Importantly, the current plan to improve pedestrian and cyclist safety has not been implemented, and construction is not expected to begin until 2027. Meaning, the proposed Project would add strain on both vehicles in the areas and increase the number of pedestrians and cyclists on site in an area with existing safety concerns.
Coupled with the fact that construction of the Project may result in road closures and detours, the Project may have significant traffic impacts which should be assessed in an EIR pursuant to CEQA Guidelines section 15064.3.
Although the Staff Report provides that the Project would result in a small increase in daily trips, the modeling data was not provided to confirm the assumptions made for the model. Additionally, the dramatically reduced available parking essentially relies on alternative modes of transportation, such as bicycles, that have currently limited accessibility in the neighborhood. Essentially, the alternative modes of transportation operate as a mitigation measure for the Project’s estimated traffic impacts. It is well established that “whether a project is eligible for a categorical exemption” should be decided “without reference to or reliance upon any proposed mitigation measures”.
Salmon Protection & Watershed Network, 125 Cal.App.4th at 1106. Accordingly, traffic modeling that has been performed cannot reliably overcome the Project’s disqualification for a Class 32 exemption due to its potentially significant traffic effects.
b) The Project May Cause Significant Noise Impacts
The Project site is next to residential areas to the East and North, as well as Santa Barbara Jr. High School. The Staff Report has failed to provide any analysis on the Project’s potential impacts on these nearby sensitive users, especially considering the proposed demolition and construction activities.
The City is required to present substantial evidence to support its findings under CEQA. Until noise modeling has been provided, the City cannot make a finding of no significant noise impacts with the substantial evidence required by CEQA.
Section 15384(a) of the CEQA Guidelines notes that substantial evidence means “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, . . .” Simply stating that the Project would not have a noise impact does not meet the evidentiary burden under CEQA. As there are nearby sensitive users that may be impacted due to the planned demolition and construction, the Class 32 exemption is improper. The City must prepare noise modeling for the Project and determine potential mitigation measures City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
necessary to reduce noise impacts.
c) The Project Site May Not be Adequately Served by All Utility Services
Yet another reason why the Class 32 CEQA exemption is inapplicable is because the Project site may not be adequately served by all utility services. CEQA Guidelines § 15332(e). Per the Staff Report, “All required utilities and public services are available.” (Staff Report, p. 10.) Yet, no evidence is provided to support this claim. As noted above, the City must support its findings with substantial evidence. At the very least, will-serve letters from the area utilities are necessary to establish that adequate service exists in the area and that the Project would produce significant strain. Without any supporting evidence, the City must study and quantify the Project’s anticipated utility use in an EIR to determine whether it can be adequately accommodated. d) The Project May Have Cumulative Impacts
Pursuant to CEQA Guidelines section 15300.2(b), all exemptions “are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant.” Here, the Project application fails to identify any projects within 0.5 miles of the Project site. The City also does not have a publicly available development map. However, the Multi-unit Housing Program Project’s map establishes over a dozen projects in the neighborhood surround the Project.
City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
The Project, along with the other nearby projects, collectively contributes to potentially significant cumulative impacts on air quality, noise, and traffic congestion in the area, and collectively burden utilities and public services’ ability to adequately serve the Project site. For this reason, too, the Class 32 CEQA exemption is not applicable.
IV. THE PROJECT’S RELIANCE ON THE HOUSING
ACCOUNTABILITY ACT AND BUILDER’S REMEDY DOES NOT
EXCUSE THE PROJECT’S INCONSISTENCIES WITH THE
GENERAL PLAN
Though the Project seeks approval under the Builder’s Remedy, there remain outstanding conflicts with the City’s General Plan and Zoning Code. As such, the Project cannot be deemed approved until the plan has been brought into compliance with the General Plan and Zoning Code.
A. Background on the Housing Accountability Act and Builder’s Remedy City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
The California Housing Accountability Act (“HAA”) provides the “builder’s remedy,” to developers of affordable housing projects. Here, Project are subject to the zoning and general plan that existed at the time the preliminary application was submitted.
Per California Government Code section 65589.5(d)(1)-(5), the following exceptions that would render the builder’s remedy inapplicable:
(1) The city has a substantially compliant housing element and has met or exceeded its share of regional housing needs for the types of housing the project would provide.
(2) The project would have a specific, adverse impact upon the public health or safety, and there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact without rendering the development unaffordable to low- and moderate income
households or rendering the development of the emergency shelter financially infeasible.
(3) The project’s denial or imposition of conditions is required in order to comply with specific state or federal law, and there is no feasible method to comply without rendering the development
unaffordable.
(4) The project site is zoned for agriculture or resource preservation or lacks adequate water or wastewater facilities to serve the project. (5) The project is inconsistent with the city’s zoning and land-use designation of its general plan (as of the date the application was deemed complete), and the city has adopted a revised housing element in accordance with Section 65588 that is substantially compliant.
Importantly, HAA does not relieve the agency from the duty to comply with the CEQA. (Gov. Code Sec. 65589.5(e).)
Similarly, HAA does not prohibit an agency from disapproving a project that is inconsistent with the objective, quantifiable, written development standards, conditions, and policies of the area, such as allowable density. (Gov. Code. Sec. 65589.5(f).) HAA defines the term “disapprove” narrowly to mean either when an agency votes on a proposed housing development project application or fails to meet the timing requirements to determine that the application is complete. (Gov. Code Sec. 65589.5(j)(6).) Critically, the written findings required for the City to disapprove a project must be made only by a preponderance of the evidence. Further, any findings City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
of consistency with the applicable standards must be made with substantial evidence. (Id.)
Finally, Government Code Section 65598.5(o) provides additional exceptions and requirements to qualify for HAA protections, such as providing all required information, noting that Project’s must conform to the ordinances, policies, and standards adopted and in effect at the time of submitting the preliminary application, and highlighting that the Project must still comply with CEQA.
A. The Project Does Not Comply with the Housing Element Here, the Project is not entitled to the Builder’s Remedy procedure outlined in the HAA, Cal. Gov. Code Section 65589.5, because the Project is not compliant with the City’s Housing Element or Zoning Code.
Thus, the City of Santa Barbara should not have deemed the Project “complete” absent an appropriate determination of whether the “Builder’s Remedy” procedure applies, supported by the necessary supporting evidence. The City’s “completeness” determination is further brought into question and undermined by the most recent Project information and description, which reveal that the Project does not achieve the number of units required by the City’s own General Plan for senior and lowincome housing. Indeed, the Project in its current configuration would require an Amendment to the City’s General Plan.
Further, the City should determine that an exception to the “Builder’s Remedy” procedure applies to the Project due to the inconsistencies with the City’s General Plan and Zoning Code as outlined Government Code Section 65589.5(d)(5).
The biggest inconsistency lies with the discrepancy in affordable units as compared to the City’s Housing Element. The Project will now provide fewer low-income units than originally included in the Housing Element inventory. (Housing Element, p. 111.) Specifically, the most recent Project Description outlined in the Planning Commission’s Staff Report provides for only nine (9) low-income units whereas the City’s Final Housing Element accounts for thirteen (13) low-income units for the same Project. The discrepancy of four (4) low-income units less than originally proposed is significant because the City will have an underproduction of affordable housing.
Similarly, the City must consider the Project’s potential negative impact on the availability of affordable housing units for seniors. The Project Site’s existing use is City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
designated as “vacant commercial” and “senior housing,” with a total of eight (8) units currently being used as “senior units.” (Staff Report, p. 5; Affordable Housing Policies and Procedures Manual, p. 27.) Critically, the Project proposes eliminating all eight (8) senior units without providing any suitable replacement. This reduction in available senior housing is in direct conflict with the Housing Element Policy 1.9, which outlines the City’s commitment to increasing senior housing as the population continues to age. (Housing Element, p. 124.) Removing these senior units without any replacement results in Project non-compliance with the City’s General Plan.
B. The Project Relies on More Incentives/Concessions than what the City’s Density Bonus Allows
The Project relies on more than the allowable number of incentives and concessions to argue its General Plan consistency. Specifically, the number of granted concessions failed to consider the reduction in senior housing and discrepancy with the Housing Element inventory. Here, the Project results in a total reduction in senior housing associated with the demolition of the existing 8 units. Further, the Housing Element inventory included the Project as producing 13 units for low-income housing. Instead, the applicant now seeks to produce only 9 units of low-income housing. These discrepancies, thus, result in an underproduction of affordable housing that does not meet the requirements of the Housing Element. As such, the Project should not be entitled to any concessions or incentives, or at least less than the three concessions stated in the Staff Report.
(City of Santa Barbara Density Bonus Program Handout, p. 2.) City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
Further, the Project already seeks three incentives/concessions along with an additional waiver. However, the Staff Report notes that the Applicant “stated on project plans submitted in December 2024 [that] the project also reserves the right to waive the purported commercial vehicle loading space requirement and any associated vertical clearance within the parking area identified by public works.” (Staff Report, Footnote 7.) If the Applicant seeks these additional two concessions/waivers, the Project will have at least 6 areas that depart from the City’s Zoning. As such, the Project is clearly not compliant with the City’s Zoning code and must be revised rather than rely on an excess of incentives and waivers.
