I. Buildout of Additional Units under the State Density Bonus Law and AB 1287 is Reasonably Foreseeable, Not Speculative, and Must be Addressed in the SEIR.
SCRD and approximately 50 other individuals and organizations submitted detailed comments on the Draft EIR, all raising essentially the same objection: that the City had failed to disclose or evaluate impacts resulting from additional foreseeable residential development that will result from implementation of the Project in combination with the State Density Bonus Law (“SDBL”) as recently amended by AB 1287. As the Final EIR itself acknowledges, AB 1287 requires local agencies to approve substantial additional residential units beyond the standard state density bonus where developers agree to maintain them for very low- or moderateincome households. Since such approvals typically occur ministerially, they will typically be exempt from environmental review under CEQA. Therefore, it is critically important that the current SEIR disclose and evaluate impacts from the full development potential of the Project in tandem with all available state density bonuses. More specifically, as SCRD commented previously, the SEIR’s analysis of impacts on aesthetics, air quality, greenhouse gas emissions, population and housing, public services, transportation, water supply, cumulative impacts, and alternatives, must be updated and recirculated in a revised Draft SEIR.
The Final SEIR’s responses to SCRD and others on this issue are specious, perfunctory, and unsupported by analysis. In a “Master Response” comprising a few short paragraphs, the Final SEIR rejects these well-documented concerns as speculative, arguing that no additional analysis is necessary because it is not reasonable to assume that all sites would develop at a 100 percent density bonus. As explained below, such responses are both substantively incorrect and legally inadequate under CEQA, since it is patently foreseeable that developers will respond to incentives specifically tailored to generate increased affordable housing development in exchange for increases in allowable density, just as they have statewide for years – and Citywide more recently.
First, we would observe that the Project itself proposes structurally identical incentives in the form of the two Downtown Density Bonus options described in the Draft SEIR. Clearly the City does not consider it purely speculative that developers will respond to these incentives – otherwise it would not have devised them and then evaluated them in the SEIR. To enact a local density bonus program designed to
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incentivize developers to respond in a particular manner, while simultaneously disclaiming the likelihood that those same developers would respond similarly to functionally identical incentives in a statewide program, is disingenuous if not nonsensical.
Second, to decline to consider impacts from buildout of additional units under the SDBL and AB 1287 based on the assertion that buildout of all lots with a 100 percent stackable density bonus is speculative is rhetorical gamesmanship. Even if it is unlikely that every developer will seek to build out every lot with the maximum available density bonus, it remains beyond reasonably foreseeable that many developers will respond to the incentives provided by the SDBL and AB 1287 and seek to develop substantially beyond the density and unit counts envisioned by the Project by itself and evaluated in the SEIR.
Third, the question whether alleged changes to the environment are reasonably foreseeable or are instead speculative is a question of fact that is determined based on the evidence in the record of the agency’s proceedings. (Rodeo Citizens Ass’n v. County of Contra Costa (2018) 22 Cal.App.5th 214, 226-218; High Sierra Rural Alliance v. County of Plumas (2018) 29 Cal.App.5th 102, 122.) Here, there is substantial evidence in the record before the City showing that developers have already responded to these incentives in the City of Santa Cruz, and will foreseeably continue to do so. As documented by Santa Cruz YIMBY in its comments on the Draft SEIR a 100 percent density bonus has already been utilized in the City by developers with applications that are currently under review. Specifically:
• 831 Almar Avenue: The base density allows for 60 units. According to Santa Cruz YIMBY, the developers are taking advantage of the SDBL to build 120 units.
• 530 Ocean Street: The base density allowed for the area is 113 units, while the project is proposed at 225 units.
• 2020 North Pacific Avenue. The calculated base density is 90 units, and the project proposes 180 units.
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The CEQA Guidelines make clear that “while foreseeing the unforeseeable is not possible, an agency must use its best efforts to find out and disclose all that it reasonably can.” (Guidelines, § 15144, underline added.) Accordingly, an agency’s finding that assessment of a particular project impact is too speculative to warrant analysis in an EIR will only be upheld if it is supported by actual evidence and analysis. (Ebbetts Pass Forest Watch v. Department of Forestry & Fire Protection (2008) 43 Cal.4th 936.) Here, as discussed further below, the Final SEIR’s dismissive and perfunctory comment responses are wholly unsupported by evidence or analysis and therefore cannot be upheld.1
II. The Final EIR’s Comment Responses are Legally Inadequate Under CEQA.
Separate and apart from the substantive error in the Final SEIR’s comment responses, their perfunctory and dismissive nature renders them inadequate under CEQA. It is well established that a lead agency’s failure to respond to comments raising significant environmental issues frustrates CEQA’s informational purpose and may render the EIR legally inadequate. (See FlandersFound. v. City of Carmel-by-the-Sea (2012) 202 Cal.App.4th 603, 615; Rural Landowners Ass’n v. City Council (1983) 143 Cal.App.3d 1013, 1020.) Responses to comments on a draft EIR must explain in detail the agency’s reasons for rejecting suggestions and objections concerning significant environmental issues. (City of Maywood v. Los Angeles Unified Sch. Dist. (2012) 208 Cal.App.4th 362, 391.) “Conclusory statements unsupported by factual information” are not an adequate response; questions raised about significant environmental issues must be addressed in detail. (CEQA Guidelines, § 15088(c); 1 Save Round Valley Alliance v. County of Inyo (2007) 157 Cal.App.4th 1437, cited in the Master Response, is not applicable. There, the court upheld an agency finding that the potential addition of ADUs to a development where the local code allowed them was speculative and did not require analysis in an EIR. The court’s reasoning, however, is plainly distinguishable: “Although a conditional use permit can be sought for a second unit, there is no factual basis for believing that a future lot owner is likely to do so. . . . Indeed, regardless of the possibility of obtaining a conditional use permit, a lot owner would likely be discouraged, if not precluded, from building a second dwelling unit by the limitation in the CC & R’s to building only “a single-family home.” (Id. at p. 1450.) This stands in stark contrast to the situation here, where not only does State law provide clear incentives to developers to pursue density bonuses, but the record shows they have actually done so in the City of Santa Cruz.
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Cleary v County of Stanislaus (1981) 118 Cal.App.3d 348, 358.) The responses should contain a “good faith, reasoned analysis” of the relevant issues. (Id.) Here, the Final SEIR’s responses to the over 50 comments requesting evolution of impacts under buildout under the SDBL and AB 1287 fail to include the requisite level of good faith, reasoned analysis necessary to comply with CEQA. They consist of conclusory, unsupported assertions that 100 percent build out would be a “worst case” scenario, that such a scenario would be “speculative,” and that the City has no duty to respond further. Given the relative ease with which the Draft SEIR’s shadow analyses, CalEEMod modeling, trip generation assumptions, and other quantitative analyses could have been re-performed with new inputs, the City had a duty under CEQA either to do the new analysis as requested, or to provide a much more thorough and detailed explanation for why it refused to do so. Its decision to do neither violates CEQA.
III. Recirculation of a Revised Draft SEIR is Required.
As SCRD previously explained in its comments on the Draft EIR, recirculation of an EIR prior to certification is required “when the new information added to an EIR discloses: (1) a new substantial environmental impact resulting from the project or from a new mitigation measure proposed to be implemented (cf.
Guidelines, § 15162, subd. (a)(1), (3)(B)(1)); (2) a substantial increase in the severity of an environmental impact unless mitigation measures are adopted that reduce the impact to a level of insignificance (cf. Guidelines, § 15162, subd. (a)(3)(B)(2)); (3) a feasible project alternative or mitigation measure that clearly would lessen the environmental impacts of the project, but which the project's proponents decline to adopt (cf. Guidelines, § 15162, subd. (a)(3)(B)(3), (4)); or (4) that the draft EIR was so fundamentally and basically inadequate and conclusory in nature that public comment on the draft was in effect meaningless.” (Laurel Heights Improvement Assn. v. Regents of University of California (1993) 6 Cal. 4th 1112, 1130, citing Mountain Lion Coalition v. Fish & Game Comm’n (1989) 214 Cal.App.3d 1043.)
Here, for the reasons set forth above, the Draft and Final SEIR remain so fundamentally and basically inadequate, that recirculation of a new DSEIR will be required to allow the public to meaningfully review and comment on the proposed project.
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IV. If the City Council Chooses to Act in Reliance on the Final EIR Despite Its Defects, It Should Adopt the Reduced Project Alternative.
For the reasons presented above, the Final EIR remains fatally flawed and cannot lawfully serve as the basis for CEQA compliance with respect to the City Council’s final action to approve the Project. Nevertheless, if the City Council sees fit to act on the Project notwithstanding the Final EIR’s deficiencies, it should adopt Alternative 1, the Reduced Project Alternative, with Downtown Density Bonus (DDB) Option B only, removing Option A. This Alternative would maintain the existing General Plan and zoning designations in the Project area, and under DDB Option B would incentivize developers to provide 20 percent affordable units while limiting building heights to 85 feet. The Council should eliminate DDB Option A, as it would allow overly massive buildings up to 145 feet tall.
As SCRD and others explained at length in comments on the Draft EIR, under recently adopted AB 1287 residential development projects already qualifying for the existing 50 percent State Density Bonus that commit to constructing additional very low-income or moderate-income units can receive additional density bonuses that in combination can amount to a 100 percent density bonus. Thus, the Project’s primary residential development objectives as described in the EIR are achievable in the Project area without the proposed changes to the General Plan or zoning designations by operation of the State Density Bonus Law as augmented by AB 1287. Adoption of the Reduced Project Alternative with DDB Option B would therefore achieve the City’s goals while minimizing or avoiding adverse impacts identified in the Draft EIR.
Thank you for your consideration of these comments and concerns.
Most sincerely,
M. R. WOLFE & ASSOCIATES, P.C
Mark R. Wolfe
On behalf of Santa Cruzans for Responsible
Development
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Brittany Inclan
From: Henry Gunn <[email protected]>
Sent: Monday, May 12, 2025 11:52 AM
To: City Council
Subject: Santa Cruz Warriors Letter of Support
Dear Councilmembers,
Hello, my name is Henry Gunn and I am a ball boy for the Santa Cruz Warriors. This past year was my first working with the team and it has been an experience I will never forget. The Warriors feel like a family.
Everyone is kind, supportive, and proud to be part of something bigger than themselves. To me and to many others in Santa Cruz, the Warriors represent more than just basketball. They bring people together, inspire kids, and show what community really means. That is why I am so excited about the idea of a new sports and entertainment venue downtown, it would give the team and the city a space that reflects how important this family is to Santa Cruz.
Thank you.
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Brittany Inclan
From: Kate Spencer (S) <[email protected]> Sent: Monday, May 12, 2025 12:00 PM
To: City Council
Subject: Letter for Santa Cruz Warriors
Dear Santa Cruz City Council,
My name is Kate Spencer, and I’m a graduating senior at Colorado College, where I recently completed my thesis analyzing the Santa Cruz Warriors’ economic impact on downtown. Using Placer.ai foot traffic data, stakeholder interviews, and regression analysis, I found that home games generate a 13.2% increase in downtown foot traffic and nearly a 19% boost in restaurant and bar revenue compared to typical winter days.
As someone who grew up in Santa Cruz, the Warriors have always been more than a basketball team.
They’ve been a symbol of community, energy, and pride. I attended many games and basketball camps in the arena growing up and decided to focus on the economic impact of the team. Through my research, it became clear they also play a vital role in stabilizing our tourism-dependent winter economy and supporting local businesses downtown as well as many nonprofits county-wide.
That’s why I’m excited about the potential for a permanent sports and entertainment venue downtown.
The data shows the team already contributes significantly to the local economy, and a new facility would amplify that impact, complement ongoing housing developments, and help revitalize our urban core.
You can read my full thesis below, and listen to a short podcast summary https://drive.google.com/file/d/1ArvfuvEYjFKjGhvCt1-XnKOJ0uRZq5Z5/view?usp=sharing.
Thank you for your time and leadership.
Sincerely,
Kate Spencer
Author, A Downtown Assist – The Santa Cruz Warriors’ Impact on the Santa Cruz Colorado College Class of 2025
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Brittany Inclan
From: Kate Spencer (S) <[email protected]> Sent: Monday, May 12, 2025 12:03 PM
To: City Council
Subject: Re: Letter for Santa Cruz Warriors
Attachments: A Downtown Assist; The Santa Cruz Warriors Impact on the Santa Cruz Economy final (1).pdf
Here is the full report.
Best,
KATHARINE SPENCER
Senior
Business, Economics, and Society
[email protected]
https://www.linkedin.com/in/katespencer831/
o (831) 435-6263
COLORADO COLLEGE
14 E. Cache La Poudre St.
Colorado Springs, CO 80903
www.coloradocollege.edu
From: Kate Spencer (S)
Sent: Monday, May 12, 2025 12:59 PM
To: [email protected] <[email protected]> Subject: Letter for Santa Cruz Warriors
Dear Santa Cruz City Council,
My name is Kate Spencer, and I’m a graduating senior at Colorado College, where I recently completed my thesis analyzing the Santa Cruz Warriors’ economic impact on downtown. Using Placer.ai foot traffic data, stakeholder interviews, and regression analysis, I found that home games generate a 13.2% increase in downtown foot traffic and nearly a 19% boost in restaurant and bar revenue compared to typical winter days.
As someone who grew up in Santa Cruz, the Warriors have always been more than a basketball team.
They’ve been a symbol of community, energy, and pride. I attended many games and basketball camps in the arena growing up and decided to focus on the economic impact of the team. Through my research, it became clear they also play a vital role in stabilizing our tourism-dependent winter economy and supporting local businesses downtown as well as many nonprofits county-wide.
That’s why I’m excited about the potential for a permanent sports and entertainment venue downtown.
The data shows the team already contributes significantly to the local economy, and a new facility would amplify that impact, complement ongoing housing developments, and help revitalize our urban core.
You can read my full thesis below, and listen to a short podcast summary https://drive.google.com/file/d/1ArvfuvEYjFKjGhvCt1-XnKOJ0uRZq5Z5/view?usp=sharing.
Thank you for your time and leadership.
Sincerely,
Kate Spencer
Author, A Downtown Assist – The Santa Cruz Warriors’ Impact on the Santa Cruz
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Colorado College Class of 2025
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A Downtown Assist: The Santa Cruz Warriors' Impact on the Local Economy
A THESIS
Presented to:
The Faculty of the Department of Economics and Business The Colorado College
In Partial Fulfillment of the Requirements for the Degree Bachelor of Arts
By:
Katharine P. Spencer
May 2025
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Photo credit: LATimes.com
Abstract
In 2012, the Golden State Warriors and the City of Santa Cruz came to an agreement that brought the Warriors’ G-League affiliate to town with the construction of a temporary 2,400-seat arena. As the basketball season runs from November to March, the City hoped that the team would stimulate economic activity in the downtown corridor during the low winter tourist season.
An economic impact report measuring the impact of the Golden State Warriors on the San Francisco economy revealed that the team and its new Chase Center Arena have generated around $4 billion over the past five seasons. Accenture worked with the Warriors to quantify direct, indirect, and induced spending that can be traced to the team. This paper aims to similarly evaluate the impact of the Warriors' G-League team on the downtown Santa Cruz economy.
Given that similar resources are unavailable for this study, such as daily sales tax data and the assistance of Accenture, this report employs a combination of new and traditional methods of assessment, including artificial intelligence, stakeholder interviews, ordinary least squares models, regression analysis, door-to-door canvassing, and a smattering of point-of-sale information.
Key findings indicate that the Santa Cruz Warriors' 24 home games generate a 13.2% bump in foot traffic downtown on a game day overall compared to an average winter day, with an approximate 19.0 % increase in revenue for downtown restaurants and bars. Analysis of the seasonal sales tax swing reveals a 14.2% winter downturn, with visitor-dependent restaurant and 2 23.400
hotel sales tax declining by 21.3% between October and March. After using multipliers, the $6.7 million direct spend would further quantify impacts felt in the community.
This study makes use of a range of data sources, including financial reports from the City of Santa Cruz, artificial intelligence from Placer.ai, reports from trade groups including the Downtown Association, Visit California, and Visit Santa Cruz, historical sales tax data as well as insights from 15 of the most affected local businesses. The academic literature review draws upon previous major league and minor league stadium development arguments to contextualize the following research process. In addition, interviews with the Santa Cruz Warriors’ President, COO, and Financial Director, as well as the current and former Mayors of Santa Cruz, and the Director of Economic Development provide perspective on the team's role in the local economy.
A key innovation of this study is the use of artificial intelligence-driven foot traffic analysis from Placer.ai to quantify visitor patterns and assess the team’s ability to drive indirect economic activity.
As expected, regression analysis does not show a direct correlation between the team’s presence and citywide financial indicators, which are tracked too generally to pinpoint the impact of fans attending games at the 2,500-seat Arena, but qualitative data and localized spending patterns describe a meaningful economic contribution. These findings support the argument made in academic literature that minor league teams in smaller, tourism-dependent markets can serve as economic stabilizers, challenging outdated economic impact models studying major league stadiums.
Finally, this research discusses the potential for a permanent mixed-use Warriors arena in Santa Cruz with an additional ~800 seats, suggesting that an increased capacity and number of events could further strengthen the team's role as an economic driver in the downtown core.
KEYWORDS: (Arena Development, Localized Economic Impact, Minor League Sports) Acknowledgements
There are many people to thank who helped me pull together and pull off this report.
Hilary Bryant had the idea, gave me guidance (always), and answered random questions for months. Chris Murphy gave me full access to the Warriors organization and was patient every time I went down a new rabbit hole for information. Jorian Wilkins, Terrence Concannon, Angela Chesnut, and Rebecca Unitt were all generous with their time, offering wise perspectives and kindly introducing me forward to help with information gathering. O, thank you for dealing with four months of thesis. Mostly my mama, for the DoorDash and unwavering support over the long winter months of writing, stacked papers, and distractions.
Honor Code:
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A Downtown Assist: The Santa Cruz Warriors Impact on the Local Economy Introduction 5
The Downtown Economy 8
The Santa Cruz Warriors: Best in Class 14
The Santa Cruz Warriors: Direct Spend 19
Academic Literature Review 22
Theory 27
Quantitative Methodology 29
Quantitative Results 33
Qualitative Methodology 41
Qualitative Results 47
Conclusion 50
References 54
Interview Transcripts 57
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Introduction
The Big Dipper is emblematic
of Santa Cruz, California. The
100-year-old wooden roller coaster
attracts over two million tourists a year
to the sunny beach town on the
Monterey Bay. It is also accurate to
describe the seasonal swing that affects
the nearby downtown corridor in roller
coaster terms, as small businesses meet
peak demand in summer and weather a
winter season with little tourism.
Santa Cruz is a mid-size
California city with a mild climate, a
world-class university, growing tech
industry and stunning natural beauty. It
is also grappling with intractable
state-wide challenges like a shrinking labor force, a severe lack of affordable housing, the homeless crisis and increasing climate-related disruptions. Hourly employees are the most affected by these issues and the winter economic slowdown only exacerbates the difficulty of making enough money to live and work in Santa Cruz. The team moved into Kaiser Permanaente Arena, still the biggest indoor entertainment venue in the county, in December 2012.
The long-debated challenge of how to mitigate the seasonal revenue swing was addressed in part by negotiations to bring the Warriors to Santa Cruz. The Warriors became the fourth NBA team to own their G-League affiliate in 2011, when they purchased the Bismarck-based Wizards D-League franchise. Gatorade entered into a multi-year expanded partnership with the NBA in 2017 for naming and logo rights for the developmental D-League, which has been known since as the G-League.
“In our discussions leading up to the vote to bring the Warriors to Santa Cruz, the city council recognized the significant potential for synergy between the team and downtown to drive off-season economic activity,” said Hilary Bryant, Mayor of Santa Cruz at the time. "We also hoped this would enhance the connection between the Beach Boardwalk and our central shopping district, benefitting local businesses and strengthening our community." The team’s economic impact is a particularly interesting case study because both Santa Cruz and the Warriors G-League team are ideal examples of their kind. The effects of one upon the other is illustrative for other small cities and minor league teams. According to Economic Development Director Bonnie Lipscomb, the Warriors have been a huge popular success. Yet the next chapter for the Santa Cruz Warriors is uncertain. The team needs a larger, permanent stadium with training facilities and infrastructure that can support off-season events and concerts. With the popularity of the Golden State Warriors regionally and nationally, the franchise has received considerable interest in relocating the G-League 5 23.403
Warriors to a permanent home elsewhere in the Bay Area, where more funding would be available to build a stadium.
The City has been actively engaged in discussions and options for creating a permanent home for the Warriors in Santa Cruz. but, “In the event we can’t figure out a way to facilitate a building in Santa Cruz, then we’ll have to evaluate other options - because we can’t play in the building we’re in now forever,” said President Chris Murphy.1 Literature on stadium economics has become more positive as single-use major league stadiums have evolved toward multi-use formats integrated into new housing and entertainment developments. Early studies, such as Baade & Dye (1990) declared that stadiums were a misuse of public funds and did not deliver an appropriate return on investment of public funding. Subsequent research by Agha (2011) investigating the impact of minor league multi-use stadiums in smaller cities, have demonstrated favorable outcomes.
This research evaluates the economic impact of the Santa Cruz Warriors upon downtown Santa Cruz, hypothesizing that the team serves as an effective economic driver by attracting visitors and increasing consumer spending during the off-season, while also offering data that could be applied to the question of how a proposed arena expansion may amplify any benefit.
By performing analysis on past
seasons’ data from Kaiser Permanente
Arena and the Warriors as well as the City
of Santa Cruz and the Tourism
Association, this report aims to describe
the economic relationship between the
Warriors and the surrounding community.
It includes personal interviews with
fifteen of the most affected local
businesses based on AI foot traffic and
customer tracking data. These insights
were provided by Placer.ai (an
anonymized cell phone traffic tool shared
by the City of Santa Cruz). Other
interviewees include the current and
former mayor, principals at the Santa Cruz
Department of Economic Development,
Visit Santa Cruz, the Santa Cruz
Beach/Boardwalk, the team partnered
Courtyard by Marriott, and the Santa Cruz Downtown Association.
According to the final model outlined below, home game days see an increase in downtown foot traffic of 13.19% compared to an average winter day. Fans come to watch games in bars and restaurants, and weekend days typically see a bump in foot traffic. Summer leads to a 1 Santa Cruz Local. (2022, February 1). Santa Cruz Warriors Explore New Arena Project With Housing. 6 23.404
29.72% increase in foot traffic overall compared to winter, congruent with results found when looking at seasonal tax data.
By quantifying the impact that a 2,500-seat arena has had on downtown Santa Cruz, this report aims to inform the increased effects on downtown businesses with the proposed stadium.
Significance of specific variables measured indicates the presence of a seasonal economy and proves that the small size of the stadium relative to the common economic conditions measured economic impact reports creates a unique relationship. Therefore, the commonly noticed effects of Team/Arena presence are not reflected in sales tax, GDP, or unemployment rates.
This research establishes a clear positive impact on downtown restaurants and businesses from the Warriors game nights through qualitative and quantitative analysis. The basketball season provides a natural winter entertainment attraction for both locals and tourists in Santa Cruz. This blend of quantitative regression analysis and qualitative economic context delivers a comprehensive argument, capturing both the measurable financial impact and the nuanced local dynamics of the Warrior’s role in the downtown economy of Santa Cruz.
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The Downtown Economy
Typical of California coastal communities, the Santa Cruz economy is heavily reliant upon sun-seeking visitors. Tourism generates over $1.58 billion in annual expenditures and supports approximately 9,000 jobs countywide. One out of every six jobs in the county is directly or indirectly tied to the sector, demonstrating the extent to which local businesses depend on a steady flow of visitors.2 Terence Concannon, CEO of Visit Santa Cruz, noted, “Santa Cruz’s number one industry is tourism, and our number one product is memories, good times, and fun. The more we can add to that, the better it will be for everyone.” Downtown Santa Cruz is centered along twelve blocks of Pacific Avenue, naturally bounded by the San Lorenzo River two blocks over on the east side and the Warriors Arena at the south end, near access to local beaches and the Boardwalk. For home games, basketball fans park at the north end of downtown in city garages, or for free at the local Trader Joe’s or CVS lots, and walk down Pacific to the Arena, stopping for dinner, or to shop or have a drink. This bustling downtown district encompasses 160 businesses, including restaurants, movie theaters, art studios, salons, a huge independent bookstore, a busy art museum, and world-renowned surf retailers.
Jorian Wilkins, director of the Santa Cruz Downtown Association, described it as "jammed with small businesses offering a wealth of options for food, shopping, and entertainment, who struggle with a winter downturn in tourism, staffing shortages, and 2 Workforce Development Board of Santa Cruz County. (2022). Tourism And Hospitality Report. 8 23.406
ever-increasing costs. The Warriors games bring visitors and remind residents to come downtown to pre-game or grab dinner -- we're happy for the boost and exposure it gives our businesses.”
Downtown Santa Cruz’s heavy dependence on tourism creates a predictable fluctuation that leads to an unstable off-season economy. The winter basketball season is ideally timed to help offset the seasonal lull. Based on sales tax data, the seasonal downturn is approximately 14.2% lower in fall and winter than during the summer. Strikingly, the seasonal fluctuation in the restaurant and hotel sector is 19.0% between summer and winter seasons.
Karl Rice, President of the Beach Boardwalk, added, “Seasonality affects all of the businesses near the beach and downtown. At the Boardwalk, we have strategic marketing to attract visitors on winter weekends so downtown is more volatile or sensitive to the seasonality.”3 Wilkins agrees, “The downtown corridor is significantly affected by the number of tourists in town and whether events are going on nearby.” The Solution is Clear and Under Construction
As Santa Cruz races to build and increase the housing stock and 1,600 new units are added to the downtown corridor alone, this research gains importance. “Restaurants, cafes, and social venues topped the list of what city dwellers say are the most important features of a great business district, followed by parks and open spaces, access to transit, shopping, theaters, museums, and other cultural attractions.” Downtown is the city’s economic and social epicenter, but the strategic integration of entertainment, housing, and restaurants with the goals of the community will define its future success.
The formal economic development strategy of the City of Santa Cruz embraced this approach. Written in response to the devastating 1989 Loma Prieta Earthquake, the City’s Beach and South of Laurel Area Plan highlights tourism as a cornerstone of the local economy and the need for integrated land use strategies to support both visitors and residents.
The plan notes, “Changing national tourism trends document growing demand for higher quality facilities and well-maintained attractions.”
Bonnie Lipscomb, Santa Cruz’s Economic Development Director, addressed the trend, commenting, “[The Warriors'] presence in the south of Laurel neighborhood of lower Pacific Avenue and Front Street has helped revitalize the area. Several significant housing projects are in development or have been completed, including the 205-unit Anton Pacific market-rate housing project and the 100% affordable Pacific Station South housing project.” This construction reflects broader trends in Santa Cruz, see Placer.ai image below) With 1600 new housing units in the works, downtown will clearly play a pivotal role in the future of Santa Cruz. Richard Florida, a social and economic theorist who studies American cities and the author of several books on the subject, is a professor at the University of Toronto and NYU. In his article, Assessing the Post-Pandemic Future of 3 Interview conducted March 12th, 2025
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American Cities, Florida writes, “As remote work continues to reshape urban landscapes, the role of
downtowns is
shifting from
being strictly
business-oriented hubs to spaces designed for living, socializing, and cultural engagement.” The Tourism and Hospitality Report’s (2022) IMPLAN, impact analysis for planning, modeled by BW Research Partnership, further quantifies the economic contributions of visitors by analyzing spending patterns, job creation, and revenue generation across industries. The model further supports the strategic development of entertainment and high-quality facilities by demonstrating how a thriving hospitality sector stimulates demand for local suppliers, contractors, and service providers, extending tourism’s economic impact beyond direct spending.
A key takeaway from this plan is the importance of mixed-use development to balance economic growth with community well-being. The report advocates for blending residential, commercial, and recreational spaces to create a vibrant, pedestrian-friendly environment that encourages both tourism and local engagement. The plan stresses that Santa Cruz’s ability to integrate these spaces effectively will determine the long-term sustainability of both its tourism sector and residential neighborhoods. By promoting walkability, high-quality amenities, and 10 23.408
economic diversity, the city can ensure that tourism continues to be a driver of growth without compromising the quality of life for its residents.
Mayor Fred Keeley ties housing construction to the success of the Downtown Expansion Plan, “If the Warriors hadn’t come to Santa Cruz, the downtown expansion plan would look very different. By design, the plan is to build an entertainment district, all centered on a new Arena, with 1,600 units of new housing.”
Indeed, the city is pushing forward to build higher-density housing, mixed-use developments, and transit-oriented projects at the south end of Pacific. Santa Cruz is working under severe pressure from the state of California to expand its housing stock and bring down median prices, create more affordable housing units and mitigate the homeless crisis. 4 Proponents for the new Arena argue that the proposed new building would feature improved acoustics to support larger performance-based events, unlike the current arena.
Santa Cruz downtown does not have a venue with more than two thousand, more for concerts and non-basketball events.5 A larger venue would allow bigger acts to come to town and provide more nights of entertainment, even during weeknights, to amplify the Warriors' economic impact on downtown. Detractors argue that Santa Cruz should be focused on the development of affordable housing solutions to homelessness and the effects of climate change. They argue that any investment in sports should go towards surfing or mountain booking, sports intertwined with the culture of Santa Cruz. 5 See the market landscape in figures 1.2 and 1.3 below 4 Santa Cruz County, Santa Cruz County Economic Outlook Report (2023), https://www.santacruzcountyca.gov/VisionSantaCruz/Budget/EconomicOutlook.aspx. 11 23.409
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The Santa Cruz Warriors - Best in Class
The Santa Cruz Warriors have earned a broad range of
accolades and are consistently honored as the best-run franchise in the 31-team G-League system. Since moving to Santa Cruz in 2012, the Warriors have earned four conference and two national titles: 2015 and 2019. The team has been awarded Franchise of the Year by the NBA four times: 2018, 2021, 2022, and 2024.
This achievement is particularly impressive, as the accolade was first introduced in 2018. The Santa Cruz Warriors attain franchise of the year with outstanding community involvement and
revenue creation above and beyond other G-League teams. Santa Cruz Warriors Alum and Golden State Champion Kevon Looney said, “To have a team right there, a team that’s running the same things that we usually run, having a great environment to play in - the crowd is great…The town is great. So, going down there as a young player, being able to develop, and play at a high level and play in a system that we’re running up here has always been great.”6
In 2024, the Santa Cruz Warriors finished first in both ticket sales and partnership revenue, setting a new G-League record. The team closed out the 2023-24 regular season with an 18-game sellout streak.7 From 2016–22, Kaiser Permanente Arena sold out 110 straight games, which could've gone
longer if not for the COVID-19 pandemic.8
Noting the success of the Warriors
compared to other franchises, Mayor Fred
Keeley observed, “I went to five or six
different G-League games with the team
over the years, and if they’ve got three or
four hundred people, that’s about right. If
they get a thousand people at a game,
they’re not quite sure what happened.”
Confirmed by a City Council report from
September 2023, the Santa Cruz Warriors
have been a popular success in the City of
Santa Cruz, enjoying sold-out games with a dedicated regional fan base. Positioned strategically, the Santa Cruz Warriors Arena was designed to contribute to the revitalization of the lower Pacific/Front Street area, strengthening the connection between Downtown and the Beach/Boardwalk district. Their presence in the South of Laurel neighborhood of lower Pacific Avenue and Front Street has helped revitalize the area and bring together ‘a diversity of fans’9
9 City of Santa Cruz. (2023). Summary sheet for amendments to extend the term of the ground lease. 8 Anderson, M. C. (2023, March 14). Santa Cruz Warriors celebrate a decade of basketball by the bay: Exploring the unpredictable and thrilling world of the “Sea Dubs”. Good Times Santa Cruz. 7 NBA G League. (2024). NBA G League announces 2023–24 team business awards. 6 San Francisco Chronicle. (2024, December 25). A perfect pairing: NBA’s Warriors and G League affiliate in Santa Cruz.
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Since the 2023 report was published, the Santa Cruz Warriors have extended their lease at the temporary Kaiser Permanente Arena through September 2026 with two optional one-year extensions and an early termination option starting in September 2025. This extension allows the team to continue playing in Santa Cruz while exploring plans for a permanent arena.
’The G-League has played a crucial role in the development of high-profile players.
For basketball fans, it is a unique opportunity to witness the growth of talent firsthand,” said Mayor Keeley, who has witnessed a lot of basketball as he sits courtside at every home game. “About 60% of NBA players have played in the G-League. Ten years ago, that wasn’t even close to the case. The NBA has emphasized the G-League, and Santa Cruz has benefited from that shift”
Last season, the number of roster spots open for players on two-way contracts expanded to three, highlighting the trend of more G-League players ‘playing up’. The G-League serves as a bridge, not just for players hoping to reach the NBA, but also for fans developing a passion for the game. The Santa Cruz Warriors exemplify this with their consistent attendance levels and high community involvement. The team also benefits from the success of the high-profile Golden State Warriors, who have won the NBA title four times since their farm team moved to Santa Cruz in 2012 (2015, 2017, 2018, and 2022) and played all the way to the Finals in both 2016 and 2019. The Warriors' dominance and marquee players created excitement and momentum for the franchise throughout the Bay Area.
It is entirely possible for fans to get familiar with players in the small KP Arena who later appear in the NBA Finals. Jordan Poole, Kevon Looney, Damion Lee, and many others have all played for Santa Cruz while developing into key players for the championship team.
Household name NBA players like Seth Curry, James Wiseman, Jeremy Lin, and Klay Thompson have all played for the Santa Cruz Warriors in rehabilitation stints.
The near dynasty status of the Golden State Warriors, sold out crowds at the 18,000 seat Chase Center as well as the recent expansion of the WNBA to the Bay Area underscore the strong consumer demand for professional basketball in the Bay Area, reflecting a growing market willing to invest in live sports entertainment, merchandise, and related experiences.
Economic Portrait: The Potential of Santa Cruz Warriors Fans This section examines the demographic composition and spending profile of the Warriors’ fan base.
Data describing Kaiser Permanente Arena visitors from Placer.ai and Visit Santa Cruz indicate a significant overlap in the geographic origins and travel behaviors of Santa Cruz Warriors fans and general tourists. (See Figure 2.2- Trade Summary and Visitor by Origin). Both datasets show that the majority of visitors come from within California, particularly from key metro areas such as San Francisco-Oakland-San Jose (20.1%) and Sacramento/Stockton/Modesto (20.4%). Visit Santa Cruz data highlights that 79.1% of domestic visitors stay overnight, suggesting that Warriors fans who travel from the same regions would also spend the night, 15 23.413
making them functionally identical to general tourists in terms of spending potential. Given this alignment, the data provided by Visit Santa Cruz on hotel revenue trends can reasonably be extended to game attendees, for both groups follow similar travel patterns, which reinforces the idea that sports tourism contributes to the hospitality economy in the same way as traditional leisure travel.
Placer.ai data on visitor behavior further strengthens this connection by detailing overlapping travel patterns between Santa Cruz tourists and basketball attendees, suggesting that visitor spending patterns extend beyond single-event attendance. In fact, according to Visit Santa Cruz, 59% of domestic visitors return annually. This indicates that sports-related attractions can function as key economic drivers, helping to sustain local businesses, hospitality, and tourism sectors throughout the year. These findings provide strong support for strategic investment in a multi-use arena in Santa Cruz, particularly one designed to maximize non-game-day utilization. By expanding Kaiser Permanente Arena’s role beyond hosting Warriors games to include concerts, trade shows, and community events, Santa Cruz could create a more stable year-round economic engine.
