CPMS
Agenda Item D.1
DISCUSSION/ACTION ITEM
Meeting Date: April 16, 2024
TO: Mayor and Councilmembers
SUBMITTED BY: Peter T. Imhof, Planning and Environmental Review Director PREPARED BY: Anne Wells, Advance Planning Manager
SUBJECT: Santa Barbara County 2023-2031 Housing Element Rezone Amendments and Final Program EIR Comment Letter
RECOMMENDATION:
Authorize staff to submit a letter to the County of Santa Barbara Boar d of Supervisors, signed by the Mayor and Councilmembers , regarding the County 2023–2031 Housing Element Rezone Amendments and Final Program Environmental Impact Report (EIR).
BACKGROUND:
City of Goleta staff and elected officials have been following the County’s 6 th Cycle Housing Element update process. On January 13, 2023, the City transmitted two comment letters to the County, one to the Board of Supervisors (BOS) signed by the Mayor and Mayor Pro Tempore and another to the County Planning and Developm ent Department Director. The letters expressed concerns regarding the County’s draft Housing Element process and prioritization of proposed housing sites, including proposed conversion of agricultural and open space lands to thousands of housing units with out including or adjusting for existing residential buildout capacity. On January 30, 2023, the County released its first 6 th Cycle Draft Housing Element for 30 -day review. City comments provided on January 13, 2023, were not addressed in the Draft.
On February 14, 2023, the BOS held a public meeting to consider the Draft. Goleta City Councilmembers spoke to express concerns , including those detailed in the January 13 comments, and alarm at the premature transmittal of the Draft Housing Element to the State without adequate outreach and revision to reflect public input. On February 28, 2023, the City transmitted another comment letter to the BOS, signed by all five Councilmembers. This letter focused on the County’s sites inventory, our shared disadvantaged community, fair housing, expanded policies and programs, public participation, and the California Environmental Quality Act (CEQA).
On December 5, 2023, the BOS adopted the County Housing Element 2023 -2031 and determined it was exempt from CEQA pursuant to State CEQA Guidelines section 1 Meeting Date: April 16, 2024
15061(b)(3). On December 20, 2023, the County released a Draft Program Environmental Impact Report (PEIR) for the 2023 -2031 Housing Element Update. The analysis in the Draft PEIR considered the impacts related to proposed rezones to accommodate the County’s Regional Housing Needs Allocation. The City provided comments on the Draft PEIR on February 9, 2024. Among other things, the comments sought to address impacts associated with significant growth at the City’s borders. Th ese impacts include significantly increased use of City infrastructure, including roadways and parks. The City sought additional mitigation measures, such as the construction of infrastructure projects and supply of impact fees collected by the County , to support the demand for City facilities.
On March 19, 2024, the County released the Final PEIR for the 2023 -2031 Housing Element Update. The Final PEIR included responses to the City’s comments but did not address the City’s substantive concerns.
The County Planning Commission considered the Final PEIR, rezones, and other policy amendments associated with the rezones at a public hearing on March 27 and April 1, 2024. At the public hearing, Councilmembers Richards and Kyriaco provided public testimony. Councilmembers Kasdin and Kyriaco submitted comment letters. These letters are provided as Attachment 2.
On April 1, 2024, the County Planning Commission recommended to the BOS certification of the Final PEIR and rezoning of several large parcels to allow several thousand new housing units adjacent to the City and certain policy amendments, including a change to how the County would analyze traffic impacts to Goleta intersections created by projects on rezoned sites in the County.
DISCUSSION:
City staff expects the County Board of Supervisors to consider the Planning Commission recommendation in later April and early May at public hearings. These hearings again provide the City an opportunity to express concerns related to the County’s zoning and policy changes and how those changes will impact the City. In preparation for the hearings, staff has prepared a draft comment letter for the Mayor and Councilmembers’ signature. This draft letter is provided as Attachment 1 to the staff report.
The draft le tter restates the City’s concerns regarding the adequacy of the PEIR, particularly in light of the minimal changes made between the Draft and Final PEIR in response to the City’s earlier comments . In addition, the comment letter specifically emphasizes Cit y concerns regarding transportation impacts associated with future development of rezone sites along the City’s border.
In addition to concerns previously expressed in the City’s letter on the Draft PEIR, the draft letter addresses concerns regarding a recently disclosed proposed amendment to the County’s Circulation Element that would reduce County accountability to address impacts to City intersections caused by development on County rezone sites.
Specifically, County staff and the Planning Commission are recommending the creation 2 Meeting Date: April 16, 2024
of an exception for County Housing Element sites to a critical County Circulation Element policy that serves to address transportation impacts within the City. For projects located within the unincorporated County, County Circulation Element Policy IV.D.5 commits the County to apply stringent level of service (LOS) standards to all affected roadway intersections, not just those within the unincorporated County but also to intersections within adjacent incorporated cities. The County now proposes to exempt the Housing Element rezone sites, with their massive potential for new residential development, from objective LOS standards under this policy and instead defer to County Public Works Department staff’s judgment as to what constitutes acceptable intersection improvements. As County staff acknowledge, under the proposed new exception, County Housing Element projects would not be required to meet current County Circulation Element LOS standards.
FISCAL IMPACTS:
There is no financial impact associated with this item. Staff time associated with the preparation of this staff report is included in the Advance Planning Work Program for Fiscal Year 2023-24.
ALTERNATIVES:
City Council could direct staff to amend the content of the letter or choose to not submit a letter to the County.
LEGAL REVIEW BY: Megan Garibaldi, City Attorney
APPROVED BY: Robert Nisbet, City Manager
ATTACHMENTS:
1. Draft Letter Regarding Santa Barbara County 2023 -2031 Housing Element Rezone Amendments and Final PEIR
Exhibit A: City of Goleta Comment Letter (Dated 2/ 9/24) Regarding the County Housing Element Draft Program EIR
2. Comment Letters on the County Housing Element and Rezoning from Councilmember Kyriaco (dated 3/28/24) and from Counci lmember Kasdin (dated 4/1/24)
3 Attachment 1
Draft Letter Regarding Santa Barbara County 2023-2031 Housing Element Rezone Amendments and Final PEIR
4 CITY COUNCIL
Paula Perotte
Mayor
Luz Reyes -Martín
Mayor Pro Tempore
District 1
Stuart Kasdin
Councilmember
James Kyriaco
Councilmember
District 2
Kyle Richards
Councilmember
CITY MANAGER
Robert Nisbet
April 16, 2024 SENT VIA EMAIL
[email protected]
[email protected]
Board of Supervisors
County of Santa Barbara
105 East Anapamu Street
Santa Barbara, CA 93101
RE: County Housing Element Rezone Amendments Comments
Dear Chair Lavagnino and Honorable Members of the Board of Supervisors:
The purpose of this letter is to convey our commitment to regional collaboration as we seek to work with you to address infrastructure needs associated with the County’s proposed housing rezone sites . As you consider the Housing Element Rezone Amendments , policy amendments, and the related Final Program EI R (FPEIR) at an upcoming hearing, significant housing is proposed in the South Coast that will create many challenges for the Goleta community. In our Draft Program EIR (DPEIR) comment letter dated February 9, 2024 (attached), we identified several solutions to address infrastructure needs, most or all of whi ch were disregarded in the FPEIR. We believe our requested solutions detailed in the letter merit your reconsideration.
