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Chris cruse
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Chris cruse; Ayala. Jose@HCD
city council meeting 3/21/23 #2 Implementation of the Poway General Plan Wednesday, March 15, 2023 4:12:46 PM
EXTtR1 AL BMAIL
City Councilmembers,
The agenda report for item #2 states: "
The projects and programs were determined to be
consistent with the goals, policies, and strategies of
the Poway General Plan; therefore, progress was
made in the implementation of the General Plan."
I disagree that all of the programs and policies, and, in particular, the adopted housing element, is consistent with the strategies of the Poway General Plan.
This letter is not meant to be an exhaustive discussion of all of the inconsistencies, but I will highlight a few of the inconsistencies as they relate to the BSL.
Poway's adopted housing element shows that without any input from the public, the council has designated the Big Stone Lodge parcels for 29 units of hi-density housing. This is despite the fact that the city asked the state to let them keep this former redevelopment parcel to be used as a passive historic park, which the city said was the highest and best possible use.
The parcel itself was designated as a an historic park, as well as the Big Stone Lodge being designated as a historic building.
The parcel is in the flood plain and the floodway. The only road accessing the parcel is also in the flood way and flood plain and is not an "all-weather access road". The adjacent parcels are mitigation parcels with easements. Both the adjacent parcels and the BSL parcels have riparian habitat on them and the BSL parcels have an old oak grove on them. The parcels are in the high fire area, and in Poway;'s habitat area and are a wildlife corridor.
Below are statements from Poway's General Plan which highlight the inconsistency with changing the use of the BSL parcels to housing:
"It is the goal of the City of Poway to preserve its natural, scenic and cultural resources for the future benefit and enjoyment of its residents and to protect biological and ecological diversity."
"Development should be sited to avoid potentially hazardous areas and environmentally sensitive areas such as land known to contain large concentrations of Friars Formation, 2 ofS March 21, 2023, Item #2
landslides, faults, and valuable biological resources such as riparian corridors, mixed chaparral and costal sge scrub."
"land within the 100 year floodplain shall be designated for low density residential or open space uses."
"Development within the 100 year floodway is prohibited." "Development in the 100 year floodplain may be approved if the following conditions are met:
All structures, both permanent and temporary, must be raised one foot above the 100 year flood level;
Information certifying the 100 year flood level must be submitted by a qualified civil or hydrological engineer;
All-weather access must be provided to all developments or divisions of land, residential units, commercial buildings, manufactured buildings, or public buildings; Information certifying that no upstream or downstream changes to the 100 year floodplain will occur must be submitted by a qualified civil or hydrological engineer." Note: Old Pomerado Rd is also in the flood way and flood plain and is not an "all-weather" access road.
"Policy A-Scenic Areas
Scenic areas, prominent vistas and open space areas that typify Poway's rural history and image should be preserved and protected through appropriate land use polices." "Policy B-Waterways
The natural character of creeks and channels should be maintained or restored to the greatest extent possible with consideration for maintaining adequate flood protection." "1. Development, including roads, should be set back from riparian corridors a minimum distance of 50 feet, or sufficient distance as determined by a qualified biologist to avoid damage to those areas. These riparian corridors and associated buffer areas should be designated as permanent natural open space easements and the buffer area should be vegetation
Note: A multi-family development uphill and adjacent to the BSL parcel has a buffer area to protect the riparian habitat on the BSL parcel that is identified for hi-density development on the housing element.
"Grading for development shall not increase the natural rate of erosion or cause siltation in stream channels."
"Policy C-Biological Resources"
"Wildlife and natural plants are a valuable resource and should be preserved and protected." "1. The acquisition and dedication of undeveloped land adjacent to and between existing dedicated open space areas is encouraged to promote large contiguous areas necessary for watershed, habitat and viewshed protection. If private development is required to purchase and dedicate land to mitigate environmental impacts, the acquisition of areas adjacent to existing large, permanent open space areas is preferred."