Community Involvement
The Warriors' ‘Swishes for Dishes’ Program has donated 162,020 meals to the Second Harvest Food Bank since 2020. The Warriors also have a partnership with UCSC Athletics to host both basketball and volleyball in the arena at reduced rates, ensuring that the teams can continue to compete at the Division III level. Furthermore, the UCSC basketball teams run the third quarter fundraiser at every home game. Players sell bags of five foam balls for $5 each, with fans hoping to land it in the buckets set up at mid-court in the ball toss. All proceeds go to UCSC athletics, which adds up to a $23,000 contribution annually. 16 23.414
As an organization,
COO Kao mentioned that
the Warriors also prioritize
inclusive community
engagement through theme
nights, such as Women’s
Empowerment Month,
Lunar New Year, and Los
Warriors Night, which
highlight diverse identities
while raising funds for local
non-profit organizations.
Kao emphasized the
Warriors’ commitment to
ensuring these funds directly
benefit local causes, stating,
“That money, every time we
do it, goes to a different
nonprofit locally. We’ve
done it with the Boys &
Girls Club to help out with
the youth and some of the youth programs they have,
we’ve done it with Pride, we’ve done it with Black Surf Club, the Monterey Bay National Marine Sanctuary
Foundation, just to name a few.”
Themed jersey nights and fundraising events benefit local charities, including Boys & Girls Club, Black Surf Club Santa Cruz who set record of $6,000 raised through the
“Santa Cruz Surfers” jersey auction, Monterey Bay
National Marine Sanctuary Foundation who partners for an annual beach cleanup with the team, front office and
season ticket holders, and many others. Fundraising efforts theme nights see proceeds supporting various local
non-profits. Events held in the Arena also generate
recognition for the team and nonprofits, for example the annual August Stuff the Bus event, which donates school supplies to local kids.
Over the years, the Arena has served as a COVID-19
vaccination center (2021), a wildfire resource center during the devastating 2020 fires in the County. It has also been a polling site for elections, highlighting its multi-functional role as a civic asset beyond just a sports and entertainment venue. With ninety-two community events held in 2024 and more 17 23.415
than one hundred in previous years, the Warriors drive awareness for local nonprofits and strengthen relationships within the community.
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The Warriors: Direct Spend
Since 2020 G-League teams have been operating as self-sustaining organizations without financial support from the NBA, according to Deb Gozzo, the team’s finance director. The team receives a small bonus for winning Franchise of the Year and/or making the playoffs and advancing to the finals. They are also compensated for most NBA- affiliated events held in the Arena. The team’s direct spend benefits the local economy by creating jobs, supporting local vendors, and generating tax revenue while providing engaging family-friendly entertainment for sports fans.
Direct spending includes all immediate economic transactions related to team operations, such as ticket sales, concessions, merchandise, salaries, vendor payments, and hotel stays. Figures provided by the team from the 2023-24 season give an accurate picture of immediate economic impact. Overall, the Santa Cruz Warriors account for $6.77 million in annual direct economic impact on the local economy, based on 2023-24 season figures provided by the team. This spending supports jobs, local businesses, and city revenues through ticket sales, concessions, merchandise, payroll, vendor contracts, hotel stays, and charitable contributions.
Total attendance reached 62,654 people across 24 home games, including the 18-game sellout streak. Ticket price averaged $39.72, adjusted with inflation a $27.07 ticket in 2013-14 would be $35.52, indicating ticket prices have remained relatively stable despite increasing popularity. Total ticket revenue in the past season grossed around $2.5 million.
Total concessions and merchandise revenue came to just over $674,000. Total full-time employment payroll equals around $2.22 million including full-time and part-time staff.
Vendor and contractor spending in partnership with local businesses equals $941,286 and hotel spending on both teams amounts to almost $360,000. (full list below). The Arena pays the City of Santa Cruz an annual land lease payment of $35,000.
The team has 25 full time employees and 35-50 part-time employees, depending on the Arena’s needs. Their near $280,000 investment in part-time labor provides employment opportunities for local businesses, while nearly $1 million spent on third-party vendors stimulates local businesses from food suppliers to maintenance services. With ninety-two community events in 2024 and more than one hundred in previous years, Charitable donations exceeding $59,000 annually support dozens of nonprofit initiatives like Swishes for Dishes and further strengthen community relationships. Additionally, the team’s hotel spending of over $350,000 annually for both home and visiting teams boosts the local hospitality sector, increasing demand for lodging, restaurants, and tourism-related businesses.
The primary focus of an economic impact report is to quantify the increased economic impact of a home game. In so doing the organization/ firm hired will conduct in-depth customer analysis to examine the increase in consumption by event attendees. To more carefully analyze the economic impact that Santa Cruz Warriors attendees generate, more research and tracking must be done to compartmentalize individuals into distinct groups. Based on this research, these groups would likely be: locals, day trip visitors and California families on weekend getaways.
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When adjusted for inflation, key spending metrics provided by the team indicate a growing and increasingly engaged local Warriors fan base. Per capita ticket spending has increased by approximately 14% since 2018-19, reflecting both rising prices and sustained demand despite economic fluctuations.
Average attendance per game has rebounded
to pre-pandemic levels, with recent seasons
surpassing full capacity, signalling strong fan
loyalty and a need for expanded seating.
Concession spending per fan has grown by
23% in real terms, suggesting that attendees
are spending more on food and beverages,
further enhancing the overall game-day
experience. Combined with a 17%
inflation-adjusted increase in in-arena
merchandise spending, these trends
demonstrate a shift toward higher consumer
engagement, reinforcing the economic
viability of a new or upgraded arena to
maximize revenue potential.
The rise in per-game spending, noticeably in
merchandise, indicates that Santa Cruz
Warriors fans are not only increasing in
number but are also becoming more loyal and
engaged. Their purchasing behavior supports both in-arena vendors and local businesses, such as restaurants, bars, and retail shops, creating a broader economic ripple effect. It is important to note that fan attendance is influenced by team performance, as proven by economic regressions in this paper.
Indirect Spend
As mentioned in the literature review, economists and scholars disagree about the validity of economic impact reports in assessing the true impact of a professional sports team on its local community. An ex ante (predictory) study of the KP Arena, such as a feasibility or economic impact report, would quantify indirect spending as a key element of the stadium's economic benefit.
The magnitude of indirect spend depends on the size of the ‘multiplier’, a scaling factor that links dollars spent directly on professional sports to a net effect on the entire local economy. For decades, economic scholars have used multipliers to investigate the net effect of specific types of spending on the overall economy. Multipliers are still a useful pedagogical tool to remind us, for example, that a $10 tip left at a restaurant goes into the server's pocket and is subsequently spent elsewhere, thus providing an economic benefit to many others in the local economy.
Economists also discuss problems associated with using multipliers to evaluate the impact of professional sports on the economy of a metropolitan area. For example, Noll and 20 23.418
Zimbalist (1997) argue that, “at best the multipliers used in ex ante impact studies overstate the contribution that professional sports make to an area's economy by failing to differentiate between net and gross spending and the effects of taxes, among other factors.” At worst, they argue, “Multipliers are completely inappropriate tools for analyzing the effects of small, specialized projects involving an atypical segment of society.” Overall, the Santa Cruz Warriors account for $6.77 million in annual direct economic impact on the local economy, based on 2023-24 season figures provided by the team. This spending supports jobs, local businesses, and city revenues through ticket sales, concessions, merchandise, payroll, vendor contracts, hotel stays, and charitable contributions.
Induced Spending
Determining the induced spending created by team activities can be calculated by using local economic multipliers to predict the recirculation of the salaries and additional direct spending throughout the local economy. This would be calculated with figures unavailable to the author of this report, such as daily revenues from surrounding restaurants POS’ or city tax data. This number should be researched and quantified to further assess the indirect financial impact of the team. After using multipliers, the $6.7 million direct spend would further quantify impacts felt in the community.
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Academic Literature Review
This report strives to review and evaluate the available data and research pertaining to the economic effects of municipal stadiums. Academic literature has changed dramatically as single-use major league arenas have evolved toward multi-use formats integrated with housing and entertainment developments. Well-known early studies, such as Baade & Dye (1990), found that stadiums were a misuse of public funds and did not deliver an appropriate return on investment. More current research by Agha (2011) investigated the impact of minor league multi-use stadiums in smaller cities, finding that they have demonstrated positive impacts.
The Economics of Stadiums: Ex Ante or Ex Post?
The development of sports stadiums has long been debated in economic literature, with researchers analyzing their potential to drive economic growth, increase tax revenues, and stimulate local business activity. Proponents argue that stadiums serve as catalysts for urban development, attracting tourism, boosting employment, and generating spending for surrounding businesses. The literature on sports and economic growth includes ex ante economic impact analyses and ex post evaluations using economic data from cities and regions.
Ex ante studies are predictive assessments that forecast the potential economic impacts of building a new stadium or attracting a professional sports franchise before such projects are initiated. These studies typically focus on potential job creation, increased local spending, and other economic benefits that are anticipated from the project. Many ex ante studies tend to provide overly optimistic predictions regarding the economic impacts of sports facilities. Critics argue that these analyses often rely on inflated multipliers that do not accurately capture actual economic benefits.
In contrast, ex post analyses provide retrospective evaluations of the economic impacts of stadiums and sports franchises after they have been built or initiated. They utilize real-world data to assess whether the anticipated benefits materialized and examine the actual changes in local economies. Ex post analyses are considered more reliable because they are based on actual outcomes rather than projections. They can offer a clearer picture of how sports franchises and stadiums affect local economies in terms of real income, employment, and other growth patterns. Researchers like Baade and Dye (1990) and Coates and Humphreys (1999) employed ex post evaluations to analyze changes in metropolitan areas' economies over time, arguing that comparing regions before and after the introduction of a sports franchise can yield valuable insights into the sports environment's true impacts. Ex post studies examine whether the existence of sports franchises leads to sustained growth in personal income or employment levels in the area. The findings from ex post analyses often lead to more nuanced understandings of the value of sports investments and highlight the need for careful consideration of opportunity costs when initiating such projects. 22 23.420
This will be an ex-post analysis of the effects of the Santa Cruz Warriors' presence in the Downtown Area, conducted through stakeholder interviews, data collection, and regression analysis.
Stadium Economics: Smaller Teams in Smaller Markets
Subsequent researchers such as Agha (2013) and Johnson (1991) provide key insights into the role of minor league stadiums in smaller markets, emphasizing their potential for economic stability when strategically planned. By examining venue utilization, urban development, and the role of minor league teams in fostering local identity, Agha and Johnson offer a more relevant framework for evaluating the economic impact of sports in mid-sized cities like Santa Cruz.
Agha’s (2013) study “The Economic Impact of Stadiums and Teams: The Case of Minor League Baseball” provides a relevant framework for evaluating the economic impact of sports venues in small markets. Agha’s findings indicate that minor league teams contribute to local economic stability, particularly in cities where their stadiums are strategically integrated into the downtown core and designed for high utilization beyond sports. Notably, Agha’s research emphasizes that per capita income growth is positively correlated with stadiums that host a variety of events, including concerts, conferences, and community gatherings, rather than being used solely for sporting purposes.
Agha’s research reinforces the importance of venue utilization beyond sports. Minor league stadiums that were used solely for sporting events had weaker economic benefits compared to those that served as multi-purpose community hubs.
In “Development Logic and Stadium Planning” (1991) Johnson argues that while minor league stadiums may not independently transform local economies, they serve as crucial drivers for urban development when implemented with a clear strategy. Johnson studied the direct economic impact of minor league teams relative to a community’s total economy and the presence of urban development efforts linked to stadium construction. He also considered community image and branding effects resulting from sports investment and public vs. private investment strategies in stadium projects.
Johnson's models found that minor league teams alone do not significantly impact a city’s total economy, but that stadiums can drive urban development when part of a larger economic strategy. His report highlighted the importance of "development logic" in planning stadiums, meaning they should be integrated with housing, retail, and infrastructure improvements to maximize benefits. Johnson concluded that successful stadium projects focus on downtown revitalization, new development, and enhancement of community image, rather than relying solely on game-day revenue.
The Economics of Stadiums: Size Matters
The literature on stadium development shows that the potential benefits from sports teams and their home arenas are particularly relevant for mid-sized cities, where a professional or minor league sports team can become a central economic and cultural driver.
However, skeptics challenge the extent of these benefits, pointing to cases where stadium 23 23.421
investments fail to yield substantial long-term economic gains. The following literature review examines empirical studies and economic models that assess the true impact of stadiums on local economies.
“The Impact of Stadium and Professional Sports on Metropolitan Area Development” by Baade & Dye (1990) is the most widely cited study arguing that sports stadiums fail to generate substantial economic benefits. Baade and Dye found that the presence of a new or renovated stadium has an uncertain impact on the levels of personal income and possibly a negative impact on local development. “Results should serve as a caution to those who assume or assert a large positive stadium impact.” Their key arguments include the presence of the substitution effect, that money spent at stadiums would have been spent elsewhere.
Second, the displacement effect argues that stadiums merely shift, rather than create, economic activity and that stadium buildings outlast their economic benefits to the surrounding area.
“The Growth Effects of Sport Franchises, Stadia, and Arenas” by Dennis Coates & Brad R. Humphreys (1999) examines the correlation between professional sports franchises and venues, and real per capita personal income in 37 U.S. metropolitan areas from 1969 to 1994. The authors argue that economic impact studies are frequently commissioned to demonstrate the benefits of new stadiums or franchises, but their results often align with the interests of those who order them, so a comprehensive evaluation of public financing for sports stadiums should assess whether the projected economic benefits are realized. “The Economic Impact Of New/Renovated NFL And MLB Stadiums On The Income Of The Surrounding Metropolitan Statistical Area.” by Branden Makara (2020) narrowed the positive effects of new stadium construction through the addition of a control variable accounting for the honeymoon period a stadium experiences two years after construction.
Makara found that Major League Baseball stadiums had a stronger positive economic impact than National Football League stadiums, likely due to the greater number of home games (81 vs. nine per season). Makara studied personal income growth in metropolitan areas before and after stadium construction, comparing MLB and NFL stadium investments and economic impacts, the effects of new vs. renovated stadiums on local markets, and using the surrounding urban environment and location as factors in determining stadium success.
Makara’s models show that new stadium construction had a more positive impact on income growth than stadium renovations, particularly in mid-sized markets. Stadium location and urban integration played a major role in economic outcomes; stadiums in entertainment districts and mixed-use areas performed better than those in isolated locations. Makara’s research underlines the proposal that properly planned stadium investments can generate long-term economic benefits, particularly in mid- sized cities that use sports facilities as multi-purpose hubs.
Overall, traditional stadium valuation methods using data such as a city’s aggregate personal income or property prices as indicators are too broad to measure the effects of a stadium with fewer seats in proportion to the MSA’s population than is traditional. 24 23.422
These methods are inapplicable to studying the impact of a minor league team and mixed-use arenas, both of which have emerged since Baade & Dye published in 1990.
Another key problem with applying this research to Santa Cruz is that Baade & Dye’s research focused on NFL stadiums in major cities like Houston, Detroit, and New Orleans in the late 1980’s, places with economic challenges dramatically different from Santa Cruz’s minor league, small-market, non-manufacturing economy.
The NFL model includes just nine home games per season, whereas basketball teams play 24 home games, spreading their economic impact more broadly. Baade & Dye also studied stadiums at the end of their 30-year lifecycles (Superdome, Silverdome, Astrodome) within sight of the time they were demolished. None of the stadiums studied were within walking distance of a retail district, designed for mixed use or developed to support other forms of entertainment with proper acoustics, staging, restaurants or retail.
Stadium Economics: Conclusions Drawn
Overall, studies looking at the economic impact of minor league stadiums agree that the relative positive effect of a team/arena depends on location, community involvement, and long-term development strategies. By focusing on various metropolitan contexts and variables such as the presence of urban development efforts linked to stadium construction, population, and geographic location, the academic literature illustrates the changing landscape of stadium economics. These studies show that both methodology and contextualization play crucial roles in understanding the true economic impact of sports teams and facility construction.
While much of the discourse has centered on major league stadiums in large urban centers, such as the analyses conducted by Baade and Dye (1990), Coates and Humphreys (1999), and others, there is an increasing acknowledgment of the distinct economic dynamics present in smaller communities. Research by Agha and Johnson highlights that these smaller towns and cities often operate under different economic principles compared to their larger counterparts. In smaller communities, local engagement and community identity play a crucial role in fostering economic vitality. Unlike major urban centers that may derive substantial economic benefits from a wide array of tourism and commerce driven by the presence of major league sports, small towns frequently rely on creating a sense of place and belonging. An example of this phenomenon can be seen in slogans like "Keep Santa Cruz Weird," which encapsulate the spirit of local culture and community pride.
The presence of a minor league team, such as the Santa Cruz Warriors, can be particularly significant in these contexts. Agha and Johnson demonstrate that minor league teams often serve as a focal point for community activities and identity, bringing residents together and instilling a sense of pride and cohesion. They can enhance local engagement by providing families with affordable entertainment options and opportunities to participate in community events.
In contrast to major league teams, whose economic impacts can be muddied by larger, more complex metropolitan metrics, the effects of minor league teams in smaller areas can be more directly observed and tied to their local economic health. In summary, as discussions 25 23.423
about the economic impact of sports teams continue to evolve, it is essential to consider the unique role of minor league teams in smaller communities. Previous research by Agha and Johnson suggests they contribute significantly to the local economy by reinforcing community identity, driving engagement, and promoting local spending, all of which can foster a more resilient and vibrant economic environment.
This debate is especially pertinent to Santa Cruz, where the current 2,500-seat arena housing the Santa Cruz Warriors plays a unique role in the city’s economy. My research quantifies this impact through regression analysis, measuring the relationship between game nights and local economic indicators such as sales tax revenue and hospitality sector performance. Unlike large-scale metropolitan areas where stadium effects may be diluted, Santa Cruz’s smaller market allows for a clearer measurement of these economic benefits.
My analysis incorporates Placer.ai foot traffic data, demonstrating a tangible increase in downtown activity on game nights, reinforcing the argument that the Arena serves as a significant economic driver.
Furthermore, this study acknowledges the seasonal nature of Santa Cruz’s economy, positioning the basketball season as a crucial source of winter tourism and entertainment spending. By blending quantitative econometric modeling with qualitative considerations of local business activity, my research provides a comprehensive assessment of the Arena’s role in the city’s financial landscape. This contributes to the broader discussion on stadium economics by offering an empirical case study of a minor league team in a mid-sized city, helping policymakers assess the potential benefits of investing in an expanded multi-use arena.
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Theory
To conduct research on the economic impact of the Santa Cruz Warriors, it was necessary to utilize a mixed-methods approach incorporating both quantitative and qualitative methodologies. To examine and pinpoint the Warriors' economic impact, I conducted an Ordinary Least Squares Regression to measure economic seasonality in Santa Cruz and its relationship to the presence of the team, finding a strong seasonal effect on sales tax overall, especially in the restaurant and hotel industry. To prove that the team has generated measurable economic benefits for downtown Santa Cruz, the assumption was tested using Ordinary Least Squares (OLS) models using AI data provided by the City. These regression analyses were informed by in-depth interviews with the Team, the City, the Mayor, and impacted businesses and stakeholders in the area. Through key themes and regression analysis, this section will explain the theory used to assess the economic impact of Warriors home games. This was done of necessity, as the City does not keep granular sales tax data, and this report was not created with the benefit of consultants.
Economic impact studies on sports teams typically rely on stadium valuation models, income multipliers, and citywide tax revenue analyses. However, these models, primarily designed for major league teams, often fail in small-market contexts such as Santa Cruz, where seasonal tourism patterns and structural economic challenges overshadow event-driven economic activity.10 In addition, these impact models rely on granular data such as daily sales tax, which is not tracked in the City of Santa Cruz, consistent with other cities of its size.
This literature builds upon prior work in sporting arena economics and urban development by modifying traditional economic impact models and using artificial intelligence data previously unavailable to researchers. Rather than focusing solely on citywide tax revenue, this study introduces a foot traffic-based approach, which better captures localized economic activity on game days.
Research has proven that foot traffic is a strong proxy for economic activity, as increased pedestrian volume correlates with higher consumer spending at nearby businesses. Studies have shown that more foot traffic leads to greater retail revenue, with findings from sources such as Unacast (2023) reinforcing the connection between physical presence and local economic performance. As Unacast notes, “foot traffic is a predictor of financial performance for industries where in-person transactions inform a majority of a company’s total revenue,” including casual restaurants, entertainment venues, and hospitality services. 11 This study draws upon several established economic theories to evaluate the Santa Cruz Warriors’ impact on downtown Santa Cruz. Central to the analysis is the multiplier effect, which 11 Unacast, Can Foot Traffic Predict Quarterly Revenue?, March 2, 2023. 10 Agha, N. (2011). The economic impact of stadiums and teams: The case of minor league baseball. Journal of Sports Economics
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explains how initial spending, such as ticket sales or dining near the arena, stimulates further rounds of economic activity within the local economy. The concentration of people and businesses around the arena increases commercial activity through proximity and convenience creating an economy of agglomeration. Finally, consumption theory supports the idea that consumer spending patterns are influenced by events and leisure opportunities, such as basketball games.
Qualitative Approach: Grounded Theory Analysis
To obtain background on fan behavior and local impact, I employed a qualitative approach using grounded theory. Through interviews with local stakeholders, including business owners, tourism experts, city officials, and team representatives, I explored perceptions of the Warriors' impact on downtown Santa Cruz. Interviewees were selected based on their ability to provide financial, policy, or operational insights. Through a thematic analysis of interview data, this report identifies recurring ideas that refine the hypothesis and provide deeper insights into the non-quantifiable factors influencing the downtown Economy.
Assumptions made in my analysis are; primarily, fan attendance patterns will remain stable or improve with a new arena. Santa Cruz fans have proven interest and WTP for Warriors games, even with increasing ticket prices. Second, that the regional economy will continue its current trajectory without major external shocks.
The quantitative portion of this study is based on semi-structured interviews conducted with key stakeholders in Santa Cruz’s civic, business, and sports sectors. The interview sample includes government officials, team executives, business owners, tourism experts, and community leaders, selected based on their direct involvement with the Santa Cruz Warriors or firsthand knowledge of the team’s impact on downtown economic activity.
Limitations include the potential for biases in stakeholder interviews due to vested interests and the challenge of forecasting long-term economic impacts with certainty, as variability in external economic conditions that may influence spending patterns. By integrating both quantitative economic modeling and qualitative stakeholder insights, I have demonstrated a quantifiable +19.0% revenue impact made by the existing stadium on Downtown Santa Cruz Restaurants, and a +13.2% increase in foot traffic downtown on game nights.
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Quantitative Methodology
This study examines the local economic impact of the Santa Cruz Warriors by analyzing whether their home games increase foot traffic and business activity in downtown Santa Cruz. To do this, it applies a statistical method known as Ordinary Least Squares (OLS) regression, a widely used tool in economics to measure relationships between variables.
Regression analysis helps determine whether changes in one factor (such as the presence of a basketball game) are associated with changes in another (like the number of people visiting downtown or the amount of sales tax collected). OLS specifically estimates these relationships by finding the best-fitting line through the data points, allowing for clear interpretation of cause and effect.
This analysis draws on two key datasets. First, citywide sales tax revenue specifically from hotels and restaurants prodded by the City, and high-frequency daily foot traffic data from downtown from Placer.ai. While the broader tax data showed a strong seasonal effect, there were no significant impacts from the team’s presence year over year. Localized foot traffic data revealed a clear increase in visitors on game days, suggesting that events at the arena do draw more people downtown and likely benefit nearby businesses. By combining macroeconomic and localized data, this study provides a more precise understanding of how sports events influence urban economic activity at different scales.
Table of Data Sources
The sample for this study includes daily foot traffic data for downtown Santa Cruz as well as quarterly sales tax revenue for the hospitality sector in the city. The dataset for measuring seasonality covers multiple years (2009-2025), allowing for both short-term and long-term economic trend analysis. Long time frames (2009-2024) and over 1,000 observations allow for structural economic analysis. This dataset was chosen to capture variations in economic activity across different seasons and events, specifically to assess the impact of Santa Cruz Warriors home games on foot traffic and local business revenue.
Daily foot traffic data is available from 2022 onward from Placer.ai for the Downtown Santa Cruz area. High-frequency data (2022-2025) captures recent, real-time behavioral trends. A three-year span allows for assessment of consistent patterns rather than short-term fluctuations. The Foot Traffic Model provides more recent game-day effects and post-pandemic recovery trends.
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While alternative methods like time-series modeling or machine learning could be applied, OLS is the most appropriate given the study’s focus on economic inference rather than prediction. OLS regression analysis provides clear estimates of causal relationships which are more applicable in this situation. This methodology was designed to provide the most reliable insights into the economic impact of the Santa Cruz Warriors. The decision to use daily foot traffic data, rather than relying solely on sales tax revenue, was based on research showing that event-based economic activity is often localized. By combining high-frequency consumer data (foot traffic) with macroeconomic data (sales tax revenue, unemployment, weather conditions), this study ensures a comprehensive understanding of game-day effects.
Hotel & Restaurant Sales Tax Model (Macroeconomic Level) To estimate seasonality, a regression analysis was conducted to determine the correlation between city-wide and restaurant and hotel sales tax revenue growth. This model measures the effect of the number of seasons the Warriors spent in town on restaurant, hospitality, and overlall tax revenue. This regression provided no significant impact of team presence on overall tax revenue. Likely because the economic footprint of the Warriors' 2,500- seat 24-home-game schedule is too small relative to Santa Cruz’s multi billion GDP.12 Major league models are built upon granular sales tax data, for stadiums with tens of thousands more seats, dedicated parking, significant staffing needs, and in the case of major league baseball, 81 home games. I tested many variables and models for the following null and alternative hypotheses in RStudio and Stata:
H₀: The presence of the Santa Cruz Warriors has no significant impact on citywide hospitality sales tax revenue. H₁: The presence of the Santa Cruz Warriors has a significant positive impact on citywide hospitality sales tax revenue. This specific regression yielded proof that the seasonal economy exists and affects the tourism industry disproportionately.
Equation and Variables Measured
The first model examines whether the Warriors' presence affects citywide hospitality tax revenue.
Equation:
SalesTax_t = β₀ + β₁ (WarriorsPresence_t) + β₂ (Unemployment_t) + β₃ (Quarter_t) + β₄ (Pandemic_t) + ε_t
Where:
➢ SalesTax_t Sales tax revenue at time t
➢ WarriorsPresence_t (0 = No team, 1 = Team present)
➢ Unemployment_t (Unemployment rate at time t)
➢ Quarter_t (Categorical: Q1, Q2, Q3, Q4)
12 Data Commons, Economics: Santa Cruz, California (City), accessed Feb 21, 2025. 30 23.428
➢ Pandemic_t (0 = No pandemic, 1 = Pandemic)
This model estimates sales tax revenue by considering key factors that influence consumer spending. WarriorsPresence_t captures the impact of the Santa Cruz Warriors on local businesses, as their games attract visitors who contribute to sales tax through spending on food, retail, and entertainment. Unemployment_t accounts for economic conditions, as higher unemployment typically leads to lower consumer spending and reduced tax collections. Quarter_t captures seasonal spending patterns, with sales tax revenue often peaking in Q4 due to holiday shopping and dipping in Q1. Pandemic_t is included to reflect the effects of major economic disruptions, such as COVID-19, which significantly reduced foot traffic, business activity, and taxable sales. Together, these variables help explain fluctuations in sales tax revenue by incorporating sports-driven economic activity, broader economic trends, seasonal variation, and external shocks.
Foot Traffic Regression Model (Localized Level)
Ordinary Least Squares (OLS) regression was chosen because it is widely used in economic impact studies, is interpretable and efficient, and allows for direct estimation of causal relationships. OLS is a form of linear regression analysis, which is a statistical method often used in economic discipline. The process of an OLS regression estimates a relationship between variables by “minimizing the sum of the squares in the difference between the observed and predicted values of the dependent variable configured as a straight line” (International Encyclopedia of the Social Sciences, n.d) More simply stated, OLS is used to quantify the relationship that exists between given dependent and independent variables.
Fans attending games often dine at local restaurants, increasing revenue for these establishments. These businesses, in turn, need to purchase supplies and services (e.g., food from distributors, additional staff hours, cleaning services, etc.). The use of Sales Tax data from the restaurants and hospitality industry which reflects economic activity on game nights, Placer.ai data, and information provided by the team can help prove the seasonality of the economy, and previously mentioned theory regarding the non-applicability of traditional stadium impact reports on Santa Cruz.
Restaurants, bars, and retail storefronts see more customers downtown on game nights, generating higher revenue. This increased business activity prompts establishments to extend hours, hire additional staff, and stock more inventory, creating a ripple effect in the local economy. The foot traffic-based approach provides a more precise measurement of these impacts upon the Downtown Core compared to citywide economic models, which may dilute the localized effects of game days.
This model focuses specifically on consumer behavior near the Arena, providing a more detailed view of how game days influence foot traffic and associated economic activity.
After checking the distribution of the data for residuals, I tested the following null and alternative hypotheses in my regression:
H₀: The presence of a home game does not significantly increase downtown foot traffic.
H₁: The presence of a home game significantly increases downtown foot traffic. 31 23.429
This model measures the direct effect of home games on downtown foot traffic. By proving that home games increase foot traffic by ~2,350 visitors per game day. The regression captures spatially concentrated spending effects that the sales tax model overlooks. Assumptions from prior studies include Baade & Dye, 1990, who suggest that sporting events can increase consumer spending in the immediate vicinity. The demonstrated increase in foot traffic allows this research to assume that events held at Kaiser Permanente Arena increase the amount of consumers in Downtown on the given night. Therefore assuming that an increased frequency of events in the proposed stadium would similarly attract customers Downtown. The regression further allows for recommendations on the best timing for future events.
Equation and Variables Measured
Given the lack of citywide impact, the study shifts focus to downtown foot traffic.
Equation: F(Downtown Foot Traffic) = β₁(Season (ordinal)) + β₂ (Game Day at Home (dummy)) + β₃ (Weekend (dummy)) + β₄ (Win Percentage)
Where:
➢ Downtown Foot Traffic = Number of visitors downtown on a given day. ➢ β₁ = Season (ordinal)
➢ β₂ = Game Day at Home (dummy) (0 = No home game, 1 = Home game). ➢ β₃ = Weekend (dummy) (0 = Weekday, 1 = Weekend).
➢ β₄ = Season Win Percentage
Each variable is included to capture factors influencing daily foot traffic downtown.
Downtown Foot Traffic is a numerical variable uploaded as a .csv from Placer.ai through their ‘daily visitor count’ tool. Downtown Foot Traffic by day over 2022, 2023, and 2024 gives 1096 observations to discern the impact of events at the Arena. The seasonal variable (β₁ Season) is ordinal and separates the daily data into four seasons to help assess how weather and seasonality might affect foot traffic. Extreme conditions may deter visitors, in Santa Cruz this simply means rain but the variable is included to asses the negative impact on foot traffic reported by business owners on days with inclement weather. β₂ Game Day at Home accounts for basketball games (events) at Kaiser Permanente Arena. This variable will prove or disprove my null hypothesis, (H₀: The presence of a home game does not significantly increase downtown foot traffic). The significance of this variable will allow this report to prove a positive relationship between events at the Arena and foot traffic in the Downtown area. The β₃ Weekend variable accounts for the natural increase in visitors Downtown on a Saturday or Sunday. The β₄ Season Win Percentage is included to measure potential fan interest in attending games relative to the success of the team throughout the season. Together, these factors provide a comprehensive view of how events, weather, seasonality, and team performance affect foot traffic trends. 32 23.430
Quantitative Results
Foot Traffic Regression Results & Interpretation
Winter = Baseline
This study examines the factors influencing foot traffic, using a regression model that incorporates variables related to local events, weather conditions, calendar effects, and historical foot traffic patterns. The model returns a p- value ~0.000 for each variable measured, suggesting that each play a significant role in affecting the foot traffic in the area.
A key finding from the regression results is that home game days significantly increase foot traffic. The coefficient for Home_Game_Day (2,350, p < ~0.000) indicates a significant positive impact, which is expected given that the qualitative research suggests 33 23.431
events draw crowds ~2,300 people downtown on a gameday versus a anrmal winter day.
Similarly, weekends show a statistically significant positive effect, yielding a coefficient of 6,727 and a p-value < 0.05 (~0.000). This suggests that increased opportunities for consumer spending—i.e. home games or free time on the weekends certainly drive higher foot traffic downtown.
The model returns a near zero p- value for each variable measured, suggesting that each play a significant role in affecting the foot traffic in the area. The percentages given help interpret the average change from the winter baseline that each variable will induce.
According to the final percentage and baseline model, home games increase foot traffic downtown by 13.19% in the
winter. Summer leads to a 29.72% increase in foot traffic overall compared to winter, congruent with results found when looking at seasonal tax data. Spring increases foot traffic 17.5% and fall 13.6% from the winter baseline.
Weekends produce the largest non-sport-related boost to foot traffic (+31.5%), emphasizing the economic importance of leisure time. Interestingly, the Win Percentage variable is significant, showing that the success of the team has a commensurate effect on how many people come to games. At a 100% win percentage, or a perfect season, the data predicts a 38.55 % increase in foot traffic downtown. This significant increase is important to note because it demonstrates an engaged fan base that wants the team to succeed. The results also indicate a strong seasonal effect, supporting the
assumption that traffic and tourism patterns fluctuate
meaningfully across different times of the year.
Robustness Checks
To ensure robustness, it is essential to check for multicollinearity between independent variables. High correlations between explanatory variables can distort the interpretation of regression coefficients. The p-values < 0.000 give evidence to the strength of the model.
Several limitations must be acknowledged due to omitted variable bias. The impact of weather may be underestimated as some business owners listed rain as a big factor in foot traffic. Highway 17, the primary route into town from the Bay Area, is easily impacted by both weather and construction, as is Highway 1. Santa Cruz suffers significant traffic and congestion issues, which can also affect foot traffic downtown. The holiday effect may vary, but the correlation between school/national holidays and a game day can affect foot traffic as well. Future research could improve upon this by incorporating more granular data and testing different functional forms.
34 Factor Percentage
Increase
Spring vs.
Winter
17.50%
Summer vs.
Winter
29.72%
Fall vs. Winter 13.59%
Home Game
Day
13.19%
Weekend vs.
Weekday
31.49%
100% Win
Percentage
38.55%
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Key Findings
The model provides a solid foundation for understanding how a game night affects Downtown in terms of population increase. Overall, the findings suggest that home games and weekends have a strong positive influence on foot traffic. According to the final model, home games increase foot traffic by 13.2% in the Downtown area on gamedays overall compared to an average winter non game day. Increased foot traffic indicates a greater number of individuals and families coming downtown to the arena. This provides opportunities for downtown businesses to engage with an increased, and potentially new, customer base when events are held in the Arena. This finding underscores the economic significance of Santa Cruz Warriors home games, demonstrating that home games contribute to higher consumer activity in the downtown area. The results also support the broader conclusion that minor league sports teams can play a role in stabilizing local economies, particularly in tourism-dependent cities such as Santa Cruz.
The most important takeaway from these results is that foot traffic is highly significant.