Regional collaboration to address shared infrastructure needs has long been our practice and we wish to continue with this approach to t he benefit of us all.
When the County released the FPEIR for the County 2023 -2031 Housing Element on March 19, 2024, the City was disappointed to see that very few of our substantive comments related to the project description, impacts, and mitigation mea sures provided in our February 9, 2024, letter were addressed. Without restating all our previous comments, which are incorporated, we do want to highlight a couple of important issues for your consideration.
In our DPEIR comments, we requested mitigatio n measures to address transportation infrastructure impacts of the new housing developments 5 April 16, 2024
at Glen Annie and the South Patterson Agricultural Area, as these areas must rely on City roads for access . Without mitigation, vehicle, bicycle, and pedestrian traffic associated with County -proposed rezone sites lead to design safety concerns and hazards on Goleta’s road network and intersections. Preventing dangerous intersections with mitigations such as restriping, signalization, improved bike lanes, and roundabouts will help us maintain level of service, safe modes of travel, and hazards reduction. Not only were no such mitigations added to the FPEIR, but we learned with the release of the Planning Commission staff report for the March 27, 2024, hearing that County staff also proposed to create an exception for Housing Element sites to a critical County Circulation Element policy that serves to address transportation impacts within the City. For projects located within the unincorporated County , County Circulati on Element Policy IV.D.5 commits the County to apply stringent level of service (LOS) standards to all affected roadway intersections, not just those within the unincor porated County but also to intersections within adjacent incorporated cities.
The Plann ing Commission supported County staff’s recommendation to exempt the Housing Element rezone sites from objective LOS standards under this policy and instead defer to County Public Works Department staff ’s judgment as to what constitutes “acceptable” intersection improvements. What is most troubling is that the March 27, 2024, staff report notes that County staff “ anticipate that some housing projects enabled by the rezones would result in some roadways and/or intersections operating below current LOS standa rds” and that “ improvements necessary to fully offset a project’s impacts to a roadway or intersection may be infeasible .” Yet the staff report fails to indicate where County staff expect these impacts to occur. At this point, we are left to assume that th e impacted intersections are within the City of Goleta and the amendment to the Circulation Element policy is intended to avoid the need to address and adequately mitigate those impacts.
In summary, we ask that you direct staff to take the necessary time to update the FEIR to address comments provided in our Draft Program EIR comment letter, particularly those comments relating to mitigating infrastructure impacts in and around the City of Goleta.
We look forward to collaborating with you and your staff to address new housing enabled by the rezoning and ensuring that new development does not come at the cost of the operability of our shared roadway network.
Sincerely,
Mayor Paula Perotte
6 April 16, 2024
Mayor Pro Tempore Luz Reyes-Martín
Councilmember Stuart Kasdin
Councilmember James Kyriaco
Councilmember Kyle Richards
cc: Robert Nisbet, City Manager
Mona Miyasato, County Executive Officer
Enc.:
City of Goleta Draft Program EIR Comment Letter, Dated February 9, 2024 7 Attachment 1, Exhibit A
City of Goleta Comment Letter (Dated 2/9/24) Regarding the County Housing Element Draft Program EIR
8 CITY COUNCI L
Paula Perotte
Mayor
Luz Reyes -Martín
Mayor Pro Tempore
District 1
S
tuart Kasdin
Councilmember
James Kyriaco
Councilmember
District 2
Ky
le Richards
Councilmember
CITY MANAGER
Robert Nisbet
February 9, 2024 SENT VIA EMAIL
[email protected]
H
annah Thomas, Project Planner
Planning & Development Department
County of Santa Barbara
123 E. Anapamu Street
Santa Barbara, CA 93101
RE
: Santa Barbara County 2023- 2031 Housing Element Update Draft Program Environmental Impact Report Comments
D
ear Ms. Thomas:
T
hank you for the oppor tunity to review and comment on the County’s 2023-2013 Housing Element Update Draft Program E nvironmental Impact Report ( Draft PEIR), dated December 2023, State Clearinghouse No. 2022070490. The 2023-2031 Housing E lement Update project (Project) includes many programs and actions to facilitate housing in the uni ncorporated areas of Santa Barbara C ounty.
We understand the challenge the County has faced in meeting state requirements related to the Project. However, it is critical to und erstand, analyze, and mitigate the impacts of the Project, thus ensuring that all impacts to the environment and surrounding community are fully addressed.
M
ost notably, the Project includes the rezoning of sites located adjacent to the City of Goleta (City), converting agricultural zoning to high density residential zoning. Of highest concern to the City is the rezoning of the following sites included in the Draft PEIR project descr iption and the significant number of potential units associated with these sites:
• S
ites 1 through 7 (South Patterson Agricultural Area) – 7,708 units • Site 11 – Glen Annie Golf Course – 2,673 units
A
ll of the above sites are only access ible through the City and any future residents on these sit es will rely on the City ’s transportation network, open space and recreational spaces, emergency response facilities, and other resources.
9 February 9, 2024
U
nder the California Environmental Quality Act, a lead agency’s duty to mitigate or avoid its project’s significant impacts extends beyond the boundaries of the project area. (See City of Marina v. Board of Trustees of Cal. State University (2006) 39 Cal.4th 341, 359-360 [agency not excused from analysis or mitigation of impacts outside of its jurisdiction]; see also Napa Citizens for Honest Gov’t v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 369 [CEQA’s purpose would be undermined if agenci es could proceed “without an awareness of the effects a project will have on areas outside the bound aries of the project area.”].) Based on our review of the Draft PEIR, we identified needed changes to better disclose, evaluate, and mitigate possible impacts relevant to the Ci ty. These changes are detailed in the attached comment matrix. Of note and as detail ed in the comment matrix, the Draft PEIR omits critical discussion or analysis of Goleta General P lan policies or existing and planned infrastructure and capital projects within the City. Without consideration of City policies and projects, the analysis in the Draft PEIR is incomplete.