V. Project Has Not Demonstrated Compliance with the Project Compatibility Findings
As acknowledged by the ABR in its April 1st Agenda, the Project requires compliance with the “Project Compatibility Findings” outlined in the Santa Barbara Municipal Code (SBMC) Section 30.220.020.F, which specify that the Historic Landmarks Commission must consider the following findings “when it reviews and approves or disapproves the design of a proposed development project in a noticed public hearing:”
a. Consistency with Design Guidelines. The design of the project is consistent with design guidelines applicable to the location of the project within the City; b. Compatible with Architectural Character of City and Neighborhood. The design of the project is compatible with the desirable architectural qualities and characteristics which are distinctive of Santa Barbara and of the particular neighborhood surrounding the project;
c. Appropriate Size, Mass, Bulk, Height, and Scale. The size, mass, bulk, height, and scale of the project is appropriate for its location and its neighborhood; d. Sensitivity to Adjacent Landmarks and Historic Resources. The design of the project is appropriately sensitive to adjacent Federal, State, or City Landmarks or other nearby designated historic resources, including City structures of merit, sites, or natural features;
e. Public Views of the Ocean and Mountains. The design of the project responds appropriately to established scenic public vistas; or
f. Use of Open Space and Landscaping. The project includes an appropriate amount of open space and landscaping.
City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
However, as made clear during the recent Planning Commission meeting on March 20, 2025, there are various legitimate concerns regarding whether the Project adequately complies with the aforementioned findings. For instance, the Meeting Minutes document concerns raised by Commission members regarding several of the Project’s physical design characteristics as well as their compatibility and harmony with the overall neighborhood. Specifically, the Commission expressed concerns regarding the Project’s design features, including: the “spread” and “mix” of “affordable units,” the “mass of the tower,” “architecture still needs review… in particular, needs something in the form of fenestration, detailing , or other architectural treatments to make it more interesting,” “prefer unbundled parking be required,” “more landscaping… to soften impact of building” and “landscaping needs to be worked on,” and “livability of the units in terms of light and air,” among other concerns. Thus, the Project’s current design features must be revised to appropriately address these concerns by the Commission and achieve compliance with the Project Compatibility Findings.
VI. Project Has Not Demonstrated Compliance with the Urban Design Guidelines
The ABR has also acknowledged that the Project requires compliance with the City of Santa Barbara Urban Design Guidelines, which “address the historic character, pedestrian-friendly qualities, and exemplary architecture of the urban grid of Santa Barbara.” The purpose of these Guidelines is “to ensure that new development projects in the City reflect… core community values” and “provide direction to decision makers, design professionals, and the public regarding site planning, building, landscaping, and infrastructure design.”
For many of the same reasons listed in the previous section, there are legitimate and significant concerns regarding whether the Project would be inconsistent and out of compliance with the Urban Design Guidelines. First, the Guidelines generally require “compatibility with the character of the City, the surrounding neighborhood, and adjacent properties.” However, during the March 20 Planning Commission meeting, Commission members raised concerns regarding the compatibility of the Project’s current design with the City’s architectural character, including noting that Project’s “architecture” and “landscaping” still need “review” and “to be worked on,” respectively. Second, the Guidelines also emphasize compatibility of a Project’s “structures” with the “existing environment.” Here, however, the Commission also City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
noted concerns with specific Project structures, including the “tower,” “archways,” “the north elevation,” and “story poles.” Third, the Guidelines similarly also emphasize “compatibility” of a Project’s “landscaping” with the “existing environment.” Here, however, Commission members specifically noted concerns regarding the Project’s “landscaping,” including that “more… should be included… to soften the impact of the building.” Thus, it appears highly likely that the Project’s current landscaping configuration would not be compatible with the existing environment as required by the Guidelines. Fourth, the Guidelines further require that “new developments should demonstrate consideration of building composition and detailing with the goal of achieving a human scale environment.” However, the Project’s compliance with achieving a desirable “human scale character” appears dubious. For example, the Commission noted issues with the Project’s design and features that impact pedestrian and human mobility and interaction, including “views from Haley St. and Alisos St.,” “livability of the units in terms of light and air,” and a need to “de-institutionalize the project design.” Lastly, as a final example, the Guidelines also require that “every effort must be made to design automobile parking facilities so that they contribute to , rather than detract from, the pedestrian life of the street.” Yet, the Planning Commission indicated several reservations regarding the Project’s current parking features, including that “the Commission would prefer unbundled parking,” needing to “explore arrangements with nearby business for additional parking,” and potentially “limiting use of "commercial loading zone… to daytime hours so they could be used as parking spaces at night.” The concerns raised by the Commission members clearly indicate a need to revise the Project in compliance and consistent with the Urban Design Guidelines.
VII. Project Has Not Demonstrated Compliance with the Haley-Milpas Design Guidelines
Finally, the ADR has acknowledged that the Project requires compliance with the Haley-Milpas Design Guidelines. However, several of the Project’s current design features are likely inconsistent with these Guidelines and should be revised accordingly with the aim of achieving compliance. First, the purpose of the Guidelines is identified as being “to assist the people in the Haley-Milpas area in improving the appearance of their property.” While the Guidelines are largely comprised of general recommendations and suggestions that are not legally binding on a Project, they emphasize an overarching imperative for the City of Santa Barbara of ensuring that a City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
Project is consistent with and in harmony with the existing environment and adequately considers its impacts on that physical environment. For instance, the primary Guideline requires “awareness” that includes an “understanding of the environment” and “becom[ing] familiar with the neighborhood,” including its “architecture.” Further, regarding “design concepts,” the Guidelines emphasize “harmony” as “probably the single most important consideration in the planning of a project for an established area” as well as “scale” as “the size and proportion of a building and the building’s detail which relate to human physical dimensions.” Beyond that, the Guidelines also emphasize “rhythm,” “proportion,” “landscaping,” “parking,” “paving,” “color,” “signage,” and “maintenance.” Here, however, the Project’s present design features appear to be in conflict, or at minimum inconsistent, with these principles.
Beyond being mere suggestions that a Project applicant may consider, the City should require that the Project be revised to appropriately address and emulate the important principles outlined in the Haley-Milpas Design Guidelines. Requiring compliance with the Haley-Milpas Design Guidelines will ensure that the Project achieves harmony with the existing environment and is conducive to human access and utility.
VIII. CONCLUSION
The WSRCC request that the City require a local workforce, that the City impose training requirements for the Project’s construction activities to prevent community spread of COVID-19 and other infectious diseases. WSRCC additionally requests that the City reject the use of a Class 32 Exemption for the Project as there are significant and cumulative impacts associated with the Project that must be explored and mitigated through an EIR. Further, WSRCC raises significant concerns surrounding the Project’s General Plan consistency and use of density bonus incentives and waivers in connection with the builder’s remedy application. These issues must be resolved before the Commission can make any recommendations on the Project. If the City has any questions, feel free to contact my Office.
Sincerely,
City of Santa Barbara – 418 N Milpas St. Project
April 14, 2025
____________________________
Omar Corona
Attorneys for Western States Regional Council of Carpenters Attached:
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).
February 13, 2025
Ginger Andersen, Land Use Planner
Brownstein Hyatt Farber Schreck, LLP
Sent via email: [email protected]
SUBJECT: CONSISTENCY REVIEW FOR 418 N. MILPAS STREET & 915-923 E. GUTIERREZ STREET; PLN2024-00156
Dear Ms. Andersen:
On October 25, 2023, the City of Santa Barbara (City) accepted your SB 330 Housing Project Application and Pre-Application Review Team (PRT) application (PRE2023-00148) for a proposed mixed-use/ housing development project at 418 N. Milpas Street (APN 031-311-034) and 915-923 E. Gutierrez Street (APN 031-311-034) (Project).
On November 17, 2023, the City provided a PRT comment letter confirming the preliminary application was submitted as of October 25, 2023 because that submittal included all items required pursuant to Government Code section 65941.1(a).
On April 22, 2024, you submitted to the City a formal Planning Application (PLN2024-00156) related to the October 25, 2023 preliminary application submission.
On May 22, 2024 the City provided an Application Completeness Letter (Review #1) deeming the application incomplete as required items from the City’s Planning Application Submittal Packet were missing from the formal development application.
On August 16, 2024, you resubmitted the formal Planning Application to the City related to the October 25, 2023 preliminary application submission.
On September 20, 2024, the City provided an Application Completeness Letter (Review #2) deeming the application incomplete as required items from the City’s Planning Application Submittal Packet were missing from the formal development application.
On December 18, 2024, you resubmitted the formal Planning Application to the City related to the October 25, 2023 preliminary application submission.
On January 17, 2025, the City provided an Application Completeness Letter (Review #3) deeming the formal development application complete with regard to basic application components.
PROJECT DESCRIPTION:
The project involves the merger of two lots (APN 031-311-033 and APN 031-311-034) to create a 41,477 square foot (0.95-acre) lot, demolition of all onsite improvements (5,095.2 square feet of nonresidential floor area, and 8 residential units), and the construction of a new four-story, 108,698 square foot (gross) mixed-use building with 90 residential units and 850 square feet Consistency Review for 419 N. Milpas St. & 915-923 E. Gutierrez St.
PLN2024-00156
February 13, 2025
(net) of commercial (nonresidential) space. Of the residential rental units, nine (9) would be restricted to very-low-income households and six (6) units would be restricted to moderateincome households.
The project utilizes the City’s Average Unit-Size Density (AUD) Incentive Program and State Density Bonus Law. The project provides at least 10% of the units dedicated to very-low-income households and qualifies as a “Builder’s Remedy” project.
Under State Density Bonus Law, the project includes an additional 50% density bonus (60 base density units x 50% = 30 additional units) for a total of 90 units because 15% of base density (60 x 15% = 9 units) are restricted to very-low-income households. The project includes 29 studio units, 46 one-bedroom units, and 15 two-bedroom units, ranging in size from 350 square feet to 974 square feet, with an average unit size of 632 square feet.
The project qualifies for three concessions/incentives under State Density Bonus Law. Currently, the application includes one concession: relief from the 5-foot variable setback on Milpas Street.
The project also includes one development standard waiver: relief from the 45-foot height requirement.
The project includes a total of 69 parking spaces; 66 for the 90 residential units, and 3 for the commercial retail component. Reduced parking is allowed by State Density Bonus Law.