The presence of an event, in this case a game night, provides a measurable boost in downtown visitation. Business owners confirm that this increase correlates with higher spending, reinforcing the link between attendance and local revenue. Projecting forward, an 800-seat expansion could draw approximately 3,100 visitors on game days, a noticeable but manageable influx for restaurants and retailers. Unacast, another AI data source, highlights “foot traffic is a predictor of financial performance for industries where in-person transactions inform a majority of a company’s total revenue,” including casual restaurants and entertainment venues.13 This connection underscores the broader economic potential of modest investments in event infrastructure. Even at a small scale, localized increases in foot traffic can generate meaningful, recurring benefits for surrounding businesses, strengthening the case for a permanent, multi-use arena as a sustainable economic asset for downtown Santa Cruz. 13 Unacast, Can Foot Traffic Predict Quarterly Revenue?, March 2, 2023. 35 23.433
Sales Tax Regression Results & Interpretation
*** p < 0.001, ** p < 0.01, * p < 0.05, . p < 0.1
Residual standard error: 72470 on 54 degrees of freedom (130 observations deleted due to missingness)
Multiple R-squared: 0.8318, Adjusted R-squared: 0.8132
F-statistic: 44.52 on 6 and 54 DF, p-value: < 2.2e-16
Analysis
Seasonality strongly affects sales tax revenue as Q2 and Q3 have highly significant effects, indicating higher sales tax revenue in spring and summer. Similarly, Q4 is not significantly different from Q1, suggesting lower spending in the off-peak season. The unemployment rate has a strong negative effect; only a 1 percentage point increase in unemployment is associated with a $33,857 decrease in restaurant/hotel sales tax revenue. This result is highly significant (p-value < 0.001), confirming that economic conditions impact spending. Next, the model tells us that the Pandemic had a major negative impact because the coefficient for the Pandemic variable is -121,860, meaning revenue dropped significantly. The p-value (0.000857) confirms this effect is statistically significant.
The Warriors' presence is not statistically significant; the p-value of 0.5826 for WarriorsPresence_Lag1 suggests no strong evidence that the Warriors directly impact sales tax revenue. However, this does not demonstrate that the team's economic influence is negligible.
Instead, my qualitative research and Placer.ai show that the impact appears to be more concentrated in downtown, where businesses benefit the most from increased foot traffic on game days. The daily/weekly sales tax reports needed to isolate the season/ game nights further are not recorded.
The model strongly supports seasonality as a key predictor of economic activity in Santa Cruz. The significant positive coefficients for Quarter 2 and Quarter 3 demonstrate that 36 23.434
restaurant and hotel sales tax revenue is highest during the spring and summer months, aligning with the city's peak tourist season. This suggests that fluctuations in economic activity are largely driven by seasonal tourism trends, where increased visitor spending fuels the hospitality sector.
In contrast, Quarter 4 does not show a statistically significant difference from Quarter 1, reinforcing the notion that fall and winter months experience a relative economic slowdown. The model captures these cyclical patterns, highlighting how Santa Cruz's economy is shaped by external seasonal factors beyond the presence of the Warriors. In Santa Cruz, tourism dwarfs game-day spending, making
it unlikely that the Warriors’
financial impact would
appear in a citywide sales tax
regression model.
Robustness Checks
A different algebraic
formulation such as a panel
regression model accounting
for fixed effects or a time
series model incorporating
autoregressive components,
could yield more precise
insights into the Warriors'
economic impact. A panel
regression incorporating
business-level data would
better capture
microeconomic changes that
a citywide sales tax analysis
would dilute. Additionally,
controlling for major
city-wide events such as
festivals, university
schedules, and other economic drivers, events such as surf competitions, festivals, and University milestones, would improve model accuracy.
The current analysis examines citywide tax revenue, but a more localized dataset focusing specifically on downtown businesses, restaurants, and hotels should reveal a stronger correlation. A spatial econometric approach conducted by a consulting firm versed in these assessments could better capture localized economic activity fluctuations.
Why the Model Fails in Santa Cruz
Due to the small size of Kaiser Permanente Arena (2,505 seats), the limited number of home games (24 per season), and the overall scale of Santa Cruz’s economy, traditional stadium valuation models, designed for major league venues, are ineffective in assessing the Warriors’ direct economic impact (Santa Cruz Economic Development Strategy, 2021). With four million annual visitors, the proportion of citywide spending attributable to game-day tourism is too small to detect a statistically significant effect on sales tax revenue. 37 23.435
Most studies measuring stadium-driven economic impact focus on major league teams playing 41+ home games per season (NBA/NHL) or 81+ (MLB). These models rely on sales tax receipts, employment multipliers, and business revenue tracking, which work well in larger cities with more robust record keeping and where sports contribute to a larger portion of overall consumer spending.
Regular economic activity, tracked in Santa Cruz with quarterly sales tax receipts, is an inappropriate measure of game-day spending, as any financial impact is unlikely to appear in a citywide sales tax regression model. The Santa Cruz Economic Development Strategy (2021) states that sales tax revenue fluctuations are primarily driven by peak tourist months, rather than event-based spending (Santa Cruz EDS, 2021). The Tourism and Hospitality Report’s IMPLAN model further supports this, showing that a thriving hospitality sector stimulates a ripple effect down local supply chains, whereas event-driven spending is localized to specific businesses.
According to economic projections by the Federal Reserve (2025), Similar to California’s overall economy, local growth is driven by tech and innovation but tempered by geopolitical risks and migration patterns according to the UCLA Anderson Forecast. The unemployment rate in Santa Cruz County is higher than the statewide average by almost two percentage points, and three percentage points higher than the national average.
Economic impact studies typically rely on personal income multipliers, such as Makara’s personal income approach, which assumes that a sports team generates local income through increased wages and consumer spending. However, a personal income based model fails in Santa Cruz for three reasons.
According to the State of the Workforce Report in 2023, and Santa Cruz City Economic Outlook report (2023) a majority of low-wage hospitality and service workers commute from outside the city because they cannot afford to live in Santa Cruz. This outmigration means game-day earnings cannot be captured in any city-wide measurement. A severe housing affordability crisis, with the median home price exceeding $1.21 million and a required hourly wage of $63.33 to rent a two-bedroom unit. As previously discussed, Santa Cruz is also under significant pressure from the state of California to expand its restricted housing stock, to address affordability, and mitigate homelessness. (see Figure 4.2- Housing trends in Santa Cruz, 1980s to now).
Worker outmigration can be attributed to one main issue: it costs more to live in town than most people can afford. In 2023, Santa Cruz
was identified as having the least affordable rental
market in the U.S., surpassing even San Francisco,
with median home prices around $640,000 as of
April 2013 (AP News, 2024). Over the past decade,
housing development in Santa Cruz has been
limited due to a combination of restrictive zoning
regulations, environmental protections, and the loss
of redevelopment funding. A significant portion of
the county is zoned for single-family homes, which
restricts higher-density developments needed to
address housing shortages. Environmental
protections have constrained land availability,
38 23.436
making it difficult to meet growing housing demands. These factors collectively contribute to the ongoing housing crisis in Santa Cruz (County of Santa Cruz Housing Dashboard).
Santa Cruz County's job quality is lower than the state average. Compared to the rest of California, Santa Cruz County tends to produce a larger share of lower-skill and lower-wage occupations in service and retail. According to the Santa Cruz State of the Workforce Report, the City has seen an 8.6% increase in Tier 1 (high-wage) jobs, Tier 3 (low-wage service) employment has declined by 8.3%, compared to just 0.4% statewide (State of the Workforce Report, 2023). See Figure 4.3; Job Tier Description, Figure 4.4: Change in Job Quality. This identifies the trend of less availability in Tier 1 and demand for Tier 3 positions. Although the county has a relatively higher proportion of lower-skilled and lower-paying jobs than the state.
The workforce composition
is changing, with a decrease
in the share of people
working in Tier 3 jobs and
an increase in people
working in Tier 1 jobs. A
shrinking local workforce, as
low-wage workers commute
long distances or leave the
region entirely, makes it
difficult for businesses to
maintain full staffing during
peak tourism months.
Lastly, the demand for
Tier 3 workers greatly
outweighs the supply.
Santa Cruz's reliance on
Tier 3 service jobs, which
make up 57.5% of local
employment, compounds
its workforce challenges
(Figure 4.5: Job
Composition by Tier).
These jobs, which include
food service, retail, and
hospitality, are essential
for sustaining the visitor
economy. Although
tourism drives local
spending, businesses
struggle with chronic labor shortages in hospitality, food service, and retail industries crucial to visitor spending (Santa Cruz Economic Outlook, 2023). This explains why traditional economic models fail to capture the Warriors’ economic impact and why sales tax revenue remains unaffected despite their presence.
39 23.437
The Santa Cruz Warriors contribute economically, but their impact is best understood through localized spending rather than traditional stadium-effect valuation methods. Unlike major league teams in larger metros, their footprint is not large enough to affect citywide sales tax revenue or aggregate personal income, but according to city officials, it has stimulated housing growth, downtown revitalization, and business activity near the Arena.
Given Santa Cruz’s structural labor shortages, housing constraints, and tourism-driven volatility, alternative methods, such as business foot traffic analysis and qualitative stakeholder interviews, offer better insights into the Warriors’ economic role. 40 23.438
Qualitative Research: Interviews and Information Collection Process The qualitative interview approach was chosen for two main reasons. Sales tax data is only aggregated quarterly for the city, making it difficult to isolate game-day effects.
Furthermore, interviews provided granular insights into how and where economic activity was occurring. The study focused on stakeholders with direct experience in Santa Cruz’s economy, ensuring that findings were grounded in local expertise.
Mayor Fred Keeley identified the team as an important off-peak season economic driver that helps to fill the city’s winter tourism gap. He pointed out, “This is roughly 2,500 people, twenty-four nights of the year, that you’re not going to have downtown otherwise.
Even if a fraction of those people are spending money outside the Arena itself, it’s still a big impact.”
This report aims to quantify this impact. Regressions were performed on quarterly sales tax data to define the seasonal swing, particularly in tourism, another was done with placer.ai data to define the number of people downtown during a home game versus non-game days, and qualitative interviews bring business effects into focus.
As mentioned, interviewees were selected based on their ability to provide financial, policy, or operational insights. Instead of random sampling, purposeful sampling was used to target businesses most impacted by the Arena. Lastly, business-level revenue data is proprietary, requiring direct conversations with owners to convince them to share information.
A real-time approach was necessary to capture current economic dynamics, especially as discussions about a new arena are unfolding. Historical studies exist, but this research aims to fill gaps in recent, on-the-ground perspectives to inform the current conversation.
Unlike quantitative models, which focus on statistical correlations, thematic analysis identifies perceptions, motivations, and
qualitative economic trends. The goal of
interviewing was to understand the
mechanisms behind a potential economic
impact, in addition to measuring it.
Interview findings directly
influenced the quantitative phase of this
study, shaping both research questions and
the structure of regression models. As a
result, the final regression models were
built with direct input from real-world
stakeholders, increasing their relevance and
accuracy in assessing the Warriors’
economic impact.
Interviewee selection was informed
by Placer.ai foot traffic data, which
identified business locations most
41 23.439
frequently visited on game days. See below for Placer.ai and custom generated maps of the area. The Prior and Post CompareTtools in Placer.ai allowed me to identify the most commonly visited restaurants and
bars around the Arena. Interviews
were conducted in person and via
virtual meetings, depending on the
participant’s availability.
Each interview followed a
semi-structured format, allowing
for comparability across responses,
exploration of unexpected themes,
and, most importantly, validation of
previous research findings,
particularly regarding economic
spillover effects from the Arena.
For business owners, follow-ups in
standardized formatting were
conducted to request revenue data
on game nights vs. non-game
nights for February and March
2024.. If owners were unable to provide exact figures due to a lack of data or inability to share sales receipts, they were asked to estimate a sales percentage change for game nights.
The qualitative data from interviews was analyzed using thematic coding to identify recurring patterns and economic themes. Interviews were transcribed and categorized based on stakeholder type (e.g., city officials, team executives, business owners), then key quotes and insights were extracted for comparative analysis.
Recurring themes were identified (e.g., off-season, downtown revitalization, business revenue spikes and community involvement) and findings were compared across interviewees to identify commonalities and discrepancies. Overall, themes uncovered in these interviews were used to refine the regression models. For example, some business owners’ insights that foot traffic varied due to rain led to the inclusion of a seasonal control in the foot traffic model. Business owners' revenue estimates also provide context for interpreting regression results and informing conversations about a larger multi-use arena in future.
Interview findings were cross-referenced to be consistent with Placer.ai foot traffic reports, city sales tax data, and tourism trends.
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Qualitative Results: Key Findings from Interviews
This section examines the Santa Cruz Warriors’ influence on the community and local businesses. (for more detailed financial data and interview transcripts, see Appendix.) These findings align with Accenture’s Chase Center Report which found that businesses near the arena benefit disproportionately from game-day spending.
Key themes from in-depth interviews centered around sponsorships, community engagement, the new arena, and hopes for economic effects. There seems to be some disappointment and confusion around the effectiveness of team sponsorships. A number of restaurants mentioned current and past sponsorship arrangements, but no one was clear about the direct business benefit. One current sponsor was unsure if they would continue because they didn’t know if it made a difference to their business, another enjoyed the brand association but was unable to quantify its value, and another planned to renew a sponsorship after a lapse but wasn't certain. Two said that they used to sponsor, but they had been priced out and spoke nostalgically about working together.
The Warriors' reputation for community involvement strikes a chord in local business owners. Many respondents highlighted the Warriors’ role in fostering community pride and local engagement, mentioning that they felt the Warriors' brand was consistent with their own values.
Restaurants said frequently that Warriors games tend to be on Fridays and Saturdays, when they’re already busy, and would welcome more weekday events when things are quiet.
Two restaurants said they saw the biggest increase in business for watch parties on away game nights, suggesting that there is potential for fan engagement even when the team isn’t playing at home.
The overall interest and excitement for a new arena was consistent across stakeholders, other than one bartender who complained about parking. Business owners felt that constant housing construction makes it difficult for fans to walk around, but hope that a new arena, housing, and broader entertainment offerings will stimulate a more vibrant and densely populated downtown.
Qualitative Results: Estimated Business Impact
Similar economic impact reports include interviews with nearby businesses to determine effects, and with the help of Placer.ai, I was able to target the top 15 businesses most visited by attendees before and after the games.
47 23.445
Table of Impacted Restaurants and Bars
BUSINESS 0-5% 5-10% 11-20% 21-30% 31-40% 41-50%
The Asti 0
Blue Lagoon 25
Big Basin
Winery
25*
Cruz Kitchen 30*
Hula’s 10
Iveta 50
Kianti’s 30*
Lupolo 10
Oswald’s 15
MH
Creamery
8 Nick the
Greek
20 Pacific
Cookie Co.
20 Penny Ice
Creamery
20 Pizza My
Heart
25 Sports Bar 10
Pono Island 20
Woodstock’s 6
Overall, this indicates an approximate 19.05882 % increase in revenues felt by the sample businesses. The observed 19.05 % increase in revenues among sample businesses, derived from a combination of point-of-sale (POS) data and qualitative interviews, provides empirical support for the hypothesis that the Santa Cruz Warriors positively impact the 48 23.446
downtown economy. This increase is particularly significant given the seasonal instability of Santa Cruz’s tourism-driven economy, reinforcing the team’s role in mitigating off-season revenue declines.
From an economic impact perspective, this revenue growth represents a positive multiplier effect, where increased consumer activity surrounding Warriors games leads to higher spending at restaurants, bars, retail stores, and other downtown establishments. This aligns with Coates & Humphreys (1999) on the economic spillover effects of sports franchises, which suggests that localized consumer spending increases when teams attract consistent attendance and engagement. Moreover, the scale of the revenue increase (almost one-fifth of winter averages) suggests that the presence of a professional sports franchise in a mid-sized city like Santa Cruz generates a disproportionate economic benefit relative to larger markets, where spending is more diffused across multiple entertainment options, agreeing with Agha (2011). The findings also support the argument that an expanded arena could further amplify this impact, as a marginally higher seating capacity would allow for greater attendance and subsequent increases in game-day spending across downtown businesses.
This data strengthens the case for continued investment in the Santa Cruz Warriors and Kaiser Permanente Arena, both as a sports entertainment asset and as a strategically located economic tool for stabilizing and enhancing downtown business performance during the off-season. By approximately quantifying the direct financial benefits experienced by local businesses, this report underscores the broader economic rationale for considering arena expansion and event-driven economic development initiatives. 49 23.447
Conclusion
This thesis set out to evaluate the economic impact of the Santa Cruz Warriors on the downtown economy. This is an illustrative case study: a mid-sized coastal city with a seasonal economy, where the minor league team serves as both a community-defining point of pride and a potentially stabilizing force for local businesses.
To measure economic impact, this study employed ordinary least squares regression and qualitative methods, integrating Placer.ai foot traffic data, regression analysis, point-of-sale (POS) data, and business owner interviews to assess the Warriors' economic footprint. The results indicate a statistically significant increase in local business revenues on game nights, averaging a 19.0% rise among fan-favorite downtown restaurants and bars. Foot traffic regression analysis demonstrates a 13.2% increase in pedestrian activity, not normally felt in the winter, on game days overall. This suggests a clear fan spillover effect that benefits surrounding businesses beyond direct in-stadium spending.
Unlike large metropolitan areas where stadium-driven spending is diluted within a diverse economy, Santa Cruz’s compact urban center and reliance on seasonal tourism create conditions where 24 home games at the 2500-seat Kaiser Permanente Arena contribute to off-season economic activity. It also suggests that more events and seats would lead to better outcomes overall. The Warriors and Kaiser Permanente Arena play a role in off-season economic activity. As the biggest indoor entertainment space in the county and for south of Santa Cruz, all indications are that the Team could play a bigger role in the area with a better Arena.
Sellout attendance history, corporate partnerships, and interviews underscore the support for the Warriors organization and their initiatives in the area. According to feedback from nearby restaurants and hotels, there is a need for increased attractions and entertainment that bring foot traffic downtown in the winter. Stakeholders14 widely agree that a larger arena would increase Santa Cruz’s ability to host non-basketball events, boosting revenue for these local businesses. A bigger arena would have the capacity to host more popular entertainment options, allow the arena to schedule more events, and attract a broader audience of visitors to downtown. Increased interest from entertainment providers to come to Santa Cruz would help raise the number of events a year, from 40 to 75 -- or even 150.15 Given the similar relationship between the economic activity of sports fans and tourists, more frequent and marginally bigger events throughout the year would help to offset the slow winter season downtown. Increased hotel stays from potential conferences, tournaments, and concerts would help diminish the 21.3% seasonal swing in the restaurant and hotel sector. 15 We can expand Santa Cruz’s entertainment market without losing what makes the city special… Instead of having events at the arena 40 days a year, we’re talking about 75 or even 150 days a year… Right now, we’re limited in who we can bring to Santa Cruz. A bigger venue changes that—it lets us attract bigger acts that wouldn’t come otherwise… The new arena will allow us to move up a tier in terms of entertainment—bigger than what goes to The Catalyst, but still fitting for Santa Cruz…”
14 Mayor Fred Keeley, City of Santa Cruz Economic Planning, Warriors Front Office, Interview Subjects 50 23.448
Contribution to Academic Research
While economic research on sports stadiums often focuses on major league teams in large metropolitan areas, minor league teams in smaller, tourism-dependent cities remain an underexplored area of study. This research challenges traditional economic models that often dismiss the financial benefits of sports stadiums, particularly in smaller markets. However, this study contributes to a growing body of literature suggesting that smaller markets with tourism-driven economies experience different economic outcomes from sports investments.
The integration of artificial intelligence data tracking of visitor patterns before and after the game will allow researchers to further drill down into fan behavior and accurately quantify their indirect contribution. The city-provided Placer.ai data access and their account allowed me to download raw foot traffic data by day. It is less granular data than their premium offerings, so additional subscriptions provide more information than what is currently available to the City, such as how long customers were in a specific restaurant, allocation, and possible revenue impacts. Furthermore, this study aligns with recent research on place-based economic development, where sports venues act as anchor institutions in mid-sized cities, as explored by Agha in 2011. Those findings suggest that stadium investments may be more effective when integrated into broader economic development strategies, particularly in cities where walkable downtowns, tourism economies, and strategic urban planning intersect.
Practical Implications and Future Research
The findings of this study offer valuable insights for policymakers, urban planners, business leaders, and sports economists. For the downtown area, these results highlight the Warriors' direct contribution to commerce, emphasizing the importance of leveraging game nights as high-traffic revenue opportunities. The 19.0% revenue increase among key businesses quantifies the spillover effect from home games at Kaiser Permanente. The +13.2% increase in foot traffic captures a significant bump in the number of people downtown on game nights, supporting the hypothesis that the Warriors make a measurable economic contribution downtown.
For local stakeholders, this data suggests that continued investment in a multi-use arena could yield significant long-term economic benefits by supporting a wider variety of events, expanding visitor engagement, and maximizing the Warriors' role as an off-season economic driver. Additionally, continued integration of sports and entertainment infrastructure within the broader downtown revitalization plan will strengthen Santa Cruz’s ability to sustain year-round economic activity.
Consistent sellouts and the 17% increase in merchandise sales reported by the team indicate strong and growing fan interest that could indicate the Warriors’ ability to fill a larger stadium. Interest in the team and the appeal of watching player development unfold is continuing to increase. The Golden State Warriors are poised for another strong season, which keeps the brand top of mind in the Bay Area. Santa Cruz Warriors tickets remain an 51 23.449
entry level for both players and fans, with tickets at around $50, about five times cheaper than the average ticket to see Golden State play at Chase Center.16 Looking ahead, future research should expand the dataset to include a larger sample of businesses, extend the analysis to other G-League markets, use more granular artificial intelligence to track spending patterns, and conduct studies on specific fan behavior trends.
A comparative analysis of minor league teams in different economic contexts, such as industrial versus tourism-driven cities, could refine our overall understanding of how sports investments function in varying regional economies. To further refine the study, this report suggests a traditional Economic Impact Report using IMPLAN modelling and exact regional multipliers.
A more comprehensive collection of point-of-sale (POS) data from a larger sample of downtown businesses would provide a clearer picture of the team’s indirect financial impact on game nights. Additionally, a detailed traffic and parking analysis, conducted in collaboration with willing city officials, could help determine the full scope of visitor patterns before and after games. A deeper dive into Placer.ai data, coupled with targeted surveys from the Downtown Association, city officials, or the tourism council could offer more nuanced insight into consumer behavior and economic spillover effects.
For the Warriors, modeling the typical fan experience would help define how a variety of scenarios impact downtown Santa Cruz. For example, the differing fan experience from people who walk/bike from home, come from a ten-mile radius, 25 miles (Los Gatos/ San Jose, Watsonville), or more than 50 miles (Bay Area, Monterey/ Salinas). What distance prompts an overnight stay? What marketing brings people to town for more than a game and a quick dinner? Customers who drive to the Arena and have to walk from their parked cars will be more likely to integrate mealtime, but more surveying of fans is needed to examine and predict customer journeys.
Final Thoughts
On a game night, foot traffic downtown increased by +13.2%, and downtown businesses experienced an approximate +19.0 % revenue increase. This study demonstrates that minor league sports teams can have substantial economic value in smaller cities, particularly those with seasonal economies and compact, walkable urban centers. The Santa Cruz Warriors serve as more than just an entertainment option—they are an economic stabilizer, a tourism asset, and a catalyst for downtown business growth since their arrival in 2012. Trends of increased fan loyalty indicated by sold-out streaks and an increase in merchandise purchasing show a strong and growing interest in the team.
Due to these factors, this report concludes that the additional ~800 seats in the proposed arena would be filled by fans likely to spend money downtown on game days.
Downtown businesses were in overall support of the proposal’s more robust event schedule and the potential for more frequent boosts in foot traffic downtown on weekdays or weekends when the team plays away.
16 According to Seatgeek.com the average Golden State ticket for the 2024-25 season was $259 52 23.450
As California coastal cities and those dependent on tourism across the United States continue to grapple with economic fluctuations, downtown redevelopment, and changing consumer behavior, the Santa Cruz model presents a case study in how a strategically positioned minor league team can contribute to long-term economic resilience. While further research is necessary, these findings suggest that investment in a new multi-use arena would enhance the long-term economic return of the City’s initial 2011 investment and solidify the Warriors' integral role in the ever-evolving character and economy of Santa Cruz. 53 23.451
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Crompton, J. L. (1995). Economic Impact Analysis Of Sports Facilities And Events: Eleven Sources Of Misapplication. Journal Of Sport Management, 9(1), 14-35. Retrieved from https://journals.humankinetics.com/view/journals/9/1/article-p14.xml Data Commons. (n.d.). Economics: Santa Cruz, California (City). Retrieved April 21, 2025, from https://datacommons.org/place/geoId/0669112?category=Economics Hefner, F. (1990). Using Economic Models To Measure The Impact Of Sports On Local Economies. Journal of Sport and Social Issues. Retrieved from:
.https://www.researchgate.net/publication/279113045_Appraisal_of_measuring_econ omic_impact_of_sport_events
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NBA G League. (2024). Nba G League Announces 2023-24 Team Business Awards.
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Placer.ai. (2025). How Stadiums And Arenas Engage Fans. Retrieved from https://go.placer.ai/library/how-stadiums-and-arenas-engage-fans San Francisco Chronicle. (2024, December 25). A perfect pairing: NBA’s Warriors and G League affiliate in Santa Cruz.
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Santa Cruz County. (2023). Santa Cruz County Economic Outlook Report. Retrieved from https://www.santacruzcountyca.gov/VisionSantaCruz/Budget/EconomicOutlook.aspx Santa Cruz Local. (2022, February 1). Santa Cruz Warriors Explore New Arena Project With Housing. Retrieved from
https://santacruzlocal.org/2022/02/01/santa-cruz-warriors-explore-new-arena-projectwith-housing/ Unacast. (2023, March 2). Can Foot Traffic Predict Quarterly Revenue? https://www.unacast.com/post/can-foot-traffic-predict-quarterly-revenue Workforce Development Board of Santa Cruz County. (2022). Tourism And Hospitality Report. Retrieved from
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Visit California, The Economic Impact of Travel in California, Issued April 2024, prepared by Dean Runyan Associates; Portland, Oregon
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Appendix: Interview Transcripts
Yoyo Chan-Murphy, Senior Vice President of Government and Community Relations, The Golden State Warriors. (1/10/2025)
Referencing the recent Chase Center Economic Impact Report that her team worked on with Accenture and recently published, I was interested in emulating a similar report in Santa Cruz because of its unique economy and relationship with the team. I asked Mrs.
Chan-Murphy about the impacts of the report since it was released, "I think, generally speaking, the report's been received super positively… just being able to quantify what we've been saying for the last five years was helpful.”
Mrs. Chan- Murphy expanded that the localized economic impact of the Chase Center was a key argument when getting the approvals for the arena when we first proposed the project, and to be able to actually show the economic impact has been incredibly valuable." The report estimated that the venue has generated $4.2 billion for the San Francisco economy, including over $2.9 billion in direct spend and over $1 billion in recirculation, since opening in 2019. The study measures activity from the more than 4.8 million fans who have attended the arena for over 400 diverse events across sports, music, comedy, theater, family entertainment, and more. The report analyses Both direct and influenced economic activity in the San Francisco community across several key categories are measured in the report, including direct spending, indirect spending, induced effects, and public sector effects.
We also talked about the potential benefits for Santa Cruz if I were to conduct a similar survey, “There’s a lot of discussion right now around whether investing in these types of things makes sense to create a more vibrant downtown corridor. If you had a financial case to be made, that could certainly kick off something for the policymakers making decisions around these types of investments." According to Mrs. Chan-Murphy, where Accenture really helped was with the external data that correlates with the indirect spending. On-the-ground interviews of local businesses and modeling around what customer/fans spend if they were, for instance, coming to watch a game or concert for the weekend and how they're experiencing San Francisco in the region as a whole.
Chris Murphy, President, Santa Cruz Warriors (Initial interview 1/13/2025) As one of the most successful organizations in the NBA G-League, Santa Cruz is an excellent case study in minor league sports stadium economics because of the high median income, high levels of fan interaction, struggling downtown, and mid-size economy. In the introductory interview, I asked Chris Murphy if he believed there was potential for a project analyzing the economic impact of the Santa Cruz Warriors, similar to the Accenture report on the Chase Center. He agreed that such a study could be valuable but emphasized key differences that make directly emulating the Chase Center report impractical.
Murphy pointed out that the City of Santa Cruz lacks the same level of economic data that Accenture had access to for the Golden State Warriors project in San Francisco.
Additionally, the scale is significantly smaller—while the Warriors sell out in Santa Cruz, the Kaiser Permanente Arena holds only 2,500 fans paying around $35 per ticket, compared to 57 23.455
18,000 fans at Chase Center paying an average of $94. Given these differences, a direct replication of the Chase Center report wouldn’t work, but a more focused study on the Santa Cruz Warriors’ economic impact- particularly on the downtown area- could be valuable.
Finding a positive correlation between events at the arena and money spent downtown would help legitimize the team’s presence in Santa Cruz, much like the Chase Center study helped validate the economic role of the arena in San Francisco. As Yoyo Chan mentioned, the most obvious and easily quantifiable economic impact of a stadium is direct spending from the team including ticket sales, concessions and merch, sponsorship deals, full time salaries paid, and community engagement efforts that contribute to the local economy.
Deb Gozzo, Finance Director, Santa Cruz Warriors (February 27th, 2025) Deb provided me with ample data from the inaugural season through 2024 including; Total Attendance, Attendance per Game, Average Price/Paid Ticket, Total Concession Revenue, Store Front Merch Sales, In Arena Merchandise Revenue, Part Time Labor, # of SCW Community Events, Visiting Team Hotel Spend, 3rd Party Local Vendors, Part Time Labor, and Total FTE Salary.
Deb shared current business practices and event schedule at Kaiser Permanente Arena. She explained that there are few events scheduled for the offseason, three fighting events. An MMA fight in May, a two-day JiuJitsu tournament in August and a Muay Thai event in September. Deb and I discussed the intended audience for non-basketball events and she explained that they have plans to appeal to South County and Watsonville as there are no larger entertainment venues in south county (See Market Landscape and KPA and Civic Center Comparison). She explained the opportunity for Santa Cruz to be a stop on tour for acts coming through California from Sacramento to Los Angeles. Although the stadium has a slightly bigger capacity for non-basketball events, the arena has to pay the same amount to secure an act no matter how many seats they have so most headliners cost too much for the arena to host them for only 3,200-3,400 people without losing money. She emphasized that a more attractive facility with a couple hundred seats would allow for Kaiser to host more frequent and bigger concerts or events.
Deb also explained that the team caters meals from local restaurants for practices and days in the arena as well as partnering with many local businesses for construction and janitorial services. Chris Murphy commented on the choice to cater from downtown restaurants, “It’s definitely intentional. We need to feed our players after practices and games, and we want to invest our money in local businesses near the arena. There’s a synergistic relationship, and we work to support our partners over just random restaurants.” 58 23.456
59 23.457
David Kao, Chief Operating Officer, Santa Cruz Warriors (March 5th, 2025)
We discussed the community involvement of the team and its broader economic impact on Santa Cruz. Kao highlighted several key initiatives that contribute to the local economy and support nonprofit organizations. One of the most significant programs is ‘Swishes for Dishes,’ a partnership with Kaiser Permanente and Second Harvest Food Bank, which donates meals based on the team’s performance during a game. Since its launch in 2020, the initiative has provided 162,020 meals, including 86,420 meals in the 2024-25 season alone. Additionally, the Warriors raise funds for local organizations through their jersey auctions. Fans pay for a unique game-worn jersey and player interaction for an average of $3000 and a record of $6000 raised for the Black Surf Club with a “Santa Cruz Surfers” jersey.
As an organization, Kao mentioned that the Warriors also prioritize inclusive community engagement through theme nights, such as Women’s Empowerment Month, Lunar New Year, and Los Warriors Night, which highlight diverse identities while raising funds for local non-profit organizations. Kao emphasized the Warriors’ commitment to 60 23.458
ensuring these funds directly benefit local causes, stating, “That money, every time we do it, goes to a different nonprofit locally… We’ve done it with the Boys & Girls Club to help out with the youth and some of the youth programs they have, we’ve done it with Pride, we’ve done it with Black Surf Club, the Monterey Bay National Marine Sanctuary Foundation… just to name a few.”
In addition to these cultural events, the team has been long standing partners with the Monterey Bay National Marine Sanctuary Foundation and conducts annual beach clean-ups that include front office staff, players, and season ticket holders. David explained, “People see the Warriors as just a basketball team, but when they see our players and staff out there cleaning the beach, it changes that perception. It shows that we are part of this community, not just here to entertain but to contribute and take care of the place we all call home.” The team also provides support for UC Santa Cruz athletics, offering the University’s Division III basketball and volleyball programs the Arena as a discounted venue for competition, ensuring their sustainability despite financial constraints. Furthermore, the basketball teams run the third quarter fundraiser at all home games. Players sell bags of five foam balls for $5 each, hoping to land it in the buckets set up at mid-court in the ball toss. All proceeds go to UCSC athletics, which contributes around $23,000 annually.
Beyond basketball, Kao discussed how the Warriors organization actively contributes to the broader economic and social landscape of Santa Cruz. With ongoing efforts to expand outreach to South County (Watsonville) and attract a diverse audience to the arena, Kao mentioned the opportunity Kaiser has as the largest indoor entertainment space in the county (See Figure 7: market landscape). The arena has served as a regional community and entertainment hub, hosting concerts, comedy shows, and mixed martial arts events. Both basketball games and other events draw visitors from beyond Santa Cruz city and increase traffic to local businesses. The arena also serves as a public resource, functioning as a polling place during the recent election. Kao explained that these efforts align with the organization’s larger goal of making the Santa Cruz Warriors a “brand that welcomes everyone” and creating spaces for the community to gather, emphasizing, “We strategically figure out what makes the most sense to continue to give people a place to gather and celebrate.” Fred Keeley, Mayor of Santa Cruz
(March 4th, 2025)
We discussed the financial justification for bringing the team to Santa Cruz and its long-term economic impact on Santa Cruz. Keeley explained that when the Warriors initially proposed moving their G-League team to Santa Cruz, the city assembled a group of financial experts to stress-test the deal, analyzing attendance projections, spending patterns, and the team’s potential impact on the downtown economy during the tourism off-season. “We took the Warriors' proposal and stress-tested the heck out of it… Even when we applied extremely conservative estimates, we couldn’t break the deal.” Their analysis found that even under conservative economic assumptions, the deal remains financially viable, leading to the city’s decision to invest in the temporary arena (See below for rendition of current Arena). Our conversation also covered the future of the team and its role in the city’s 61 23.459
Downtown Expansion Plan. Keely explained, “If the Warriors hadn’t come to Santa Cruz, the downtown expansion plan would look very different…By design, the plan is to build an entertainment district…It is all centered on a new arena, but not only that—there’s also going to be another 1,600 units of housing.” He noted that this larger venue would elevate Santa Cruz’s ability to attract mid-tier entertainment acts, strengthening the city’s economy year-round.