A
lso of note and detailed in the comment matrix is the need to add additional mitigation measures to address the impacts of th e Project on our comm unity. These include the need for a Traffic Mitigation Agreement between the City and County to address growth in the County lands south east and north of the City . The comment matrix identifies the need for a broader agreement between the County and City to address payment of impact fees to Goleta, fair share paym ents for Goleta capital projects, the construction of Fire Station 10, and the construction of needed infrastructure a s part of housing projects envision ed under the Project. The timing of the se necessary mitigation measures is also critical to ensure adequate services are provided to the community. As such, these mitigation measures must include requirements that the impacts to t he City be addressed prior to issuing any certificates of occupancy for new housing development envisioned with the project.
A
ddressing City comments will be critical to ensure that the Final PEIR provides adequate environmental analysis and mitigation for the Project. The Ci ty respectfully requests that the necessary changes as identified and described in this letter and in the attached comment matrix be included in the Final PEIR. If you have any questions regarding our comments, don’ t hesitate to contact me at [email protected] or 805-961-7541.
Si
ncerely,
P
eter Imhof
Planning and Environmental Review Department Director
A
ttachment: Goleta Comment Matrix
10 February 9, 2024
cc:
Robert Nisbet, City Manager
Charlie Ebeling, Public Works Director
Nina Buelna, Assistant Public Works Director
Anne Wells, Advance Planning Manager
11 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
General Comments
Global The regulatory se�ng includes details regarding County policies but there is no informa�on provided regarding the City of Goleta se�ng. The EIR must analyze all direct and reasonably foreseeable indirect impacts of the Housing Element, including impacts rela�ng to a change in the patern of land use or popula�on density. (State CEQA Guidelines, §§ 15126.2(a), §15358(a).) A lead agency’s duty to mi�gate or avoid its project’s significant impacts extends beyond the boundaries of the project area. (See City of Marina v. Board of Trustees of Cal.
State University (2006) 39 Cal.4th 341, 359-360; see also Napa Citizens for Honest Gov’t v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 369.) Because Rezone Sites 1-7 and 11 are on the City of Goleta’s boundary and will impact City resources, Goleta General Plan / Coastal Land Use Plan policies must be included in the DPEIR and analyzed throughout. Addi�onal mi�ga�on should be included to address consistency with Goleta policy.
Execu�ve Summary
ES-14 (and
Global)
Table ES-3 The impacts listed in the column �tled “Impact Classifica�on” needs to reflect the categories explained on page ES-6. Failure to dis�nguish poten�ally significant impacts between those that are unmi�gable and those that are mi�gable obfuscates the impacts of the project as displayed in the Execu�ve Summary. Some specific examples are provided below. The same clarity must also be provided in the individual impact analysis sec�ons.
ES-14 Table ES-3 Impact AV-2 is not iden�fied correctly. Currently, this impact restates Impact AV-3.
ES-15 Table ES-3 In Sec�on 3.2, Impacts AG-1, AG-2, and Cumula�ve Impacts are all listed as “Significant and unavoidable” but are listed in Table ES-3 as “Poten�ally significant.”
ES-53-54 Table ES-3 The impacts for LU-2 and LU-3 must be listed as “Significant and unavoidable.” See comments under Sec�on
3.10. ES-53 Table ES-3 The Residual Impacts for LU-3 need to be listed as “Significant and unavoidable.” See comment under Sec�on
3.10. ES-54 Table ES-3 In Sec�on 3.10.4.3, the Cumula�ve Impacts for Land Use and Planning are iden�fied as “Significant and unavoidable” (p. 3.10-64) but are iden�fied as “Poten�ally significant” in Table ES-3. This discrepancy must be remedied.
ES 65–66 Table ES-3 In Sec�on 3.15.4.2, Impacts USW-1 through USW-4 are listed as significant and unavoidable, but are listed in Table ES-3 as “Poten�ally significant.” Table ES-3 needs to be corrected.
Chapter 1: Introduc�on
Sec�on 1.5: Agencies and Roles
1-6 Table 1-1.
Agencies and
Roles
The City of Goleta should be added to the “Other Interested Agencies” category due to the fact that many of the impacts analyzed will be borne, at least in part, by the City of Goleta. (See Pub. Resources Code, §21153(a); State CEQA Guidelines, §15086(a) [consulta�on is required from any city which borders on a city or county within which the project is located].)
Chapter 2: Project Descrip�on
Sec�on 2.3: Housing Element Update
12 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
2-15 Table 2-4 Allowing conversion of agricultural water to residen�al water for affordable housing projects and the transfer of water credits between proper�es could impact the City of Goleta’s water resources and infrastructure. This could be mi�gated by addi�onal water allotments for the Goleta Water District to address these changes. (State CEQA Guidelines, §§ 15121(a), 15126.4(a) [EIR must iden�fy and describe feasible mi�ga�on measures that can minimize each of the project’s significant environmental impacts].) 2-17 Scope of Analysis The EIR must include analysis of Housing Element Program 16 (allowing mul�family in commercials zones) and this program needs to be described in detail and analyzed throughout the EIR. (State CEQA Guidelines, §15378 [project is defined as “the whole of ac�on”]; see Laurel Heights Improvement Ass’n. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 396 [EIR must consider all phases of project].) Assump�ons need to be detailed on the increase in development that this program will lead to. This program will likely drama�cally change the poten�al popula�on buildout in this EIR and will thus drama�cally impact many sec�ons of the EIR. New mi�ga�on measures, or altered mi�ga�on measures, including those related to transporta�on and services, may be needed.
2-18 2.3.2 Project
Components
Poten�ally reduced setbacks and an increase in developable area from 30% to 40% for DR could nega�vely impact the aesthe�c quality of the City of Goleta, par�cularly along borders adjacent to the County’s DR rezone sites. Addi�onally, these development standard changes would reduce opportuni�es for on-site open space and thus exacerbate demands for these public services elsewhere. These impacts must be analyzed.
Finally, these changes and the reduced open space provided on site, serve to counteract MM LU-1 (which allowed commercial recrea�onal facili�es in DR).
2-30 Poten�al Housing
Growth
This analysis must include the mixed-use development poten�al pursuant to Program 16.
Sec�on 2.4: Required Ac�ons and Approvals
2-39 2.4 Required
Ac�ons and
Approvals
The EIR must provide much clearer details on the community plan amendments that are needed to implement this project. These community plan amendments are part of the project, not mi�ga�on for a later date. As such, they need to be made clear in the project descrip�on. (State CEQA Guidelines, §15378 [project is defined as “the whole of ac�on”]; see Laurel Heights Improvement Ass’n. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 396 [EIR must consider all phases of project]; Cleveland Nat’l Forest Found. v. San Diego Ass’n. of Gov’ts. (2017) 17 Cal.App.5th 413, 440 [it is not appropriate to defer more specific analysis if such informa�on is available at the program EIR stage or if there is no substan�al evidence to support the decision to defer such analysis].) The project must also analyze whether any changes (SEIR, Addendum, etc.) are needed for community plans. Any changes to other CEQA documents to amend community plans must also be included with the Project.