CONSISTENCY REVIEW:
Please be advised that the formal development application for the Project has been reviewed for consistency with development standards that were adopted and in effect at the time the SB 330 preliminary application was submitted on October 25, 2023, as well as at the time the formal development application was deemed complete on January 17, 2025, as appropriate.
Average Unit-Size Density (AUD) Incentive Program. The Project has been found to be consistent with the City’s Average Unit-Size Density (AUD) Incentive Program in regard to maximum average unit size, setback requirements (except along Milpas Street; see below), and open yard. The project does not comply with AUD parking or height, but that is addressed by State Density Bonus Law; see below).
State Density Bonus Law. State Density Bonus Law allows relief from development standards.
The Project includes relief from the following AUD requirements: 5-foot variable front setback requirement along Milpas Street, the maximum building height requirement, and the parking requirement.
Inclusionary Housing Ordinance. The project is consistent with the Inclusionary Requirements for AUD Rental Housing by providing six (6) units restricted to moderate-income households.
City’s Affordable Housing Policies and Procedures. The project is not consistent with the affordable housing requirements (e.g., dispersed evenly, average size of affordable units compared to market-rate units) as outlined in the Affordable Housing Policies and Procedures (March 2021). See also SBMC §30.145.020.B.
Public Improvements. The project is consistent with the requirements of Chapter 22.44 (Street Dedication and Improvement Requirements for Building Permits) in effect at the time of the SB Consistency Review for 419 N. Milpas St. & 915-923 E. Gutierrez St.
PLN2024-00156
February 13, 2025
330 preliminary housing application submittal on October 25, 2023. Subsequent changes to the ordinance do not apply to the project.
The January 17, 2025 Application Completeness Letter (Review #3) included a number of advisory comments. It has been determined that Marborg can service the site from Gutierrez Street per applicant correspondence with Marborg dated February 10, 2025.
After the project has completed construction, a request can be made to the City’s Downtown Parking Division and Traffic Engineer to review a potential loading zone on Gutierrez Street.
Staff would monitor the operational needs of the street and the adjacent loading areas to determine the need for an on-street loading zone that would service the entire block. If operations warrant the need for on-street loading, consideration will be made at that time. The loading zone is subject to approval and is not guaranteed to be approved. If approved, the loading zone would not be exclusive to the site and would serve the needs of the entire block.
All other comments related to parking design, water meters, etc. are required to be addressed as part of the building permit application. Additional advisory comments were provided in the Review # 1 letter related to Storm Water Management and building code requirements. These comments are also required to be addressed as part of the building permit application.
Please be advised that prior to building permit issuance, the applicant shall also comply with other relevant local/State/federal agencies’ regulations that are directly applicable to the project.
This consistency review is performed based on application materials submitted to date. As the Project application materials are revised and new information is provided, these changes may result in updates to the City’s consistency review determinations.
If you have any questions, please feel free to contact me at [email protected].
Sincerely,
Kathleen A. Kennedy
Project Planner
PLANNING COMMISSION
STAFF REPORT
REPORT DATE: March 13, 2025
AGENDA DATE: March 20, 2025
PROJECT ADDRESS: 418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) TO: Planning Commission
FROM: Planning Division
Megan Arciniega, Senior Planner
Kathleen Kennedy, Project Planner
I. PROJECT DESCRIPTION
The project involves the voluntary lot merger of 418 N. Milpas St. (APN 031-311-033) and 915- 923 E. Gutierrez St. (APN 031-311-034) to create a 41,477-square-foot (0.95-acre) lot, demolition of all onsite improvements (5,850 square feet of nonresidential floor area, 8 residential units, and 13 trees), and construction of a new four-story, 108,698 square foot (gross) mixed-use building with 90 residential rental units and 850 square feet (net) of commercial space.
The project includes 29 studio units, 46 one-bedroom units, and 15 two-bedroom units, ranging in size from 350 square feet to 974 square feet, with an average unit size of 632 square feet. Nine (9) units would be restricted to very-low-income households and six (6) units would be restricted to moderate-income households. The project includes 65 residential parking stalls, 3 commercial parking stalls, and one loading parking stall for smaller size delivery/service vehicles. Vehicular access to the site is from E. Gutierrez Street.
The project is proposed under the City’s Average Unit-Size Density (AUD) Incentive Program and State Density Bonus Law. A Preliminary Housing Development (SB 330) Pre-application was submitted on October 25, 2023 to lock in development standards and fees in effect at that time. The project also qualifies as a “Builder’s Remedy” project. See Exhibits B and C for project plans and applicant letter, respectively.
The project is being presented for concept review and comments only. No appealable decisions will be made at this meeting.
II. PURPOSE OF CONCEPT REVIEW HEARING
Planning Commission Conceptual Review is required because the cumulative lot area is greater than 15,000 square feet and the project site has a General Plan land use designation of High Density Residential (28-36 du/acre) (SBMC §30.150.060.A). The purpose of the hearing is for the Planning Commission to review the proposed design and provide the applicant, staff, and the Architectural Board of Review (ABR) with comments regarding the design, overall improvements, and consistency with the City’s General Plan (SBMC §30.150.060.E). As designed, the ABR is the decision-maker for the project.
III Item III Page 1 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
III. RECOMMENDATION
Staff recommends that the Planning Commission review the project and provide comment and recommendation by majority vote regarding the proposed design and improvements of the project, and the project’s consistency with the City’s General Plan. The Planning Commission’s comments and recommendations will be communicated to the ABR for use in their future deliberations on the project.
Vicinity Map: 418 N. Milpas St. (outlined in yellow) and 915-923 E. Gutierrez St. (outlined in blue)
418 N Milpas St.
915-923 E Gutierrez St.
Item III Page 2 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
IV. BACKGROUND
Previous designs. On July16, 2018, the ABR reviewed a project (submitted as a one-time preapplication consultation) that consisted of a four-story, 45-foot tall mixed-use building with 27 residential rental units and an 84-room bed and breakfast hotel.
On August 22, 2022, the ABR reviewed a project (submitted as a one-time pre-application consultation) that consisted of a four-story, mixed-use building with 90 residential rental units and 6,118 square feet of commercial space (1,557 square-foot retail; 4,561-square-foot bed and breakfast hotel).
Current Project. On October 25, 2023, the City accepted the SB 330 Housing Project Application and Pre-Application Review Team (PRT) application (PRE2023-00148) for the proposed mixeduse/ housing development project. On November 17, 2023, the City provided a PRT comment letter regarding the project. On April 22, 2024, the applicant submitted a formal Planning Application (PLN2024-00156) within the required 180-day period to keep the SB 330 application from expiring. The project qualifies as a “Builder’s Remedy” project. On January 17, 2025, the City provided an Application Completeness Letter (Review #3) deeming the formal development application complete.
Item III Page 3 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
V. SITE INFORMATION AND PROJECT STATISTICS
A. SITE INFORMATION
Applicant:
Beth Collins & Ginger Andersen, Brownstein Hyatt Farber Schreck; Riviera Vista I, LLC, Robert Ludwick, Manager
Property Owner: Goldenstone Trust, Carol Kallman and Donald Barthelmess Trustees Site Information
Parcel Number: 031-311-033 and
031-311-034 Lot Area: 0.95 acres; 41,477 SF
General Plan: Commercial High Density
Residential; Priority Housing Overlay (37-
63 du/acre)
Zoning: C-G (Commercial General)
Existing Use: Vacant Commercial/
Senior Housing Topography: < 3% slope
Adjacent Zoning and Land Uses
North: C-G/R-2 Commercial
East: R-2 Residential
South: C-G Public Right-of-Way (E. Gutierrez St.)
West: C-G Commercial; Public Right-of-Way (N. Milpas St.) B. PROJECT STATISTICS
Existing Proposed
Residential Units 8 Units 90 Units
Commercial Floor Area 5,850 SF 850 SF
Number of Units Commercial Space Other Uses
First Floor 3 850 SF
parking stalls;
residential lobbies;
bicycle rooms; leasing
office; activity room
Second Floor 34 - podium courtyards
Third Floor 33 - -
Fourth Floor 20 - roof terraces;
amenity rooms
TOTAL 90 850 SF
Item III Page 4 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
VI. POLICY AND ZONING CONSISTENCY ANALYSIS
A. ZONING ORDINANCE CONSISTENCY
Standard Requirement/ Allowance Proposed
Setbacks
-Front
-Interior
Front: 5’ variable
Interior: Adjacent to
Nonresidential 0’
Interior: Adjacent to Residential
6’ variable
Front: N. Milpas St. (<5-
foot variable*)
Front: E. Gutierrez St. (5-
foot variable)
Interior: Adjacent to
Nonresidential 0’
Interior: Adjacent to
Residential > 6’
Building Height 45 feet, or up to 60 feet with
height exception
50’-9” * with
64’-10” element
Parking
-Vehicle
-Bicycle
90 (1 space/ unit);
3 (1 space/ 250 s.f. commercial);
90 (1 covered & secured bicycle
stall/ unit)
1 (1 short-term bicycle stall/
1,750 s.f. commercial)
65 residential*;
3 commercial;
1 loading
124 standard covered;
4 non-standard covered
Density
Priority Housing Overlay:
63 units/acre (60 units) or
State Density Bonus
State Density Bonus*
94.5 units/acre (90 units)
Average Unit Size Maximum 811 s.f. 632 s.f.
Open Yard
Alternative Open Yard Design
(SBMC §30.140.140.F)
6,222 s.f. (15% of lot area; one
area with dimensions of 20’x 20’)
11,701 s. f.