Additionally, Keeley discussed how Santa Cruz’s lack of competing professional sports teams has made the Warriors a uniquely valuable local asset, driving consistent attendance and fan engagement. His insights reinforced my research findings, particularly on the team’s indirect economic impact and the strategic role of arena development in shaping Santa Cruz’s future. The Warriors are an ‘off season’ economic driver that helps to fill the city’s winter tourism gap…“The Warriors are a ‘shoulder season’ sport, meaning they drive economic activity in the winter when tourism is down… This is roughly 3,000 people, 24 nights of the year, that you’re not going to have otherwise… Even if a significant fraction of those people are spending money outside the Arena itself, that’s still a big impact.” “The new Arena will have 1,500 more seats, meaning bigger acts, better events, and a stronger local economy… We can expand Santa Cruz’s entertainment market without losing what makes the city special… Instead of having events at the arena 40 days a year, we’re talking about 75 or even 150 days a year… Right now, we’re limited in who we can bring to Santa Cruz. A bigger venue changes that—it lets us attract bigger acts that wouldn’t come otherwise… The new arena will allow us to move up a tier in terms of entertainment—bigger than what goes to The Catalyst, but still fitting for Santa Cruz…” Jorian Wilkins, director of the Santa Cruz Downtown Association (initial meeting January 23rd, 2025)
Wilkins connected me with Rebecca Unitt (contacted 1/24/25, meeting February 3rd, 2025), manager of the Economic Development Department at the City of Santa Cruz, and Gaven Hussey (contacted 1/24/25, meeting 2/6/25), Parking Program Manager for the City of Santa Cruz. These interviews helped gauge the team’s impact on local businesses, the city’s stance on approvals for a new arena and lease deal, and how the team fits into broader mixed-use housing and development plans. Rebecca gave me access to Placer.ai.
Jorian Wilkins and I talked about current revitalization efforts downtown, including the development of housing and infrastructure on South Pacific Ave. She connected me with Terrence Concannon, CEO of Visit Santa Cruz, the local tourism coordinator.
Terrence Concannon, director of Visit Santa Cruz (contacted 2/6/25, multiple meetings) Emphasized the economic and tourism impact of the Santa Cruz Warriors on the local economy. He noted that many Warriors fans, including those from outside the county, travel to Santa Cruz to attend games, particularly due to the success of the Golden State Warriors and the appeal of watching young players develop. He highlighted the seasonal challenges faced by downtown businesses, particularly in the winter, and stressed the need for further investment in the Warriors' arena and surrounding infrastructure. “I’d love to see the Warriors get a more attractive and more dynamic arena. What we need is an entertainment zone—like 62 23.460
at Major League parks—where you have retail, taverns, and fun activities to really create a vibrant atmosphere.”
Concannon also underscored Santa Cruz’s deep-rooted connection to entertainment and sports, noting that tourism is the city’s top industry. He sees the city’s welcoming and progressive culture as a potential tourism draw, with visitors appreciating its inclusive atmosphere and values. “Visitors come to Santa Cruz to go the beach, surf, wine taste, or go to redwoods. Our brand is Keep Santa Cruz Weird so we have to encourage economic development that is consistent with the laid-back beach vibe of a California beach town where Jack O’Neill invented the wetsuit.”
“Santa Cruz’s number one industry is tourism, and our products are fun, transformational experiences, and lifelong memories. We strive to learn more about our visitors, their trends, their desires, and their concerns, so that we may work with our stakeholders, our partners, and our government entities to manage the destination for the benefit of our residents and visitors alike.”
APPENDIX 2: Secondary Interviews with Team Partners
(see Fig. 1- Area Map).
March 3rd, 2025. Ivy Riberio, Director of Sales & Marketing, Courtyard by Marriott (313 Riverside Ave). Riberio is actively working to expand their current partnership with the Warriors. Visiting and home team players and families receive a discounted group rate at the Courtyard and have been staying there since the beginning of the partnership in 2023. She mentioned, "Having the groups here, especially in the off-season, it's been very, very helpful, not just in our occupancy, but also in our revenues. It's hard to get groups to come out during the low season, so that has helped us a lot. Every team that comes, they get, you know, 20 to 25 rooms. Our hotel has 151 rooms, so I want to say that 20 to 25 percent of the revenue in lower months can be attributed to the Warriors."
Ms Ribeiro was enthusiastic about the contributions the basketball season makes to the Courtyard’s off-peak season dip. The Courtyard has extended its partnership contract with the Warriors until 2026. "We are looking forward to continuing to have a partnership because it definitely helps, especially on the slower months, you know, during the winter and everything… The Warriors season is a great addition to our hotel for sure." John Bilanko, owner, Iveta Downtown (545 Pacific Ave.), email and phone interview John and his partner own a restaurant on the UCSC campus and one restaurant on the West Side of Santa Cruz that are counter service. The location near the stadium is their first table service restaurant in Santa Cruz. They made the decision to open in this location because Mr. Bilanko got a great deal on the property and according to him “everything in the area is growing.” I asked John about changes in business before and after the Warriors came to town in 2012, and to help me by quantifying how much their business had been impacted.
He says there is definitely an earlier dinner crowd between 4:00 and 7:00 before Warriors games with an estimated increase of 50% over a non-game night. They are a promotional partner of the Warriors but are not sure if the promotion is worth continuing. 63 23.461
Zach Davis, owner, Penny Ice Creamery (913 Cedar Street), email and phone interview When the Warriors score their 100th point of the game, the Arena goes crazy.
Everyone inside just got a free ice cream! Until all locations close, any game ticket holder can walk in and get a free scoop. Davis started his partnership with the Warriors in 2016. He explained that Penny’s partnership with the Warriors affiliates the two brands in customers’ minds. He believes the Warriors’ high level of community involvement and the overall respect the brand has gained in the past decade align well with his personal business goals.
Placer.ai data shows that visitors stop by each of Penny’s three locations after games.
Although the line is always out the door at the downtown location on weekend nights, a significant percentage of customers head to Scotts Valley and Aptos for their free scoop as well. Overall, game nights generate foot traffic and increased revenue for Penny. Even with the free scoops, game nights lead to a 20.4% increase in sales compared to non-game nights.
They hold charity events and get the team to scoop ice cream “I think what's pretty obvious is that the non-Fri/Sat games activate the Cedar Street location beyond the norm…Broadly, it looks like the per guest spend drops on game nights (which makes sense since some people just get the free ice cream) but it does appear that the store is up overall, and as we discussed, the expectation is that activity leads to top of mind positioning for the Penny when people want to pay for ice cream.” Forrest Prosser, manager, Woodstock’s Pizza- Manager, Forrest (710 Front St), email and in-person interview
Woodstock’s Pizza is a bar and popular dinner spot downtown for fans before and after games. They do a volume business. Forest has been the manager at Woodstock's since 2015 and says they definitely have an increase in foot traffic on game nights before and after games. “We recently remodeled in 2025, and I've been getting a lot more fans after games now, and also to watch Warriors away games at the new bar.” Forrest met with me on February 3rd and we went over sales data and calculated the sales boost that Woodstock’s experiences in revenues on game nights. He agrees with my calculations that ‘I think 5.88% for last year seems right, as winter was much rougher last year for the entirety of Santa Cruz.’
Timmy Hunt, owner, Pono Island Grill (120 Union Street), email and phone interview Timmy left Downtown in 2020 during COVID because of break-ins and had no intention of coming back, but did because he got a great deal on the building and has his own liquor license and a lot more control as the sole owner. Pono Grill frequently hosts live music nights and Warriors away game watch parties.
Yes, the team definitely has an impact. We see a 20-25% boost on a weekend night when there is a game, but it is weather-dependent. Rain keeps people away. Season ticket holders bring people in, and we run a promotion where kids eat free before games. We do watch parties for away games. We provide the neighborhood with a community-oriented business with an island vibe. I can say it’s probably about 15% on average for games. If it’s a weekend, we can see 20% and on watch parties 25%. As a promotional partner, Timmy says, “The team is doing things the right way and for a purpose. We believe in giving back and 64 23.462
serving others. The G-League players' stories and mentality are inspiring. They have a strong work ethic and have an impact, living here in the community.” Interviews with Key Downtown Businesses:
Pacific Cookie Co., Mission Hill Creamery, Hula’s Bar and Grill, Kianti’s Pizza, Lupolo Craft, Nick the Greek, Oswald Restaurant, Top Spot Sports Bar, The Blue Lagoon, The Asti, Big Basin Tasting, Pizza My Heart
For all of these businesses, I visited first in person and asked the following: Will you talk about changes to your business as a result of the Warriors coming to town in 2012, and would you help me by quantifying how much your business has been impacted on game nights? A follow-up call/ meeting was scheduled, and key themes were recorded below.
Cara Pearson, second-generation owner, Pacific Cookie Co. (1203 Pacific Avenue).
She is a large employer in Santa Cruz and has multiple locations throughout the county, as well as a strong commercial business with grocery stores. “I ran our sales for all the February dates listed below and then used a non-Warriors weekend to compare it to. On Friday game nights, we saw a 14% increase in sales, and Saturday games brought a 37% increase in sales.
She is looking forward to another redevelopment phase downtown, and is excited about an activated South Pacific Avenue, and thinking about how to creatively fill those spaces. She also pointed out the importance of the location of the arena and new development as it is right between downtown and The Wharf, and actually brings people from one to the other.
She is very excited and told me to emphasize that change happens, and is needed, even though some people don't want to see development in Santa Cruz. Even though development is needed there is also a need to sustain the uniqueness of Santa Cruz and embrace its unique character, because that is why people come.
email, manager, Mission Hill Creamery, Manager (1101 Pacific Avenue) “So sorry, but we are very short-staffed and wouldn’t be able to research the specific information you’re requesting. I’d say we see an 8-10% bump on game nights if it’s not raining, but we can’t be sure.”
Ian McRae, owner, Hula’s Bar & Grill (221 Cathcart Street) Hula’s is an island-themed bar and popular dinner spot near the stadium downtown. “Ian asked me to give you a general percentage for sales impact on game nights. “We see that our sales increase by about 10% on game days. We believe the Warriors have impacted our business in a positive way”
Tracy Parks-Barber, owner, Kianti’s Pizza (1100 Pacific Avenue).
Kianti’s Pizza is a very popular dinner spot downtown for fans before and after games. “We felt a big impact in 2012, and invested in an affordable sponsorship with the team. Kianti's participated in the Pizza Run, in sponsoring the t-shirts thrown at games, and halftime Pizza Spinning Performances. The Warriors have been good for revenues, and our past association with the team has continued on with busy game nights at Kianti's. Now the cost is way too 65 23.463
high for sponsorship for small businesses, but overall the Warrior game nights are great for business.
John, Lupolo Craft Beer House, (233 Cathcart Street)
“I wouldn't say it's like something that we need to [prepare for]. But it will bring a little bit of traffic, about ten percent? We saw a big boost for the game that was on Martin Luther King Jr Monday. Normally, the 7PM game, whatever, it'll bring people in but not that crazy. Yeah, just more people for a Friday, it's exciting before the game.” She estimated the percentage impact.
Sol, manager, Nick the Greek (1133 Pacific Avenue)
“There is a noticeable difference on game nights/days because she notices a bigger crowd and people come in with their Warriors merch on. She has her kitchen prep about twenty percent more on game days to account for more people coming in.
Damani Thomas, owner, Oswald Restaurant (121 Soquel Avenue) Thomas talked to me about his love for the Warriors and the business the team brings in on game nights, “Yeah, so the game night's pretty sweet. When the game starts [at] seven, well we open at five. It's like a two-hour window for people to have a nice little dinner and everything, and at our place, there's usually a line to the parking lot, so yeah, I like it.” He knows the season ticket holders who come in before games by name, and welcomes Chris Murphy and friends or colleagues after games.”I’d say that on game nights we see 10-20 % more revenue on those nights. The weekends are where most of the games are scheduled. For me, it’s better if the games fall on weeknights. That’s where I could use a surge in occupancy the most.”
Chuck Hammers, owner, Pizza My Heart, (1116 Pacific Avenue) Hammers was willing to share POS data for me to analyze. According to the sample dates, I found revenue spikes on game nights with an average boost of about 24.55%. Before 7 PM games, 5 to 6 pm is 49.58% higher, and 6 to 7 PM is 54.87% higher. I also uncovered a latenight increase in post-game activity; 12 to 1 AM revenue is up 19.26% on game nights.
Overall, game days tend to have more consistent revenue levels than non-game days, and it is safe to assume that an event at Kaiser Permanente Arena brings increased foot traffic into Pizza My Heart.
Bartender, Top Spot Sports Bar (923 Pacific Avenue)
“It's pretty common almost every time there's the Santa Cruz Warriors match, I hear about it from the customers, people who come in wearing merch. I've been a bartender for like three years, and it's like I immediately noticed it.” Reported 10% increase.
Manager, Big Basin Winery, (525 Pacific )
Contacted in person on 2/6/2025- Informational sheet and contact info, Follow-up in person 2/9/2025, Follow-up call and email to manager
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Contacted multiple times, percentage change is based on the experience and knowledge of next-door Iveta, with similar hours and customers.
Bartender, The Asti (715 Pacific Avenue)
Contacted in person on 2/6/2025- Informational sheet and contact info. Follow-up in person 2/9/2025. Follow-up call and information received on Feb 16th.
Contend no change in business game nights
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Brittany Inclan
From: Gabrielle Diane Laney-Andrews <[email protected]> Sent: Monday, May 12, 2025 12:18 PM
To: City Council
Cc: Fred Keeley
Subject: Say NO to Rezoning Santa Cruz for Unaffordable Skyscrapers Dear City Council and Mayer Keeley,
I am writing to you today about the shocking and dismaying plans for building in our small city. I agree with many points made by other citizens of Santa Cruz regarding Item #23 Item #23: Downtown Plan Expansion, Extending and Amending the Downtown Specific Plan, Including for Areas South of Laurel Street, Roughly to the Roundabout at Pacific and Center Streets, and Making Related Changes to the General Plan, Local Coastal Plan, Beach/South of Laurel Plan, and Zoning. Applicant: City of Santa Cruz. CEQA: EIR (PL) We have limited space in our town, we need to plan wisely, not only downtown but on the projects proposed for Ocean Street, Water Street and Soquel. The amount of housing units is staggering when added all together. Please take more time to consider the impacts on our infrastructure, environment and resources impacting all how live here now and in the future.
I wholeheartedly support these points:
TAKE TIME TO MAKE AN IMPORTANT DECISION
-Don't follow the orders of staff, STAND UP, REPRESENT US, DECIDE CAREFULLY to upzone the Downtown Plan Expansion, this is on one of the most serious, pivotal change in the history of Santa Cruz! Time your time, stop the rush! DELAY making a decision- take more time to fully read and consider the Environmental Impact Report (EIR). The planning commission was given only 2 days to analyze the Environmental Impact Report of 370 pagesNOT enough time for such a huge document and big decision! Incremental development is a better choice, not a dramatic, all-out assault on our downtown.
THE 100% DENSITY BONUS kills the "More housing" argument. -The downtown plan expansion (DPE) rezoning or "UPzoning" for housing is NOT needed since with State Law AB1287, or the 100% density bonus legislation, it is required to build DOUBLE the existing density, with 15% affordable units. The DPE area is 29 acres, but the total area subject to the double density of AB1287 is 1735 acres-plenty space for housing! (see General Plan Table Lu-2) Housing developers do NOT need an increase in height limits since AB1287 waives height limits when you build housing.
IS THE HIDDEN AGENDA MORE HOTELS?
The Downtown Plan Amendments would change South of Laurel zoning from High and Medium Density Residential to "Visitor Serving Commercial."
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This allows housing developers to compete with wealthy corporate hotel developers for this project area. Upzoning from 45 to 85 feet in the DPE will give a huge feast for hungry hotel developers. Especially near the transit center, residential housing (not hotels) should be a priority.
DO WHAT YOU PROMISED
On Jan 10, 2023, this city council asked staff to reduce heights and limit the apartment units to a max of 1600. Keep your word! Stand up for these original goals in the face of staff pushing now to build 1800 units (which with the 100% density bonus law ,can easily be over 3000 units! With over 6000 cars and with the very high, corporate rents encourage overcrowding.
Can we trust you as our elected officials to do what they say? Please listen to the citizens you represent,
thank you,
Sincerely,
Gabrielle Laney-Andrews
316 Grant St
Santa Cruz 95060
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Brittany Inclan
From: Richard McGahey <[email protected]>
Sent: Monday, May 12, 2025 1:12 PM
To: City Council
Cc: [email protected]
Subject: Comment in favor of strengthening Downtown Plan Expansion, from progressive economist and Santa Cruz homeowner
Attachments: McGahey Comment Santa Cruz Downtown Plan Expansion.docx Dear City Council and Staff:
I am an owner in the DeAnza mobile home park in Santa Cruz, and a progressive economist who studies housing and cities. I’m writing to strongly support the Downtown Plan Expansion, and I urge the Council to not cut it further—in fact, you should be expanding it and increasing the density to its legal limit. Santa Cruz is one of the nation’s most costly housing markets, and research shows that building all types of housing, including market rate, helps lower rents and housing costs. (I’ve written elsewhere about housing for Santa Cruz, including this piece for Santa Cruz Lookout opposing Measure M, https://lookout.co/author/richard-mcgahey).
The 2024 annual “Out of Reach” report by the National Low Income Housing Coalition once again found the Santa Cruz-Watsonville region to be the most expensive in the nation, measured by income to rent ratios. That’s more expensive than San Francisco, Boston, or New York City.
Sadly, Santa Cruz has held this position for several years. It means regular workers who make the city go—including teachers, firefighters, public safety officers, and regular employees of all kinds—can’t afford to live here. And higher housing costs also contribute to making people unhoused, by pushing prospective owners and renters down the housing supply chain, which in turn pushes lower-income people out of housing.
A growing body of economic research shows that building housing of all sorts, and rezoning to allow more density, brings down housing costs. Recent experiences in Austin and Minneapolis provide the latest positive examples. (There’s too much research to cite in this brief comment, but I’m happy to share it with you and the planning staff.) Regrettably, the Council has been cutting allowable housing for this project, and according to Santa Cruz YIMBY, the current proposal provides “less than 25%” of the potential housing that could go into the neighborhood. Don’t throw away this once-in-a-lifetime opportunity. The neighborhood is close to public transit, provides good walking opportunities, and housing growth will help the city link downtown and the beach and boardwalk, a long-desired economic development objective.
I fully endorse the recommendations of Santa Cruz YIMBY, such as including more parcels, and adjusting FAR ratios to match those above Laurel Street.
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Although you may be hearing objections to the project through public meetings and comments, you should be aware that research shows such public comment is generally not representative of the full community, especially lower-income and non-white people. Research shows that speakers in public meetings and other housing opponents are disproportionately wealthier, older, and whiter than their respective communities overall. And I know you care about all our people, not just the affluent subset that opposes housing.
Again, this is a once-in-a-lifetime opportunity to help address the city’s chronic housing shortage and very high costs, provide housing near public transportation that will not disrupt primarily residential neighborhoods, help economic development by linking downtown with the beach, and—most importantly—add significant housing that will help lower costs for economically excluded workers and families. Listen to Santa Cruz YIMBY and other advocates and allow more density and housing in this keystone project. It already has been cut back too much and should be expanded within legal limits.
I am happy to share the research mentioned in this comment or discuss any of these issues with you and relevant staff if that would be helpful.
Here’s an attached Word version of this comment:
________________________________
Rick McGahey (he/him/his)
Author, Unequal Cities, Columbia U. Press, (nominated for the National Book Award) http://cup.columbia.edu/book/unequal-cities/9780231173346 Senior Fellow, Schwartz Center for Economic Policy Analysis Senior Fellow, Institute on Race, Power, and Political Economy The New School
[email protected]
[email protected]
mobile: 347-931-0304
Twitter: @rickmcgahey
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TO: Santa Cruz City Council and Planning Commission
FROM: Richard McGahey, Ph.D, economist, Institute on Race, Power and Political Economy, The New School (for identification purposes only) SUBJECT: Approve and strengthen the Downtown Plan Expansion, and reverse the cuts already made to it
DATE: May 12, 2025
I am an owner in the DeAnza mobile home park in Santa Cruz, and a progressive economist who studies housing and cities. I’m writing to strongly support the Downtown Plan Expansion, and I urge the Council to not cut it further—in fact, you should be expanding it and increasing the density to its legal limit. Santa Cruz is one of the nation’s most costly housing markets, and research shows that building all types of housing, including market rate, helps lower rents and housing costs. (I’ve written elsewhere about housing for Santa Cruz, including this piece for Santa Cruz Lookout opposing Measure M, https://lookout.co/author/richard-mcgahey).
The 2024 annual “Out of Reach” report by the National Low Income Housing Coalition once again found the Santa Cruz-Watsonville region to be the most expensive in the nation, measured by income to rent ratios. That’s more expensive than San Francisco, Boston, or New York City.
Sadly, Santa Cruz has held this position for several years. It means regular workers who make the city go—including teachers, firefighters, public safety officers, and regular employees of all kinds—can’t afford to live here. And higher housing costs also contribute to making people unhoused, by pushing prospective owners and renters down the housing supply chain, which in turn pushes lower-income people out of housing.
A growing body of economic research shows that building housing of all sorts, and rezoning to allow more density, brings down housing costs. Recent experiences in Austin and Minneapolis provide the latest positive examples. (There’s too much research to cite in this brief comment, but I’m happy to share it with you and the planning staff.) Regrettably, the Council has been cutting allowable housing for this project, and according to Santa Cruz YIMBY, the current proposal provides “less than 25%” of the potential housing that could go into the neighborhood. Don’t throw away this once-in-a-lifetime opportunity. The neighborhood is close to public transit, provides good walking opportunities, and housing growth will help the city link downtown and the beach and boardwalk, a long-desired economic development objective.
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I fully endorse the recommendations of Santa Cruz YIMBY, such as including more parcels, and adjusting FAR ratios to match those above Laurel Street.
Although you may be hearing objections to the project through public meetings and comments, you should be aware that research shows such public comment is generally not representative of the full community, especially lower-income and non-white people.
Research shows that speakers in public meetings and other housing opponents are disproportionately wealthier, older, and whiter than their respective communities overall.
And I know you care about all our people, not just the affluent subset that opposes housing.
Again, this is a once-in-a-lifetime opportunity to help address the city’s chronic housing shortage and very high costs, provide housing near public transportation that will not disrupt primarily residential neighborhoods, help economic development by linking downtown with the beach, and—most importantly—add significant housing that will help lower costs for economically excluded workers and families. Listen to Santa Cruz YIMBY and other advocates and allow more density and housing in this keystone project. It already has been cut back too much and should be expanded within legal limits.
I am happy to share the research mentioned in this comment or discuss any of these issues with you and relevant staff if that would be helpful.
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Brittany Inclan
From: Roland Saher <[email protected]>
Sent: Monday, May 12, 2025 1:18 PM
To: City Council
Subject: No to skyscrapers!
Dear Council members and mayor,
I am all for creating affordable housing in SC, but not in this way! Are you thinking of sea level rise at all? In addition to the traffic that would come with skyscrapers, not to mention the aesthetics?
Roland Saher
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Brittany Inclan
From: Garrett <[email protected]>
Sent: Monday, May 12, 2025 1:30 PM
To: City Council
Subject: 5.13.25 Item # 23 Expanding Downtown
5.13.25 Item # 23 Expanding Downtown
Since whatever I, or anyone, writes doesn't matter, I'll keep it simple.
NO
Garrett Philipp
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Brittany Inclan
From: Juan Serna <[email protected]>
Sent: Monday, May 12, 2025 1:35 PM
To: City Council
Subject: Downtown expansion plan
Hi, as a person who has lived in Santa Cruz their whole life we don't need higher buildings... we need rent control. Not just 20% affordable housing. Most new apartments aren't even filled up yet either we are trying to be like a mini city it doesn't work
Sent from my Galaxy
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Brittany Inclan
From: Simone Young <[email protected]>
Sent: Monday, May 12, 2025 1:39 PM
To: City Council
Cc: Heather Hall
Subject: Downtown expansion plan
To whom it may concern:
I have been a resident of Santa Cruz Since 1974. The family came here while I was in high school. I have lived here ever since. My adult daughter and 20 year old grandson live here. We love this community and feel strongly that allowing buildings of 12-20 stories will destroy what makes Santa Cruz unique, lovely and enjoyable to live.
Buildings of 4-8 stories is plenty for downtown. So please please please, vote for EIR Alternative 1, with Option B only.
Thank you
Simone Young
Homeowner
307 Mountain View Ave
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Brittany Inclan
From: [email protected]
Sent: Monday, May 12, 2025 2:12 PM
To: City Council
Subject: Support for Warriors
Greetings Mayor, Vice Mayor and City Council Members,
I am writing in support of a permanent arena for the Santa Cruz Warriors in Downtown Santa Cruz. The Warriors are a major vibrancy driver for the area, attracting thousands of people on a regular basis during our “oƯ-season” from tourism. This customer boost is critical to many of the small, locally-owned businesses in our district. Thank you for helping the Warriors get their arena built.
Warmly,
Jorian Wilkins
Executive Director
Downtown Association of Santa Cruz
www.DowntownSantaCruz.com
Instagram | Facebook | Newsletter
Upcoming Downtown Events!
JUNE 1 PARADE & FESTIVAL DOWNTOWN
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*Be a Downtown Event Sponsor*
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Brittany Inclan
From: J. D. Hillard <[email protected]>
Sent: Monday, May 12, 2025 2:29 PM
To: City Council
Subject: Item 23 on May 13 Agenda, Downtown Plan Expansion needs more density From J.D. Hillard, 1035 Laurent Street
Dear Councilmembers,
I urge you to ensure the Downtown Plan Expansion envisions an increase in density commensurate with the urgent housing and economic situation in our city.
Please use your vote to increase the General Plan development capacities of all 42 parcels in the project area, instead of just six, and to increase the floor area ratio (FAR) from the current maximum of 3.5 to match the maximum for the rest of the downtown area, which is 5.
With a bunch of new empty stores and decades and decades of flight by young families and along with decades of failure addressing homelessness, the unsuitability of our construction for our population could not be more clear.
The downtown area and this plan represent an opportunity that comes only rarely for our community to make a realistic plan for our future. We know we need thousands of additional units to meet the needs of Santa Cruz's residents today. Downtown is an ideal location for families and workers, who will enjoy more quality of life with reduced need to drive for services and employment.
Please reject any form of this plan that fails to take advantage of the opportunity to increase density across all the parcels in the project area.
Thank you for hearing my comment.
Sincerely,
J.D. Hillard
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Brittany Inclan
From: Ashley Spencer <[email protected]>
Sent: Monday, May 12, 2025 2:58 PM
To: City Council
Subject: I write in SUPPORT of a permanent stadium for the Warriors Dear Members and Mayor Keeley
I am a lifelong Santa Cruz resident who convinced her husband to raise children in town. It’s my belief that The Santa Cruz Warriors could make it possible for them to return to Santa Cruz as adults.
The Warriors are an economic engine for downtown Santa Cruz and will anchor all the new construction on lower Pacific Avenue.
Without the new stadium as a draw, apartments will be purchased as investment properties -- which adds little to the vibrancy and appeal of our city. With concerts, games and events at a new stadium, we're a magnet for year round activity, supporting local businesses.
Our eldest daughter did her thesis on the Warriors’ economic impact and found that the team boosts downtown foot traffic by 13% on game nights. There are now just 24 game nights and a smattering of other events. With a larger stadium, training facilities and better seating The Warriors will be able to expand this impact — and continue to be an outstanding model of corporate citizenship. Rarely does a city get the opportunity to invest in a proven model. This is that chance.
Please stand in support of the future of Santa Cruz, one where young families and professionals are happy to put down roots.
Thank you,
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Ashley Spencer
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Brittany Inclan
From: Keith McHenry <[email protected]>
Sent: Monday, May 12, 2025 3:04 PM
To: City Council
Cc: Fred Keeley; Renee Golder; Susie O'Hara; Sonja Brunner; Shebreh Kalantari-Johnson; Scott Newsome; [email protected]
Subject: I am against the rezoning under Item #23
Dear Council
Please stop all these developments. Not only are they ugly and a blight on our community but services like our hospital are already stretched.
Our emergency room often is forced to move people into hallways and if their is another drought we will be in a huge crisis if all these units are filled.
I have attended may public hearings on these projects and most local people who attend are angry that our voices are being ignored.
Thanks for voting to stop all these horrid projects.
Keith McHnery
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Brittany Inclan
From: Frank Barron <[email protected]>
Sent: Monday, May 12, 2025 3:26 PM
To: City Council
Subject: Fwd: Comments for 5/13/25 CC - Item #23
Attachments: City Council Comments 5-13-25.pdf
Hi Bonnie,
Please let me know you got this attached comment letter on the DPE project (Item #23) ok.
Also, as you probably saw, the Mayor has given me extra time to present tomorrow night (5 min.). What's your deadline for me getting you my short slideshow? Or do I need to bring it on a thumb drive? Thanks,
Frank Barron
Santa Cruzans for Responsible Development
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May 12, 2025
City Council
City of Santa Cruz
809 Center St.
Santa Cruz, CA 95060
Sent via email to: [email protected]
Re: Downtown Plan Expansion Project
Mayor Keeley and Councilmembers:
Thank you for the opportunity to provide comments on the proposed Downtown Plan Expansion (DPE) Project. This project in the 29-acre South of Laurel area (SOLA), with its proposed 1,600 new housing units in a series of new high-rises and a new 3,200 seat sports arena, constitutes one of the largest most impactful land use changes in the city’s history. While there are many potentially significant negative issues associated with this development, I am personally supportive of several aspects of the project. I realize that recent state law laws and housing mandates will ensure that there will be significant new development in SOLA no matter what skeptics and opponents want. It’s inevitable. That said, I and many others in this town would strongly favor a scaled back version of the DPE proposal.
Today city staff is asking your Council to approve the DPE project and certify the Final Environmental Impact Report (EIR) for the project. On April 17, 2025 the city Planning Commission recommended approval of the project and EIR by your Council. However, the Planning Commission barely had a chance to review the Final EIR, since it was released only two days before the hearing. Moreover, the public had less than 24 hours to review its 370 pages before the 12-noon Wed. 4/16 Planning Commission comment deadline. This is an inappropriately short amount of time considering that numerous groups and citizens submitted voluminous comments pointing out many EIR deficiencies. There is no way that the Planning Commission had adequate time to fully review the 370-page document and to conscientiously recommend its approval by your Council, as they did.
Aside from the issue of inadequate time to review the project’s Final EIR, I have numerous concerns with the project as proposed. But I will focus here primarily on the overriding issue of building heights and the unintended consequences that will arise from raising the height limits in the 29-acre South of Laurel (SOLA) project area, as is proposed and shown in the maps below:
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Current Base Height Limits (35’-48’) before Density Bonuses:
This map is from the “Development Scenarios” document presented at 6/14/22 City Council mtg.
Proposed Base Height Limits (50’-85’) before Density Bonuses:
This map is from proposed Downtown Plan amendments document As shown above, the DPE project proposes to raise base height limits from the existing range of 35-48 feet to a proposed range of 50-85 feet. Which doesn’t sound so bad, until you add on the relatively new 100% state Density Bonus provisions in AB 1287, that allows qualifying developments to exceed those height limits by 2 to 3 times. For 2 23.484
instance, in the new 85-ft. height limit zones that are proposed for most of SOLA, buildings 170-255-ft. tall could result - those would be 16 to 20+ story highrises depending on how the provisions of AB 1287 are applied. It might not happen, but by irreversibly raising the height/density limits, that possibility will always be there. Take for example the recently proposed 192-ft. Clocktower Center, which can apparently be allowed in a 50-ft. height limit zone on North Pacific due to AB 1287. That’s 3.8 times taller than the city’s height limit. The city couldn’t say “no” if it complies with the provisions of AB 1287, as state laws like AB 1287 have supremacy over local regulations.
Workbench’s 192-ft. “Clocktower Center” would likely have to be approved in a 50-ft. height limit zone due to AB 1287. The City would have no ability to deny it if it complies with the provisions of AB 1287.
The Clocktower Center is on hold for now, but Workbench says it could come back at any time once the needed additional financing is secured.
Your Council’s direction for the parameters of the Downtown Plan Expansion project, as given on on 1/10/23, was for a “maximum” of 1,600 new housing units (not “around” 1,600 units as stated in the staff report), with a net 20% below market rate, and with no 3 23.485
building exceeding 12-stories in height. Those were the staff’s marching orders. And the DPE plan was designed around those parameters. But when AB 1287 came along, giving additional state mandated height and density waivers, the DPE plan did not adjust accordingly.
The original intent of raising the height limits in Blocks A-D (i.e., Ace Hardware, Wheel Works, Kaiser Arena, and Aloha Motors and the areas in between) up to 85-feet, or 8-stories, was to allow for the 12-story height limit to be achieved after the old 50% state density bonus was applied. But that calculation is now out the window with the advent of the new 100% state density bonus (AB 1287), since buildings taller than 12-stories would be possible in an 85-ft. (or 3.5 FAR) zone. The ground has shifted. However, the Final EIR doesn’t analyze the potential effect AB 1287 at all, saying such impacts are just “speculative” and therefore don’t need to be addressed or analyzed.
In our comments on the Draft EIR, many of us asked that the graphic renderings in the plan and EIR be revised to account for the impacts of the proposed height increases if the AB 1287 density bonus is applied, which as already stated, would give developers a permanent entitlement to build 14-20+ story buildings, potentially, in the proposed 85-ft. height limit (3.5 FAR) areas. Since that request was denied, here are some hypothetical depictions that give an idea of the scale of the buildings the proposed project would allow:
This is an altered version of one of the renderings in the DPE plan that give an idea of what 15 stories would look like on Blocks B (Wheel Works) and D (Kaiser Arena). The original only showed 10-12 stories.
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These hypothetical 20-story and 12-story buildings show the scale of what could appear in SOLA
This hypothetical 15-story building is an example of the height of what could potentially be built if base height limits are increased to 85-ft., as proposed. 5 23.487
This 16-story tower is a hypothetical example of the scale of building, as seen from Broadway looking towards downtown/SOLA, that could be allowed if the proposed upzoning goes forward.
Our main message to the City Council is don’t make an unforced error. It would be an error to raise the height limits in SOLA because it would unintentionally give developers the permanent entitlement to build 14-20+ story buildings. Buildings this tall could result even with the proposed 3.5 Floor Area Ratio (i.e., 14 or more stories could easily result if the building footprint uses only a portion of the lot square footage). It’s unforced because raising height limits in SOLA is not needed to achieve the DPE goals of 1,600 new units, with 20% affordable, and a new SC Warriors arena. All this can be done with the 6-8 story buildings that current height limits allow (with density bonuses). The SC Warriors have even said they only need 7-8 stories (see Max Chun’s Lookout article of 3/1/24).
Suggested Alternative to Proposed Project
I and other members of Santa Cruzans for Responsible Development would be supportive of a reduced scale DPE project similar to the Reduced Project Alternative (Alternative 1) presented in the EIR, which has also been deemed the “Environmentally Superior Alternative” in the EIR. This alternative would keep the existing zoning and height limits in SOLA, subject to applicable density bonuses. Our recommendation 6 23.488
includes a reduced scale version of the city’s Downtown Density Bonus (DDB) Option B, but not Option A. We support removing DDB Option A because its 12-story (145-foot) buildings would be overly massive (twice as tall as Anton-Pacific) and are not necessary to meet the City Council’s goals.
We believe Option B should be modified to lower height limits on two blocks for the same reasons (i.e., 70-ft. max in Blocks A and C - from Ace Hardware down to Aloha Motors, with 85-ft. max allowed only in Blocks B and D along the levee). The EIR’s Alternative 1, with this reduced DDB Option B-only, would achieve the DPE project goals and allow for the project to go forward with no objections from our group.