Chapter 3: Environmental Impact Analysis
Sec�on 3.0: Introduc�on and Approach to Analysis
13 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
3-4 Impact
Assessment
Assump�ons and
Buildout Scenarios
The descrip�on of the buildout scenario reflects the development envisioned in the County’s Housing Element, not a reflec�on of future development in the Project area. This summary omits considera�on of projects within incorporated ci�es, like Goleta. For instance, new housing projects like Heritage Ridge should be included as well as capital projects, like the roundabouts at Highway 217 and Hollister Avenue (now part of Project Connect, but on the City’s CIP list for many years).
3-4 Baseline A second No�ce of Prepara�on was released on August 11, 2022. This should be noted in this sec�on and any changes in the baseline should be included in the EIR.
Sec�on 3.1: Aesthe�cs and Visual Resources
3.1-23,
3.1-25
Impact AV-1 and
AV-2
The PDEIR includes no explana�on as to how Mi�ga�on Measure MM AV-1 would help address public scenic vistas and visual resources or scenic quali�es. (League to Save Lake Tahoe v. County of Placer (2022) 75 Cal.App.5th 63, 121 [courts will not defer to lead agency’s determina�on that mi�ga�on measure will work when their efficacy is not apparent and there is no evidence in the record showing they will be effec�ve].) The County’s objec�ve design standards do not include specific protec�ons for visual resources. As such, MM AV-1 is an inadequate mi�ga�on measure to address this impact.
3.1-26 Impact AV-3 The EIR must include addi�onal mi�ga�on for Impact AV-3 (and AV-1 and AV-2) that addresses impacts to the surrounding community and scenic resources, as the poten�al impacts from this project from light and glare are not insignificant. Mi�ga�on must include specific standards related to ligh�ng at the top of, and above, the exis�ng height standards for DR to address new ligh�ng impacts from the taller projects allowed under this Project.
Addi�onally, mi�ga�on is also needed to ensure there is no light trespass as a result of allowing structures closer to property lines under this Project. As the DPEIR notes, “light trespass and glare shall be reduced to the maximum extent feasible.” This is a subjec�ve requirement that is not enforceable on ministerial projects.
Sec�on 3.4: Biological Resources
3.4-39 MM BIO-2 For MM BIO-2, there is poten�al for an applicant to argue that the decision for “avoidance, minimiza�on, or compensatory measures” is subjec�ve and thus enforceable. To ensure protec�on of biological resources, the language of this mi�ga�on measure must be revised to ensure enforceability and protec�on of cri�cal biological resources, including for several creeks that run through, or adjacent to, sites included in the Project for rezoning.
3.4-39 MM BIO-2 “Compensatory measures” should not be included in MM BIO-2. If the project cannot avoid the impacts, the project design needs to be reconsidered.
3.4-39 MM BIO-2 Allowing a biologist to determine “to the maximum extent feasible” a 100-foot buffer for ground disturbance and vegeta�on removal from sensi�ve habitats, watercourses, or riparian habitats is subjec�ve and poten�ally unenforceable. This language must be revised to ensure the applica�on of the buffer standard is objec�ve and enforceable and protects the resources in ques�on.
14 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
3-4.35 Impact BIO-4 The PDEIR concludes that no mi�ga�on is feasible for the conflicts with exis�ng policy and regula�on regarding protec�on of creeks. However, there is poten�al mi�ga�on for this impact that must be iden�fied as follows. A mi�ga�on measure must be included to revise the relevant policies in the Goleta Community Plan and Eastern Goleta Valley Community Plan to ensure their applica�on to ministerial projects. The �meline for implementa�on of this measure must be in the next year to ensure new housing development does not sacrifice cri�cal local biological resources.
Sec�on 3.8: Hazards and Hazardous Materials
3.8-39 MM HAZ-3 This mi�ga�on measure must not be limited as it is writen. This requirement must apply to all projects, not just those on County property or qualifying for ministerial review, as applica�on of the newly adopted ALUCP is not currently included in the County’s policies or development standards.
3.8-39 MM HAZ-3 MM HAZ-3 must not be limited to ALUCP density, height, and open space standards. This mi�ga�on measure should make clear that new development must comply with the en�rety of the ALUCPs.
This mi�ga�on should also explicitly acknowledge the need to comply with FAA requirements, including a Part 77 analysis (which may significantly limit the height of proposed housing development).
3.8-39 MM HAZ-3 Figures 7 and 24 of the Eastern Goleta Valley Community Plan will also need upda�ng.
Sec�on 3.10: Land Use and Planning
3.10-20 Local Regulatory
Se�ng
The regulatory se�ng includes details regarding County policies but there is no informa�on provided regarding the City of Goleta se�ng. Because Rezone Sites 1-7 and 11 are on the City of Goleta’s boundary and will impact City resources, a sec�on detailing related Goleta General Plan / Coastal Land Use Plan policies must be added and analyzed throughout Sec�on 3.10. Addi�onal mi�ga�on should be included to address consistency with Goleta policy.
3.10-25–
63 Impacts LU-2 and
LU-3
The analysis of these two impacts does not disclose whether the impacts are “Significant and unavoidable” or “Less than significant with mi�ga�on.” For both impacts, the analysis concludes that mi�ga�on measures would reduce significant impacts, but provides no explana�on as to whether or how those mi�ga�on measures could reduce impacts to less than significant. As such, the analysis of Impacts LU-1 and LU-2 must disclose that these impacts, even with mi�ga�on, are significant and unavoidable. Table ES-3 should be updated to reflect this as well.
3.10-25–
60 Impact LU-2 and
Table 3.10-3.
The analysis of this impact must include Eastern Goleta Valley Community Plan policies TC-EGV-1.1 and TC-EGV-
1.2. These policies require level of service standards and long-term improvements to mul�modal transporta�on facili�es targeted to provide for these levels of service. Mi�ga�on measures to address impacts due to development that must rely on City of Goleta roadway infrastructure, including execu�on of an MOU with the City of Goleta for contribu�ons of impacts fees and for the provision of fair-share contribu�ons for City of Goleta capital projects, must be included in the mi�ga�on for any impacts iden�fied. Without such analysis and mi�ga�on, the EIR does not adequately address and analyze this impact. 15 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
3.10-28 Table 3.10-3 (and
Impact LU-2)
Table 3.10-3 includes no references to the Goleta Community Plan. As such, the analysis provided is en�rely inadequate for considera�on of Rezone Site No. 11 (Glen Annie).
