in a beautiful and unique physical setting. It is also a place where citizens care about the quality of architecture and urban design, and participate in the design review process.
1.1 – Purpose of the Design Guidelines
All development projects should be designed in a manner that responds to the unique characteristics of their individual sites, but also to fit into the wider context of San Luis Obispo.
These guidelines have been prepared because San Luis Obispo has become a city with a physical character and identity that are distinct, attractive, and widely appreciated by residents and visitors. At the same time, changes in the nature of business, marketing, and the California economy have created pressures for types and styles of development that have made many other communities lose their distinctiveness and look and feel like everywhere else, and nowhere in particular.

1.4 – Goals for Design Quality and Character

How the built environment appears in relation to the surrounding landscape, and the quality of the architecture and site design within the city, are key to continuing and advancing the high quality of life.

A. Keep San Luis Obispo architecturally distinctive, don’t let it become “anywhere USA.”
3. The quality of development at city gateways and along key corridors is critical to the city’s overall image for residents and visitors.
4. Design with consideration of the site context in terms of the best nearby examples of massing, scale, and land uses when the site is located in a notable area of the city
C. Site planning. Project site planning should comply with the following guidelines.
1. Consider neighboring development. Each development proposal should demonstrate consideration for the existing conditions on and off the site including the following:
a. The uses on, and site layout of neighboring properties;
c. Existing natural features (i.e., mature trees, landforms, etc);
d. Opportunities to preserve or enhance views of the hills;
e. Privacy and solar access of the site and neighboring properties;
d. Scenic views and natural features around the site, and a site’s location on a scenic route (see the Circulation and Open Space Elements of the General Plan) should be considered early in project design. For instance, the placement of buildings against the backdrop of the hills should not obscure views by being oversized, extremely tall, or use materials or colors to draw attention away from the natural environment.

Agricultural Impacts (Item 2)

Given the proximity of the immediate neighbor, City Farm San Luis Obispo, the Initial Study doesn’t adequately take into account two serious impacts on the agricultural activities presently conducted there.
1. The shadowing study shows shadowing at four times of the year but only at noon.  Shadow impacts on crop growth need to be shown at other times of the day, especially during Winter. The farm uses solar radiation all day to produce food 365 days year.
2. The impact of construction dust on crops grown on the adjacent and proximate lots also needs to be considered.

Land Use Impacts (Item 10)

The proposed project “Conflict[s] with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?” as specified in the earlier quotes.

In addition, the project has unacknowledged cumulative impacts resulting from its “leapfrog development” location.  Being placed one lot short of the northeast border with the Calle Joaquin Agricultural Preserve will encourage unsuitable development on both sides. The incompatible size and appearance of the hotel will overshadow any efforts at compatibility on the lot between it and City Farm, and there will be no incentive to achieve any compatibility in the development to the south.  However, if this project, despite all the drawbacks noted here, were placed next to the present car-dealership, a number of the impacts that concern us might be mitigated.


Some of the most serious negative impacts of this project go beyond the parameters in the Initial Study.  The unique future potentials of the Calle Joaquin Agricultural Preserve are long-range and only starting to become evident in the present activities on City Farm SLO, an endeavor in which the City of San Luis Obispo is partnering with the non-profit Central Coast Grown, three independent young organic farming enterprises, the Food Bank, the San Luis Obispo and Paso Robles School Districts and many local citizen supporters and volunteers.  (For more information, please see The vision guiding these developments promises to make the Preserve a showpiece for the City as well as an exemplary operation at the forefront of the urban farm, local food, sustainable agriculture movement.

The citizens and political leaders of San Luis Obispo struggled long and hard to make it possible to realize this vision.  Please don’t let this development block that vision either literally or figuratively.

Respectfully submitted,

Board of Directors of Central Coast Grown

Wendy Brown

Brian Engleton

Hunter Francis

Jerusha Greenwood

Terry Hooker

Steven Marx

John Phillips

Attachment 1: List of parties noticed of the project


Leave a Reply