Moreover, we believe it would be broadly acceptable to most Santa Cruzans.
This is what Anton-Pacific would look like as a 12-story building (instead of 6). This is to give an idea of what would be allowed throughout SOLA if the proposed Downtown Density Bonus Option A is retained.
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Potential new home for the SC Warriors? The Warriors have indicated that they can build their arena and meet the 1,600 unit project goal with 7-8 story buildings (see Max Chun’s article in the 3/1/24 issue of Lookout). No upzoning would be needed to achieve 7-8 stories.
The project goals of 1,600 units, with 20% affordable, a new Warriors arena, and public space and infrastructure improvements, can be accomplished with 6-8 story buildings…which are allowed now under current height limits. Selecting the EIR’s Alternative 1, with a reduced Downtown Density Bonus Option B-only, would accomplish this, and would result in a project that looks like the images above.
In conclusion, I urge your Council to keep height (and density) limits in SOLA where they are now, by adopting the EIR’s Alternative 1, with the reduced Downtown Density Bonus (DDB) Option B-only (as explained above). It would be a huge mistake to give away your power, our power, our local control, over the shape of the future of Santa Cruz. By raising the height limits we are ceding that control, that power, to whatever developer may come along anytime in the future. It could be some out-of-town, fly-by-night hustler who just wants to cash in and bail, leaving us with some ugly 14-20 8 23.490
story monstrosity. If we raise the height limits as the DPE project currently proposes, it will be entirely up to them. Moreover, buildings of greater than 8-stories are not needed to meet the DPE project’s goals of 1,600 new units, with a net 20% being below market-rate if DDB Option B is utilized. Building heights of 8-stories are already allowed (with DDB Option B or AB 1287), making the proposed upzoning unnecessary. Please adopt EIR Alternative 1, with a reduced DDB Option B-only.
SIncerely,
Frank Barron, AICP
Retired Land Use Planner
Member of Santa Cruzans for Responsible Development
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Brittany Inclan
From: Ed Castagna <[email protected]>
Sent: Monday, May 12, 2025 3:30 PM
To: City Council
Cc: Ed Castagna
Subject: item #23-Downtown Plan Expansion
Dear Councilmembers,
When the Planning Commission heard details on the Downtown Plan Expansion on 4/17/25, several issues, in addition to the out-of-control urban development, came to the public's attention. Height restrictions are technically at the whim of developers as highrise landlords are in control of rental costs to tenants.
Tenants is the term used because, although the Planning Commission admitted ignorance of the fact stated by the presented details, 100% of the 6-25 story buildings will be rentals. There is no rent control plan or proposal, while a mere 15 up to 25% of future high-rise apartments will include status as "affordable housing." Rents for other tenants will be high and unregulated.
The current state-mandated housing goals are met. The massive vertical expansion and upheaval of Santa Cruz's former identity related to unsightly building and height restrictions would lead to further chaos in our troubled downtown. Further vertical construction needs to be paused while infrastructure, further environmental and transportation conversations are carried out. Businesses are leaving downtown due to theft and lawlessness in our city. Families avoid the area for the same reasons.
The Pacific and Laurel apartments are architecturally grotesque and at $5k/month, are termed 'luxury.' The businesses at Pacific and Laurel are unoccupied. There is no demand.
The council needs to scrutinize the demand that exists for the proposed and current partially constructed 6-story buildings lining the riverfront. 100% rentals. You have responsibility for the future tenancy. The Planning Commission stated there was a need for housing for those employed downtown.
Because a minor percentage of rentals would be subsidized as lower rent/affordable, that could be possible on a small scale, but largely not true.
Has the council considered and investigated the question of who would rent one of these apartments? All single people under 65 or seniors and retirees? Most unlikely. Ask yourselves if families would live in a 6-story rental unit in downtown Santa Cruz. There are no schools, parks, or green spaces near the building side of the river. However, full-time security guards are on duty at the bus loading area nearby due to crime and disorder. Who would bring their family to live in downtown Santa Cruz to put their children in an elevator and send them into the disreputable streets of Pacific and River Streets? Do you have data on the demographic and demand for the current partially constructed and future planned SOLA apartments?
The California Environmental Quality Act must be fully satisfied. Has the Council studied, reviewed, and reported to the community the results of the projected transportation impact of the existing and the proposed SOLA development? Taking license to build because of proximity to a bus stop is absurd. Will there be police escorts for the masses competing for a bus ride?
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Further infrastructure and environmental conversations must take place before Santa Cruz creates a kingdom of rentals for the profit of developers and landlords. Please explain why there are no condos for sale for people who want to invest in the future of Santa Cruz. The explanation given by the Planning Commission was weak and unclear.
Residents of Santa Cruz are alarmed at the rushed pace of this building frenzy. It appears to be frantically driven by outside interests and corporate profit. The architecturally bleak buildings thus displayed scream slow down and save Santa Cruz! The appearance of the buildings under current construction is reminiscent of housing projects of the 1960's and have disfigured the local skyline.
As elected officials, your responsibility is to the people and voters of Santa Cruz. Please exercise your roles in the best interests of the identity, and true housing needs of families and local residents with regard to transportation, environmental, and logistical concerns. Remove the current urgency to expand and build higher and cheaper as you investigate the impact of a potential massive increase in transportation on the environment, infrastructure, and review the impact on quality of life in our city. Conduct actual studies with data and conduct community conversations. Put away the rubber stamp. Pause and put people before profit.
Thank you,
Paula Castagna
Seabright
503-881-6253
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Brittany Inclan
From: [email protected]
Sent: Monday, May 12, 2025 3:33 PM
To: City Council
Subject: Downtown Expansion Plan
Dear City Council,
Please consider the impacts this plan could have on our small town. Please vote for EIR Alternative 1, with Option B only.
Thank you,
Lisa Ford
Sent telepathically...
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Brittany Inclan
From: Judy Weaver <[email protected]>
Sent: Monday, May 12, 2025 4:13 PM
To: City Council
Subject: Downtown Plan Expansion/SOLA Project
To Mayor Keeley and Members of the Santa Cruz City Council:
As a resident of the City of Santa Cruz, I urge you to consider carefully the approval of the Final Environmental Impact Report (EIR) and its effects on the City.
I am advocating for your vote for EIR Alternative 1, with Option B-only. This option meets the project goals WITHOUT raising height limits (resulting in mostly 4-8 story buildings, instead of 12-20 story ones).
The SOLA project is one of the largest and most impactful land use changes in the history of Santa Cruz! The City does not need to raise the height limits to be able to reach the housing goals in SOLA or to build the new Warriors arena. Current height limits are sufficient.
Thank you for your consideration!
Judy Weaver
Taylor Street
Santa Cruz CA 95060
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Brittany Inclan
From: John Hall <[email protected]>
Sent: Monday, May 12, 2025 4:16 PM
To: Fred Keeley; City Council
Subject: Keep DPE buildings 8 stories or less!
Dear Mayor and City Councilmembers:
Many community members already have communicated with you concerning opposition to the Downtown Plan Expansion in the form presently proposed and I will not repeat the details of the concerns here.
Fundamentally, the city’s choice is about the scale of the downtown’s buildings that are used to fulfill housing needs.
Other cities have shown a capacity to meet housing needs while building a city that remains at human scale, typically under 6 stories. Please look to the example of our sister city to the south, Santa Barbara.
I ask that the City Council forge a course of action that will limit absolute building heights in the DPE to eight stories, even with all density bonuses applied, whether under state law or through an alternative developed by the Council.
The present DPE proposal is both unnecessary to meet RHNA requirements and excessive in its social and environmental impacts to our community.
The vitality of our downtown, and thus the entire city of Santa Cruz, depends on your decision on how to expand the downtown. Please make the right decision. Keep the buildings eight stories and under!
Thank you for your consideration.
John Hall
. . . . . . . .
John R. Hall
Research Professor of Sociology
University of California - Santa Cruz and Davis
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Brittany Inclan
From: Santa Cruz YIMBY <[email protected]>
Sent: Monday, May 12, 2025 4:17 PM
To: City Council
Subject: City Council Agenda Item #23 - Downtown Plan Expansion Attachments: Support for Downtown Expansion Plan, City Council Meeting.pdf Please find Santa Cruz YIMBY's comment letter for the downtown expansion agenda item attached.
Thank you,
Santa Cruz YIMBY Leads
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May 12, 2025
To: Santa Cruz City Council
Re: Item #23, Downtown Plan Expansion
Dear City Councillors,
Santa Cruz YIMBY advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County.
We are writing to provide input on Item #23 of your May 13, 2025 agenda on the Downtown Plan Expansion.
It is clear that staff has done the best that they could given the direction provided. However, the reality is stark: the City of Santa Cruz is unable to place housing where it is most needed, and is in the process of potentially causing illegal downzoning. The city must upzone enough to offset the planned downzoning by 47 units of the Leonard Street neighborhood and/or the 116 units at the Homeless Garden Project site on Delaware Avenue or risk violation of the no-net-loss provision of the Housing Crisis Act of 2019. (Government Code §66300(b)(1)(A) and (i).) Ultimately, we support staff in their analysis and their recommendation. However, we encourage council to go further: to increase the General Plan development capacities to the legal maximum, and to increase the floor area ratio (FAR) from the current maximum of 3.5 to match the maximum for the rest of the downtown area, which is 5.
While Santa Cruz YIMBY (Yes In My BackYard) writes in support of efforts by the city to expand the Downtown Plan to include areas south of Laurel Street, we are deeply frustrated with how unambitious the proposed plan actually is. The staff note from the Planning & Community Development Department on page 23.8 of the City Council Agenda Report states, “Given the local, regional, and statewide housing shortage, as well as the state housing targets the City is striving to meet and exceed, staff continues to believe that the downtown area is the best place for more housing, and any underutilization is a missed opportunity to achieve the City’s goals. That said, as this compromise stands, this minor increase in
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development capacity of six parcels still meaningfully encourages development of underutilized parcels and helps create more vibrancy in the downtown.” (emphasis added).
This is not the first time that the City of Santa Cruz has attempted to address its local housing shortage by increasing the ability to build downtown. Planning staff has spent over a decade engaging with the community to decide how and where to plan for more housing in our city. Residents gave public input at years of community meetings on the city’s 2030 General Plan update and Housing Corridors Plan rezoning to say that downtown Santa Cruz and our commercial corridors are where we should be planning to direct the majority of our needed housing stock.
While the City adopted the 2030 General Plan after five years of public process ending in 2012, carrying out the necessary rezoning to implement the 2012 General Plan update took another ten years. In 2019, the city killed the Housing Corridors Plan. State law highlighted a lack of objective standards in our zoning code necessary to maintain local input in the design of our community. Local desire to have objective standards for the corridors resulted in the Objective Standards Update of 2022. Without the changes to state law the output of that years-long public process would have been lost entirely.
It is deeply unfortunate that the South of Laurel Downtown Plan Expansion looks to be recreating the mistakes of the recent past. What started as a bold plan to significantly increase the ability of our downtown to meet our community’s needs has been compromised down to a “minor increase in development capacity of six parcels.” And even this minor change is uncertain.
When it takes us years and years of public input to maintain the status quo, the public process is broken. The voices of the loudest minority cannot be allowed to drown out the needs of the city at a whole.
Downtown Santa Cruz is a vibrant cultural core of our community because it is a wonderful mix of shopping, dining and upper floor residences and offices along our most walkable streets. What makes this special area possible is the eclectic mix of new and historic, tall, mixed-use buildings that support retail and provide opportunities for folks to live in a place without the need to drive. Downtown's tall, functional buildings are part of its historic character. By expanding the footprint of our downtown area towards the beach, we will help foster a stronger pedestrian-friendly connection between our tourist area and the existing downtown with new businesses and homes in buildings that will create a more inviting, more defined sense of place than the warehouses and empty lots do today.
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Most importantly, expanding the Downtown Plan will increase opportunities for more folks to live in our community without the need for driving, and will increase our supply of affordable housing. Increasing the housing options in Santa Cruz, including a mix of market rate workforce housing and deed-restricted affordable housing, is crucial to improving the city's affordability and vibrancy.
Moving forward with the staff recommendation is a chance for this city council to show that you prioritise the needs of our entire community over the wants of a few detractors who have been fighting change for decades.
Thank you,
Rafa Sonnenfeld
Jocelyn Wolf
Leads, Santa Cruz YIMBY
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Brittany Inclan
From: Terry Lewis <[email protected]>
Sent: Monday, May 12, 2025 4:26 PM
To: City Council; Fred Keeley; [email protected]; Renee Golder; Susie O'Hara; Sonja Brunner; Shebreh Kalantari-Johnson; [email protected] Subject: Re: Item Meeting 5/13/25 Downtown Expansion Plan comments Item #23 Having lived in Santa Cruz county for 43 years and lived downtown, my comments to the proposed redevelopment changes are backed by my experience with constant usage of the downtown area.
This being a tourist town, the economy is best served by allowing the sunlight to penetrate the downtown area, keeping building heights uniform with the Anton Pacific project on Pacific. This has already been a major change of cityscape with much to adjust to for locals and visitors alike. Asthetics are critical to encouraging tourist and local trade, and overbuilding will discourage visitors from their purpose in enjoying this area.
This zone is also prone to catastrophic earthquake activity, as well as being on a floodplain. The buildings here must not be of such extreme height as to hinder emergency situations that will definitely occur. Traffic and parking also have
shown to make many stay away from doing business here already, plus we cannot afford to make a major disconnect with the
ocean and leisure environment that is what draws people into town to spend huge amount of tourist dollars.
San Jose is an entirely different area with no
beach and summer vacation area, which is precisely what brings visitors HERE. We will fail if we erase any vestiges of that uniqueness
which is the primary reason to be downtown.
We can build responsibly, and keep heights uniform to the approximately 8 story level and use a more gradual approach to ensure
success, maintain some scenic charm, and avoid the pitfalls of downtown L.A., San Jose and other overbuilt areas.
I believe the overbuilt and overreaching buildings will make the area unpleasant to live in and commute through, and add to the
overpriced housing situation we already have. We are getting way ahead of ourselves in judging the outcome of changing this environment forever and must take a responsible approach to avoid future pitfalls. These outsized developents are planned in many areas of town, and we must also consider infastructure and resource limitations as well as lack of hospital and emergency care in the area. Livability has to be considered here - there are ways to allow for housing without utilizing Extremism!
I thank you for your attention and look forward to updates on this critical situation regarding our responsible stewardship of the Santa Cruz area.
Sincerely,
Terry Lee Lewis
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Brittany Inclan
From: Bonnie Bush
Sent: Monday, May 12, 2025 4:27 PM
To: City Council
Subject: Fwd: Correspondence for 5/13/2025 City Council meeting (Item 23) Attachments: Item 23 Santa Cruz Downtown Expansion Plan Letter.pdf Bonnie Bush, CMC
City Clerk
City of Santa Cruz
809 Center St., Room 8, Santa Cruz, CA 95060
Phone: 831-420-5035
Email:[email protected] Web: www.cityofsantacruz.com Begin forwarded message:
From: Kieran M Kelly <[email protected]>
Date: May 12, 2025 at 4:01:32 PM PDT
To: Bonnie Bush <[email protected]>
Cc: Karla I Rodriguez Lomax <[email protected]>
Subject: Correspondence for 5/13/2025 City Council meeting (Item 23)
****CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.**** Good afternoon,
I’ve attached correspondence for Item 23 (Downtown Expansion Plan) on tomorrow’s City Council agenda. Please let me know if you have any questions.
Thanks!
Kieran Kelly
Community & Government Relations Manager
KAISER PERMANENTE
19000 Homestead Road
Cupertino, CA 95014
(408) 303-6900 (cell)
kp.org/sanjose kp.org/santaclara
--------
NOTICE TO RECIPIENT: If you are not the intended recipient of this e-mail, you are prohibited from sharing, copying, or otherwise using or disclosing its contents. If you have received this e-mail in error, please notify the sender immediately by reply e-mail and permanently delete this e-mail and any attachments without reading, forwarding or saving them. v.173.295 Thank you.
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110 Cooper Street #500
Santa Cruz, CA 95060
Phone: 831-425-4100
May 12, 2025
City Council
City of Santa Cruz
809 Center Street, Room 10
Santa Cruz, CA 95060
Dear Mayor Keeley and Members of the City Council,
On behalf of Kaiser Permanente, I am writing to express our strong support for the City of Santa Cruz’s Downtown Expansion Plan and the proposed development of a new permanent arena for the Santa Cruz Warriors.
As a long-standing health care provider committed to the well-being of our members and the broader community, Kaiser Permanente understands that health extends beyond clinical settings.
Vibrant, inclusive, and thoughtfully developed urban spaces are essential to creating environments that promote physical activity, mental wellness, economic opportunity, and social connection. The Downtown Expansion Plan is a bold and timely vision that aligns with our values of community health and sustainability.
We are particularly enthusiastic about the development of the new Santa Cruz Warriors arena. The team has become an integral part of the local community and a reliable supporter for local nonprofits. The Warriors partnered with Kaiser Permanente on the Swishes for Dishes initiative, which has donated over 280,000 meals to Second Harvest of Santa Cruz County. They have also helped us engage over 3,400 local students in the Read to Achieve, Math Warriors and Get Fit programs. The current home of the Santa Cruz Warriors, Kaiser Permanente Arena hosted a Resource Recovery Center for CZU wildfire victims and served as a vaccination center during the COVID-19 pandemic.
A permanent facility would solidify Santa Cruz’s place as a regional destination for sports, youth engagement, and family-friendly entertainment. The arena is poised to generate meaningful economic activity, create jobs, and provide a vital gathering place for community events. We believe this initiative will create long-term benefits for public health, economic vitality, and social cohesion in Santa Cruz.
Kaiser Permanente looks forward to partnering in the continued growth and well-being of the Santa Cruz community. We fully support the Downtown Expansion Plan and the construction of the new Santa Cruz Warriors arena, and we urge the City Council to advance this transformative vision.
Sincerely,
Karla Rodriguez Lomax
Senior Public Affairs Director
Kaiser Permanente
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Brittany Inclan
From: Alia Elyas <[email protected]>
Sent: Monday, May 12, 2025 4:27 PM
To: City Council
Cc: Matt Huerta; Tahra Goraya
Subject: Santa Cruz Downtown Expansion Plan MBEP Letter Attachments: Support Letter for Downtown Plan Expansion 05.12.25.pdf Hello,
My name is Alia Elyas and on behalf of MBEP I would like to turn in MBEP's letter regarding the Santa Cruz Downtown Expansion Plan. A PDF of the letter is attached to this email for your reference. Please let me know if you have any questions or concerns.
Thank you for your time.
Sincerely,
Alia Elyas
--
______________________________
Alia Elyas
Policy and Research Associate | Monterey Bay Economic Partnership 3180 Imjin Road, #153, Marina, CA 93933
Phone: 831-917-5240
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. https://www.mbep.biz
Support a THRIVING Monterey Bay Region: Donate Today!
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Serving the counties of Monterey, San Benito, & Santa Cruz
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May 12, 2025
Santa Cruz City Council
809 Center Street
Santa Cruz, CA 95060
Subject: Support for Downtown Plan Expansion
Dear Mayor Keeley and Santa Cruz City Councilmembers,
Monterey Bay Economic Partnership (MBEP) endorses the Santa Cruz City Downtown Expansion Plan. We support its goals to redevelop the existing neighborhood south of Laurel Street.
MBEP’s Housing Initiative promotes the expansion of housing across all income levels and types within the region, advocating for infill development near transportation hubs and commercial corridors to maximize land use for housing, community services, and climate resilience. We are steadfast in our support for the Santa Cruz Downtown Expansion Plan because we believe that the outlined expansion plan will make great strides toward addressing the ongoing housing crisis, aid diverse communities and contribute to the city’s economic vitality.
The Plan incorporates a development scenario that would include developing buildings with a minimum of 1,600 housing units which will assist the City in reaching its increased 6th Cycle RHNA targets of 3,736 new units by 2031. Strategically planned high-rise buildings offer a crucial opportunity to increase housing density, accommodate a growing workforce, and attract residents, businesses, and visitors. Delaying or significantly reducing the plan's implementation would be a missed opportunity to address affordable housing shortages, infrastructure improvements, and the creation of a more dynamic and resilient urban environment.
In conclusion, we believe that the Expansion Plan aids the City of Santa Cruz towards becoming a vibrant, inclusive, and economically thriving city that can serve as a model for other cities in California and we respectfully request the City Council’s support.
Please contact our VP of Community Development, Matt Huerta at [email protected] with any questions or concerns.
Sincerely,
Tahra Goraya, MA, MPA
President & CEO
3180 Imjin Road, Suite 102
Marina, CA 93933 831.915.2806
23.505
Brittany Inclan
From: Ronald Pomerantz <[email protected]>
Sent: Monday, May 12, 2025 4:39 PM
To: City Council
Cc: Sarah Neuse
Subject: 5/13/2025 Council agenda Item #23: Downtown Plan Expansion May 12, 2025
Re. 5/13/2025 Council agenda Item #23: Downtown Plan Expansion Good day Mayor and Council members and staff.
The fix appears to be in for approval of the massive Downtown Plan Expansion.
Let me list some of the ways:
1) The Planning Commission staff report for the Downtown Plan Expansion originally didn’t have the Final EIR, 370 page document, and posted this critical document 2 days before the vote. The self-interested Commissioners (with one outstanding exception) representing architects, developers, and real estate interests had already made their minds up and went thru the motion of a public hearing. There was no interest in knowing about the significant inadequacies of the Final EIR, especially by Commissioner Kennedy. 2) The Beach Hill residents received their required meeting notification for the Planning Commission Hearing a couple of days before the meeting.
3) The 5/10/25 Sentinel article reports "downtown expansion plan is a product of years of collaboration between the city’s Planning and Community Development Department, developers, property owners and the Santa Cruz Warriors." I would ask why wasn't the public included in the collaboration in this massive 29 acre development? The most major land use change in memory. Doesn’t the City and elected officials represent all people living and working here, not just those that line the pockets of the decision makers? 4) The question will hotels be built in this Downtown Plan Expansion area is yet to be answered?
5) Will the 60K square feet of new commercial space, especially in the Warriors arena, compete and potentially undermine businesses and the economic recovery on the Pacific GardenMall?
6) There’s been no Staff planning to anticipate pending and future State Legislation that will force further density, height, traffic and the like on our fair city. 7) For every new occupied market rate housing unit “affordable” housing will get more and more expensive for our vital service workers and their families due to the increasing Area Median Income (AMI) on which the calculation formula is based. Would any of you think
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earning $120K qualifies you for affordable housing? Well it currently does and this will keep going up and up. How many of you can currently afford $2800-$3600/month for a new one bedroom apartment or $5500 for 2 bedrooms?
8) What consideration has been made to requiring union scale workers, best if local, when developments exceed the General Plan height requirements? 9) The Planning Director Lee Butler and City Manager Matt Huffaker represent developers and big real estate interests unconditionally, and support any development, no matter how gargantuan. Their salaries should be paid by the big developers and not the taxpayers. 10) As our most powerful elected official Mayor Keeley is a devout Santa Cruz Warriors fan and wants them to stay forever and have the Downtown Plan Expansion be his major legacy as mayor. Proceeds from the 1,800 units originally slated for downtown were enough to underwrite the new Warriors Arena. An additional 1,800 units encouraged by Density Bonus laws will be profits in excess of the purpose for which this colossal project was originally conceived.
What’s the rush to fast track the General Plan changes regarding the Downtown Plan Expansion project? The Final EIR has yet to be formally publicly presented, vetted, discussed, analyzed.The next step should be to have the Downtown Plan Expansion Final EIR as the sole agenda item on your agenda to determine if the zoning height should be raised, amendments to the Downtown Plan, 2030 General Plan, and anything else. Staff’s insistence of your concurrence must wait to make sure you get this right. What staff wants doesn’t always line up with good public process. In this case the cart has been placed way before the horse.
When publicly requested to make the local building boom more to a historic Santa Cruz scale by reducing the height and scale of new construction Mayor Keeley and the past 2 Councils have cried crocodile tears that there’s nothing that can be done. What’s been said is there’s nothing that can be done to control massive residential construction because our hands are tied by State legislation. We find it hard to believe this is the case. Instead the City has attempted to up-zone areas to enable developers more monstrous buildings throughout the city. Never has the Council explored joining forces with other jurisdictions to exert pushback on the State.
Now before you for the public Hearing is the most obvious and direct way for the City to be true to their word, if sincere, to reduce the overbuilding heights and scale in the South of Laurel profit scheme. It’s simple, ALL YOU HAVE TOP DO IS NOT approve the General Plan changes to rezone for 85’ buildings in the Downtown Plan Expansion that’s before you. As you are aware permitting 85’ buildings in reality can easily turn into 200 to 250’ high rises due to AB 1287 with the 100% density bonus. Under current zoning of heights of 35’-50’ a 150’,12+ story, mid-rise structures can be built to dominate our river front floodplain in the Kaiser Arena area. The Final EIR acknowledged the possibility of a 50% density bonus but never really considered, let alone analyzed, a 100% density bonus. This must be done before certifying the Final EIR or making any other decisions on the Downtown Plan Expansion.
Under current zoning with a 100% density bonus an overwhelming 12 story building can still
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be built just as Mayor Keeley wants. No additional height and density would be needed to fulfill the Regional Housing Needs Allocation (RHNA) mandates. EIR alternative 1, option B is the best of all the bad options before you today. Now is the time for the the Council to step-up and do as they said they would. Stop at heights where the air is thicker at 12 stories or lower, which we and MANY others feel is still way too high. Eight stories should be the reluctant maximum. We can now see what the Great Wall of Santa Cruz will look like along the River. Doesn’t that already send chills through you destroying the beauty and charm of what we all love about Santa Cruz?
With State legislation AB 2097 no, none, zilch parking is required to be built under many conditions. What do you think about that outrageous non-requirement? Where do you think the additional thousands of new residents and customers are going to park? What about trying to drive on roads never designed or intended to carry thousands of more vehicles? Please don’t tell us these new residents will all ride bikes and busses. We wish this was the case but it ain't. Has the City done a study to see how many of the new residents and customers will or will not have a car? We will submit an educated guess this was never done.
Folks will not willingly pay taxes for the city to pave over our precious downtown to accommodate these new vehicles on the streets and for parking, nor provide infrastructure that the developers should be paying for. Did you know studies have shown new residences do not pay for all the services that the City will need to provide them? Are hotels being planned to cover some of these costs? Has the City done any sort of study or investigation to find out the costs of providing essential services like fire and police protection, water resources, sewage, roads, parks, and the like? This calculation should be publicly presented and discussed before giving the green light to all the new residential development in Downtown Plan Expansion along with how these services will be paid for. The city is now trying to pass on the costs of the Downtown Plan Expansion onto the an unsuspecting public by taking the additionally generated property taxes from the development and pay for infrastructure improvements for the developers. Then the City will come hat-in-hand and tell us how broke the City is and must raise some new taxes.
We strongly urge the Council vote to postpone this agenda item to approve allowing 85’ buildings and any other major related issues to the Downtown Plan Expansion until such time as the Final EIR is publicly presented and fully vetted, and also until the pending ramifications from the changes to the General Plan. How can the Council make any determination about height changes, water resources, accommodating AB 2097’s no parking requirement, allowing in-lieu fees, AB1287 impacts, or anything else without knowing the impacts as well as how current and new State legislation will affect the Downtown Plan Expansion without this vital document and further public comment and analysis? We hope the Council is not going to act as developer lap dogs, and look foolish without any basis of objectivity or crucial information. Remember this is the most major land use transformations in Santa Cruz history. Please take your time. Get it right for all folks living and visiting here.
Thank you for your time and thoughtful consideration.
Ron Pomerantz
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Susan Monheit
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Brittany Inclan
From: Shelley Hatch <[email protected]>
Sent: Monday, May 12, 2025 4:40 PM
To: City Council; City Council
Subject: Fwd: SOLA agenda item for 5/13 council meeting For agenda packet , SOLA , 5/13/2025 meeting
Mayor and City Council members
Because of the 100% State Density Bonus , upzoning of the Downtown Plan Expansion SOLA should not be voted for, but against.
There will still be the opportunity for many more tall apartments in the 29 acres in the SOLA under our current zoning. And since it is known that after
upzoning, the property value and the price for the land increases and thus will cost more to produce units in the rezoned area. . Do we really need the cost of providing housing to increase due to zoning changes ? ..
https://www.google.com/search?q=does+upzoning+increase+property+value&rlz=1C1NDCM_enUS757 US757&oq=does+upzoning+increase+property+value+&gs_lcrp=EgZjaHJvbWUyCAgAEEUYHhg5Mg0IAR AAGIYDGIAEGIoFMg0IAhAAGIYDGIAEGIoFMg0IAxAAGIYDGIAEGIoFMg0IBBAAGIYDGIAEGIoFMg0IBRAAG IYDGIAEGIoFMgoIBhAAGKIEGIkFMgoIBxAAGIAEGKIEMgoICBAAGIAEGKIEMgoICRAAGIAEGKIE0gEJMjQ2 MjJqMGo3qAIAsAIA&sourceid=chrome&ie=UTF-8
Please consider that this upzoning is not necessary to meet our housing goals.and wil make the housing even more expensive. .
Shelley Hatch
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Brittany Inclan
From: Betsy Ryan <[email protected]>
Sent: Monday, May 12, 2025 4:44 PM
To: Scott Newsome; City Council
Subject: Item 23 - Downtown Plan Expansion
Dear Scott and Councilmembers:
RE: the Santa Cruz downtown plan expansion vote on 5/13/25, I hope you will cast your vote for EIR Alternative 1 with Option B only. I do not want the base height in SOLA raised to 85 ft. because it will actually allow buildings twice that high to be built when the state density bonus (AB 1287) is applied. I believe developers will quickly move to capitalize on that and our small city with an already inadequate infrastructure will be ruined.
I think EIR Alternative 1 with option B only will allow you to achieve your 1700 new units, with 20% below market rates, and build a new Warriors arena without risking that scenario.
Thank you,
Betsy Ryan
1121 Laurel Street
Santa Cruz CA 95060
--
Betsy Ryan
[email protected]
23.511
Brittany Inclan
From: Lira Filippini <[email protected]>
Sent: Monday, May 12, 2025 4:47 PM
To: City Council; Fred Keeley; Bonnie Bush
Subject: Agenda Item 23; May 13th, 2025
Dear Honorable Mayor Keeley and City Council Elect,
In regards to the EIR for the SOLA/Downtown Plan Expansion, I am actually grateful that we have an environmental impact report that analyzes a level of development that could currently be achieved — even if our local density, height, and FAR limits don't change for that area.
It's important to recognize that the EIR does not account for the fact that whatever we study and set as our local code and limits... is only about half of what the actual subsequent development will result in.
At this point I hope that our city staff and elected officials are aware of the magnitude of size and density-increase the new various CA state laws encourage and facilitate that is beyond whatever we set as our local regulations. The state even encourages the stacking of many of their newly adopted laws, to increase the density and size of a project to the point that it exceeds double what our locally adopted code allows.
Within the very real context of not only these current new state laws, but the fact there are more being passed monthly — furthering the gap between what our local code allows and the state facilitates — it is imperative that our locally-elected and most direct representatives, retain what little oversight we have as a city to mitigate what is likely to be quite the dramatic strain on our city's carrying capacity over time.
Whatever you decide to pass and set as our local code for this massive development project, please be sure to set it at half the height and density of what you actually intend for this area. It is a very scary period we have entered, in which our studies on impact to resources, safety, and the continual need to grow, are not even close to determining what will actually be built and the corresponding impacts.
We rely on you to plan for the safety and overall longevity of our city. In a time in which we have lost so much control to the state on how we develop as a municipality, it's crucial that our representatives think holistically and in some respects defensively.
Thank you for your service and thoughtful consideration, Lira Filippini
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Brittany Inclan
From: kevin hoeke <[email protected]>
Sent: Monday, May 12, 2025 4:55 PM
To: City Council; Summer Huffman
Subject: Item 23 downtown expansion
NO MORE ... enough is enough with these .ultimately story buildings Sent from my Verizon, Samsung Galaxy smartphone
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Brittany Inclan
From: Summer Huffman <[email protected]>
Sent: Monday, May 12, 2025 4:59 PM
To: City Council
Subject: Item 23 downtown expansion
Item 23 downtown expansion
NO MORE ... enough is enough with these .ultimately story buildings -The downtown plan expansion (DPE) rezoning or "UPzoning" for housing is NOT needed since with State Law AB1287, or the 100% density bonus legislation, it is required to build DOUBLE the existing density, with 15% affordable units. The DPE area is 29 acres, but the total area subject to the double density of AB1287 is 1735 acres-plenty space for housing! (see General Plan Table Lu-2) Housing developers do NOT need an increase in height limits since AB1287 waives height limits when you build housing.
On Jan 10, 2023, this city council asked staff to reduce heights and limit the apartment units to a max of 1600. Keep your word! Stand up for these original goals in the face of staff pushing now to build 1800 units (which with the 100% density bonus law ,can easily be over 3000 units! With over 6000 cars and with the very high, corporate rents encourage overcrowding.
Can we trust you as our elected officials to do what they say? Best,
Summer Huffman
(831) 535-3935
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Downtown Plan
ExpansionCity CouncilPublic HearingMay 13, 2025
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Sarah Neuse
Senior PlannerMatt VanHuaPrincipal PlannerBill WisemanPlanning Practice Leader Project Team
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Project Area
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South of Laurel
Area District
• Total Area = ~ 29 acres• 42 Parcels
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Downtown Plan
Area Districts
Laurel Area
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SOLA District Plan Objectives
1. Adding capacity for multi-family housing.2. Accommodate a permanent Warrior’s arena into the plan.3. Create opportunities for public amenities and infrastructure including parks, the Santa Cruz Riverwalk trail, or other spaces for community use.
4. Improve the pedestrian & bicycle experience.5. Better connect downtown with the river and beach areas.
6. Create new economic opportunities for local businesses and workers.
7. Generate new tax revenue to support City services.
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City Council Direction
• 1,600 residential units• 20% below-market (after
density bonus)
• 12 stories height limit• Increase development
intensity on
6 of 42 parcels
(January 2023)
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Community
Spaces
Spruce Street Plaza
Pacific Avenue
Front StreetLaurel Street Extension
New Roundabout
New ArenaSanta Cruz Riverwalk
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SC Warriors Arena
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SC Warriors Arena
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Spruce Street Plaza
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Spruce Street Plaza
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Santa Cruz Riverwalk & Beach Connection
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Santa Cruz Riverwalk
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Downtown Gateway
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Downtown Gateway
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Pedestrian & Bicycle Circulation
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Community Outreach
• Community Workshop
• November 2021 ~30 attendees
• 1st Community Survey
• November/December 2021 ~90 responses
• Community Open House
• April 2022 ~250 attendees
• CEQA Scoping
• September 2022
•
2nd Community Survey
• June 2023 ~1,000 responses
• Community Focus Groups
• October 2023 ~50 participants
• Public Review Draft Plan
• June-July 2024 ~80 comment letters
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Public Hearings
• City Council
• December 2020• June 2021• June 2022• January 2023• June 2024 (Joint with PC)• October 2024• May 2025 • Planning Commission
• May 2022• June 2024 (Joint with CC)• April 2025
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Key Issues
1. Building Heights2. Density Bonus3. Below-market Housing 4. Environmental Analysis
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Building Height
0 50
100150200250
April 2022 June 2022 January 2023 May 2025
220
175
150
85 Feet
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Building Heights
• No buildings have been constructed over
85’ in the City inclusive of Density Bonus*
• Building taller than 85’ are considerably
more expensive
• Steel and Concrete Building materials• More stringent building codes (e.g., sprinklers, fire apparatus)
• Planning ahead for new technology
• Cross-Laminated Timbers (CLT), others
* Except for the Palomar Hotel which is 90 feet, built in 1929.