Mi�ga�on for this planning area must be included similar to that noted above, including an MOU with the City of Goleta, to address transporta�on impacts in Goleta.
3.10-63 Impact LU-3 This impact must acknowledge that the local streets impacts will be in the City of Goleta. This is made evident by the fact that the development of the South Paterson agriculture block es�mated growth would increase average daily trips (ADT) on South Paterson Avenue (a City of Goleta street) by 130 percent.
3.10-64–
65 MM LU-1 MM LU-1, as prepared, is far too broad in scope and vague to the point where the impacts created by this mi�ga�on measure may be significant and unavoidable in their own right. If a mi�ga�on measure iden�fied in an EIR would itself cause significant environmental impacts dis�nct from the significant effects caused by the project, those impacts must be discussed in the EIR. (State CEQA Guidelines, §15126.4(a)(1)(D).) MM LU-1 must be revised to (1) limit the allowances to the sites considered for rezoning as part of this project; (2) limit the size of commercial development (by square footage and/or size of the project; and (3) only allow with discre�onary review. This is needed because there is no way to understand the impacts of this mi�ga�on measure simply by limi�ng the uses to “neighborhood-serving commercial uses.” The reality is that these uses could vary greatly. For example, a coffee shop can serve the neighborhood, yet also generate significant traffic and impacts to the area that may already be stressed by the significant new residen�al development.
Addi�onally, by allowing commercial uses in all of DR, the County may poten�ally contribute to a loss of housing on sites where a property owner chooses to convert exis�ng housing on a DR site to commercial uses.
Addi�onally, the language of the mi�ga�on measure (e.g. “steep slopes,” “may require,” “are compa�ble,” “an integral part, ” “adverse effects on residen�al uses”) are subjec�ve and therefore unenforceable for ministerial projects. As such, the language needs to be revised unless these uses are reviewed only through a discre�onary process.
3.10-65 MM LU-1,
(Residual Impacts)
The analysis of secondary impacts for MM LU-1 is purely specula�ve. The commercial uses could include addi�onal impacts throughout the County on DR designated parcels and must be analyzed. Impacts could include loss of exis�ng housing and new impacts from commercial uses sites throughout the County on sites previously designated only for residen�al use.
3.10-66 Impact LU-3
(Residual Impacts)
The analysis of this impact does not explain whether the impact is “significant and unavoidable” or “less than significant with mi�ga�on.” The analysis concludes that mi�ga�on measures would reduce significant impacts but provides no explana�on as to whether or how those mi�ga�on measures could reduce impacts to less than significant. As such, the analysis of residual impacts of Impact LU-3 must disclose that this impact, even with mi�ga�on, is significant and unavoidable. Table ES-3 should be updated to reflect this as well.
16 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
Sec�on 3.12: Popula�on and Housing
3.12-20 Impact PH-2 This impact must consider the impact of allowing commercial development within the DR zone district and the impacts that could have on displacement of people and housing.
Sec�on 3.13: Public Services and Recrea�on
3.13-45 Impact PSR-1 The analysis of this impact includes discussion of impact fees, however, because a new fire sta�on is proposed in the City of Goleta, a mi�ga�on measure needs to be included to provide funding for Fire Sta�on 10, par�cularly for rezone sites (such as, but not limited to, Glen Annie, Rezone Site No. 11) that will likely rely on service from that sta�on. Add a mi�ga�on requiring an MOU between the County and City of Goleta to ensure fees and payments associated with fire response are appropriately allocated to Fire Sta�on 10.
Addi�onally, a mi�ga�on measure must be added to require the construc�on of Fire Sta�on 10 prior to any new demand for fire services at Glen Annie (Rezone Site No. 11).
3.13-51 Impact PSR-5 A new mi�ga�on measure needs to be included to reflect the reality that increased housing adjacent to the City of Goleta will increase demand for and pressure on City of Goleta parks. This mi�ga�on measure must include a commitment for the County to provide the City of Goleta with park (and Quimby where applicable) fees collected for County housing projects on rezone sites where the residents will rely on City of Goleta parks and open spaces.
Sec�on 3.14: Transporta�on
3.14-9 Table 3.14-4 This table accurately includes Annual Average Daily Trips (AADT) volume and design capacity along Paterson Avenue in the City of Goleta. Because the proposed rezone sites also affect other north-south corridor roadways in the City of Goleta, AADT volume and design capacity needs to be included in Table 3.14-4 for Glen Annie Road (8,000 AADT), Storke Road (35,000 AADT) or Hollister Avenue west of Storke (25,000 AADT). The text summarizing the AADT and design capacity presented in this table also needs to be updated to reflect the addi�on of these three north-south corridors.
3.14-25 Local Policies The regulatory se�ng includes details regarding SBCAG and County se�ngs but there is no informa�on provided regarding the City of Goleta se�ng. Because Rezone Sites 1-7 and 11 are on the City of Goleta’s boundary and will impact City resources, including the City’s transporta�on network, a sec�on detailing related Goleta General Plan / Coastal Land Use Plan policies and analyzed throughout Sec�on 3.14 must be added.
Addi�onal mi�ga�on should be included to address consistency with Goleta transporta�on policies.
3.14-30 Local Policies Because Sites 1-7 are within the Eastern Goleta Valley Community Plan planning area and Site 11 is within the Goleta Community Plan planning area, the LOS standards from these two planning documents, and other relevant transporta�on policies from these two plans, must be included and considered in the analysis of impacts in the DPEIR.
17 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
Because the project will impact City streets, bike paths, and sidewalks, it must be clarified (in the first paragraph on page 3.14-30) that in addi�on to the County‘s Circula�on Element, the Goleta General Plan / Coastal Land Use Plan Transporta�on Element details standards for LOS.
3.14-40 Table 3.14-8 This table summarizes transporta�on impacts and mi�ga�on measures. Update the table to reflect the addi�onal analysis of City of Goleta transporta�on policies (not just County) for Impact T-1.
Update the table to reflect the new mi�ga�on measure requiring an MOU between the City of Goleta and the County, as detailed in this comment matrix. Such an agreement between the City of Goleta and the County is explicitly iden�fied in the City of Goleta’s General Plan subpolicy LU 12.7(c).
3.14-54 Impact T-3, Table
3.14-11
The roadways included in this table are inadequate. The data is provided from Appendix E, which serves to analyze noise, not opera�onal traffic safety. This table must also look at impacts to Storke Road and Glen Annie and Hollister Avenue between Fairview and Paterson. This analysis must also include planned CIPs, such as the Hollister Avenue striping project and the 217 ramp roundabouts. Without including these road segments in the analysis, the scope of this impact is unclear.