*State Density Bonus Law (see below)
1. STATE DENSITY BONUS LAW
Pursuant to Government Code §65915, the project includes an additional 50% density bonus (60 base density units x 50% = 30 additional units) for a total of 90 units because 15% of base density (60 x 15%=9 units) are restricted to very-low-income households. In addition, the project qualifies for three concessions/incentives as well as waivers or reductions in development standards. As designed, the project includes one concession: relief from the 5- foot variable setback on Milpas Street. The project also includes one development standard waiver: relief from the 45-foot height requirement. The project also qualifies for a reduction in the number of required vehicle parking stalls from 1 stall per unit to 0.5 stalls per unit because at least 11% of the units restricted to very -low income households (Government Item III Page 5 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
Code §65915(p)), resulting in a total of 45 required parking stalls. However, the project includes a total of 65 parking stalls for the residential units.
2. SETBACKS
As noted above, the project includes a concession for relief from the 5-foot variable setback on Milpas Street. The project meets all other required setbacks. The interior setback adjacent to a residential zone is six feet. This applies to the east elevation of the project, where the proposal provides a minimum of 14 feet for the first and second stories, more than 20 feet for the third story, and more than 36 feet for the fourth story. The project also meets the solar access height limitations.
3. BUILDING HEIGHT
As noted above, the project includes a density bonus concession for relief from the 45-foot height requirement. The proposed height of the building is 50’-9”. Because the project site is located in the C-G zone and would qualify as a Community Benefit Housing project, the applicant could have requested a height exception from the Planning Commission to allow the height to be between 45 and 60 feet tall if the applicable findings could be made (SBMC §30.140.100.B.1).
4. OPEN YARD
The project proposes to provide open yard using the AUD Alternative Open Yard Design criteria (SBMC §30.150.090.G.2.b.iii.). This section requires that projects provide 15% of the net lot area as open yard, and at least one common area with a minimum dimension of 20 feet long and 20 feet wide, located on the ground or any floor of the building that is accessible to all units. For this project, the open yard requirement is 6,222 square feet. The project provides approximately 11,700 square feet of open yard area throughout the development.
5. INCLUSIONARY HOUSING REQUIREMENTS (SBMC §30.150.110.A.1) The project requires at least 10% of the units to be constructed and offered at an affordable rent as moderate-income units. The project complies with this requirement by providing 6 units affordable to moderate income households (10% of 60 base density units = 6 units).
Other Requirements. The project is consistent with the requirements of SBMC Chapter 22.44 (Street Dedication and Improvement Requirements for Building Permits) in effect at the time of the SB 330 preliminary housing application submittal on October 25, 2023. Subsequent changes to the ordinance adopted in February 2024 do not apply to the project. The project includes a 1’- 8” dedication of easement along N. Milpas Street. The street tree (Ficus) along Milpas Street is in poor health and is expected to be removed by the City by the end of the calendar year.
B. POLICY CONSISTENCY
The project is consistent with the City’s General Plan, which includes policies established in the Land Use Element, Housing Element, Environmental Resources Element (including Noise and Conservation), and Circulation Element. A complete list of policies that apply to the project, situated within the Milpas Neighborhood, is attached as Exhibit D.
Item III Page 6 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
1. LAND USE ELEMENT
The project site is in the C-G (General Commercial) zone, within the Priority Housing Overlay, and has a General Plan Land Use designation of Commercial/High-Density Residential. The project site is in the Milpas Neighborhood of the General Plan, bounded on the north by Canon Perdido Street; on the south by Highway 101; and on the east and west by a line mid-block behind commercial properties along on Milpas Street.
Milpas is developed as primarily a strip of commercial uses along both sides of the street, consistent with the General Plan designation of Commercial High Density. There is a scattering of residential uses above and behind shops. This area serves not only the residential areas surrounding Milpas Street, but the Eucalyptus and Riviera neighborhoods as well.
The Milpas corridor generally supports neighborhood commercial uses, with two large shopping centers. Due to the availability of neighborhood serving uses on Milpas Street, and the close proximity to transit, this area could redevelop to incorporate more residential in mixed use projects to form a unique urban neighborhood.
The project is consistent with the Land Use Element Policy LG4. Principles for Development, which encourages workforce and affordable housing within a quarter mile of frequent transit service and commercial services through smaller units and increased density; encourages a mix of land uses; and encourages easy access to basic needs such as groceries and drug stores.
The project is consistent with the Land Use Element Policy LG5. Community Benefit Housing, which encourages new residential development in commercial zones to include affordable housing, and LG5.1 Affordable Housing, an implementation action to encourage rental housing, and housing affordable to low, moderate, or middle income households.
The project is consistent with the Land Use Element Policy LG6. Location of Residential Growth, which encourages new residential units in multi-family and commercial areas of the City with the highest densities to be located in the Downtown, La Cumbre Plaza/Five Points area and along Milpas Street, and Land Use Element Policy LG6.3 Priority Housing Overlay, which encourages increased density (over Average Unit-Size Density Incentive Program).
The project is consistent with the General Plan Land Use designation of Commercial/High Density Residential, located in areas of the City that are along and/or near major transit corridors and where the highest residential densities are encouraged.
The project is consistent with the policies described above, and therefore is consistent with the Land Use Element.
2. HOUSING ELEMENT
The goals of the new 2023 Housing Element include Create New Housing; Prioritize Affordable Housing; Provide Housing Assistance; Promote Housing Stability; Preserve Housing; Engage the Community; Coordinate with Regional Partners; and Fund Affordable Housing.
Item III Page 7 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
As a housing development project, the proposal is consistent with policies related to Goal 1, Create New Housing and Goal 2, Prioritize Affordable Housing.
In regard to Goal 1, Create New Housing, the project is consistent with Housing Policy
1.2: Infill Housing, which encourages development of housing on infill sites near transit and jobs, particularly redevelopment of sites suitable for housing, and Housing Policy
1.7: Prioritize Housing and Community Benefit, which prioritize residential development on sites zoned for both residential and other uses.
In regard to Goal 2, Prioritize Affordable Housing, the project is consistent with Housing Policy 2.1: Prioritize Affordable Housing and Community Priority Projects and Housing Policy 2.2 Increase Production of Affordable Housing, both of which encourage the production of affordable housing; and Housing Policy 2.5: Rental Housing, which encourages smaller rental units close to transit, and easy walking and biking distance to commercial services.
The project would provide 90 rental units (82 net new) to the City’s housing stock, comprised of 9 very-low-income, 6 moderate-income, and 75 market-rate units, in an area designated for high residential densities. The project is consistent with the policies described above, and therefore is consistent with the Housing Element.
3. CIRCULATION ELEMENT
The Circulation Element’s comprehensive goal and vision statement is, “While sustaining or increasing economic vitality and quality of life, Santa Barbara should be a city in which alternative forms of transportation and mobility are so available and so attractive that use of an automobile is a choice, not a necessity.” The project site is located on N. Milpas Street between E. Haley Street and W. Gutierrez Street, where residents are within proximity to sidewalk, bicycle, and transit facilities. The project provides 124 standard covered and secure bicycle parking stalls and 4 non-standard covered and secure bicycle stalls. Given the location of the site and the variety of transportation methods present, dependency on automobiles is minimized. Therefore, the project can be found consistent with the Circulation Element.
4. ENVIRONMENTAL RESOURCES ELEMENT & CONSERVATION ELEMENT The Environmental Resources Element and the Conservation Element include aesthetic and visual resource policies to protect visual resources. There are no clear public views of the ocean from Milpas Street at the project site due to the location, and the existing neighborhood development. Views of the mountains are intermittently visible along Milpas Street. The proposed development replaces one-story buildings along Milpas Street and one-story residential units on E. Gutierrez St. with a new four-story building.
While any multi-story structure has the likelihood to block views of the mountains, this would be intermittent along Milpas Street. Views of the Riviera and mountains as viewed from the beach, harbor, and other important viewing areas would not be impacted by the project. Therefore, the project can be found consistent with the Environmental Resources and Conservation Element.
Item III Page 8 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
5. TRAFFIC GENERATION AND CONSISTENCY WITH THE CITY’S TRAFFIC MANAGEMENT
STRATEGY
Using the City’s Traffic Model rates for the proposed project located in Traffic Model Area 2, the proposed 90 residential units and 850 net square foot retail building would generate approximately 22 AM and 22 PM new peak hour trips. The existing nursery (retail use) and eight residential units generate approximately 11 AM and 14 PM peak hour trips. The net change in peak hour trips is 11 AM and 8 PM peak hour trips.
Distributing these trips to the City grid would not use one percent or more of the intersection capacity at any of the 27 identified future 2030 anticipated impacted intersections. Therefore, a project specific traffic effect is not anticipated.
VII. DESIGN REVIEW
As noted above, previous designs for the project site were reviewed by the Architectural Board of Review (ABR) in 2018 and 2022. The minutes from the August 22, 2022 hearing are attached (see Exhibit C). On August 22, 2022 , the ABR expressed concerns regarding the mass, bulk, and scale of the project and neighborhood compatibility. The applicant has indicated that a number of changes have been made to the project since the 2022 ABR hearing. Some of the changes are listed below.
• reduced size overall
• eliminated bed and breakfast component
• increased number of parking stalls
• reduced massing and increased setback along both streets • further articulated the north elevation
• made changes to mass, bulk, and scale
• reduced building height
• designated a loading stall for smaller size delivery/service vehicles Project Compatibility Findings. The ABR will consider the following Project Compatibility Findings during the course of its review prior to granting an approval of the project.
1. Consistency with Design Guidelines. The design of the project is consistent with design guidelines applicable to the location of the project within the City.
2. Compatible with Architectural Character of City and Neighborhood. The design of the project is compatible with the desirable architectural qualities and characteristics which are distinctive of Santa Barbara and of the particular neighborhood surrounding the project.
3. Appropriate size, mass, bulk, height, and scale. The size, mass, bulk, height, and scale of the project is appropriate for its location and its neighborhood.