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201 Front Street*
• 8 story mixed-use• 245 residential units• 10,000 SF commercial• 256 parking spaces• Floor Area Ratio ~ 6.0*Preliminary Application ACE Hardware Site
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Downtown vs. State Density Bonus
State Density
Bonus
Downtown Density
Bonus
> 20% of Total
Units Below Market
Height Limit
Discretionary
Design Review
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Below-Market Housing
• Downtown Residential
Construction since 2019
• 643 units built / under construction
• 280 Below Market (44%)
• 400 more approved
• 160 Below Market (40%)
Downtown Library Affordable Housing Project
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Environmental Impact Report
• Subsequent Draft EIR (SEIR)
• January 2025• 74 comment letters received
• Final SEIR
• April 2025
• Significant and Unavoidable Impact to
Historic Resources
• In each Alternative, including No Project
• Local Traffic Analysis also conducted
• Not a CEQA issue
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Summary
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Staff Recommendation
1. Certify the Final Subsequent Environmental Impact
Report (EIR)
2. Adopt Amendments:
a) Local Coastal Program Land Use Plan and Implementation Planb) Beach/South of Laurel Comprehensive Area Planc) Downtown Pland) Municipal Code, including the zoning mape) 2030 General Plan
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● This 192 ft. “Clocktower Center”
building was proposed in an area with a
50 ft. height limit
● This was possible because of AB 1287 -
the new 100% “stackable” state density
bonus law
● AB 1287 overrides local height limits.
The city would not be able to deny it.
● Even though it is almost 4x taller than
the city height limit!
● Project is currently on hold, but could
be brought back at any time.
Remember this?
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Proposed Increased base height limits in SOLA
(not including AB 1287 100% density bonus):
CURRENT HEIGHT LIMIT: 35’-48’ Ft PROPOSED HEIGHT LIMIT: 50’-85’
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When formulating
their plans, the city
didn’t anticipate that
the State would
mandate allowing
heights 2-3x higher
than the city height
limits. That is the new
reality thanks to AB
1287.
These hypothetical 15-story example shows the scale of what could be built in SOLA if proposed upzoning is approved 23.546 The ground has shifted, due to AB 1287
Here’s what 15-stories would look like23.547
City Council: Don’t make a huge unforced error!
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It’s an error because raising
height limits to 85 ft. will allow
multiple buildings of 2-3x that
height - potentially resulting in
towers of 14-20 stories
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It’s unforced because the city doesn’t need to raise height limits to get the density required to meet our housing goals AND to get a new Warriors arena. The Warriors have indicated that they can do the project with 7-8 story buildings, which are allowed now.
Possible New Warriors Arena 23.550 Possible New Mid-Rise Housing Don’t give away our local
control.
Don’t give developers the
permanent entitlement to
build 14-20 story towers
in Santa Cruz.
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Under the proposed Downtown
Density Bonus Option A, towers like
these hypothetical 12 story versions
of Anton Pacific would be allowed
throughout SOLA.
Option A (12-stories) should be
eliminated.
Option B (8-stories) should be
retained.
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We urge the City Council to:
● Postpone consideration of this issue so that the insufficient and faulty EIR can be revised and recirculated.
● Short of that, approve the Reduced Project Alternative - “Alternative 1” in the EIR, which will meet the project goals, including a new warriors arena, and keep current height limits, resulting in mostly 6-8 story buildings. ● Drop “Option A” (12-stories) from the Downtown Density Bonus ● Keep a reduced version of “Option B” (8-stories), that would result in 85-ft. max along levee, 50-70ft. max (4-6 stories) elsewhere, and would achieve the net 20% affordable units goal.
● Remove the extra height waiver provisions in DDB. 23.553 City Council:
● Please don’t commit an unforced error.
● Adopt EIR Alternative 1, with reduced DDB Option B-only, to get this:
New Warriors Arena
New 4-8 story Housing &
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SANTA CRUZ WARRIORS
CITY COUNCIL MEETING
CHRIS MURPHYPRESIDENT, SANTA CRUZ WARRIORSMAY 13, 2025
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1 2
Commitment to Santa Cruz
3 Downtown Expansion Plan - SOLA → Impact on WarriorsConceptual Drawings TONIGHT’S MESSAGE
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CONCEPTUAL DRAWINGS
● Concept Drawings● Community Input Process in the Future● Front Door View → 3 timeline scenarios
● San Lorenzo Riverwalk View
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FRONT DOOR VIEW - GAME NIGHT
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FRONT DOOR VIEW - COMMUNITY EVENT NIGHT
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FRONT DOOR VIEW - NON-EVENT DAY
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SAN LORENZO RIVERWALK VIEW
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THANK YOU
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Cities For People
For ordinary, essential workers who already work in Santa Cruz ● As “fair” market rates unfairly skyrocket ● Area Median Income increases ● Teachers, police, fire fighters, nurses Anyone who makes 100K considered moderately-LOW INCOME
● Competing with corporate investors
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Policy for Built Environments
“The government has a duty to help people from all socio-economic backgrounds live & share our beautifully-designed cities. After we design these attractive cities for people, then we need government regulation for equity, inclusion and rent stabilization to prevent gentrification. ” ~Jan Gehl~
Urban planner, social scientist and author of “Cities for People”Orienting city design for peopleFor all income levelsProvide more car-free, pedestrian zones.
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4 to 6 stories
Tourist
Destinations
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Pedestrian & Bike Zones
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“Downtown is
for the People”
By Jane Jacobs
The Death and Life of Great
American Cities“
Spend time in the streets and
squares and see how people actually use spaces, learn from that, and use it in planning cities. “Human-scale” architecture!
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RESEARCH ON UPZONING & HOUSING
An MIT study by Urban Institute researcher and leading researcher on land-use reform, Yonah Freemark (2019)found that upzoning increases housing prices but not housing supply.
Research by Andrés Rodríguez-Pose (London
School of Economics) and Michael Storper (UCLA)have concluded that there is insufficient evidence that “upzoning”can improve housing affordability and that it usually “increases gentrification Wendell Cox (Professor, Urban Reform Institute), claims that upzoning worsens gentrification and increases land prices: Upzoning did make land more valuable, which was passed on quickly as increased rent (and increased property taxation).
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Government must design and provide mixed income housing for our workforce, for working families, seniors and our kids.
We are a DESTINATION LOCATION -make downtown,
livable, inviting and attractive, with public space and landscaping, a place where people want to go, to visit, to linger, shop & eat! HUMAN-SCALE, like Compact European citiesNot creating dark, sunless canyons or prison-like towers with no landscaping, parks or public space. The City Climate Adaptation Plan: “ Santa Cruz expects 2.4 feet of water downtown by 2060”
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Harvard Business Review, (Calacci and Vaheesan Sept.
2024) “The Market Alone Can’t Fix the U.S. Housing Crisis” : “the national scandal - unaffordable housing.” “Landlords are using software to collectively raise their rents or for high price-fixing rents (and then accept low occupancy).We need “government policy to ban rents that are set by algorithmic price-fixing systems and introduce new regulations for corporate landlords. “Research from around the world shows that more permissive zoning rules do not lead to a major increase in housing supply nor more affordable housing.”
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“Profit-motivated corporations build luxury units, focus their efforts on and cater to the affluent.” Havard Business Review (Calacci and Vaheesan, September, 2024)“ There is very little evidence that private developers alone will -or can- provide enough housing to fix this housing crisis.”
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“Upzoning did not produce
affordable housing or even a net addition of housing.Instead, it resulted in replacement of older residential buildings and small businesseswith higher-end apartments, condos, retail and higher-end restaurants.” Harvard Business Review, (Calacci and Vaheesan Sept. 2024) “The Market Alone Can’t Fix the U.S. Housing Crisis”
GENTRIFICATION
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1) NOT GIVEN ENOUGH TIME
The planning commission was given only 2 days to consider this 370 page plus document . Take more thoughtful time and consideration for such an important document and project. 1) PRIORITIZE AFFORDABLE HOUSING near the city
transit center and employment center downtown. Then should you be increasing the Warrior Stadium from 35K square feet by 5 times, up to 180K square feet? Increase housing by the arena instead of this 1) IS THE REAL AGENDA MORE HOTELS?
Downtown Plan Amendments will change South of Laurel
zoning from Medium to High Density Residential to "Visitor Serving Commercial" This allows housing developers to compete with wealthy, corporate hotel developers for this project area.
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4) THE 100% DENSITY BONUS ENDS THE
"More Housing" ARGUMENT: Housing developers do NOT need an increase in height limits since AB1287 waives height limits.The DPE area is 29 acres, but the total area subject to the statevdensity bonus is 1735 acres. THE STATES DENSITY BONUS MAKES THE 12 STORY HEIGHT LIMIT UNENFORCEABLE5) WILL NEW COMMERCIAL SPACE BE UTILIZED?With so many empty, unrented spaces around downtown,explain the need to build 60 thousand square feet of more commercial space. Will this newer “entertainment district” compete with the older quaint downtown and add to its neglect? SCREAM = Santa Cruz Residents Against Massive,
Mega-development without Input!
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6) MANY DEVELOPER OPT-OUT INCENTIVES
The Downtown Density Bonus offers too many incentives for developers to not build Below Market Rate (BMR) housing as if you are trying to convince them not to build affordable units. They do not need to build any BMR units:
1) If they build some units off site at another location 2) If they pay a fee to the city3) If the developer exchanges land for not building Below Market Rate/Affordable units
Housing shortage or affordable housing shortage.7 ) ALTERNATIVE ONE, OPTION B meets GOALSIf you must vote, please choose the EIR alternative 1, option B, which meets all the project goals and embraces inevitable change; Alternative ONE, Option B will build thousands of apartments and the rebuild the Warrior Stadium into the "entertainment district"of your dreams, while staying within the current (more reasonable height limits) up to eight stories.
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Housing Solutions through Government Policy
“Public governance can stop the landlords from having a monopoly of power and stop the price-fixing cartel.”Solutions lie in “fixing the market” by: 1) confronting the power of landlords. 2) rethinking public governance of housing 3) more muscular government involvement in housing (through price regulation,and social housing) Example: San Francisco, non-profits get first dibs “Zoning reform will not fix America’s housing woes but public governance and direct participation in housing markets can make affordable housing and decent shelter a universal reality, which requires a 3 part program of:
1) Stronger public governance2) Local, regional and federal planning3) Social housing
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Prioritize affordable housing
Incremental changes in urban design- Attractive- Peoplecentered Upzoning for massive high rises the Downtown Plan Expansion area to 12 stories and higher is the biggest policy change in the history of Santa Cruz.
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City Council
AGENDA REPORT
DATE: 05/08/2025
AGENDA OF: 05/13/2025
DEPARTMENT: Planning and Community Development
SUBJECT: Ordinance to Amend the Zoning Designation of the Northern Four Acres of 2394 Delaware Avenue From R-1-5 (Single Family Residence District) to E-A (Exclusive Agricultural District); Ordinance to Amend the Zoning Designation of the Southern Approximately 6.3 Acres of 2394 Delaware Avenue From R-1-5 (Single Family Residence District) to R-L (Multiple Residence – Low-Density District); Resolution to Amend the General Plan Land Use Designation of 2394 Delaware Avenue from L (Low Density Residential) to AG (Agriculture/Grazing) and LM (Low-Medium Density Residential) and for Related General Plan Text Amendments to the Description of the Agriculture/Grazing Land Use Designation and Land Use Action LU 1.1.4; and Resolution for Local Coastal Program (LCP) Amendments to Certify the Northern Four Acres of 2394 Delaware Avenue Into the LCP, Including Assignment of the Coastal Appeal Zone Level of Permit Authority and Assignment of the Agriculture/Grazing Land Use Designation, and to Amend the Text of the Agriculture/Grazing Land Use Designation Description within the LCP Land Use Plan (LCLUP).
Amendments to the Subject Site’s Zoning, Certification Into the LCP, and LCLUP Text Amendments Are Part of the LCP Implementation Plan and LCLUP and Require Approval by the California Coastal Commission Prior to Taking Effect Inside the Coastal Zone. (PL)
LOCATION: District 6
RECOMMENDATION: Motion to:
1) Adopt a resolution amending the general plan land use designation of the site and make related general plan text amendments;
2) Introduce for publication an ordinance amending the zoning designation of the northern four acres of the subject site; and
3) Introduce for publication an ordinance amending the zoning designation of the southern approximately 6.3 acres of the subject site.
24.1 BACKGROUND: The subject site proposed for zoning designation amendment is 2394 Delaware Avenue, Assessor’s Parcel Number 003-061-09, located at the northeast corner of the intersection of Delaware Avenue and Shaffer Road on the lower westside. The 10.3-acre site is surrounded by the railroad, multi-family housing, and industrial uses to the north, Antonelli Pond to the east, Delaware Avenue and a mobile home park to the south, and Shaffer Road and UCSC owned land to the west. The site has historically had agricultural uses, and the Homeless Garden Project has been farming on the northern part of the site since 1995. The remainder of the site is undeveloped.
The site has a general plan designation of Low Density Residential and a zoning designation of Single-Family Residential, which typically allows the development of single-family homes with a density range of 1.1 to 10 units per acre. General Plan 2030 action LU 1.1.4 calls for future site development to be based on land use designations with a higher density of up to 20 units per acre and includes other actions that address this specific site, as follows:
LU1.1.4 Obtain Local Coastal Plan certification for the 11-acre Swenson parcel pursuant to the following:
Require a specific plan for the property (with a land use designation as Low Medium Density Residential/Neighborhood Commercial/Office).
The environmental review process shall guide the location and intensity of all uses. The height, scale, and bulk of development shall take into consideration the rural transition at the city’s edge.
Neighborhood Commercial and Office land uses shall be at least 10 percent but no more than 20 percent of the total net developable area.
The extent of open space buffers/setbacks to wetland areas on and adjoining the site will ultimately be determined by the California Coastal Commission. Based upon the Coastal Commission’s buffer/setback determination, neighborhood park land shall be considered on the site.
The specific plan shall prioritize away from the pond, any required uncovered off-street parking for residential uses. Except for parking for the disabled, off-street uncovered parking and driveways near Antonelli Pond and residential uses is discouraged. The circulation system of the specific plan shall provide access from Shaffer Road. Public access to Antonelli Pond shall be preserved.
While the site is within the geographic area covered by the Coastal Zone Overlay zoning district, this site is the lone exception in that it has not been certified as part of the Local Coastal Program (LCP). This means that the California Coastal Commission currently has coastal development permitting jurisdiction over the site.
At the November 19, 2024 City Council meeting, the City Council passed a motion directing staff to expeditiously process an amendment to the General Plan 2030 Land Use Map to designate the northern 4 acres of the 11-acre Swenson parcel as Agriculture/Grazing (AG) land, an amendment to the Zoning Ordinance to classify these 4 acres as Exclusive Agricultural District (E-A), and an LCP Amendment for submittal to the Coastal Commission to designate these 4 acres as Agriculture/Grazing (AG) land, while meeting state law “no net loss” requirements as more fully discussed below. To carry out the City Council’s direction, the proposal therefore includes the following:
24.2 For the northern four acres, change:
o The general plan land use designation from Low Density Residential (L) to Agriculture/Grazing (AG);
o The zoning designation from Single Family Residential (R-1-5) to Exclusive Agriculture (E-A);
For the southern 6.3 acres, change:
o The general plan land use designation from Low Density Residential (L) to LowMedium Density Residential (LM); o The zoning designation from Single Family Residential (R-1-5) to Multiple Residence – Low-Density (R-L);
General plan text amendment to modify action LU1.1.4 to:
o Include the Agriculture/Grazing land use designation, o Remove the requirement for a specific plan,
o Cluster residential uses on the southern portion of the site to ensure no net loss of future housing potential, and
o Make the Citywide Creeks and Wetlands Management Plan the standard of review for development near wetlands;
General plan text amendment to make a minor change to the description of the Agriculture/Grazing (AG) land use designation to allow this designation for smaller-scale agricultural sites that intend to stay in agricultural use long term; and Amendment to the City’s LCP to:
o Certify the northern four acres of the site into the LCP with a land use designation of Agriculture/Grazing (AG) and
o Make minor changes to the definition of the LCP’s Agricultural/Grazing land use designation definition.
o Amend the zoning designation of the site’s northern four acres to Exclusive Agriculture as part of the LCP Implementation Plan (LCP IP).
Upon a positive recommendation by the Planning Commission, the proposed amendments require City Council approval. Changes to the zoning designations require City Council approval via an ordinance with a first and second reading. Changes to the general plan and LCP require City Council approval with a resolution. Amendments to the LCP would subsequently require approval by the California Coastal Commission.
DISCUSSION: The proposal is consistent with no net loss state law, which requires that the City not reduce residential development capacity. That analysis is detailed in the attached April 17, 2025 Planning Commission staff report and is particularly important for this package of proposed changes. The proposal is also consistent with the general plan, the zoning ordinance, and the LCP, also as described more fully in the attached April 17, 2025 Planning Commission staff report.
Planning Commission Recommendation
This proposal was brought to the April 17, 2025 Planning Commission meeting. Several members of the public submitted correspondence and spoke at the hearing with comments expressing support for the Homeless Garden Project as well as concerns about the number of dwelling units that could be constructed on the southern 6.3 acres of the site. The Commission
24.3 recommended approval of this item as part of a two-item consent-public hearing agenda (5-1-1, Commissioner Dann opposed, Commissioner Thompson absent) with minimal discussion.
Clarifications in Response to Public Comments at Planning Commission Based on public comment at the Planning Commission hearing, some members of the public may have been under the impression that a housing development was or is being proposed. For purposes of clarity, no housing development proposal has been submitted at this time.
Furthermore, the southern 6.3 acres is not proposed to be submitted to the Coastal Commission for certification. Therefore, permitting authority would remain with the Coastal Commission for the southern 6.3 acres.
As noted above, General Plan action LU1.1.4 calls for a long-term plan of Low Medium Density Residential, Neighborhood Commercial, and Office General Plan designations and uses on the site. The City is not seeking to fully effectuate the long-term plan as part of this action, as: 1) none of the commercial land use designations are currently proposed, and 2) no LCP certification of the southern 6.3 acres is sought. As such, it is anticipated that many more steps are needed, including many more public hearings, before any development would occur on the southerly 6.3 acres.
Community Outreach
The Department of Planning and Community Development Community Outreach Policy for Planning Projects states that outreach for policy changes is based on the scope of the project.
This proposal is considered a minor policy change, as it generally aligns with the existing agricultural use of the site and the anticipated long-term uses of the site, as called for in the general plan. Thus, the level of outreach aligned with that required for public hearings.
Opportunities for public input included the November 19, 2024 City Council meeting where City Council gave direction to initiate this proposal, a subsequent City Council meeting where Council gave direction for the City to cover the costs of the application, the April 17, 2025 Planning Commission hearing, the subject City Council meeting, and the second reading of the ordinances associated with this proposal currently anticipated for May 27, 2025.
Next Steps
If approved, the resolution amending the general plan land use designation and general plan text would take effect immediately and does not need further review by the California Coastal Commission, since the general plan is not part of the LCP. All other parts of the proposal, including the two ordinances amending the site’s zoning designation and a resolution to certify the northern four acres of the site and amend the LCLUP, require approval by City Council and subsequent approval by the Coastal Commission to be accepted into the LCP.
The two ordinances amending the zoning designations of the northern and southern parts of the site, respectively, require two readings to come before the City Council. If the first reading is approved, a second reading is anticipated to take place at the May 27, 2025 City Council meeting. Should the ordinances be adopted by the City Council, the proposal involves submitting only the ordinance amending the zoning designation for the northern four acres to the Coastal Commission. The rezoning of the southern 6.3 acres may be submitted to the Coastal Commission at a yet undetermined time in the future via Council resolution, which would require action at a separate Council meeting.
24.4 A resolution to certify the northern four acres of the site into the LCP, including assignment of an Agriculture/Grazing LCP land use designation and Coastal Appeal zone permitting authority and making associated amendments to the LCP text, requires one approval hearing from the City Council. This resolution is not presented today as it will be heard along with the second reading of the rezoning ordinances, anticipated to take place on May 27, 2025. This resolution would subsequently be submitted to the California Coastal Commission for review along with the ordinance rezoning the northern four acres. Those amendments would be in effect after approval by the Coastal Commission, which is anticipated to act on this item in the Summer of 2025.
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION: The proposed amendments fall within the analyzed development potential in an addendum to the City’s existing 2030 General Plan EIR.
The General Plan 2030 EIR is a “program” EIR prepared pursuant to the State CEQA Guidelines Section 15168. The EIR reviewed direct and indirect impacts of implementation of the General Plan, as well as indirect environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. The EIR reviewed updated policies, new land use designations, and changes in the Land Use Map for the subject site.
Pursuant to Section 15164 of the State CEQA Guidelines, an addendum to a certified EIR may be prepared if only minor technical changes or additions are necessary and none of the conditions described in State CEQA Guidelines Section 15162 that call for preparation of a subsequent EIR have occurred. The CEQA analysis concluded that the proposal would cause none of the conditions described in Section 15162 to occur. Based on the level of previous environmental review and the scope of the proposed revisions to existing regulations, the City has determined that the project changes are minor and no substantial changes in the project or environmental conditions have occurred since certification of the General Plan 2030 EIR on June 26, 2012. Thus, an Addendum to the General Plan 2030 EIR is the appropriate environmental review document for the proposed project modifications. The Addendum is attached to this report.
HEALTH IN ALL POLICIES (HiAP): HiAP is a collaborative approach to improving the community well-being of the City’s residents by prioritizing public health, sustainability, and equity into decision-making across sectors and policy areas. The goal of HiAP is to ensure that all decision-makers are informed about the health, equity, and sustainability impacts of various policy options during the policy development process so that they have holistic information upon which to make decisions. The proposed general plan, zoning, and LCP amendments support the pillars of equity and public health by advancing efforts to create a permanent agricultural site for the Homeless Garden Project, ensuring the program can continue to provide job training services for those who need it most, and to provide an option for consumers to make healthy food choices with the produce grown by the garden. The proposal supports the pillar of sustainability by creating land use parameters for a site to implement organic gardening, a sustainable use of the land. Transferring housing capacity from this site to the downtown area further supports the pillar of sustainability by concentrating housing near services and jobs. Therefore, the proposed code amendments are considered consistent with the three pillars of HiAP.
24.5 FISCAL IMPACT:
1. The recommendation in this report impacts the General Fund: Yes
2. This recommendation requires a budget adjustment: No
3. The recommendation creates an on-going expenditure commitment: No FISCAL IMPACT DESCRIPTION: At its December 10, 2024 meeting, the City Council directed staff to waive processing fees associated with these amendments resulting in an approximately $12,000 loss to the General Fund. Additionally, it is estimated that the CEQA work for this project completed by the City’s third-party consultant will cost approximately $7,142.50, also covered by the City. If approved, there are no additional direct fiscal impacts to the General Fund from the proposed amendments to the General Plan, Zoning Map, and Local Coastal Program. Changing the land use and zoning designations and general plan text associated with this site shifts housing capacity on each side of the site and affects development policy on the site, which may affect the number and types of development permits that an applicant may apply for in the future and the associated fees for the permits; however, as the housing capacity remains generally the same for the overall site, the General Fund revenue associated with such permit fees and future property taxes are unlikely to be substantially different from what it would be without these modifications.
Prepared By:
Clara Stanger
Senior Planner
Submitted By:
Lee Butler, LEED AP, AICP
Director of Planning and
Community Development
Approved By:
Matt Huffaker
City Manager
ATTACHMENTS:
1. RESOLUTION AMENDING THE GENERAL PLAN LAND USE DESIGNATION OF 2394 DELAWARE AVENUE AND FOR RELATED GENERAL PLAN TEXT
AMENDMENTS, CLEAN.DOC
2. EXHIBIT A TO RESOLUTION AMENDING THE GENERAL PLAN LAND USE DESIGNATION OF 2394 DELAWARE AVENUE AND FOR RELATED GENERAL PLAN TEXT AMENDMENTS.PDF
3. RESOLUTION AMENDING THE GENERAL PLAN LAND USE DESIGNATION OF 2394 DELAWARE AVENUE AND FOR RELATED GENERAL PLAN TEXT
AMENDMENTS, TRACK CHANGES.DOC
4. ORDINANCE REZONING THE NORTHERN FOUR ACRES OF 2394 DELAWARE AVENUE.DOC
5. EXHIBIT A TO ORDINANCE REZONING THE NORTHERN FOUR ACRES OF 2394 DELAWARE AVENUE.PDF
6. ORDINANCE REZONING THE SOUTHERN APPROXIMATELY 6.3 ACRES OF 2394 DELAWARE AVENUE.DOC
7. EXHIBIT A TO ORDINANCE REZONING THE SOUTHERN APPROXIMATELY 6.3 ACRES OF 2394 DELAWARE AVENUE.PDF
8. APRIL 17, 2025 PLANNING COMMISSION MEETING AGENDA REPORT.PDF
9. ADDENDUM TO THE ENVIRONMENTAL IMPACT REPORT FOR GENERAL PLAN 2030.PDF
24.6 RESOLUTION NO. NS-XX,XXX
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ AMENDING THE CITY’S GENERAL PLAN 2030 BY CHANGING THE LAND USE DESIGNATION OF 2394 DELAWARE AVENUE, ASSESSOR’S PARCEL NUMBER 003-061-09, AMENDING
THE DESCRIPTION OF THE AGRICULTURE/GRAZING (AG) LAND USE DESIGNATION, AND AMENDING THE TEXT OF ACTION LU 1.1.4.
WHEREAS, the Homeless Garden Project, a local nonprofit organization that provides organic agriculture job training to homeless individuals, among other services, has been utilizing the northern four acres of 2394 Delaware Avenue for organic gardening since 1995 and wishes to make this site the garden’s permanent location; and
WHEREAS, Government Code Section 66300(b)(1) that prohibits a local jurisdiction from changing the general plan land use designation, rezoning, or taking another action that would have the effect of reducing the residential capacity of a site, with an exception under Government Code Section 66300(h) that allows such a reduction in capacity if the local jurisdiction concurrently upzones another site at the same hearing of the legislative body so that the result is no net loss of housing potential among the sites; and
WHEREAS, on November 19, 2024, the City Council passed a motion directing staff to make general plan and zoning changes to the northern four acres of the subject site while ensuring conformance with state law requiring no net loss of housing potential to facilitate creation of a permanent site for the Homeless Garden Project; and
WHEREAS, on December 10, 2024, the City Council passed a motion to waive processing fees for the Homeless Garden Project with respect to the motion from the November 19, 2024 City Council meeting; and
WHEREAS, General Plan Action LU 1.1.4 calls for the site to include the Low-Medium Density (LM) land use designation; and
WHEREAS, minor amendments to General Plan Action LU 1.1.4 are needed to allow the Agriculture/Grazing land use designation on the site, to eliminate the need for a specific plan, and other minor changes related to future site development; and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission reviewed the proposed amendments to the General Plan and found that the public necessity, and the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Plan and any adopted area or specific plan; and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission passed a motion that recommended the City Council approve the proposed amendments; and WHEREAS, the City Council conducted a public hearing on May 13, 2025; and
24.7 RESOLUTION NO. NS-XX,XXX
2 WHEREAS, the General Plan land use designations for the northern and southern portions of the site would ensure no net loss of housing potential if approved concurrently today; and WHEREAS, the proposed amendments have been analyzed under an addendum to the EIR for General Plan 2030, pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15164.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Cruz as follows:
Section 1. That it hereby adopts the amendment to the General Plan 2030 Land Use Designation Map to change the land use designation of the northern four acres of the subject site to Agriculture/Grazing (AG) and to change the land use designation of the southern approximately
6.3 acres of the subject site to Low-Medium Density Residential (LM), as shown in Exhibit A.
Section 2. That it hereby adopts the amendments to the text of General Plan 2030, page 43, regarding the description of the Agriculture/Grazing (AG) land use designation as follows:
Agriculture/Grazing (AG), 0.5 du/ac. Applies to grazing land on the western edge of the city. The AG designation is generally applied to areas that are used predominantly for large-scale agriculture or grazing. It is not typically applied to community gardens or other small-scale agricultural uses unless the site is intended to remain in long-term agricultural use.
Section 3. That it hereby adopts the amendments to the text of General Plan 2030, page 43, Action LU 1.1.4 regarding the subject property as follows:
LU1.1.4 Obtain Local Coastal Plan certification for the 10.3-acre Swenson parcel pursuant to the following:
• The land use designations shall be Agriculture/Grazing and a mix of Low Medium Density Residential/Neighborhood Commercial/Office).
• Implement general plan or zoning changes, or pursue alternative entitlement paths, such as a planned development permit, as needed, to cluster the residential development capacity of 20 dwelling units per acre for the entire 10.3-acre parcel on the southern 6.3 acres to ensure no net loss of housing potential while retaining agricultural use on the northern 4 acres and while considering the other development guidance contained in this action. • The environmental review process shall guide the location and intensity of all uses. The height, scale, and bulk of development shall take into consideration the rural transition at the city’s edge. • Neighborhood Commercial and Office land uses shall be at least 10 percent but no more than 20 percent of the total net developable area.
24.8 RESOLUTION NO. NS-XX,XXX
3 • Wetland setbacks and buffer areas shall be determined by a biological report consistent with the City-Wide Creeks and Wetlands Management Plan, and based upon the buffer/setback determination, neighborhood park land shall be considered on the site. • Any required uncovered off-street parking for residential uses shall be prioritized away from the pond. Except for parking for the disabled, off-street uncovered parking and driveways near Antonelli Pond and residential uses is discouraged.
• The site design shall provide access from Shaffer Road. • Public access to Antonelli Pond shall be preserved.
PASSED AND ADOPTED this 13th day of May, 2025 by the following vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
24.9 24.10
RESOLUTION NO. NS-XX,XXX
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ AMENDING THE CITY’S GENERAL PLAN 2030 BY CHANGING THE LAND USE DESIGNATION OF 2394 DELAWARE AVENUE, ASSESSOR’S PARCEL NUMBER 003-061-09, AMENDING
THE DESCRIPTION OF THE AGRICULTURE/GRAZING (AG) LAND USE DESIGNATION, AND AMENDING THE TEXT OF ACTION LU 1.1.4.
WHEREAS, the Homeless Garden Project, a local nonprofit organization that provides organic agriculture job training to homeless individuals, among other services, has been utilizing the northern four acres of 2394 Delaware Avenue for organic gardening since 1995 and wishes to make this site the garden’s permanent location; and
WHEREAS, Government Code Section 66300(b)(1) that prohibits a local jurisdiction from changing the general plan land use designation, rezoning, or taking another action that would have the effect of reducing the residential capacity of a site, with an exception under Government Code Section 66300(h) that allows such a reduction in capacity if the local jurisdiction concurrently upzones another site at the same hearing of the legislative body so that the result is no net loss of housing potential among the sites; and
WHEREAS, on November 19, 2024, the City Council passed a motion directing staff to make general plan and zoning changes to the northern four acres of the subject site while ensuring conformance with state law requiring no net loss of housing potential to facilitate creation of a permanent site for the Homeless Garden Project; and
WHEREAS, on December 10, 2024, the City Council passed a motion to waive processing fees for the Homeless Garden Project with respect to the motion from the November 19, 2024 City Council meeting; and
WHEREAS, General Plan Action LU 1.1.4 calls for the site to include the Low-Medium Density (LM) land use designation; and
WHEREAS, minor amendments to General Plan Action LU 1.1.4 are needed to allow the Agriculture/Grazing land use designation on the site, to eliminate the need for a specific plan, and other minor changes related to future site development; and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission reviewed the proposed amendments to the General Plan and found that the public necessity, and the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Plan and any adopted area or specific plan; and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission passed a motion that recommended the City Council approve the proposed amendments; and WHEREAS, the City Council conducted a public hearing on May 13, 2025; and
24.11 RESOLUTION NO. NS-XX,XXX
WHEREAS, the General Plan land use designations for the northern and southern portions of the site would ensure no net loss of housing potential if approved concurrently today; and WHEREAS, the proposed amendments have been analyzed under an addendum to the EIR for General Plan 2030, pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15164.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Cruz as follows:
Section 1. That it hereby adopts the amendment to the General Plan 2030 Land Use Designation Map to change the land use designation of the northern four acres of the subject site to Agriculture/Grazing (AG) and to change the land use designation of the southern approximately
6.3 acres of the subject site to Low-Medium Density Residential (LM), as shown in Exhibit A.
Section 2. That it hereby adopts the amendments to the text of General Plan 2030, page 43, regarding the description of the Agriculture/Grazing (AG) land use designation as follows:
Agriculture/Grazing (AG), 0.5 du/ac. Applies to grazing land on the western edge of the city. The AG designation is generally applied only to areas that are used predominantly for largescale agriculture or grazing. It is not typically applied to community gardens or other small-scale agricultural uses unless the site is intended to remain in long-term agricultural use.
Section 3. That it hereby adopts the amendments to the text of General Plan 2030, page 43, Action LU 1.1.4 regarding the subject property as follows:
LU1.1.4 Obtain Local Coastal Plan certification for the 1110.3-acre Swenson parcel pursuant to the following:
• Require a specific plan for the property (with aThe land use designationsed asshall be Agriculture/Grazing and a mix of Low Medium Density Residential/Neighborhood Commercial/Office).
• Implement general plan or zoning changes, or pursue alternative entitlement paths, such as a planned development permit, as needed, to cluster the residential development capacity of 20 dwelling units per acre for the entire 10.3-acre parcel on the southern 6.3 acres to ensure no net loss of housing potential while retaining agricultural use on the northern 4 acres and while considering the other development guidance contained in this action. • The environmental review process shall guide the location and intensity of all uses. The height, scale, and bulk of development shall take into consideration the rural transition at the city’s edge. • Neighborhood Commercial and Office land uses shall be at least 10 percent but no more than 20 percent of the total net developable area.
• The extent of open space buffers/setbacks to wetland areas on and adjoining the site will ultimately be determined by the California Coastal Commission. Based upon the Coastal
24.12 RESOLUTION NO. NS-XX,XXX
Commission’s buffer/setback determination, Wetland setbacks and buffer areas shall be determined by a biological report consistent with the City-Wide Creeks and Wetlands Management Plan, and based upon the buffer/setback determination, neighborhood park land shall be considered on the site.
• The specific plan shall prioritize away from the pond, Aany required uncovered off-street parking for residential uses shall be prioritized away from the pond. Except for parking for the disabled, off- street uncovered parking and driveways near Antonelli Pond and residential uses is discouraged.
• The site design circulation system of the specific plan shall provide access from Shaffer Road. • Public access to Antonelli Pond shall be preserved.