Roadway capacity analysis is cri�cal to understanding the impact of housing on the rezone sites and how that will impact current and future Goleta capital projects. Addi�onally, understanding the func�onality of Hollister Avenue and Paterson are essen�al to understanding the viability of access to Goleta Valley Cotage Hospital for emergency services.
3.14-58 Design Features
and Hazards
Add text explaining that in addi�on to MM T-3 (Funding and Mi�ga�on Fee Programs Update), a mi�ga�on measure requiring the execu�on of an MOU between the City of Goleta and the County to address the mi�ga�on fee program update.
3.14-59 MM T-1 Mi�ga�on measure MM T-1 cannot be required “as feasible.” This language makes the implementa�on subjec�ve and therefore unenforceable for ministerial projects.
3.14-59 MM T-1 Mi�ga�on measure MM T-1 must include reference to City of Goleta planned bike infrastructure, not just projects iden�fied in the County’s ATP .
3.14-59 3.14.4.4 Add a new mi�ga�on measure requiring the execu�on of an MOU between the City of Goleta and the County to address the mi�ga�on fee program, contribu�ons of impact fees to the City of Goleta, the provision of fair- share contribu�ons for City of Goleta capital projects (see also comment on Impact LU-2), and construc�on of public infrastructure improvements to mi�ga�on impacts to the transporta�on network as supported by Land Use Element Policies LU 1.13, LU 11, and LU 12 of the City of Goleta’s General Plan. The program, impact fee contribu�ons, fair-share capital projects contribu�ons, and construc�on of public infrastructure improvements will address impacts due to development that must rely on City of Goleta transporta�on network infrastructure. Without such analysis and mi�ga�on, the EIR does not adequately address and analyze this impact.
18 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
3.14-59 3.14.4.4 Sec�on 3.14.4.4 of the DPEIR details proposed transporta�on mi�ga�on measures. The mi�ga�on measures as presented in the DPEIR do not adequately address the need for safety improvement. Update this sec�on to include safety improvement mi�ga�on measures. At a minimum, address safety improvements at the intersec�ons of Cathedral Oaks and Glen Annie, Hollister and Storke, and Storke and Marketplace, and the street segments of Cathedral Oaks, east of Glen Annie and Paterson north of Hollister. These intersec�ons and street segments have all been iden�fied in the Goleta Traffic Safety Study as high collision loca�ons and must be adequately mi�gated in this DPEIR. Include detail in the DPEIR explaining that development on Rezone Sites 1-7 and 11 will increase traffic volumes at these intersec�on and roadways and will therefore increase the number of collisions at these high-collision loca�ons, thus jus�fying the need for safety improvement mi�ga�on measures.
3.14-61 MM T-3 This mi�ga�on needs to provide for the inclusion of the City of Goleta in this process and to create a mechanism to provide support for the City of Goleta to update and implement capital projects to accommodate the increased demands for City transporta�on projects for housing projects in the County that will rely on the Goleta transporta�on network.
3.14-61 MM T-3 The updated fees must include considera�on of the improvements needed in the City of Goleta, as that is where the impacts will occur for many of the rezone sites.
3.14-61 MM T-3 The �ming of this item must be brought forward as it is a cri�cal mi�ga�on measure. With the �meline currently outlined, this mi�ga�on measure cannot reduce Impact T-1 to significant but mi�gable.
3.14-61 MM T-3 The budget and work program must include this item in the first year. Otherwise, it is likely many projects will move forward without addressing the iden�fied impact.
Sec�on 3.15: U�li�es and Water Supply
3.15-34 Table 3.15-10 This table needs to be corrected to accurately reflect the severity of impacts analyzed in this sec�on.
Sec�on 3.16: Wildfire
3.16-35 MM WF-1 The language of the mi�ga�on needs to change, as shown, to ensure the mi�ga�on measure is objec�ve in nature and thereby applicable: “A larger setback shallmay be required if SBCFD determines that a greater distance is required for public and/or firefighter safety.” Chapter 4: Alterna�ves Analysis
Sec�on 4.3: Alterna�ves Selec�on Methodology
4-6 Alterna�ves
Selec�on
Methodology
An EIR’s statement of project objec�ves is the touchstone for selec�on of alterna�ves for evalua�on. (State CEQA Guidelines, § 15124(b).) The alterna�ves discussed must be able to atain most of the basic objec�ves of the project. (State CEQA Guidelines, § 15126.6(b).) Based on the comment below, the environmental analysis of the project needs to include feasible alterna�ves that meet the project objec�ves. Alterna�ves should consider other approaches to meet RHNA, such as further suppor�ng infill redevelopment, incen�vizing ADUs to a greater extent, and changing the affordability assump�ons for rezone sites to count all units towards lower and/or moderate income (as is allowed under state law) and then include fewer rezone sites.
19 Santa Barbara County Housing Element Dra� Program EIR – City of Goleta Comment Matrix (February 2024)
Page Ref. Doc. Reference Comments
Sec�on 4.5: Alterna�ves Considered and Analyzed
4.26–94 Alterna�ves 2-5 A�er running the “Balancing Act” online rezone site selec�on tool for each of the proposed alterna�ves, the North County subregion met and exceeded its RHNA targets for all income categories. However, for the South Coast subregion, only Alterna�ve 5 met its RHNA target for all 3 income categories. While the overall RHNA target plus 15% buffer is met for all 4 proposed alterna�ves, not mee�ng the South Coast subregion’s RHNA target for 3 out of 4 alterna�ves renders these alterna�ves inconsistent with the Project’s objec�ves. For the one alterna�ve (Reduced Project C) that s�ll meets the RHNA objec�ve, the only large sites adjacent to the City of Goleta that is not included for rezone is Site No. 1 (Giorgi). However, Giorgi has a builder’s remedy applica�on, thereby making the dis�nc�on between this alterna�ve and the proposed project insignificant.
Without viable alterna�ves, the analysis of the EIR is incomplete. 20 Attachment 2
Comment Letters on the County Housing Element and Rezoning from Councilmember Kyriaco (dated 3/28/24) and from Councilmember Kasdin (dated 4/1/24)
21 CITY COUNCIL
Paula Perotte
M<1'fO(
Luz Reyes-Martin
Mayor Pro T cmpore
District I
Stuart Kasdin
Coonolmcmbtt
James Kyriaco
Coonolmcmber
District 2
Kyle Richards
Coonolmcmber
CITY MANAGER
Robert Nisbet
CINOf~
GOLETA
March 28, 2024
Vincent Martinez, Chair
Santa Barbara County Planning Commission
County of Santa Barbara Planning & Development Department 123 East Anapamu Street
Santa Barbara, CA 93101
RE: Rezone Site Selection bordering Goleta City Council District 2 Dear Chair Martinez and Members of the Commission,
As the Goleta City Council representative for areas bordering the South Patterson Agriculture Block, including the Rancho Goleta Mobile Home Park and Old Town Goleta I would like to share a few thoughts ahead of your Monday April 1st hearing.