4. Sensitivity to Adjacent Landmarks and Historic Resources. The design of the project is appropriately sensitive to adjacent Federal, State, and City Landmarks and other nearby designated historic resources, including City structures of merit, sites, or natural features.
Item III Page 9 of 23
Planning Commission Staff Report
418 N. Milpas St. and 915-923 E. Gutierrez St. (PLN2024-00156) Report Date: March 13, 2025
5. Public Views of the Ocean and Mountains. The design of the project responds appropriately to established scenic public vistas.
6. Use of Open Space and Landscaping. The project includes an appropriate amount of open space and landscaping.
VIII. ENVIRONMENTAL REVIEW
Staff determined that the project qualifies for an exemption from further environmental review under Section 15332 (In-fill Development Projects) of the California Environmental Quality Act (CEQA) Guidelines. Additionally, none of the exceptions under CEQA Guidelines Section 15300.2 apply. There would be no significant project-specific or cumulative impact on the environment due to unusual circumstances, the project does not have the potential to damage scenic highways or historic resources, and the project site is not identified as a hazardous waste site. Section 15332 allows an exemption for projects meeting the following:
(a) The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.
The proposed project is consistent with the General Plan and Zoning Ordinance as described in this staff report.
(b) The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses. The project is located in an urban setting on an 0.95 acre lot.
(c) The project site has no value as habitat for endangered, rare or threatened species. The project site is located in an urban setting and developed with structures and paved surfaces and has no value as habitat for endangered, rare or threatened species. (d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality. The project would not result in impacts related to traffic, noise, air quality, or water quality.
(e) The site can be adequately served by all required utilities and public services. All required utilities and public services are available.
EXHIBITS
A. Project Plans
B. Applicant's Letter, dated March 7, 2025
C. ABR Minutes dated August 22, 2022
D. Applicable General Plan Policies
Contact/Case Planner: Kathleen A. Kennedy, Project Planner ([email protected])
630 Garden Street, Santa Barbara, CA 93101
Phone: (805) 564-5470 x4560
Item III Page 10 of 23
EXHIBIT A
City of Santa Barbara
California
Exhibit B: Project Plans Dated for the March 20, 2025 Planning Commission Meeting, are available electronically for view online at: SantaBarbaraCA.gov/PC and will be transferred the city’s Archived Agendas & Documents system after the hearing.
Item III Page 11 of 23
Ginger C. Andersen
Land Use Planner
805.882.1460 direct
[email protected]
www.bhfs.com
Brownstein Hyatt Farber Schreck, LLP
805.963.7000 main
1021 Anacapa Street, 2nd Floor
Santa Barbara, California 93101
March 7, 2025
Planning Commission
City of Santa Barbara
PO Box 1990
Santa Barbara, CA 93102
RE: Planning Commission Conceptual Review of Milpas Gardens 418 North Milpas, 915‐923 East Gutierrez; City Case No. PRE2023‐00148, PLN2024‐00156
Dear Chair Wardlow and Members of the Planning Commission:
We are pleased to present the Milpas Garden project for conceptual review by the Planning Commission. This project utilizes the City’s Average Unit Density (“AUD”) Incentive Program and the State Density Bonus Law in proposing a mixed use project, including 90 residential units and 850 square feet of commercial space, located at 418 North Milpas and 915‐923 East Gutierrez Streets (“Project”) within the City of Santa Barbara (“City”).
In addition to the conceptual feedback received by the City’s Architectural Board of Review (“ABR”) in 2022, the pre‐application review team (“PRT”) feedback received in the past two years, the City requires conceptual feedback by the Planning Commission (“PC”)1. The PC’s role is to review Project’s consistency with City goals and the General Plan, and to provide comments and recommendations for staff and the ABR before the next meeting, where project design review and approval (“PDA”) will be requested by the applicant. Here, we note that City staff issued their Consistency Letter on February 13, 2025 finding the project consistent with City policies, and later clarified that any final minor inconsistencies can be addressed at the building permit stage.2 I. Section 30.150.010 Average Unit Density Incentive Program The AUD Program was established in 2013 to carry out the key implementation action of the City’s 2011 General Plan. The intent of the AUD Program is to promote the construction of smaller residential units near transit and within easy walking and biking distance to commercial services and activity centers. The AUD Program established density overlays areas throughout the City, including the Priority Housing Overlay, which allows for projects with up to 63 units per acre before density 1 Per Santa Barbara Municipal Code (SBMC) § 30.205.040,30.150.060.E. 2 February 13, 2025 letter from K. Kennedy to G. Andersen Subject: Consistency Review for 418 N. Milpas Street & 915‐923 E Gutierrez Street; PLN2024‐00156 (Consistency Letter), and email from K. Kennedy dated March 6, 2025.
EXHIBIT B Item III Page 12 of 23
March 7, 2025
bonus and supports smaller unit sizes. The Project is located within this Priority Housing Overlay3 and is consistent with the goals of the AUD Program, as described below:
The Project’s average size unit is approximately 632 square feet, well below the AUD program’s suggested size range, which helps minimize the overall building size. The Project proposes a mix of unit types including studios, one‐bedroom, and two‐bedroom units (29 studios, 46 one‐bedrooms and 15 two‐bedroom units for a total of 90 units). In addition to promoting affordability with these smaller units sizes, the Project proposes to restrict 9 of these to very low income households.
In addition to the 9 very low units, the project proposes 6 units for moderate‐income households, consistent with City Inclusionary requirements. The Project density is below the maximum density allowed with State Density Bonus Law4.
II. Section 22.68.045.B Architectural Board of Review Project Compatibility Findings The current design of the Project incorporates the feedback received by the ABR in August 2022.
Significant changes were made to address their comments, and the Project will return to ABR for Project Design Approval in the coming weeks. For reference, the ABR’s findings, and our summary discussion of each are as follows:
1. Consistency with Design Guidelines. The design of the project is consistent with design guidelines applicable to the location of the project within the City.
This Project is consistent with all applicable objective design guidelines and voluntarily complies with other City guidelines. This mixed use Project is located within the Milpas Urban Corridor and the AUD Program Priority Housing Overlay. The Project utilizes the majority of the design and detail recommendations in the City’s Urban Infill Design Guidelines as well as the Haley‐Milpas Design Manual.
3 It is our understanding that there were previously error(s) in GIS mapping on certain City platforms regarding this property. City staff has confirmed via email on January 16, 2024 that the property is in the High Priority Overlay, and it is our understanding that online City mapping has been updated to show the High Priority Overlay on the property. 4 Priority overlay density prescribes 63 units per acre, with the inclusion of 9 very low units, the project achieves a 50% bonus density resulting in 90 units. The project has not elected to exercise additional bonus units that would be allowed per Government Code section 65915 (v)(1)(B), and (v)(2) (allowing for an additional density bonus of 32.5%) but reserves the right to do so.
Item III Page 13 of 23
March 7, 2025
2. Compatible with Architectural Character of City and Neighborhood. The design of the project is compatible with the desirable architectural qualities and characteristics which are distinctive of Santa Barbara and of the particular neighborhood surrounding the project.5 The proposed architectural style is Mediterranean with elements and details that draw extensively from the iconic Santa Barbara style and design guidelines. The Project includes terraces, interior hall and courtyards, decorative tile, awnings, gabled and hipped roof elements, colonnades, a tower element, clay tile roofing, wrought iron balconies and detailing. While the roofscape of the architecture is predominantly one of sloping red tile roofs germane to the iconography of Santa Barbara, concealed mechanical wells are incorporated to facilitate unit heat pumps and solar panel utilization. A complete discussion and response to ABR comments has been supplied to City staff.6
3. Appropriate size, mass, bulk, height, and scale. The size, mass, bulk, height, and scale of the project is appropriate for its location and its neighborhood.
Significant revisions have been made to the Project since the August 2022 ABR meeting including a reduction to the overall size, height, massing, bulk, and scale. The Project utilizes one concession and one waiver7 as allowed with the State Density Bonus to 1) exceed the height limit of the zone ‐ but otherwise allowed in the AUD ordinance8 and 2) waive compliance with the variable setback along Milpas. These parameters could not be met without reducing the project density. The project also provides 66 residential parking spaces and 3 commercial spaces.
4. Sensitivity to Adjacent Landmarks and Historic Resources. The design of the project is appropriately sensitive to adjacent Federal, State, and City Landmarks and other nearby designated historic resources, including City structures of merit, sites, or natural features.
The Project is not located adjacent to any landmarks, structures of merit, or historic resources.
5. Public Views of the Ocean and Mountains. The design of the project responds appropriately to established scenic public vistas.
5 The City’s recently‐adopted Objective Design and Development Standards (ODDS) do not apply to this project as the project’s SB 330 Preliminary Application ‐ which freezes the local standards in effect at the time ‐ was submitted in 2023, prior to the adoption of the ODDS in 2025. 6 See Brownstein letter dated October 2023. 7 As stated on project plans submitted in December 2024, the project also reserves the right to waive the purported commercial vehicle loading space requirement and any associated vertical clearance within the parking area identified by public works. 8 The project qualifies for an increased height of up to 60‐feet via SBMC 30.140.100.B as a Community Benefit Housing Project as described in the Applicant’s April 18, 2024 letter, however a waiver is instead being applied.
Item III Page 14 of 23
March 7, 2025
The only public views potentially impacted by the Project are the views of the mountains from public roads near the project site. The Project’s design however minimizes these impacts. The Project qualifies for a State Density Bonus Law waiver to exceed the City’s height limit; however, the project has been revised since the previous ABR review to minimize height to the maximum extent feasible while maintaining the project density. The Project applicant opted not to maximize State Bonus Density – which would have allowed about 20 more units on the site and the Project applicant is minimizing average unit size to further reduce size bulk and scale. Additionally, the Project complies with the City’s solar ordinance, and exceeds the required setbacks from the neighboring residential neighborhood to the east. Thus, the Project complies with this standard and sufficiently protects public views.