PASSED AND ADOPTED this 13th day of May, 2025 by the following vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
24.13 ORDINANCE NO.
AN ORDINANCE OF THE CITY OF SANTA CRUZ AMENDING THE ZONING MAP RELATING TO THE NORTHERN FOUR ACRES OF 2394 DELAWARE AVE, ASSESSOR’S PARCEL NUMBER 003-061-09 IN THE R-1-5/CZ-O ORIGINAL JURISDICTION (SINGLE FAMILY ZONE/COASTAL ZONE OVERLAY – ORIGINAL PERMIT JURISDICTION) DISTRICT. THE ZONING MAP IS PART OF THE LOCAL
COASTAL PROGRAM IMPLEMENTATION PLAN (LCP IP) AND THE AMENDMENT
THERETO WILL REQUIRE APPROVAL BY THE CALIFORNIA COASTAL COMMISSION PRIOR TO TAKING EFFECT INSIDE THE COASTAL ZONE. (CEQA:
EVALUATED UNDER AN ADDENDUM TO THE EIR FOR GENERAL PLAN 2030.) WHEREAS, the Homeless Garden Project, a local nonprofit organization that provides organic agriculture job training to homeless individuals, among other services, has been utilizing the subject location for organic gardening since 1995 and wishes to make this site the garden’s permanent location; and
WHEREAS, on November 19, 2024, the City Council passed a motion directing staff to make the subject general plan and zoning changes to the subject site while ensuring conformance with state law requiring no net loss of housing potential to facilitate creation of a permanent site for the Homeless Garden Project; and
WHEREAS, on December 10, 2024, the City Council passed a motion to waive processing fees for the Homeless Garden Project with respect to the motion from the November 19, 2024 City Council meeting; and
WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission reviewed the proposed amendments to the Zoning Map and found that the public necessity, and the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies and land use designations set forth in the General Plan, Local Coastal Plan and any adopted area or specific plan; and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission considered the proposed amendment to the Zoning Map as modifications to the Local Coastal Program and found that (1) the proposed amendment is deemed to be in the public interest; (2) the proposed General Plan and/or Local Coastal Program amendment is consistent and compatible with the rest of the General Plan and LCP and any implementation programs that may be affected; (3) the potential impacts of the proposed amendment have been assessed and have been determined not to be detrimental to the public health, safety, or welfare; and (4) the proposed amendment has been processed in accordance with the applicable provisions of the California Government Code and the California Environmental Quality Act (CEQA); and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission passed a motion that recommended the City Council approve the proposed amendments; and
24.14 ORDINANCE NO. 2025-
WHEREAS, Government Code Section 66300(b)(1) that prohibits a local jurisdiction from changing the general plan land use designation, rezoning, or taking another action that would have the effect of reducing the residential capacity of a site, with an exception under Government Code Section 66300(h) that allows such a reduction in capacity if the local jurisdiction concurrently upzones another site at the same hearing of the legislative body so that the result is no net loss of housing potential among the sites; and
WHEREAS, today’s City Council agenda includes two additional proposals to rezone sites that would increase the City’s housing potential, and that each, on its own, would ensure no net loss of today’s housing potential if approved today; and WHEREAS, the proposed amendments have been analyzed under an addendum to the EIR for General Plan 2030, pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15164.
BE IT ORDAINED By the City of Santa Cruz as follows:
Section 1. The Zoning Map shall be amended to change the zoning designation of the northern four acres of the subject site from Single-Family Residential (R-1-5) to Exclusive Agriculture (E-A) as depicted in Exhibit A.
Section 2. The City Council finds and determines that the adoption of this ordinance is considered a “project” under California Code of Regulations, Title 14, section 15378(a)(1) of the California Environmental Quality Act (CEQA) Guidelines, typically subject to environmental review. The City Council finds that these amendments have been considered under an addendum to the EIR for General Plan 2030 dated April 10, 2025.
Section 3. If any section or portion of this ordinance is found to be invalid by a court of competent jurisdiction, such finding shall not affect the validity of the remainder of the ordinance, which shall continue in full force and effect.
Section 4. This ordinance is part of the Local Coastal Program and shall take effect and be in full force after approval by the California Coastal Commission, but no earlier than thirty (30) days after final adoption.
PASSED FOR PUBLICATION this 13th day of May 2025, by the following vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
APPROVED: __________________________
Fred Keeley, Mayor
ATTEST: ___________________________
Bonnie Bush, City Clerk Administrator
24.15 ORDINANCE NO. 2025-
PASSED FOR FINAL ADOPTION this XX day of XX 2025 by the following vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
APPROVED: ___________________________
Fred Keeley, Mayor
ATTEST: ___________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above
and foregoing document is the
original of Ordinance No. 2025-XX
and that it has been published or
posted in accordance with the
Charter of the City of Santa Cruz.
___________________________
City Clerk Administrator
24.16 24.17
ORDINANCE NO.
AN ORDINANCE OF THE CITY OF SANTA CRUZ AMENDING THE ZONING MAP RELATING TO THE SOUTHERN APPROXIMATELY 6.3 ACRES OF 2394 DELAWARE AVE, ASSESSOR’S PARCEL NUMBER 003-061-09, IN THE R-1-5/CZ-O ORIGINAL JURISDICTION (SINGLE FAMILY ZONE/COASTAL ZONE OVERLAY – ORIGINAL PERMIT JURISDICTION) DISTRICT. THE ZONING MAP IS PART OF THE LOCAL
COASTAL PROGRAM IMPLEMENTATION PLAN (LCP IP) AND THE AMENDMENT
THERETO WILL REQUIRE APPROVAL BY THE CALIFORNIA COASTAL COMMISSION PRIOR TO TAKING EFFECT INSIDE THE COASTAL ZONE. (CEQA:
EVALUATED UNDER AN ADDENDUM TO THE EIR FOR GENERAL PLAN 2030.) WHEREAS, the Homeless Garden Project, a local nonprofit organization that provides organic agriculture job training to homeless individuals, among other services, has been utilizing the northern four acres of 2394 Delaware Avenue for organic gardening since 1995 and wishes to make this site the garden’s permanent location; and
WHEREAS, Government Code Section 66300(b)(1) that prohibits a local jurisdiction from changing the general plan land use designation, rezoning, or taking another action that would have the effect of reducing the residential capacity of a site, with an exception under Government Code Section 66300(h) that allows such a reduction in capacity if the local jurisdiction concurrently upzones another site at the same hearing of the legislative body so that the result is no net loss of housing potential among the sites; and
WHEREAS, on November 19, 2024, the City Council passed a motion directing staff to make general plan and zoning changes to the northern four acres of the subject site while ensuring conformance with state law requiring no net loss of housing potential to facilitate creation of a permanent site for the Homeless Garden Project; and
WHEREAS, on December 10, 2024, the City Council passed a motion to waive processing fees for the Homeless Garden Project with respect to the motion from the November 19, 2024 City Council meeting; and
WHEREAS, the zoning designation change for the southern approximately 6.3 acres of the site would ensure no net loss of today’s housing potential between the northern and southern ends of the site; and
WHEREAS, General Plan Action LU 1.1.4 calls for the site to include the Low-Medium Density (LM) land use designation, and the Multiple Residence – Low-Density (R-L) zone district implements that designation; and
WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission reviewed the proposed amendments to the Zoning Map and found that the public necessity, and the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies and land use designations set forth in the General Plan, Local Coastal Plan and any adopted area or specific plan; and
24.18 ORDINANCE NO. 2025-
WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission considered the proposed amendment to the Zoning Map as modifications to the Local Coastal Program and found that (1) the proposed amendment is deemed to be in the public interest; (2) the proposed General Plan and/or Local Coastal Program amendment is consistent and compatible with the rest of the General Plan and LCP and any implementation programs that may be affected; (3) the potential impacts of the proposed amendment have been assessed and have been determined not to be detrimental to the public health, safety, or welfare; and (4) the proposed amendment has been processed in accordance with the applicable provisions of the California Government Code and the California Environmental Quality Act (CEQA); and WHEREAS, at its April 17, 2025 meeting, the Santa Cruz Planning Commission passed a motion that recommended the City Council approve the proposed amendments; and WHEREAS, today’s City Council agenda includes proposals to rezone both the northern and southern portions of the site that would ensure no net loss of housing potential if both were approved today; and
WHEREAS, the proposed amendments have been analyzed under an addendum to the EIR for General Plan 2030, pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15164.
BE IT ORDAINED By the City of Santa Cruz as follows:
Section 1. The Zoning Map shall be amended to change the zoning designation of the southern approximately 6.3 acres of the subject site from Single-Family Residential (R-1-5) to Multiple Residence – Low-Density (R-L) as depicted in Exhibit A.
Section 2. The City Council finds and determines that the adoption of this ordinance is considered a “project” under California Code of Regulations, Title 14, section 15378(a)(1) of the California Environmental Quality Act (CEQA) Guidelines, typically subject to environmental review. The City Council finds that these amendments have been considered under an addendum to the EIR for General Plan 2030 dated April 10, 2025.
Section 3. If any section or portion of this ordinance is found to be invalid by a court of competent jurisdiction, such finding shall not affect the validity of the remainder of the ordinance, which shall continue in full force and effect.
Section 4. This ordinance is part of the Local Coastal Program and shall take effect and be in full force after approval by the California Coastal Commission, but no earlier than thirty (30) days after final adoption.
24.19 ORDINANCE NO. 2025-
PASSED FOR PUBLICATION this 13th day of May 2025, by the following vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
APPROVED: __________________________
Fred Keeley, Mayor
ATTEST: ___________________________
Bonnie Bush, City Clerk Administrator
PASSED FOR FINAL ADOPTION this XX day of XX 2025 by the following vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
APPROVED: ___________________________
Fred Keeley, Mayor
ATTEST: ___________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above
and foregoing document is the
original of Ordinance No. 2025-XX
and that it has been published or
posted in accordance with the
Charter of the City of Santa Cruz.
___________________________
City Clerk Administrator
24.20 24.21
PLANNING COMMISSION
AGENDA REPORT
DATE: 04/11/2025
AGENDA OF: 04/17/2025
ITEM NO: FP25-0002: General Plan amendment, Zoning Map amendment, and Local Coastal Program amendment to: change the general plan designation and zoning of a 10.3-acre site zoned R-1-5/CZ Permit Jurisdiction (Single Family Residence/Coastal Zone- Original Permit Jurisdiction) and with a Low-Density Residential general plan designation so that the northern four acres of the site shall be changed to the Agriculture/Grazing (AG) designation and the E-A/CZ Appeal (Exclusive Agricultural District/Coastal Zone Overlay Appeal zone), and the 6.3-acre southern portion of the site shall be changed to the Low-Medium-Density Residential (LM) designation and the R-L/CZ Permit Jurisdiction (Multiple-Residence – Low Density District (R-L) district/Coastal Zone Overlay original jurisdiction zone); amend the text of general plan action LU 1.1.4; amend the Agriculture/Grazing land use designation definitions in the General Plan and Local Coastal Program; and obtain Local Coastal Program certification for the northern portion of the site.
District: District 6
RECOMMENDATION: Motion to find that the Planning Commission concurs with the required findings, as specified in the staff report and to recommend that the City Council:
1) approve the proposed amendments to the City of Santa Cruz General Plan, Zoning Map, and Local Coastal Program Land Use Plan as shown in the attachments, and 2) acknowledge the addendum to the Environmental Impact Report (EIR) prepared for the City’s General Plan.
BACKGROUND: The subject site is 2394 Delaware Avenue, Assessor’s Parcel Number 003- 061-09, located at the northeast corner of the intersection of Delaware Avenue and Shaffer Road on the lower westside. The 10.3-acre site is surrounded by the railroad, multi-family housing, and industrial uses to the north, Antonelli Pond to the east, Delaware Avenue and a mobile home park to the south, and Shaffer Road and UCSC owned land to the west. The site has historically had agricultural uses, and the Homeless Garden Project has been farming on the northern part of the site since 1995. The remainder of the site is undeveloped.
The site has a general plan designation of Low Density Residential and a zoning designation of Single-Family Residential, which typically allows the development of single-family homes with a density range of 1.1 to 10 units per acre. General Plan 2030 action LU 1.1.4 calls for future site development to be based on land use designations with a higher density of up to 20 units per acre and includes other actions that address this specific site, as follows:
24.22 LU1.1.4 Obtain Local Coastal Plan certification for the 11-acre Swenson parcel pursuant to the following:
• Require a specific plan for the property (with a land use designation as Low Medium Density Residential/Neighborhood Commercial/Office).
• The environmental review process shall guide the location and intensity of all uses. The height, scale, and bulk of development shall take into consideration the rural transition at the city’s edge.
• Neighborhood Commercial and Office land uses shall be at least 10 percent but no more than 20 percent of the total net developable area.
• The extent of open space buffers/setbacks to wetland areas on and adjoining the site will ultimately be determined by the California Coastal Commission. Based upon the Coastal Commission’s buffer/setback determination, neighborhood park land shall be considered on the site.
• The specific plan shall prioritize away from the pond, any required uncovered off-street parking for residential uses. Except for parking for the disabled, off street uncovered parking and driveways near Antonelli Pond and residential uses is discouraged. • The circulation system of the specific plan shall provide access from Shaffer Road. • Public access to Antonelli Pond shall be preserved.
While the site is within the geographic area covered by the Coastal Zone Overlay zoning district, this site is the lone exception in that has not been certified as part of the Local Coastal Program (LCP). This means that the California Coastal Commission currently has coastal development permitting jurisdiction over the site.
At the November 19, 2024 City Council meeting, the City Council passed a motion directing staff to process expeditiously an amendment to the General Plan 2030 Land Use Map to designate the northern 4 acres of the 11-acre Swenson parcel as Agriculture/Grazing (AG) land, an amendment to the Zoning Ordinance to classify these 4 acres as Exclusive Agricultural District (E-A), and a LCP Amendment for submittal to the Coastal Commission to designate these 4 acres as Agriculture/Grazing (AG) land, while meeting state law “no net loss” requirements as more fully discussed below. To carry out the City Council’s direction, the proposal therefore includes the following:
• For the northern four acres, change:
o The general plan land use designation from Low Density Residential (L) to Agriculture/Grazing (AG);
o The zoning designation from Single Family Residential (R-1-5) to Exclusive Agriculture (E-A);
• For the southern 6.3 acres, change:
o The general plan land use designation from Low Density Residential (L) to LowMedium Density Residential (LM); o The zoning designation from Single Family Residential (R-1-5) to Multiple Residence – Low-Density (R-L);
• General plan text amendment to modify action LU1.1.4 to:
o Include the Agriculture/Grazing land use designation, o Remove the requirement for a specific plan,
o Cluster residential uses on the southern portion of the site to ensure no net loss of housing potential, and
o Make the Citywide Creeks and Wetlands Management Plan the standard of review for development near wetlands;
24.23 • General plan text amendment to make a minor change to the description of the Agriculture/Grazing (AG) land use designation to allow this designation for smaller-scale agricultural sites that intend to stay in agricultural use long term; and • Amendment to the City’s LCP to:
o Certify the northern four acres of the site into the LCP with a land use designation of Agriculture/Grazing (AG) and
o Make minor changes to the definition of the LCP’s Agricultural/Grazing land use designation definition.
Changes to the general plan land use designations, general plan text, and zoning designations require a recommendation by the Planning Commission and approval by City Council.
Amendments to the LCP involve a recommendation by Planning Commission, approval by City Council with a resolution, and subsequent submittal to and approval by the California Coastal Commission. Maps depicting the proposed land use and zoning changes and strikeout-underline versions of the proposed general plan and LCP text amendments are attached.
DISCUSSION: The proposal is consistent with no net loss state law, the general plan, the zoning ordinance, and the LCP as described below.
Not Net Loss State Law Consistency
The Housing Accountability Act includes a requirement under Government Code Section 66300(b)(1) that prohibits a local jurisdiction from changing the general plan land use designation, rezoning, or taking another action that would have the effect of reducing the residential capacity of a site, with some limited exceptions. One exception allows this reduction in capacity to take place if the local jurisdiction concurrently upzones another site at the same hearing of the legislative body so that the result is no net loss of housing potential among the sites (Government Code Section 66300(h)).
The site currently has a general plan land use designation of Low Density Residential, which allows a range of one to 10 dwellings per acre for a total capacity of 103 units on 10.3 acres.
General Plan action LU1.1.4 calls for the site to obtain LCP certification subject to creation of a specific plan with new general plan land use designations of Low Medium Density Residential/Neighborhood Commercial/Office, which would increase the residential capacity to 20 units per acre, or 206 units on the 10.3-acre site. Therefore, any changes to the general plan designation or zoning must be coupled with an action that not only maintains the site’s current capacity of 103 units but also preserves the future potential of 206 units under action LU 1.1.4.
The proposal involves changing the general plan designation of the northern four acres of the site from Low Density Residential to Agriculture/Grazing, which reduces the current residential development capacity from 10 dwellings per acre down to 0.5 dwelling per acre, a reduction in capacity from 40 units down to two, which is a 38-unit reduction. In terms of future capacity based on the text of general plan action LU 1.1.4, the reduction would be from 20 units per acre down to 0.5 units per acre, a reduction of 78 units over the northern four acres. To achieve consistency with the no net loss requirement under state law, the proposal must change the general plan designation of another site to make up for those lost units.
The proposal uses two approaches that each separately would achieve consistency with the no net loss requirements. The first approach involves both changing the general plan designation and zoning of the southern 6.3 acres of the site to maintain the current capacity and amending the text of the general plan action (LU 1.1.4) associated with the site to maintain the general plan’s future capacity. The general plan designation would be changed from Low-Density Residential
24.24 to Low-Medium Density Residential, and the zoning designation would be changed from R-1-5 (Single Family Residential) to R-L (Multiple Residence – Low-Density), which would increase the residential capacity on that portion of the site from 10 units per acre up to 20 units per acre, from 63 to 126 units, an increase of 63 units. This increase in residential capacity more than makes up for the 38 units of capacity lost by changing the northern four acres to the agricultural land use designation. In addition, the proposed amendments to the text of general plan action LU
1.4.4 include new language indicating that the total 206 units conceived under the action would be clustered housing on the southern 6.3 acres of the site, ensuring no net loss of future housing potential.
The second approach is to take this proposal to City Council concurrently with the proposed upzoning associated with the Downtown Plan Expansion, which increases the housing capacity of the downtown plan area south of Laurel Street by 263 units. The Downtown Plan Expansion will also provide no net loss housing potential for the downzoning of another site comprising three lots on Leonard Street that will reduce housing capacity by 47 units. The remaining “extra” housing capacity from the Downtown Plan Expansion is 216 units, more than that what is needed to achieve no net loss for either today’s 38-unit capacity reduction for the northern four acres of the subject site or the future housing capacity reduction (78 units) anticipated by general plan action LU 1.1.4.
It can be argued that only one of these separate upzonings, either the southern side of the subject site or the downtown plan expansion site, is needed to achieve consistency with no net loss state law requirements. However, it is not anticipated that the City will pursue LCP certification for the southerly 6.3 acres of the site at this time. While the state law’s approach to a situation such as this is not explicit, to ensure that the no net loss provisions of state law are still met, the additional residential capacity of the downtown plan expansion is also being coupled with this project. Undertaking both approaches provides the certainty that the state law’s no net loss will be achieved.
General Plan Consistency
The proposal intends to change the general plan land use designation of the site’s northern four acres to Agriculture/Grazing and to change the designation of the southern 6.3 acres to LowMedium Density Residential. Text amendments to the general plan include minor changes to the description of the Agriculture/Grazing land use designation and modifications to general plan action LU 1.1.4 as described earlier.
The proposed changes to the land use designation and zoning of the southern 6.3 acres partially implement the existing action LU 1.1.4, which calls for the site to have designations of LowMedium Density Residential, Office, and Neighborhood Commercial. The proposed changes to establish the northern four acres’ agricultural general plan land use and zoning designations implement a part of the proposed language of LU 1.1.4, which calls for the site to include land in the Agriculture/Grazing designation and to preserve the northern four acres of the site in agricultural use.
The proposed changes are consistent with the following general plan goals, policies, and actions that seek to preserve and promote agricultural uses and encourage residential clustering to preserve open space areas:
CD1.4.1 Use planned development and other clustering techniques to protect resources and views and allow for siting that is sensitive to adjacent uses.
24.25 LU2.3 Preserve open space and agricultural land uses at the edge of the city. Cf. LU1.2, NRC3.4.
HZ4.1.6 Emphasize the city’s role as an organic agricultural center and work with appropriate agencies to develop demonstration projects on non-chemical pest control and soil management practices. Cf. CC6.1.8, NRC3.2
NRC3.4 Conserve agricultural and known mineral resources in the Planning Area. Cf.
LU1.2, LU2.3, LU2.3.5.
Local Coastal Program (LCP) Consistency
The City’s LCP is the tool used by the City and the California Coastal Commission to effectively regulate development activities within the Coastal Zone. The proposal includes changes to the LCP, including certifying the northern four acres of the site with an Agriculture/Grazing land use designation and Exclusive Agriculture zoning as part of the LCP and making minor changes to the LCP’s description of the Agriculture/Grazing land use designation. The proposal is consistent with the following LCP policies and programs that support the preservation of agricultural uses:
Environmental Quality Element 3.4 Protect significant agriculture and grazing lands within and along the periphery of the City from development utilizing exclusive agriculture/grazing zoning and Williamson Act contracts. (See Map EQ-5, policy L 3.1.3 and policies under L 3.1.4.)
Land Use Element 3.1.3 Support County policies and programs aimed at preservation of agricultural/grazing uses on the North Coast and utilize exclusive agriculture/grazing zoning, Williamson Act contracts, agricultural easements and transfers of development rights to preserve agricultural/grazing lands within the City. (See Policies EQ 3.4 and CD
1.3.1.2.)
Land Use Element 3.1.3.1 Encourage organic farming practices on agricultural lands and community gardens within the City. (See policies PR 1.3 and S 6.5.2) Economic Development Element 1.6.5 Promote protection of significant agricultural lands and sustainable agriculture programs throughout the City and County. (See policies L 3.1.3 and L 3.1.4)
Zoning Ordinance Consistency
The proposal includes changing the northern four acres of the site from a zoning designation of R-1-5 to E-A. The purpose of the zone district is to preserve in agricultural use land presently best suited to that use. The northern four acres are currently in organic agricultural use by the Homeless Garden Project, and the intention of the zoning designation change is to provide for continued agricultural use of the site for the foreseeable future. Therefore, the use of the site prompting the change to E-A zoning is consistent with the intent of the zone district. While the E-A zone district requires a minimum lot width of 500 feet and a minimum net lot area of 20 acres, and the area proposed to be zoned E-A is less than these amounts at 490 feet wide and four gross acres in size, the proposal does not involve creation of a lot. If the City received an application to create a new lot on this site in the future, Section 23.04.060 of the subdivision ordinance would allow for a modification to the size and width standards if it were reasonably necessary and expedient and the proposal conformed to the requirements of the state subdivision map act. Should the creation of a separate lot for this E-A-zoned area be considered in the future, that proposal would likely meet those findings.
24.26 The proposal would also change the zoning of the southern 6.3 acres of the site from R-1-5 to RL. The purpose of the R-L zone district is to promote the development of various types of multifamily housing at a density of 10.1 to 20 units per acre, to promote residential characteristics of the zone, and to encourage a stable living environment for families and single persons. This zoning aligns with the current general plan action LU 1.1.4, which calls for residential development of the site within this same density range. The R-L zone district development standards include a minimum net lot area of 5,000 square feet and a minimum lot width of 50 feet. The area and width of the portion of the site proposed for R-L zoning greatly exceeds these standards and would allow the site to be subdivided into one or more R-L zoned lots in the future.
Community Outreach
The Department of Planning and Community Development Community Outreach Policy for Planning Projects states that outreach for policy changes is based on the scope of the project.
This proposal is considered a minor policy change, as it generally aligns with the existing agricultural use of the site and the anticipated long-term uses of the site, as called for in the general plan. Thus, the level of outreach aligned with that required for public hearings.
Opportunities for public input included the November 19, 2024 City Council meeting where City Council gave direction to initiate this proposal, a subsequent City Council meeting where Council gave direction for the City to cover the costs of the application, the subject Planning Commission hearing, and the upcoming City Council meetings, currently anticipated for May 13, 2025 and May 27, 2025 for the first and second readings of the ordinances associated with this proposal.
Next Steps
Following action by the Planning Commission, the proposal will proceed to a first reading before the City Council, currently anticipated for the meeting of May 13, 2025. A second reading before the Council is required for the ordinance changes and is anticipated to take place at the meeting of May 27, 2025. Should the amendments be approved by the City Council, the portions of the proposal that constitute amendments to the LCP and for which direction is provided to pursue an LCP amendment, including certification of the northern four acres into the LCP and associated amendments to the LCP text, will be submitted to the California Coastal Commission for review.
Those portions of the package that do not amend the LCP will take effect thirty days after final action by the City Council, while those that are subject to Coastal Commission jurisdiction will take effect immediately upon final action by that body. Staff anticipate the Coastal Commission will act on this item in the Summer of 2025.
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION: The proposed amendments fall within the analyzed development potential in an addendum to the City’s existing 2030 General Plan EIR.
The General Plan 2030 EIR is a “program” EIR prepared pursuant to the State CEQA Guidelines Section 15168. The EIR reviewed direct and indirect impacts of implementation of the General Plan, as well as indirect environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. The EIR reviewed updated policies, new land use designations, and changes in the Land Use Map for the subject site.
Pursuant to Section 15164 of the State CEQA Guidelines, an addendum to a certified EIR may be prepared if only minor technical changes or additions are necessary and none of the
24.27 conditions described in State CEQA Guidelines Section 15162 that call for preparation of a subsequent EIR have occurred. The CEQA analysis concluded that the proposal would cause none of the conditions described in Section 15162 to occur. Based on the level of previous environmental review and the scope of the proposed revisions to existing regulations, the City has determined that the project changes are minor and no substantial changes in the project or environmental conditions have occurred since certification of the General Plan 2030 EIR on June 26, 2012. Thus, an Addendum to the General Plan 2030 EIR is the appropriate environmental review document for the proposed project modifications. The Addendum is attached to this report.
HEALTH IN ALL POLICIES (HiAP): HiAP is a collaborative approach to improving the community well-being of the City’s residents by prioritizing public health, sustainability, and equity into decision-making across sectors and policy areas. The goal of HiAP is to ensure that all decision-makers are informed about the health, equity, and sustainability impacts of various policy options during the policy development process so that they have holistic information upon which to make decisions. The proposed general plan, zoning, and LCP amendments support the pillars of equity and public health by advancing efforts to create a permanent agricultural site for the Homeless Garden Project, ensuring the program can continue to provide job training services for those who need it most, and to provide an option for consumers to make healthy food choices with the produce grown by the garden. The proposal supports the pillar of sustainability by creating land use parameters for a site to implement organic gardening, a sustainable use of the land. Transferring housing capacity from this site to the downtown area further supports the pillar of sustainability by concentrating housing near services and jobs. Therefore, the proposed code amendments are considered consistent with the three pillars of HiAP.
FINDINGS: Zoning Ordinance Section 24.06.040 requires that prior to making a recommendation for approval of General Plan or Zoning Ordinance amendments to the City Council, the Planning Commission shall make findings that the public necessity, and the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendment is in general conformance with the principles, policies and land use designations set forth in the General Plan, Local Coastal Plan and any adopted area or specific plan.
Similar findings are also required in the Local Coastal Program for any amendments to the LCP.
These findings include: (1) the proposed amendment is deemed to be in the public interest; (2) the proposed General Plan and/or Local Coastal Program amendment is consistent and compatible with the rest of the General Plan and LCP and any implementation programs that may be affected; (3) the potential impacts of the proposed amendment have been assessed and have been determined not to be detrimental to the public health, safety, or welfare; and (4) the proposed amendment has been processed in accordance with the applicable provisions of the California Government Code and CEQA.
The proposed amendments serve and further public necessity and general community welfare by furthering a variety of public policy goals including conformance with State law governing land uses; they fulfill a number of objectives in the general that support agricultural uses and the clustering of housing to maintain open space areas; and they further the intention of the City to support job training services for those who need them the most. The amendments further good zoning practice by maintaining consistency with State law and zoning land consistent with their current and intended uses. The proposed amendments are in general conformance with the principles, policies and land use designations set forth in the General Plan, Local Coastal Plan
24.28 and any adopted area or specific plan as described above. The proposed amendments are consistent with the provisions of CEQA as discussed above.
Submitted By:
Clara Stanger
Senior Planner
Approved By:
Lee Butler, AICP, LEED AP
Director of Planning &
Community Development
ATTACHMENTS:
1. Diagrams depicting proposed changes to zoning and general plan land use designations
2. Proposed General Plan text amendments, track changes
3. Diagrams depicting proposed LCP land use and zoning designations for northern four acres
4. Proposed Local Coastal Land Use Plan text amendment, track changes
5. Addendum to the Environmental Impact Report for General Plan 2030
24.29 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 1 A p r i l 2025
City of Santa Cruz
GENERAL PLAN 2030 EIR ADDENDUM
Proposed General Plan 2030 , Zoning and
Local Coastal Program Amendments
APRIL 2025
I. B A C K G R O U N D
Project Title: 2394 Delaware Avenue General Plan, Zoning, and LCP Amendments Project Number: FP25-0002
Project Location: 2394 Delaware Avenue in the westside of the City of Santa Cruz (APN 003- 061-09); see Figure 1-Regional Location
Lead Agency Name and Address:
City of Santa Cruz, Planning and Community Development Department 809 Center Street, Room 101
Santa Cruz, CA 95060
Contact Person and Phone Number: Clara Stanger, (831) 420-5247 | [email protected] Project Applicant’s/Sponsor’s Name and Address: City of Santa Cruz Project Overview: The proposed project consists of amendments to the City’s General Plan 2030 and General Plan land use designation and zone district amendments for a 10.3-acre parcel at 2394 Delaware Avenue on the westside of Santa Cruz that is referenced as the “Swenson parcel” in the City’s General Plan 2030; see Figure 2. The project also proposes obtaining Local Coastal Program (LCP) certification for the northern portion of the site. Details of the proposed amendments are provided below.
General Plan 2030 Background: In June 2012, the Santa Cruz City Council adopted the General Plan 2030 (after certification of the Environmental Impact Report [EIR] prepared for the General Plan). The General Plan is a required, comprehensive, long-range plan to guide development within the City. The adopted General Plan 2030 covers an approximate 20-year planning period and provides goals, policies and actions that address: land use; transportation; community C O N T E N T S :
I. Background
II. Project Description
III. Environmental Setting
IV. Use of An Addendum
V. Environmental Review
VI. References
24.30 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 2 A p r i l 2025
design; historic preservation, arts and culture; community facilities; hazards, safety and noise; parks, recreation and open space; and natural resources and conservation.
The General Plan 2030 includes goals, policies, and actions. A goal is a general, overall, and ultimate purpose, aim, or end, toward which the City will direct effort during the timeframe of the general plan. A policy is a specific statement of principle or guidance that implies clear commitment and the direction the City elects to follow in order to meet its goals. An action is program, activity, or strategy carried out in response to an adopted policy to achieve a specific goal. Chapter 11, Implementation, of the General Plan 2030 identifies a timeframe and responsible City departments for implementation of the General Plan policies and actions.
Pursuant to State law, the City must provide annual reports to the City Council and the State regarding progress of implementation.
The City’s General Plan 2030 guides the location, density and intensity of future development, and includes a Land Use Map that graphically expresses the General Plan’s development and conservation policies by showing the desired arrangement and location of land uses. According to the General Plan, the map is consistent with the General Plan text, goals, policies, and actions.
The General Plan 2030 also notes that State planning law does not require a general plan land use map to be specific as to how it designates individual parcels. In fact, Government Code section 65302 refers to “diagrams” and not to “maps.” Either way, the Land Use “map” or “diagram” must allow anyone who uses the General Plan to reach the same conclusion about the designated use of any property covered by the Plan.
The General Plan 2030 land use designations and Land Use Map were largely unchanged from the former General Plan, except for inclusion of three new mixed-use land use designations and Land Use Map changes for three areas: 1) properties along Golf Club Drive (20 acres); 2) the parcel on the westside of Santa Cruz referred to as the “Swenson parcel” (approximately 11 acres); and 3) the City’s Dimeo Land Landfill and Resource Recovery Center (5.5 acres).
General Plan 2030 EIR Background. The General Plan 2030 EIR is a “program” EIR prepared pursuant to the State CEQA Guidelines Section 15168. The EIR reviewed direct and indirect impacts of implementation of the General Plan, as well as indirect environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. The EIR reviewed updated policies, new land use designations, and changes in Land Use Maps for three specific areas identified above. As part of the overall estimated buildout, the EIR considered construction of new housing units and nonresidential uses in the City with an estimated buildout of 3,350 new residential units and approximately 3,000,000 square feet of non-residential uses throughout the City by the year 2030 (City of Santa Cruz 2012, DEIR volume, page 3-13). It is noted that these potential development estimates included in the EIR were estimates developed for the purpose of completing environmental analyses, but were not adopted as caps or development limits.
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F I G U R E 1 : R e g i o n a l L o c a t i o n
Project Site
24.32 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 4 A p r i l 2025
F I G U R E 2 : P r o j e c t S i t e V i c i n i t y L o c a t i o n General Plan 2030 Background for the Project Site: The adopted General Plan 2030 includes Action LU1.1.4, which provides guidance regarding future development of the 11-acre property “Swenson parcel.” To date the parcel has not been certified as part of the City’s LCP. Action LU1.1.4 calls for obtaining LCP certification for the property with preparation of a Specific Plan with a mix of land use designations: Low Medium Density Residential, Neighborhood Commercial and Office. The Implementation Chapter of the General Plan identifies implementation of Action LU1.1.4 by the Planning Department within the short-term timeframe (by 2018). This implementation has not yet occurred. Because the City has not yet implemented the Land Use Map change for the property as called for in Action LU1.1.4 and the Implementation Chapter of the General Plan 2030, the parcel currently is shown with a General Plan land use designation of Low Density Residential (L) and is zoned R-1-5/CZ Permit Jurisdiction (Single-Family Residential/Coastal Zone-Original Permit Jurisdiction).
I I . P R O J E C T D E S C R I P T I O N
The proposed project consists of several amendments to the City’s General Plan 2030, including land use designation change for the parcel at 2394 Delaware Avenue that is referenced as the “Swenson parcel” in the City’s General Plan 2030. The project also includes a Zoning Map amendment for the “Swenson parcel” and proposes obtaining Local Coastal Program (LCP) certification for the northern portion of the site. Details of the proposed amendments are provided below.
General Plan 2030 Amendments. The proposed project consists of the two revisions to General Plan 2030 text and amendment to the Land Use Map for the Swenson parcel as described below. • Amend General Plan 2030 Action LU1.1.4 to reflect the proposed land use designation amendment and other minor revisions as follows:
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LU1.1.4 Obtain Local Coastal Plan certification for the 11 10.31-acre Swenson parcel pursuant to the following:
▪ Require a specific plan for the property (with a The land use designationsed as shall be Agriculture/Grazing and a mix of Low Medium Density Residential/Neighborhood Commercial/Office).
▪ Implement general plan or zoning changes, or pursue alternative entitlement paths, such as a planned development permit, as needed to cluster the residential development capacity of 20 dwelling units per acre for the entire
10.3-acre parcel on the southern 6.3 acres to ensure no net loss of housing potential while retaining agricultural use on the northern 4 acres and while considering the other development guidance contained in this action. ▪ The environmental review process shall guide the location and intensity of all uses. The height, scale, and bulk of development shall take into consideration the rural transition at the city’s edge.
▪ Neighborhood Commercial and Office land uses shall be at least 10 percent but no more than 20 percent of the total net developable area. ▪ The extent of open space buffers/setbacks to wetland areas on and adjoining the site will ultimately be determined by the California Coastal Commission.