The combined North and South County Unincorporated area RHNA requirement mandated by the State of California and assigned by SBCAG was 5,664 units for an area stretching from Cuyama to Carpinteria.
According to the South County Balancing Act Tool, the rezones proposed by your staff would lead to as many as 3,634 new units on the City of Goleta's border, and 2,634 of them on the border of Goleta City Council District 2.
• St. Athanasius: 300 units
• Caird (Caird 1-3 + Ekwill): 876 units
• Scott: 246 units
• Giorgi aka The Orchard: 1212 units
Total: 2,634 units or 46.5% of the Countywide RHNA requirement That's nearly 47% of the entire county unincorporated area requirement, located on sites next to my district, all of which are placed in a state designated SB 535 disadvantaged area.
That would most assuredly affect city roads, infrastructure and 130 Cremona Drive, Suite B, Goleta, CA 93117 , 805.961.7500 F 805.685.2635 www.cityofgoleta.org 22 disproportionately my constituents.
By contrast when Goleta completed its own housing element process in early December of 2023, our City Council placed no housing sites on county borders that would affect county roads or infrastructure.
Done right, you can plan in a way that helps my community and provides them with a diversity of housing choices and community benefits. We need more housing and better housing, but especially affordable housing.
Done wrong, and choices will disproportionately impact one of the few working class, diverse communities we have on the South Coast, Old Town Goleta.
I would ask for Planning Commissioners to consider location but also two other factors - Affordability and Community Benefit- when deciding which properties to rezone, recognizing you don't have the flexibility promised earlier in this process.
Affordability. There is a significant gap between what the County is planning for, in terms of affordability, and what developers suggest is feasible. A compromise is in order.
I would suggest challenging developers in the Goleta area to at least match the 30% low and very low-income housing provided at Heritage Ridge in the City of Goleta.
Heritage Ridge is a new 332-unit housing project that will provide affordable housing and a new public park.
Instead of a 20% affordability ceiling there should be a 30% affordability floor, with a mix of that being for both lower income and moderate-income households. For every two units that are priced for as much as the market will allow, developers should be willing to provide one housing unit for our teachers, nurses, public safety personnel and other members of our workforce that make this community so special.
Community Benefit:
Rezoning will lead to new projects contributing millions - perhaps tens of millions - of dollars in development fees to the county. The county will receive millions more in new property tax and new sales tax revenues. Meanwhile the City of Goleta will receive no property tax revenue from this new housing, and little if any sales tax benefit because of the County/City Revenue Neutrality Agreement.
A provision of Goleta's own Housing Element calls for us to follow principles of Affirmatively Furthering Fair Housing, making needed financial investments in services and infrastructure to disadvantaged areas of our city when adding housing in these areas. In that spirit I would ask that developments approved by the County that are located in the South Patterson Ag Block in a Disadvantaged Area should be prioritized based on their willingness to provide benefits for the surrounding community not just the new residents these developments will attract.
CITY Of
GOLETA 130 Cremona Drive.Suite B,Goleta, CA 93117 , 805.961.7500 • 805.685.2635 www.cityofgoleca.org 23 Goleta's Project Connect, which is just beginning construction, will add new roundabouts, multi-modal bike pedestrian paths, a new east-west route through Old Town, and a bridge replacement across San Jose Creek. These improvements are being paid for by city funds, with support from State and Federal partners. I am not aware at this time of any promises from any of these developers to contribute towards this new infrastructure or to provide enhancements. One project (The Orchard) has openly touted the roundabouts as being a reason to pick their site.
The roundabout was supposed to serve communities like the seniors living at Rancho Goleta Mobile Home Park on Ward Drive, and the low-income residents living at Sumida Gardens across from the Ag Block on the North side of Hollister, or the Villa La Esperanza apartments on South Kellogg Avenue.
The Giorgi Family - the landowners behind the Orchard Project saw the roundabout as an opportunity for themselves. Rather than offering to contribute towards the costs of constructing the roundabout adjacent to their property, and knowing the City of Goleta was under tight deadlines to begin construction they took advantage, leading Goleta to pay $162,500 along with conveyance of some extra land so we could complete the roundabout, which their representatives now tout as a key reason to pick their project.
We had to pay them to make their project more feasible.
The Orchard is located on Prime Agricultural Soils and is home to lemon orchards that are an important but increasingly diminishing part of Goleta's identity.
The Orchard is disproportionately, compared to the other projects, benefiting from the city's soon to be constructed infrastructure without contributing towards it. The commercial offerings on their site along Hollister - a market, a bakery, and a coffee shop would compete with existing Old Town businesses like Goleta Bakery, Santa Cruz Market and Old Town Coffee. I had hoped the Giorgi representatives would at least agree to use some of their Hollister Avenue frontage to put in a pharmacy, something Old Town lacks. They told me a pharmacy would be too big and would require too much parking.
As of right now I would ask that this one project come out, which would still place as many as 1,422 units of development from other projects on my city council district border, or 25% of the countywide 5,664-unit requirement. While still a lot of housing for such a small area, the other projects provide community benefits and diverse housing options that will enhance and support Old Town without as much risk of gentrification.
The sites you select for rezones will in effect become your partners in planning. I would take care in choosing who you select as your future partners. 1 would urge you to go forward with the other projects bordering my district - such as the Caird project - that offer the most community benefits and needed housing while withholding for now the Orchard Project in favor of other non-Builder's Remedy Projects.
Time is short, and both precision and fairness are critical. Failure to plan properly in either South or North County can lead to loss of local control for the entire Cl1Y Of
GOLETA 130 Cremona Drive, Suite B, Goleta, CA 93117 ,. 805.961.7500 F 805.68S.2635 www.cityofgoleta.org 24 unincorporated county. Please plan carefully and fairly for the entire county, including the disadvantaged communities I represent.