6. Use of Open Space and Landscaping. The project includes an appropriate amount of open space and landscaping.
The project proposes:
To hide project parking within the ground floor of this podium project. Ground‐floor landscape areas located primarily on the eastern side of the property, exceeding the side‐yard setback on that side.
12.4% of the ground floor area as proposed landscape, and another 5.7% as hardscape. 12,379 square feet of common open space, nearly double the required amount9. Exterior residential balconies and walkways.
Fourth floor amenity spaces connected to a roof terrace of 1,208 square feet. Two additional fourth‐floor roof terraces.
III. Closing
This Project proves that high quality architecture can be achieved in high‐density multi‐family development. City staff has concluded that the Project is consistent with the City’s General Plan and municipal code policies as well as the City’s goals and infill guidelines with application of AUD incentives and minimal state density bonus concessions, incentives, and waivers. The Project will be a great addition to the Milpas corridor and a wonderful transition from the commercial uses along Milpas to the residential uses to the east.
The applicant team has been working very closely with City staff on the Project and thank you in advance for your feedback. If you have any questions or would like to discuss further please contact me at (805) 260‐8392 or [email protected].
9 See project plan sheet A0.2 per 30.140.140.2.F, total common open space is required to be greater than 15% of site area where 15% of net lot area (41,477 SF) is 6,221.6 SF required; Project provides 12,379 SF which is 188% of required.
Item III Page 15 of 23
March 7, 2025
We look forward to providing the City with much‐needed residential for‐rent units with this Project.
Sincerely,
Ginger C. Andersen
Senior Land Use Planner
cc: Kathleen Kennedy via email [email protected] Item III Page 16 of 23
City of Santa Barbara
ARCHITECTURAL BOARD OF REVIEW
MINUTES
AUGUST 22, 2022
3:00 P.M.
David Gebhard Public Meeting Room
630 Garden Street
SantaBarbaraCA.gov
BOARD MEMBERS:
Kevin Moore, Chair
Richard Six, Vice Chair
Lauren Anderson
David Black
Steve Nuhn
Leon A. Olson
Dennis Whelan
CITY COUNCIL LIAISON:
Mike Jordan
PLANNING COMMISSION LIAISON:
Roxana Bonderson
STAFF:
Tava Ostrenger, Assistant City Attorney
Ellen Kokinda, Design Review Supervisor
William Russell, Assistant Planner
Kira Esparza, Commission Secretary
CALL TO ORDER
The Full Board meeting was called to order at 3:01 p.m. by Chair Moore.
ATTENDANCE
Members present: Moore, Six, Anderson, Nuhn, Olson and Whelan Members absent: Black
Staff present: Kokinda, Russell, and Esparza
GENERAL BUSINESS
A. Public Comment:
Written correspondence from Kathleen Dagg and Bob Cunningham was acknowledged.
B. Approval of Minutes:
Motion: Approve the minutes of the Architectural Board of Review meeting of August 8, 2022, as submitted.
Action: Six/ Moore, 6/0/0. (Black absent.) Motion carried.
C. Approval of the Consent Calendar:
Motion: Ratify the Consent Calendar of August 15, 2022, as reviewed by Board Members Whelan and Moore.
Action: Whelan/ Olson, 6/0/0. (Black absent.) Motion carried.
EXHIBIT C Item III Page 17 of 23
Architectural Board of Review Minutes August 22, 2022 Page 8 of 9 (6:10PM) ONE-TIME PRE-APPLICATION CONSULTATION
5. 418 N MILPAS ST
Assessor's Parcel Number: 031-311-033
Zone: C-G
Application Number: PRE2022-00116
Owner: Kallman Family Trust,
Robert Ludwick, Managing Member
Applicant: Jan Hochhauser, Hochhauser Blatter Architecture (Proposal for a 101,204 square foot, four story, 90-unit mixed-use building, comprised of 34 studio units, 44 one-bedroom units, and 12 two-bedroom units, and 6,118 square feet of commercial / retail space on the ground level for commercial retail (1,557 square feet) and bed & breakfast hotel (4,561 square feet). The project is designed to comply with the City’s Average Unit Size Density Incentive program (AUD), City Inclusionary housing requirements, California State Density Program (SDB), and the streamlined housing project program (CA State Senate Bill 330). The project site is 41,473 square feet (.952 acre). Under the AUD priority overlay maximum of 63 units per acre, 60 units would be allowed on the site. The project will include 9 very low-income units (15% of 90 units). This would allow a 50% density bonus under SDB bringing the total to 90 units. The project will also include 6 moderate income units (10% of 60 units) satisfying the City Inclusionary requirement. In total there will be 15 below market units and 75 market units within the 90 total units. The project provides 52 parking spaces for residential units of .5 spaces per bedroom as allowed by the SDB parking incentive for 15% very low-income units. The commercial / retail and bed & breakfast hotel requirements adds 14 additional spaces for a total of 69 spaces. Development Plan approval at Planning Commission is required for the project, along with the request for a 52-foot maximum height as a community benefit project. A waver /concession is requested for relief from solar set back) No final appealable decision will be made at this hearing. Project requires compliance with the Project Compatibility Findings.
Actual time: 7:25 p.m.
Present: Jan Hochhauser, Architect, Hochhauser Blatter Architecture; Tim Johnson, Hochhauser Blatter Architecture; Ginger Anderson, Council for Owner Staff comments: Ms. Kokinda stated that this is a onetime pre-application consultation, not a formal application. The applicants are looking for the Board’s feedback on the design of the project. Ms.
Kokinda gave instructions to members of the public on how to get signed up as an interested party for the project.
Public comment opened at 7:45 p.m.
The following individuals spoke:
1. Natasha Todorovic
2. Jose Gallegos
3. Fred Sweeney
4. Britta Bartels
5. Danny Moreno
6. Chris Scott
Item III Page 18 of 23
Architectural Board of Review Minutes August 22, 2022 Page 9 of 9
7. Julie Stark
8. Carole Wockner
9. Paul Fletcher
10.Susan shields
11.Natalia Govoni
12.Chris Burros
13.Martha Fragosa
14.Victoria Valente
15.Tino De Guevarra
16.Sebastian Aldana Jr
17.Abbey Fragosa
Written correspondence from Cynthia Blanton, Sebastian Aldana Jr, Steve Sherwin, Pat Saley, Steve Dowty, Lyn Proctor, Brian Tanguay, Victoria Valente, Natasha Todorovic-Cowan, Marell Brooks, Lisa Jehle, Ann Hefferman, Brent Ortiz, Christine Neuhauser, Steve Johnson, Lia Romero, Kathryn Clarke, Mary Turley, Susan Sherwin, Eric Stowell, Mary Robles, Christina Stowell was acknowledged.
Public comment closed at 8:16 p.m.
Board comments:
1. Board Member Nuhn appreciates the Applicant’s effort at achieving the goals of the program. The project does not seem compatible with the relation to neighborhood and is not in favor of the project yet.
2. Board Member Six appreciates the design effort and is sensitive to the constraints of the project.
This design is more refined than the previous design that was submitted. Board member Six has significant concerns of the compatibility of the project with the texture of neighborhood. The project would have to be half in height and half in footprint to be compatible in the neighborhood. Board Member Six believes there was a mistake in the priority housing overlay that allows this size of development on Milpas. The blank walls on north elevations are not acceptable. The streetscape on Milpas is not compatible with rhythm of street front. In future meetings, there needs to be documentation of the condition of the neighbors to the east and include the 3D elevation in the presentation.
3. Board Member Anderson stated that the north elevation without relief is not compatible with the neighborhood. The 3rd story at Milpas is not compatible. The street trees that are existing are trees that can ruin existing buildings and will most likely have to be removed at some point. Currently, Board member Anderson cannot support this size or architectural style of the project. The style is not fully developed and is not compatible with neighborhood or Santa Barbara Style. It would benefit the Applicant to study breaking the building up into multiple buildings if possible.
4. Board Member Moore stated that he acknowledges that this is a difficult location. If the project comes back, the Applicant should study the condition and how to juggle massing to better address the contradiction.
5. Board Member Whelan stated that the illustrations are too large and it is on an awkward site. Board Member Whelan agrees with other comments on the North elevation, which speaks to blankness and bulk and scale. It is a good neighborhood for reasonable housing, but this project does not fit in nicely with the neighborhood.
6. Board Member Olson stated that he believes the Applicant has the ability to address the issues with the project, and hopes that as the applicant progresses with this project, that the same level of attention to the west side of the project is given to the neighbors on the east side. * MEETING ADJOURNED AT 9:01 P.M. *
Item III Page 19 of 23
Applicable General Plan Policies
418 N. Milpas St. and 915-923 E. Gutierrez St. Project
Land Use Element (2011)
LG1. Resource Allocation Priority. Prioritize the use of available resources capacities for additional affordable housing for extremely low, very low, low, moderate, and middle income households over all other new development.
LG4. Principles for Development. Establish the following Principles for Development to focus growth, encourage a mix of land uses, strengthen mobility options and promote healthy active living.
Focus Growth. Encourage workforce and affordable housing within a quarter mile of frequent transit service and commercial services through smaller units and increased density, transit resources, parking demand standards, targeted infrastructure improvements, and increased public areas and open space. Incorporate ideas as a result of an employee survey.
Mix of Land Uses. Encourage a mix of land uses, particularly in the Downtown to maintain its strength as a viable commercial center, to include retail, office, restaurant, residential, institutional, financial and cultural arts, encourage easy access to basic needs such as groceries, drug stores, community services, recreation, and public space.