"2. Biological corridors shall be preserved in order to provide linkages for vegetative and wildlife communities between nonconnective open space areas. " 3 ofS March 21, 2023, Item #2
Note: several trail systems also connect on the BSL parcel. "3 Development should not disrupt habitats considered to be sensitive, or the habitat of sensitive, declining, threatened or endangered species. " "5. Access of humans and domestic animals to preserved biological habitats and sensitive biological areas shall be limited as deemed necessary to preserve the integrity of the areas." "13 Development proposals shall consider areas determined to be particularly valuable to wildlife, as identified for each quadrant of the City in the Detailed Biological Assessment.
Efforts should be made to minimize encroachment in those areas." "14. Plant resources, particularly, large expanses of undisturbed natural areas, oak woodlands, riparian corridors, significant tree stands and sensitive, declining, threatened and endangered species should be preserved through appropriate means such as buffering and dedicated open space."
"Policy E-Historical Sites"
"4. Maintain appropriate legislation to apply alternative building code requirements as deemed necessary on an individual basis to preserve historic structures. The City shall also maintain appropriate legislatio prohbiting the demolition of an historic structure without evaluation of the condition of the structure and the costs ofrehabilitation." "7. Mitigation of impacts to significant or sensitive historic tructures may be accomplished by moving the structure to a new location within the city. YThis location should be similar in setting to the original site, depending upon the uniqueness of the site. " Note_ The only site unique enough for the Big Stone Lodge, is the Big Stone Lodge parcels which also have been designated with historical status. "8. Historic structures or places should not be designated for land uses that would lead to their demolition or to a depreciation in their value. Adjacent land uses should not conflict with the preservation of an historic structure or place."
Housing Element Update
The city seems to be making exceptional progress on meeting the above-moderate RHNA quotas for this housing cycle. In fact, million dollar condos are being built on Poway Rd on parcels that were rezoned, specifically so that the city could meet housing densities necessary to build low, very low and moderate housing. The rezoning has simply made an opportunity for developers to profit from higher density houses for the wealthy.
Poway has just about built all of their RHNA obligation for above moderate housing within the first 2 yrs of the 9 yr housing cycle. The recent developer proposal for Harmon's Ranch which is now past the scoping for the EIR stage, will put an additional 64 above-moderate 4 ofS March 21, 2023, Item #2
houses in development. The developer of this project is asking for all kinds of development concessions to build more houses with reduced setbacks and street widths and no sidewalks on one side on RS-7 parcels. The proposal is very similar to the state bonus density law which allows a developer to sidestep local laws and zoning requirements, in return for building deed r~stricted affordable units. However, the developer of the Harmon Ranch project is not building any affordable units, and the city seems to be going along with this project even though it is inconsistent with Poway's general plan and zoning requirements.
No moderate.income housing units have been built or are in the planning stages except for ADUs. I agree that some moderate income individuals may possibly rent ADUs, although I don't believe there has been a survey done to ascertain how many ADUs are actually rented out (for non BNB uses) or how much the are. In general, ADUs are not sized for families.
They usually do not have that many bedrooms. I am concerned that housing that moderate income families can afford to buy is just not being built in Poway. Even new rental housing for moderate income families does not seem to be a part of meeting the RHNA. Why not? Why did we rezone all that property to price everyone but the wealthy out of the market? One low-income project has been built-but it is also not for families. It is for seniors. The previous project was for disabled adults, a worthwhile project, but it is not for families, it is for individual disabled adults. Poway also has accepted a proposal to build a second project for disabled adults and veterans. THe veterans side of the project might possibly rent to some low income veteran families, but in general, there seems to be an effort to ignore the housing needs of moderate or low income families in Poway. Poway still needs to build 454 of 468 very low income units, and 197 of 268 low income units. I do not think that the moderate, low and very low income units for families are sufficient to meet the RHNA, and I do not think the way they are not being done in Poway furthers fair housing.
Sincerely,
Chris Cruse
5 ofS March 21, 2023, Item #2