¾
Sincerely, r
ilmembe, Y
Kyriaco
City Council
cc: Laura Capps, 2nd District Supervisor; Joan Hartmann, 3rd District Supervisor OlYOf
GOLETA 130 Cremona Drive.Suite B,Goleta,CA 93117 , 805.961.7500 F 805.685.2635 www.cityolgoleta.org 25 CITY COUNCIL
Paula Perotte
Mayor
Luz Reyes -Martín
Mayor Pro Tempore
District 1
Stuart Kasdin
Councilmember
James Kyriaco
Councilmember
District 2
Kyle Richards
Councilmember
CITY MANAGER
Robert Nisbet
April 1, 2024
Vincent Martinez, Chair
Santa Barbara County Planning Commission
County of Santa Barbara Planning & Development Department 123 East Anapamu Street
Santa Barbara, CA 93101
Dear Chair Martinez and Members of the Commission,
I offer comments, speaking on my own behalf, for the Planning Commission meeting concerning the County Housing Element. In this letter, I want to focus on two questions, the traffic impacts resulting from the proposed rezones and the amount of financially accessible workforce housing.
When I have considered the County’s housing element proposed rezones, I have wondered how they would be able to manage these changes without either bearing massive mitigation expenses or reducing the size or density of their projects. For example, consider the Glen Annie Golf Course proposed housing project. The proposal to rezone the Glen Annie golf course would add up to 800 units (close to 7% of Goleta’s current housing).
• It would seem to require that Cathedral Oaks become a multi-lane road, more like Hollister, if that is even feasible.
• The proximity of the new housing to the Dos Pueblos high school especially would make the intersection into a dangerous and even more congested site, especially in the mornings and afternoons.
• It would make an already heavily congested 101 highway northbound offramp extremely unsafe, by exacerbating the traffic already backed up along the highway.
• It would further congest the Hollister-Storke intersection, which is already the most congested Goleta intersection.
If like me, you wondered how the county would overcome these challenges, waiting for some answers, the other shoe has now been dropped. As the Commission considered the rezones and EIR for North County, County staff added something not studied in the EIR. They are proposing to remove level of service standards, which are part of the County’s Circulation Element of the County’s Comprehensive Plan, specifically just for the housing rezone sites.
DocuSign Envelope ID: 333CB9F9-C150-44DF-9BC1-E02B77BDDA8C 26 From the staff report, the county staff are proposing to add a new exemption from roadway and intersection standards for specified housing sites indicating that, “However, a project shall not be required to fully offset its impacts if doing so would render the project infeasible or require a reduction in density. If roadway and intersection improvements required to meet LOS standards and fully offset its impacts are infeasible [such as because they were too expensive], the project shall be required to implement roadway and intersection improvements to address LOS acceptable to the Public Works Department.”
In short, the county proposes to approve projects without reducing the project density when the traffic impacts cannot be readily mitigated and if the cost for the mitigation would make the project economically infeasible, according to the project developers. Instead, the county would abandon any objective standard for the level of mitigation that must be accomplished. Instead County Planning proposes to allow Public Works staff to determine those improvements that seem acceptable according to some subjective assessment of the Public Works Department, with the concurrence of the developers.
Costs of mitigation deemed too high by Public Works, such as requiring adverse possession, would be forgone -- and Public Works could just accept that the adverse traffic impacts are acceptable, seemingly not subject to review.
Such a process leaves unanswered, many safety concerns questions: How will all those added vehicles endanger Dos Pueblos high school students on e-bikes, for example? Or what happens when traffic is backed up on the freeway exit making an unsafe situation even more dangerous – who anticipates stopped cars on the freeway? Cathedral Oaks was not built for this extra volume of cars – what happens to Cathedral Oaks traffic generally, one of only 3 East- West roads traversing the Goleta Valley? Apparently, the answer from the county staff is to proceed with the projects without maintaining reasonable traffic circulation and protecting the safety of the public. This answer can hardly be considered an unacceptable solution for the residents of Goleta and the area.
In 2009, the county staff (LAFCO) observed that “Staff believes that the Glen Annie golf course fits the criteria for inclusion in a Sphere for Goleta. All of the traffic associated with the golf course and facilities must travel through the City. Delivery vehicles, customers, employees, etc. must traverse City streets; all the while the City receives no taxable revenue or land-use oversight.” In 2009, the county expressed concerns about adding housing to the Glen Annie golf course, in part due to its impacts to Goleta. In 2024, the county staff just does not care.
The second question I want to discuss is housing affordability. We spend a lot of time discussing the below-market-rate housing, but I want to point out that not all market-rate housing is the same. Some types of housing will be more attainable as workforce housing than other types of units.
Consider the Glenn Annie Golf course proposal again. They are proposing to build not just apartments and condos, but townhouses and single-family homes.
Those single-family homes, as the project is now designed won’t be attainable for any but the very wealthy. They seem to be creating Little Montecito or Hope Ranch. Many of the single- family houses will have ocean views. All will get ocean views from areas around the parks and so forth. The housing at the site is going to be surrounded by an array of amenities, like a pool, trails, and pickleball. (Glen Annie (imagineglenannie.com). The amenities are spread all about the complex. They are diverse. What all these amenities will do is to make the housing more expensive. Will the homes be $5 million? More? The market rate housing will not be workforce housing, unless the workforce is CEOs and doctors.
DocuSign Envelope ID: 333CB9F9-C150-44DF-9BC1-E02B77BDDA8C 27 J
ust because people say a home is workforce housing does not make it so. For example, the Marc, an 89-unit apartment complex in Santa Barbara, was the first project to receive the high- density-zoning bonuses aimed at creating apartments that were affordable by design. In practice, the Marc offered abundant amenities -- lots of interior open space, rooftop gardens, fire pits, a pool, and bocce ball courts – catered to people at the higher end of the income scale, and charged significantly higher than market-rate rents. The Marc’s marketing campaign in 2019 included brochures boasted that more than half the residents made more than $150,000 a year and 22 percent brought home more than $200,000. The Glen Annie market rate homes are designed to be expensive, based on its size and amenities; it will not affordable for the workforce of average workers.
That
brings me to a related concern. We don’t have that many CEOs and doctors looking for houses in the area. If you look at who moved into a lot of these expensive neighborhoods, you’ll see they recruit from out of the area. Expensive homes require out-of-town buyers. Obviously, it will not help our workforce housing concerns if people out of the region are buying homes here.
The s
ingle-family housing being proposed is not likely to help with the housing crisis in the Santa Barbara region. Duplexes and apartments can help with our housing needs; none of the single-family housing and townhouses are not likely to benefit the region.
O
f course, this same discussion is relevant for other projects elsewhere. The types of housing in a project matters. The more apartments with studios and 1 bedroom apartment, or even better with single room occupancy/micro units, the better the potential for affordable housing.
Ther
e is a cost to the community in converting the agricultural areas and open spaces. Let’s try to limit those costs and let’s make sure there is a benefit.
Thank
you,
S
tuart Kasdin
Councilmember
c
c: Members of the Board of Supervisors
DocuSign Envelope ID: 333CB9F9-C150-44DF-9BC1-E02B77BDDA8C 28