Mobility and Active Living. Link mixed-use development with main transit lines; promote active living by encouraging compact, vibrant, walkable places; encourage the use of bicycles; and reduce the need for residential parking.
LG5. Community Benefit Housing. While acknowledging the need to balance the provision of affordable housing with market-rate housing, new residential development in multifamily and commercial zones, including mixed-use projects, should include affordable housing and open space benefits.
Possible Implementation Actions to be Considered
LG5.1 Affordable Housing. Develop standards and project level findings to encourage the development of Community Benefit Housing defined as:
Rental housing;
Housing affordable to low, moderate, or middle income households; Employer sponsored workforce housing;
Limited Equity Co-operative Housing;
Affordable Housing Downtown for Downtown Workers; and/or EXHIBIT D Item III Page 20 of 23
APPLICABLE GENERAL PLAN POLICIES
418 N MILPAS ST. AND 915-923 E. GUTIERREZ ST. (PLN2024-00156) PAGE 2 OF 4
Transitional housing, single residential occupancy, and other housing for special needs populations including seniors, physically or mentally disabled, homeless, and children aging out of foster care.
LG6. Location of Residential Growth. Encourage new residential units in multi-family and commercial areas of the City with the highest densities to be located in the Downtown, La Cumbre Plaza/Five Points area and along Milpas Street.
Possible Implementation Actions to be Considered
LG6.3 Priority Housing Overlay. Encourage the construction of rental and employer housing and limited equity co-operatives in select multi-family and commercial zones where residential use is allowed by providing increased density (over Average Unit-Size Density Incentive Program).
LG12. Community Character. Strengthen and enhance design and development review standards and process to enhance community character, promote affordable housing, and further community sustainability principles.
LG12.2 Building Size, Bulk and Scale. Ensure that proposed buildings are compatible in scale with the surrounding built environment.
Housing Element (2023)
Goal 1 Create New Housing: Create new healthy, safe, and energy‐efficient housing that meets community needs, within our resources.
POLICIES
Policy 1.1: Sustainable and Livable Neighborhoods. Ensure that new housing programs, housing developments, and related infrastructure improvements include community-led strategies that encourage community revitalization in areas of lower opportunity to meet the needs of lower-income residents and are consistent with the City’s sustainability initiatives for energy efficiency and active transportation goals.
Policy 1.2: Infill Housing. Encourage development of housing on infill sites near transit and jobs, particularly redevelopment of sites suitable for housing, while continuing to limit residential density in High Fire Hazard Areas.
Policy 1.7: Prioritize Housing and Community Benefit. Prioritize residential development and nonresidential priority projects with broad community benefit on sites zoned for both residential and other uses.
Goal 2 ‐ Prioritize Affordable Housing: Prioritize housing that is affordable to the workforce and vulnerable communities, by the use of deed restrictions and other measures, over other types of development, with special emphasis on housing that meets the needs of extremely low, very low, low, moderate, and middle income, and special needs households.
Item III Page 21 of 23
APPLICABLE GENERAL PLAN POLICIES
418 N MILPAS ST. AND 915-923 E. GUTIERREZ ST. (PLN2024-00156) PAGE 3 OF 4
POLICIES
Policy 2.1: Prioritize Affordable Housing and Community Priority Projects. Prioritize production of deed restricted affordable housing and nonresidential community priority projects with broad community benefits over all other land uses and housing types.
Policy 2.2 Increase Production of Affordable Housing. Encourage and provide development opportunities and incentives to increase production of affordable housing.
Policy 2.5: Rental Housing. Continue to encourage smaller rental units close to transit, and easy walking and biking distance to commercial services and recreational opportunities.
Environmental Resources Element (2011)
ER29. Visual Resources Protection. New development or redevelopment shall preserve or enhance important public views and viewpoints for public enjoyment, where such protection would not preclude reasonable development of a property.
ER30. Enhance Visual Quality. Not only retain, but improve visual quality of the city wherever practicable.
Conservation Element (1979, prior amendment 1994)
Visual Resources
3.0 New development shall not obstruct scenic view corridors, including those of the ocean and lower elevations of the City viewed respectively from the shoreline and upper foothills, and of the upper foothills and mountains viewed respectively from the beach and lower elevations of the City.
4.0 Trees enhance the general appearance of the City’s landscape and should be preserved and protected.
4.1 Mature trees should be integrated into project design rather than removed. The Tree Ordinance should be reviewed to ensure adequate provision for review of protection measures proposed for the preservation of trees in the project design.
4.2 All feasible options should be exhausted prior to the removal of trees.
4.3 Major trees removed as a result of development or other property improvement shall be replaced by specimen trees on a minimum one-for-one basis.
4.4 Private efforts to increase the number of street trees throughout the City should be encouraged.
Circulation Element (2011)
C1. Transportation Infrastructure Enhancement and Preservation. Assess the current and potential demand for alternative transportation and where warranted increase the availability and attractiveness of alternative transportation by improving related infrastructure and facilities without reducing vehicle access.
Item III Page 22 of 23
APPLICABLE GENERAL PLAN POLICIES
418 N MILPAS ST. AND 915-923 E. GUTIERREZ ST. (PLN2024-00156) PAGE 4 OF 4
Circulation Element (1997, original 1964)
1.1 The City shall establish, maintain, and expand a mobility system that supports the economic vitality of local businesses.
1.1.1 Optimize access and parking for customers in business areas by implementing policies of the Circulation Element aimed at reducing dependence upon the automobile, and improving and increasing pedestrian, bicycle use, and transit use.
1.1.2 Review traffic impact standards used at City intersections for consistency with the goals of the Circulation Element and General Plan through public worksessions with the Planning Commission and the City Council.
1.1.3 Enhance alternative transportation services and infrastructure access between residential, recreational, educational, institutional and commercial areas.
1.1.4 Provide adequate infrastructure and info-structure to support the delivery of goods and services to and from area businesses.
4.2 The City shall work to expand, enhance, and maintain the system of bikeways to serve current community needs and to develop increased ridership for bicycle transportation and recreation.
4.2.3 Encourage facilities for bicycle travel and parking in any future development, construction, or reconstruction projects during the review of new development and infrastructure improvements. Bicycle facilities can be achieved through methods such as:
• purchase, dedication, and other means of property acquisition, • conditions of approval,
• expanding the scope of maintenance projects, and
• enforcement of the Santa Barbara Municipal Code, Parking Section.
8.5 The City shall promote/facilitate the development of housing to decrease the need for parking through an increased walking/biking population that lives, works, and shops in the Downtown (See Chapter 13).
Item III Page 23 of 23
ASSOCIATED TRANSPORTATION ENGINEERS
100 N. Hope Avenue, Suite 4, Santa Barbara, CA 93110 • (805)687-4418 • FAX (805)682-8509 • [email protected] Since 1978
Richard L. Pool, P.E.
Scott A. Schell
June 16, 2025 22095L03
Bob Ludwick
Riviera Vista I, LLC
924 Anacapa Street, Suite 3K
Santa Barbara, CA 93101
TRIP GENERATION AND TRANSPORTATION POLICY CONSISTENCY ANALYSIS FOR
THE MILPAS GARDENS MIXED-USE PROJECT, CITY OF SANTA BARBARA Associated Transportation Engineers (ATE) has prepared the following trip generation analysis and transportation policy consistency analysis for the Milpas Gardens Mixed-Use Project (the “Project”), proposed in the City of Santa Barbara. ATE previously submitted a trip generation analysis and policy consistency assessment dated January 26, 2023. This study addresses the revised Project statistics and evaluates the consistency of the Project with the City’s current Traffic Management Strategy (TMS) policies (adopted in 2024) based in the City’s Traffic Analysis Guidelines. The adequacy of the proposed parking supply is also evaluated.
PROJECT DESCRIPTION
The Milpas Gardens Mixed-Use Project is located at 418 N. Milpas Street in the City of Santa Barbara’s east side area. Figure 1 (attached) shows the location of the Project site within the City. Figure 2 shows the Project site plan. The Project is proposing to construct a four-story mixed-use building with 90-unit apartment units (15 affordable) and an 850 SF commercial space fronting Milpas Street. A total of 69 parking spaces would be provided for the Project (65 spaces for the residential units and 4 spaces for the commercial area).
Milpas Gardens Mixed-Use Page 2 June 16, 2025
PROJECT CONSISTENCY EVALUATION
The following section evaluates the consistency of the current Project with the City’s current Traffic Management Strategy policies based on the methodologies in the City's Traffic Analysis Guidelines that were recently updated in December 2023 and approved by City Council in March 2024. These policies apply to the commercial component of the Project.
Traffic Management Strategy Policy
A significant project-specific traffic effect would result when a project’s net peak-hour traffic generation would constitute one percent (0.01) or more of a signalized intersection’s capacity (V/C) at one or more of the following intersections, (or one second or more delay time in the case of unsignalized intersections or roundabouts).
1. SR-154 & Calle Real 2. Las Positas Road & State Street
3. US 101 NB On-Ramp & Calle Real 4. Las Positas Road & Calle Real
5. Las Positas Road & US 101 SB Ramps 6. Las Positas Road & Modoc Road
7. Constance Avenue & State Street 8. State Street & Mission Street
9. US 101 NB Ramps & Mission Street 10. US 101 SB Ramps & Mission Street
11. Modoc Road & Mission Street 12. Chapala Street & Carillo Street
13. De la Vina Street & Carillo Street 14. Castillo Street & Carillo Street
15. US 101 NB Ramps & Carillo Street 16. US 101 SB Ramps & Carillo Street
17. San Andres Street & Carillo Street 18. Meigs Road & Cliff Drive
19. Castillo Street & US 101 NB Ramps/Haley Street 20. Castillo Street & US 101 SB Ramps
21. Castillo Street & Montecito Street 22. Garden Street & Haley Street
23. Garden Street & Gutierrez Street 24. Garden Street & US 101 NB Ramps
25. Milpas Street & US 101 NB Ramps 26. Cabrillo Boulevard & US 101 Ramps
27. Hot Springs Road & Coast Village Road
Trip Generation Analysis
Trip generation estimates were developed for the Project using the rates presented in the City’s Traffic Model. The rates for model “Zone 2” were used for the analysis. The model rates for residential developments are based on the number of parking spaces provided per unit (the analysis assumes 65 units with 1 space and 25 units with zero spaces). The trip generation analysis completed for the retail portion of the Project assumes the “retail” rates.
It is noted that the existing on-site uses have been vacant for an extended period of time, therefore no existing trip credits were assumed for the Project trip generation estimates.
Table 1 summarizes the Project trip generation estimates based on the City traffic model rates (detailed trip generation spreadsheet attached).
Milpas Gardens Mixed-Use Page 3 June 16, 2025
Table 1
Project Trip Generation Summary
Land Use Size
AM Peak Hour PM Peak Hour
Rate Trips Rate Trips
Multi-Family (0 Cars) 25 Units 0.25 6 (1/5) 0.27 7 (4/3) Multi-Family (1 Car) 65 Units 0.46 30 (7/23) 0.42 27 (16/11) Retail 850 SF 2.38 2 (1/1) 3.37 3 (2/1)
Total Trip Generation: 38 (9/29) 37 (22/15)
The data presented in Table 1 indicate that the Project is forecast to generate 38 AM peak hour trips (PHT) and 37 PM PHT. The retail portion of the Project is forecast to generate 2 PHT and 3 PM PHT.
Consistency with Intersection Policies
The City’s Traffic Management Strategy assesses traffic generated by proposed new nonresidential developments, therefore only the retail trips were analyzed for consistency with the intersection policies. As shown in Table 1, the retail component of the Project is forecast to generate 2 AM peak hour trips and 3 PM peak hour trips. When distributed from the Project site, this level of traffic would not cause a V/C ratio increase of 1% or a delay increase of 1 second at the study-area intersection impacted in 2030. The Project would therefore be consistent with the policies contained in the City’s Traffic Management Strategy.
PARKING ANALYSIS
Parking Supply
As shown on the Project site plan (see Figure 2) the Project is proposing to provide 69 parking spaces (65 spaces for the residential units and 4 spaces for the commercial area).
Zoning Ordinance Parking Requirements
The parking requirements for the Project were calculated for the Project based on the rates presented in the City of Santa Barbara’s Zoning Ordinance. The average unity density (AUD) rates were used for the apartments and the Commercial rates were used for the retail component. Table 2 presents the City of Zoning Ordinance parking requirements for the Project.
Milpas Gardens Mixed-Use Page 4 June 16, 2025
Table 2
Parking Requirements
Per SBMC Section 30.175.040 (AUD)
Land Use Size
City Parking
Requirement
Parking
Requirement
Parking
Supply
Residential 90 Units 1 Space/Unit 90 Spaces 65 Spaces
Commercial 850 SF 1 Space/250 SF 3 Spaces 4 Spaces
Total 93 Spaces 69 Spaces
The data presented in Table 2 indicate that the City Zoning Ordinance parking requirement for the Project is 90 spaces for the residential units and 3 spaces for the commercial space.
The 65 parking spaces provided for the residential units would not meet the City’s requirements for the apartments. The 4 parking spaces provided for the commercial space would satisfy the Zoning Ordinance requirements for this component.
It is noted that the Project qualifies for reduced parking requirements under the State’s Bonus Density law, as reviewed in the following section.
State Bonus Density Parking Requirements
The State Bonus Density law (Gov. Code § 65915) contains the following parking requirements for Project’s that meet the applicable affordable housing percentages:
Gov. Code § 65915 (p)(2)(A)
Notwithstanding paragraph (1), if a development includes at least 20 percent low-income units for housing developments meeting the criteria of subparagraph (A) of paragraph (1) of subdivision (b) or at least 11 percent1very low income units for housing developments meeting the criteria of subparagraph (B) of paragraph (1) of subdivision (b), is located within one-half mile of a major transit stop2-3and there is unobstructed access to the major transit stop from the development, then, upon the request of the developer, a city, county, or city and county shall not impose a vehicular parking ratio, inclusive of parking for persons with a disability and guests, that exceeds 0.5 spaces per unit. 1 Percentages are the percent of the base density. Here the base density is 60; the project meets the criteria because it has 9 very low (15%) which is more than the 11% required.
2 Milpas corridor qualifies as a major transit stop per PRC 21064.3. “Major transit stop” means a site containing any of the following: (a) An existing rail or bus rapid transit station. (b) A ferry terminal served by either a bus or rail transit service. (c) The intersection of two or more major bus routes with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods.
3 Service intervals along the Milpas corridor are confirmed by the City’s Master Environmental Assessment Guidelines for Transportation Analysis December 2023, and MTD website: Maps & Schedules – Santa Barbara MTD Milpas Gardens Mixed-Use Page 5 June 16, 2025
The Project exceeds the minimum of 11% of very low income units, and is located within a high-quality transit corridor, as shown on Figure 3, therefore the State Bonus Density ratio was used. Table 3 presents the parking requirements for the Project assuming the State Bonus Density ratio for the apartments and the City’s requirements for the commercial component.
Table 3
Parking Requirements
State Bonus Density Law
Land Use Size
Parking
Requirement
Parking
Requirement
Parking
Supply
Residential 90 Units 0.5 Space/Unit 45 Spaces 65 Spaces Commercial 850 SF 1 Space/250 SF 3 Spaces 4 Spaces
Total 48 Spaces 69 Spaces
The data presented in Table 3 indicate that the State Bonus Density parking requirement for the apartments is 45 spaces and the City’s requirement for the commercial space is 3 spaces.
The 65 parking spaces provided for the apartments would exceed the State Bonus Density requirements by 20 for the apartments. The 4 parking spaces provided for the commercial space would satisfy the Zoning Ordinance requirements for this component.
Parking Demand Analysis
Additional parking demand estimates were developed for the Project based on the rates presented in the Institute of Transportation Engineers (ITE) Parking Generation, 6th Edition4. The average rates for Multifamily Housing – 1 BR Mid-Rise (Land Use Code #218), Multifamily Housing – 2 BR Mid-Rise (Land Use Code #221) and Strip Retail Plaza <40k (Land Use Code #822) were used for the analysis. Table 4 presents the parking demand estimates for the Project. 4 Parking Generation Manual, Institute of Transportation Engineers, 6th Edition, 2023.
Milpas Gardens Mixed-Use Page 6 June 16, 2025
Table 4
Project Parking Demand Estimates – ITE Rates
Land Use Size
Demand
Rate
Parking
Demand
Parking
Supply
Residential – 1 BR (a) 75 DU 0.28/Unit 21 Spaces
65 Spaces
Residential – 2 BR (b) 15 DU 1.04/Unit 16 Spaces
Subtotal 37 Spaces
Commercial (c) 850 SF 3.13/KSF 3 Spaces 4 Spaces
Total 40 Spaces 69 Spaces
(a) ITE average parking demand rate for Multifamily Housing – 1 BR Mid-Rise (#218) – Weekday for Dense Multi-Use Urban area.
(b) ITE average parking demand rate for Multifamily Housing – 2+ BR Mid-Rise (#221) – Sunday for Dense Multi-Use Urban area.
(c) ITE average parking demand rate for Strip Retail Plaza <40k (#822) – Friday.
The data presented in Table 3 show that the residential component of the Project would generate a peak parking demand of 37 spaces and the commercial component of the Project would generate a peak parking demand of 3 spaces. The 65 parking spaces provided for the residential units and 4 parking spaces provided for the commercial space would accommodate the peak parking demands generated by the Project.
This concludes ATE’s updated trip generation analysis and policy consistency assessment for the Milpas Gardens Mixed-Use Project.
Associated Transportation Engineers
Scott A. Schell
Principal Transportation Planner
SAS/GOM
Attachments:
PROJECT SITE LOCATION AT SSOCIATED RANSPORTATION E NGINEERS FIGURE N NOT TO SCALE GM- ATE#22095 1 PROJECT SITE PROJECT SITE PLAN AT SSOCIATED RANSPORTATION E NGINEERS FIGURE NNOT TO SCALE GM- ATE#22095 2
CITY OF SANTA BARBARA HIGH QUALITY TRANSIT CORRIDORS
A
T SSOCIATED RANSPORTATION E NGINEERS FIGURE GM- ATE#22095 3 PROJECT SITE
Associated Transportation Engineers
Trip Generation Worksheet - CITY MODEL RATES AREA 2
MILPAS GARDENS MIXED-USE PROJECT - #22095
Use Rate Trips In % Trips Out % Trips Rate Trips In % Trips Out % Trips
PROPOSED
Multi-Family (0 Cars) (a) 25 DU 0.25 6 23% 1 77% 5 0.27 7 61% 4 39% 3 Multi-Family (1 Car) (a) 65 DU 0.46 30 23% 7 77% 23 0.42 27 61% 16 39% 11 Retail (b) 850 SF 2.38 2 60% 1 40% 1 3.37 3 50% 2 50% 1 Totals 38 9 29 37 22 15
NOTES: Trip generation based on City Model Rates.
(a) City rates for Multi-Family. In and out percentages based on ITE Multifamily Housing Mid-Rise (#221). (b) City rates for Retail. In and out percentages based on ITE Strip Retail Plaza (#822).
Proposed
90 Units 65 Spaces
25 Units 0 Cars 0 Spaces
65 Units 1 Car 65 Spaces
90 Units 65 Spaces
PM PEAK HOUR
Cars Per Unit Breakdown
Size
AM PEAK HOUR