Based upon the Coastal Commission’s buffer/setback determination, Wetland setbacks and buffer areas shall be determined by a biological report consistent with the City-Wide Creeks and Wetlands Management Plan, and based upon the buffer/setback determination, neighborhood park land shall be considered on the site.
▪ The specific plan shall prioritize away from the pond, Aany required uncovered off-street parking for residential uses shall be prioritized away from the pond.
Except for parking for the disabled, off-street uncovered parking and driveways near Antonelli Pond and residential uses is discouraged. ▪ The site design circulation system of the specific plan shall provide access from Shaffer Road.
▪ Public access to Antonelli Pond shall be preserved.
• Amend the description of the AG land use designation description as follows:
Agriculture/Grazing (AG), 0.5 du/ac. Applies to grazing land on the western edge of the city. The AG designation is generally applied only to areas that are used predominantly for large-scale agriculture or grazing. It is not typically applied to community gardens or other small-scale agricultural uses unless the site is intended to remain in long-term agricultural use.
• Amend the General Plan Land Use Map land use designation for the northern 4 acres of the parcel at 2394 Delaware Avenue (“Swenson parcel”) to Agriculture/Grazing (AG); see Figure
3. 1 The General Plan 2030 references the site as being 11 acres, but site-specific surveys indicate the parcel is 10.3 acres in size.
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• Amend the General Plan Land Use Map land use designation for the southern 6.3 acres of the parcel at 2394 Delaware Avenue (“Swenson parcel”) to Low Medium Density Residential (LM) as shown on Figure 3. This action partially implements General Plan Action LU1.1.4, which is identified in the Implementation chapter of the General Plan 2030 as being implemented within a short-term framework.
Zone District Amendments. The proposed project also includes a Zoning Map amendment to change the northern 4 acres of the project site to the Exclusive Agriculture (E-A) District and the southern portion of the project site to the Multiple-Residence – Low Density District (R-L) District from the existing Single Family Residence (R-1-5) District. The existing Coastal Zone (CZ) Overlay District would remain. The proposed Zoning Map amendments would provide zoning consistent with the proposed General Plan Land Use Map designations.
LCP Certification. The project also includes obtaining LCP certification of the northern 4 acres of the property with the proposed General Plan land use and zone district designations. With the approval of the project amendments, the City Council would direct staff to submit the request for certification to the California Coastal Commission (CCC) for this area.
III. E N V I R O N M E N T A L S E T T I N G
The City of Santa Cruz is located along the northern shore of Monterey Bay, approximately 75 miles south of San Francisco, 25 miles south of San Jose and 40 miles north of Monterey. The City is bordered by parks, open space, and residential uses to the north, open space lands on the west, the Monterey Bay on the south, and a portion of the unincorporated urban community of Live Oak on the east. The City’s western and northern borders are mostly defined by publicly- and privatelyowned open space, agricultural, and park lands.
The approximate 10.3-acre Swenson parcel is located on the west side of the City of Santa Cruz north of Delaware Avenue and Natural Bridges State Park. The property is located west of Antonelli Pond (see Figure 1). Access to the site is currently provided via Shaffer Road from Delaware Avenue.
The project site is located in an area with a mix of uses, including residential uses to the south, the University of California Santa Cruz (UCSC) Coastal Sciences Campus to the west, railroad tracks and the Pacific Shore Apartments to the north, and Antonelli Pond and a UCSC Administration Building to the east. Antonelli Pond, a 6.4-acre, human-constructed pond, is fed by Moore Creek that flows into the pond from the north. The pond is on a 13-acre parcel is owned and managed by the Land Trust of Santa Cruz County for public access, and numerous trails exist on the property.
The project site was historically in row crop agriculture production. The project site is currently undeveloped, except the northern approximately 3.5 acres of the site have been used by the Homeless Garden Project for organic farming since 1995. A variety of produce and flower crops are grown that are sold at an on-site produce stand, available for customers to pick, and distributed to a Community Supported Agricultural (CSA) system during part of the year (Per Santa Cruz Homeless Garden Project website at: https://homelessgardenproject.org/).
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F I G U R E 3 : P ro p o s e d D e s i g n a t i o n s
PROPOSED GENERAL PLAN DESIGNATION: AGRICULTURE / GRAZING PROPOSED ZONE DISTRICT: E-A – EXCLUSIVE AGRICULTURE
GENERAL PLAN DESIGNATION PER LU1.1.4: LOW MEDIUM DENSITY RESIDENTIAL /
NEIGHBORHOOD COMMERCIAL / OFFICE
PROPOSED GENERAL PLAN DESIGNATION: LOW MEDIUM DENSITY RESIDENTIAL PROPOSED ZONING: R-L – MULTIPLE RESIDENCE-LOW DENSITY
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I V . U S E O F A N A D D E N D U M
Pursuant to Section 15164 of the State CEQA Guidelines, an addendum to a certified EIR may be prepared if only minor technical changes or additions are necessary and none of the conditions described in State CEQA Guidelines Section 15162 that call for preparation of a subsequent EIR have occurred. Under State CEQA Guidelines Section 15162, no subsequent EIR would need to be prepared unless the lead agency determines, on the basis of substantial evidence, one or more of the following:
• Substantial changes are proposed in the project which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; • Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
• New information of substantial importance, which was not known and could not have been known at the time the previous EIR was prepared, shows any of the following:
▪ The project will have one or more significant effects not discussed in the previous EIR; ▪ Significant effects previously discussed will be substantially more severe than shown in the previous EIR;
▪ Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measures or alternatives; or
▪ Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation or alternative.
Project Review
The proposed project consists of General Plan and Zone Map district amendments. The proposed General Plan amendments include both amendments to the General Plan text and Land Use Map.
The proposed text revisions to General Plan Action LU1.1.4 would eliminate the requirement for a Specific Plan for the property; allow agricultural uses on the northern portion of the site; add language to implement general plan or zoning changes to cluster residential development on the southern portion of the site; and revise language for determination of wetland buffers, siting parking away from Antonelli Pond, and site access. City staff determined that a specific plan is not required for future development given the size of the parcel and availability of public service infrastructure. The change of land use designation to AG on the northern portion of the site is addressed below. The other text revisions represent minor clarifications to the text to clarify text or provide consistency with other City plans. The General Plan amendments also include minor
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revisions to AG land use designation to clarify the applicability of this designation as identified above.
As indicated above, General Plan Action LU1.1.4 calls for obtaining LCP certification for the site with a land use designation of Low Medium Density Residential/Neighborhood Commercial/Office and provides development standards. The Implementation Chapter of the General Plan 2030 shows implementation of Action LU1.1.4 in a short-term timeframe. The project would result in partial implementation of this action with designation of the southern 6.3 acres of the site as Low Medium Density Residential in the General Plan with a Zoning Map amendment to include this portion of the site in the RL zone district, consistent with the General Plan Land Use Map change. This area would continue to be planned for mixed residential-office-neighborhood commercial uses as set forth in the General Plan 2030 Action LU1.1.4. No development is proposed at this time. However, future development of this area would be subject to inclusion of the site in the LCP through approval by the CCC and also would be subject to the development requirements set forth in Action LU1.1.4, as revised with the proposed amendments, including provision of neighborhood commercial and office uses as specified in the Action, as well as subject to other applicable General Plan and LCP policies and implementing regulations.
The project proposes that the General Plan land use designation for the northern 4 acres of the project site be changed to AG with a zone district of E-A. The proposed land use changes reflect historic agricultural uses of the property, and the current use of this area for organic farming by the Homeless Garden Project. The re-designation of the northern portion of the “Swenson parcel” to an agricultural designation would not result in future mixed residential-neighborhood commercialoffice development that was envisioned for the entire parcel as set forth in Action LU1.1.4 of the General Plan 2030. With the proposed amendments, it is expected that agricultural uses undertaken by the Homeless Garden Project would continue, and there would be no development of that portion of the site, except for potential future accessory agricultural-related structures to support the agricultural activities on the site, although none are proposed at this time. Under provisions of the proposed E-A zone district, potential structural development allowed as principally permitted uses within the coastal zone, include: ranch and farm dwellings incidental to a principal agricultural use; stables, barns, silos, and windmills, but would not include other types of “accessory” structures permitted outside the coastal zone.
The project before the City also includes partially implementing General Plan Action LU1.1.4 by designating the remaining 6.3 acres of the “Swenson parcel” as Low Medium Density Residential as directed in the action with a rezoning to RL, consistent with the General Plan Land Use Map change.
This area would continue to be planned for mixed residential-office-neighborhood commercial uses as set forth in the General Plan 2030 Action LU1.1.4. As indicated above, this is consistent with General Plan Implementation Chapter that called for Implementation Action LU1.1.4, but within an earlier timeframe. No development is proposed at this time.
As previously indicated, the General Plan 2030 EIR is a “program” EIR, which reviewed environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. The EIR specifically addressed and evaluated the Land Use Map change for the “Swenson parcel” to Low Medium Density Residential/Neighborhood Commercial/Office and impacts of potential future development as a
24.38 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 10 A p r i l 2025
result of this change. The proposed amendments would not increase the number of residential units or non-residential uses that could be constructed on the Swenson parcel from what was evaluated in the EIR, but the area available for development would be reduced from 10.3 to 6.3 acres with designation of 4 northern acres to agricultural uses, although the proposed revisions to Action LU1.1.4 calls for clustered residential development to “ensure no net loss of housing potential”2 while retaining agricultural use on the northern portion of the site.
Under the proposed amendments, 4 acres of the site would be re-designated for agricultural use, a change from what was considered in the General Plan 2030 EIR, which is consistent with current use of the site and historic uses of the property. While the City is now proposing partial implementation of Action LU1.1.4 by making the General Plan land use designation change to LM for the remainder of the project site, potential impacts resulting from this re-designation were already evaluated for the entire site in the certified General Plan 2030 EIR and do not represent a new change to the General Plan 2030. While this part of the proposed amendments (with the corresponding Zoning Map change to RL) is part of the project under consideration by the City, it is not subject to further CEQA review as development of the site with land uses allowed under the LM designation was analyzed in the certified General Plan 2030 EIR, so the review in this Addendum is focused on the General Plan text amendments and change to agricultural uses for the northern 4 acres.
Conclusion
The proposed amendments would reduce the area of potential residential, neighborhood commercial and office development by approximately 4 acres from what was evaluated in the General Plan 2030 EIR; no development is currently proposed. The proposed General Plan text revisions to General Plan Action LU1.1.4 and the agricultural land use designation text represent minor changes to provide clarification, but do not change the requirements for future development of the “Swenson parcel” on the portion of the site that remains designated for residential, neighborhood commercial and office uses, and do not change the types of agricultural uses envisioned in the General Plan with minor revisions to the AG land use designation. Completion of the following checklist has led to the conclusion that the approval of the proposed amendments would not result in new potentially significant impacts or substantially more severe significant impacts than those already identified in the 2012 certified EIR for the General Plan 2030. Similarly, there are no substantial changes with respect to the circumstances under which the project is undertaken or new information of substantial importance that would result in new significant impacts or a substantial increase in the significance of previously identified impacts as summarized below.
2 State law (Government Code Section 66300(b)(1) includes a no net loss requirement that prohibits local government from downzoning a property with few exceptions, one being where the loss in housing potential is offset by upzoning another site at the same time. The proposal achieves no net loss using two approaches that would each meet this requirement independently: first, by upzoning the southern portion of the site and amending policy LU 1.1.4 to ensure that future housing potential for the entire site is clustered on the southern portion of the site; second, by concurrently upzoning properties in the downtown area south of Laurel Street as part of the Downtown Plan Expansion (under separate environmental review).
24.39 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 11 A p r i l 2025
Based on the level of previous environmental review and the scope of the proposed revisions to existing regulations, the City has determined that the project changes are minor and no substantial changes in the project or relevant environmental conditions have occurred since certification of the General Plan 2030 EIR on June 26, 2012. Thus, the City has determined that an Addendum to the General Plan 2030 EIR is the appropriate environmental review document for the proposed project modifications, in accordance with CEQA Guidelines section 15164.
V . E N V I R O N M E N T A L R E V I E W
Organization of Section
The purpose of the checklist presented on the following pages is to evaluate the impact categories in terms of any “changed condition” (i.e., changed circumstances, project changes, or new information of substantial importance) that may result in a changed environmental result. A “no” answer does not necessarily mean that there are no potential impacts relative to the environmental category, but that there is no change in the condition or status of the impact since it was analyzed and addressed with mitigations in prior environmental documents. • Where Impact Was Analyzed. This column provides a cross-reference to the pages of the prior environmental documents where information and analysis may be found relative to the environmental issue listed under each topic.
• Do Proposed Changes Involve New Significant Impacts? Pursuant to Section 15162(a)(1) of the State CEQA Guidelines, this column indicates whether the changes represented by the current project will result in new significant impacts that have not already been considered and mitigated by the prior environmental review or whether the new information or changes will substantially increase the severity of significant impacts that have not already been considered and mitigated by the prior environmental review. • Any New Circumstances Involving New Impacts? Pursuant to Section 15162(a)(2) of the CEQA Guidelines, this column indicates whether there have been changes in circumstances under which the project is undertaken, which have occurred subsequent to the prior environmental documents, which would result in the current project having new significant environmental impacts that were not considered in the prior environmental documents or that substantially increase the severity of a previously identified impact. • Any New Information Requiring New Analysis or Verification? Pursuant to Section 15162(a)(3)(A-D) of the CEQA Guidelines, this column indicates whether new information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time the previous environmental documents were certified as complete is available, requiring an update to the analysis of the previous environmental documents to verify that the environmental conclusions and mitigations remain valid. If the new information shows that: (A) the project will have one or more significant effects not discussed in the prior environmental documents; or (B) that significant effects previously examined will be substantially more severe than shown in the prior environmental documents; or (C) that mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the
24.40 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 12 A p r i l 2025
mitigation measure or alternative; or (D) that mitigation measures or alternatives which are considerably different from those analyzed in the prior environmental documents would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative, than the question would be answered ‘Yes,’ requiring the preparation of a subsequent or supplemental EIR.
However, if the additional analysis completed as part of this environmental review finds that the conclusions of the prior environmental documents remain the same and no new significant impacts are identified, or identified environmental impacts are not found to be more severe, or additional mitigation is not necessary, than the question would be answered ‘No’ and no additional environmental documentation (supplemental or subsequent EIR) is required.
• Mitigations Implemented or Address Impacts. Pursuant to Section 15162(a)(3) of the CEQA Guidelines, this column indicates whether the prior environmental documents provide mitigations to address effects in the related impact category. In some cases, the mitigations have already been implemented. A “yes” response will be provided in either instance. If “NA” is indicated, this Environmental Review concludes that the impact does not occur with this project and therefore no mitigations are needed.
• Discussion. A discussion of the elements of the checklist is provided under each environmental category in order to clarify the answers. The discussion provides information about the particular environmental issue, how the project relates to the issue and the status of any mitigation that may be required or that has already been implemented. • Mitigation Measures. Applicable mitigation measures from the prior environmental review that apply to the project are listed under each environmental category. • Conclusions. A discussion of the conclusion relating to the analysis contained in each section.
24.41 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 13 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
1. Aesthetics. Would the project:
a) Have a substantial adverse effect on a scenic
vista?
DEIR, pg 4.3-2 to 4.3-7; 4.3-13 to
4.3-14; 4.3-15
FEIR, pg 3-2
No No No No
b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
DEIR, pg 4.3-14 to 4.3-17
No No No No
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views
of the site and its surroundings? (Public views are
those that are experienced from publicly
accessible vantage point). If the project is in an
urbanized area, would the project conflict with
applicable zoning and other regulations
governing scenic quality?
DEIR, pg 4.3-7 to 4.3-8; 4.3-15 to
4.3-19
FEIR pg 3-2
No No No
Design Permit
May Be
Required
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime
views in the area?
DEIR, pg 4.3-19 to 4.3-20
No No No Design Permit
May Be required
Discussion: (a-b) The General Plan 2030 EIR indicates that prominent scenic views are those that are oriented toward Monterey Bay and the Pacific Ocean or toward the Santa Cruz Mountains that frame the northern boundary of the City. The EIR identified less-than-significant impacts related to scenic views and scenic resources. The EIR concluded that most of the anticipated new development occurring as a result of implementation of the General Plan 2030 would be infill development that would not be located within panoramic scenic public viewsheds. There are no designated state scenic highways or roads within the City.
The project site is located near the western edge of the City, north of Delaware Avenue and approximately one-quarter mile south of Highway 1. The site is located north of Natural Bridges State Park and west of Antonelli Pond. Views across the project parcel from Delaware Avenue consist of views of the undeveloped project site, and background views of existing multi-family residential development along Shaffer Road with a backdrop of a portion of a vegetated sloping hillside and residences above Highway 1.
According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, there are no identified panoramic views that include the project site (SOURCE V.1b-DEIR Figure 4.3 1). However, the General Plan EIR reported that future development on the site would be partially within scenic views of the Monterey Bay as seen from the lower portions of the Moore Creek Preserve and Wilder Ranch State Park to the north, although
24.42 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 14 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
existing, intervening tree cover partially screens the project site from these public views. The EIR also concluded that future development on the Swenson parcel would not be expected to be of the height or mass that would obstruct or block ocean views from these vantage points, and that General Plan Action LU1.1.4 sets forth specific development guidelines/parameters for the “Swenson parcel,” which indicates that the “height, scale, and bulk of development shall take into consideration the rural transition at the City’s edge.” The proposed project includes minor revisions to General Plan Action LU1.1.4, but does not change the development standards contained in the action to take height, scale and bulk of development into consideration as part of future development that may be proposed on the 6.3 acres of the project site that would remain available for future development and as evaluated in the General Plan 2030 EIR. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in development that would affect scenic views or resources. Under provisions of the proposed E-A zone district, potential structural development allowed as principal permitted uses, include: ranch and farm dwellings incidental to a principal agricultural use; stables, barns, silos, and windmills. Permitted building heights in the E-A zone district are 3 stories feet. Even if future permitted agricultural structures were to reach 50 feet, such development would not block or obstruct scenic views identified in the General Plan EIR given limited area of development and distance from the viewpoints. Therefore, the proposed General Plan revisions would not directly or indirectly lead to development, would not result in significant impacts to scenic views or scenic resources, and would not be located near a state scenic highway. (c) The General Plan 2030 EIR identified less-than-significant impacts regarding potential degradation of the visual character of an area. The proposed agricultural designations would not result in new development, except for potential ancillary structures associated with agricultural uses. According to the State CEQA Guidelines, potential substantial degradation of visual character is based on conflicts with applicable zoning and other regulations governing scenic quality in urbanized areas. The City of Santa Cruz is an “urbanized area” under the definition of the term in CEQA Guidelines section 15387. Therefore, the City need not specifically consider existing visual character or the quality of the existing views and the project’s potential effect on them. Scenic views require consideration as part of approval of a coastal development permit as set forth in Municipal Code section 24.08.250, and future development in the northern portion of the project site would be subject to approval of coastal development permit by the City once the area is included as part of the City’s LCP through CCC approval. Protection of the ocean or of scenic coastal areas also is a required finding for a Design Permit pursuant to Municipal Code section 24.08.430.
It is not expected that development would occur as a result of the proposed project, except for ancillary, agriculturally-related structures, which would not affect ocean or scenic coastal views because the property subject to the amendments is not located in proximity to the coast and is not visible from the coast. Similarly, potential future development would not affect distant mountain views that have been identified in the General Plan 2030 EIR as being scenic views. Therefore, the project does not conflict with applicable zoning and other regulations governing scenic quality.
24.43 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 15 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
(d) The General Plan EIR concluded that residential development likely would include exterior lighting that is typical of a residential neighborhood in an urbanized setting, but with implementation of General Plan and zoning requirements, the EIR concluded that the impact would be less than significant.
The proposed project would not lead to new development, except for potential ancillary agricultural structures as discussed above, which would not contain any design elements or features that would result in the introduction of a substantial new source of light or glare not otherwise considered in the General Plan EIR.
Mitigation Measures: None were identified in the EIR. None are required with the proposed project as a significant impact has not been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR related to scenic views, scenic resources, potential degradation of the visual character of surrounding areas, and/or creation of a source of substantial light or glare.
2. Agriculture. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to nonagricultural use? DEIR, pg 4.15-3, 4.15-6 to 4.15-8
No No No NA
b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract?
DEIR, pg 4.15-3; 4.15-6 to 4.15-8
No No No NA
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland (as
defined by Public Resources Code section 4526),
or timberland zoned Timberland Production (as
defined by Government Code section 51104(g))?
DEIR, pg 4.15-3; 4.15-5 to 4.15-6
No No No NA
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
DEIR, pg 4.15-3; 4.15-5
No No No NA
e) Involve other changes in the existing environment
which, due to their location or nature, could
DEIR, pg 4.15-3; 4.15-5 to 4.15-8
No No No NA
24.44 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 16 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
result in conversion of Farmland, to nonagricultural use or conversion of forest land to non-forest use?
Discussion: The General Plan 2030 EIR concluded that impacts to agricultural and forest resources would not occur or would be less-than-significant as a result of future development accommodated by the General Plan as these resources are not present within City limits. There are no designated agricultural lands as part of the State Farmland Mapping and Monitoring Program or timberland preserve lands within the City, and areas of mixed evergreen, redwood forest and oak woodlands within the City are located primarily within the City-owned and managed open space greenbelt lands.
The project site is not designated as farmland in the State Farmland Mapping and Monitoring Program; the site is designated “Other Land” (California Department of Conservation). The proposed amendments would not directly or indirectly lead to development on forest lands as none exist on, adjacent to or within proximity to the project site. As indicated in Section II, the project site has a history of agricultural production in the past; at the time of purchase in the 1960s by the current owners and family, the site was intensively farmed in row crop agriculture (brussels sprouts). The proposed amendments would designate 4 acres for agricultural use on a portion of the site that is currently being used for organic farming by the Homeless Garden Project. Therefore, the proposed project would have no effect on forest resources and would not lead to conversion of agricultural uses, but would result in continued support of existing agricultural uses that exist on the project site.
Mitigation Measures: None were identified in the EIR and none are required with the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR related to agricultural or forest resources.
3. Air Quality. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
DEIR pg 4.11-11 to 4.11-12; 4.11-
15 to 4.11-18; FEIR pg 3-24 No No No
General Plan EIR
Mitigation
Measure 4.11-1
b) Result in a cumulatively considerable net increase
of any criteria pollutant for which the project
region is non-attainment under an applicable
federal or state ambient air quality standard?
DEIR pg 4.11-6 to 4.11-10; 4.11-18
to 4.11-24
FEIR pg 3-24 to 3-26
No No No No
c) Expose sensitive receptors to substantial
pollutant concentrations?
DEIR pg 4.11-7 to 4.11-8; 4.11-10
to 4.11-11; 4.11-18; 4.11-24 to
4.11-26
No No No No
24.45 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 17 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial
number of people?
DEIR pg 4.11-26 to 4.11-27
No No No No
Discussion: (a) The General Plan 2030 EIR concluded that future development accommodated by the General Plan could result in population increases that exceed Air Quality Management Plan (AQMP) projections for which one mitigation measure was included that calls for the City to work with AMBAG to ensure that population projections reflect City growth. Subsequent to the City’s certification of the General Plan EIR and adoption of the General Plan 2030, AMBAG updated its population and housing projections twice, which now go to the year 2040. The current AMBAG-adopted regional growth projections forecast a slightly higher population for the year 2030 than identified in the General Plan EIR. The proposed project includes minor revisions to General Plan Action LU1.1.4, but does not change the development standards contained in the action for future development that may be proposed on the 6.3 acres of the project site that would remain available for future development and as evaluated in the General Plan 2030 EIR. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in residential development. Thus, the proposed project would not conflict with or obstruct implementation of the AQMP, and would not result in a substantially more severe significant impact than evaluated in the General Plan EIR.
(b-c) The project site is located within the North Central Coast Air Basin (NCCAB), which is under the jurisdiction of the Monterey Bay Air Resources District (MBARD). The NCCAB is designated attainment for the federal PM10 and SO2 standards, and is designated attainment/unclassified for the other federal standards. The NCCAB is designated attainment for the state PM2.5, NO2, SO2, and lead standards, and is designated unclassified for CO in Santa Cruz County. The NCCAB has nonattainment designations for state O3 and PM10 standards.
The General Plan EIR concluded that future development could result in air emissions, but overall future emissions of ozone precursor pollutants were projected to decrease or remain nearly unchanged over the next 20 years after its certification. General Plan Actions LU21.2.1 and HZ2.2.1 (as modified by the General Plan EIR), require future project-level review and implementation of mitigation measures if warranted, consistent with the adopted standards in the MBARD’s CEQA Guidelines. The General Plan 2030 EIR indicated that future development accommodated by the Plan could result in air pollutant emissions, but overall future emissions of ozone precursor pollutants are projected to decrease or remain nearly unchanged over the next 20 years, and thus, project-level emissions would not contribute to existing or potential future violations of air quality standards. The General Plan EIR further concluded that, while PM10 emissions would increase, review for compliance with MBARD significance criteria at a project level would ensure that emissions would not exceed daily standards. The General Plan EIR concluded that contributions to air emissions as a result of development accommodated by the General Plan would be less than significant.
The proposed amendments would not lead to residential, commercial or office development or indirectly result in air emissions associated with
24.46 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 18 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
development that was not already evaluated in the General Plan 2030 EIR, but would reduce the area available for future development. Agricultural uses on the portion of the project site proposed for agricultural Land Use Map and Zoning Map amendments would generate limited daily vehicular traffic and would not result in stationary sources of emissions. While routine preparation of fields for cultivation could result in potential dust and PM10 emissions, such activities would not result in grading or excavation. According to MBARD’s CEQA Air Quality Guidelines (2008), construction activity on
8.1 acres per day with minimal earthmoving or 2.2 acres per day with grading and excavation are assumed to be below the MBARD’s PM10 significance threshold of 82 pounds per day. The area of proposed development is approximately 4 acres in size and is below this level. Thus, the project would not directly or indirectly result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment. (d) Given the type of land uses envisioned in the General Plan, the General Plan EIR concluded that implementation of the General Plan and future development would not result in introduction of new sources of substantial odors. No significant impacts were identified regarding exposure of sensitive receptors to substantial pollutant concentrations. According to the Air District’s CEQA Guidelines, land uses associated with odor complaints typically include landfills, agricultural uses, wastewater treatment plants, food processing plants, chemical plants, and refineries. While existing and future agricultural uses of the northern portion of the project site could result in intermittent generation of odors, there are no sensitive receptors, i.e., residences immediately adjacent to the area with proposed General Plan and zoning agricultural land use designation amendments. Potential future residential development on the southern portion of the project site would be subject to General Plan policies and may be required to provide a buffer to the adjacent agricultural use pursuant to General Plan Action CD1.4.3, which requires an appropriate buffer to commercial agricultural fields, where appropriate.
Mitigation Measures: Mitigation Measure 4.11-1 is not applicable to the proposed project because the project would not result in conflicts with the AQMP and would not result in a new significant impact. No new mitigation measures are required as no significant impacts have been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to air quality.
4. Biological Resources. Would the project:
a) Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or special
status species in local or regional plans, policies,
or regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
DEIR pg 4.8-13 to 14; 4.8-16 to 4.8-
21; 4.8-41; 4.8-43 to 4.8-44; 4.8-
48 to 4.8-51
FEIR pg 3-23, 3-25 to 3-40
No No No No
24.47 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 19 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
DEIR pg 4.8-9 to 4.8-10;4.8-12; 4.8-
14 to 4.8-15; 4.8-22; 4.8-24; 4.8-26
to 4.8-30; 4.8-22; pg 4.8-38 to 4.8-
41; 4.8-48 to 4.8-51
FEIR pg 3-23
No No No No
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?
DEIR pg 4.8-7 to 4.8-9; 4.8-15; 4.8-
41; 4.8-38 to 4.8-39; 4.8-41; 4.8-48
to 4.8-51 No No No No
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use of
native wildlife nursery sites?
DEIR pg 4.8-22 to 4.8-25; 4.8-41;
pg 4.8-44 to 4.8.45
No No No No
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
DEIR pg 4.8-41; pg 4.8-45 to 4.8.47
No No No No
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
DEIR pg 4.5-11 to 4.5-12; 4.8-25 to
4.8-26; 4.8-37
FEIR pg 3-23
No No No No
Discussion: (a-f) The City of Santa Cruz is primarily developed, but supports special status species and sensitive habitat areas, mostly within the Cityowned and managed greenbelt and open space areas and along creeks and watercourses. According to the General Plan 2030 EIR, a number of special status plant and wildlife species are found within the City, typically in managed greenbelt and open space areas. Sensitive habitat areas include riparian areas, wetlands and native grassland areas. The City adopted a Citywide Creeks and Wetlands Management Plan that identifies major resources and provides required development setbacks, standards and guidelines. There are no Habitat Conservation Plans (HCPs) or Natural Community Conservation Plans that are applicable to the proposed project. The HCP for City maintenance activities or projects that may affect a federally-listed species was described in the General Plan 2030 EIR, and the HCP for operation and maintenance of City facilities was issued in 2021. However, this HCP does not pertain to the proposed project as the project does not involve maintenance and operation of City facilities and operational and maintenance activities specified in the HCP.
24.48 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 20 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
The General Plan 2030 EIR identified less-than-significant impacts related to biological resources. The EIR concluded that with implementation of General Plan policies and actions related to new development, future development accommodated by the General Plan would not result in significant impacts to biological resources as most development areas are infill areas that are not located within or adjacent to sensitive habitats or areas with biological resources. The General Plan EIR provides protocols for project-level biological assessments to protect sensitive resources as set forth in General Plan policies and actions. Furthermore, future site-specific development would be subject to site-specific environmental review, including review for consistency with City resource management plans, which include the City-wide Creeks and Wetlands Management Plan and San Lorenzo Urban River Plan, as well as compliance with Zoning Ordinance environmental regulations contained in Chapter 24.14 of the Santa Cruz Municipal Code and heritage tree requirements.
According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is identified as have having annual grassland/potential coastal prairie habitat, which is considered a sensitive habitat (SOURCE V.1b-DEIR Figure 4.8-3). The project site is located west of Antonelli that is identified in the City’s General Plan as supporting sensitive wetland and riparian habitats (SOURCE V.1b-DEIR Figure 4.8-3). The General Plan 2030 EIR identified these potential resources that may be affected by future development of the Swenson parcel, however, concluded that General Plan Action LU1.1.4 sets forth specific development/design directives for the Swenson parcel, which include: wetland buffers, locating parking away from Antonelli Pond and preserving public access to Antonelli Pond that would serve to avoid or minimize potential impacts. The EIR also indicates that as part of the CEQA review process, future development projects will be required to evaluate and mitigate potential impacts to sensitive habitat (including special-status species) for sites located within or adjacent to these areas (NRC2.2.1). Furthermore, the proposed General Plan 2030 includes a table that identifies habitat assessment and management protocols for sensitive habitat areas, including the type of reviews/studies that will be required along with potential mitigation and/or management. In addition, compliance with Section 24.14.080 of the City’s Municipal Code includes provisions to protect wildlife habitat and protected species for areas specified in the City’s existing General Plan.
The proposed project includes minor revisions to General Plan Action LU1.1.4 that would require wetland setbacks to be determined by a biological report and consistent with the City-wide Creeks and Wetlands Management Plan instead of being determined by the CCC as part of future development that may be proposed on the 6.3 acres of the project site that would remain available for future development and as evaluated in the General Plan 2030 EIR. The proposed text revisions also continue to require that future parking areas be sited away from Antonelli Pond.
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site would not result in new development, except for potential future agriculturally-related structures. Under provisions of the proposed E-A zone district, potential structural development allowed as principal permitted uses, include: ranch and farm dwellings incidental to a principal agricultural use, stables, barns, silos, and windmills. Future development would be subject to review and approval of a coastal development permit that would be subject to CEQA, at which time site-specific studies would be required to determine whether or not impacts to special status species or sensitive habitat
24.49 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 21 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
would occur in accordance with General Plan biological resource survey protocols, and if so develop appropriate measures to avoid or minimize impacts as established in the protocols. Requirements for wetland protection and buffers also would be provided at this time based on results a biological report. The agricultural designations would allow for agricultural uses and maintenance of this portion of the project site in open space, except for potential future structures to support the agricultural operations. Thus, the proposed amendments and potential future development of agriculturallyrelated structures would not interfere with wildlife movement.
Mitigation Measures: None were identified in the EIR, and none are required with the proposed project as a significant impact has not been identified.
The General Plan and EIR provide project-level assessment protocols to protect biological resources.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding biological resources.
5. Cultural Resources. Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource as defined in
§15064.5?
DEIR pg 4.9-12 to 4.9-1; 4.9-15;
4.9-21; 4.9-23 to 4.9-24
FEIR pg 3-24
No No No None
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?
DEIR pg 4.9-10 to 4.9-12; 4.9-19 to
4.9-23
No No No
General Plan EIR
Mitigation
Measure 4.9-1
and Municipal
Code section
24.12.430
c) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
DEIR pg 4.9-14 to 4.9-16; 4.9-21;
4.9-24 to 4.9-25 No No No
General Plan EIR
Mitigation
Measure 4.9-2
d) Disturb any human remains, including those
interred outside of formal cemeteries?
DEIR pg 4.9-10 to 4.9-12; 4.9-19 to
4.9-23
No No No
General Plan EIR
Mitigation
Measure 4.9-1
and Municipal
Code section
24.12.430
24.50 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 22 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Discussion: (a-d) The General Plan 2030 EIR identified less-than-significant impacts related to historical resources. The EIR concluded that future development accommodated by the General Plan would not result in potential impacts to archaeological resources with implementation of EIR Mitigation Measures 4.9-1 and 4.9-2, which includes General Plan Actions (HA1.2.2 and HA1.2.3) that were subsequently added to the General Plan. The action sets forth the process for preparation of archaeological investigations and project-level significance determinations and mitigations for development projects located within sensitive archaeological areas. Furthermore, Section 24.12.430 of the City’s Municipal Code sets forth the procedure to follow in the event that prehistoric or cultural features are discovered during the monitoring or accidentally discovered during construction. Under provisions of this Code section, work shall be halted within 100 feet of the find and the Planning Director shall be immediately notified to determine the appropriate course of action, including implementation of potential mitigation measures. Additionally, the County Coroner shall be notified in accordance with provisions of Public Resources Code 5097.98-99 in the event human remains are found and the Native American Heritage Commission shall be notified in accordance with the provisions of Public Resources Code section 5097 if the remains are determined to be Native American.
According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR and updated in 2018, the project site is located within an area that is sensitive for archaeological resources, and where an exemption may apply (SOURCE V.1c). An archaeological report would be required as part of any future development proposal, such as future structures to support agricultural operations. However, the project site is located within an area that City maps indicate an exemption to this requirement may apply. Exempt projects are projects with low potential to impact a cultural resource, such as: spot excavation less than 12 inches deep; other small projects, such a minor building additions, deck construction; or excavation in soil documented as previously disturbed. The decision classify a project “exempt” is determined by the Planning Department on a case-by-case basis.
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site would not result in development, except for potential future agriculturally-related structures. However, future development would be subject to review and approval of a coastal development permit that would be subject to CEQA, at which time the appropriate level of review of cultural resources would be undertaken as required by the General Plan 2030 and as evaluated in the General Plan 2030 EIR.
Mitigation Measures: Mitigation Measures 4.9-1 and 4.9-2 of the General Plan EIR are intended to establish procedures for archaeological investigations. Adherence to these procedures would be required during construction of future development on the site as described above. No new mitigation measures are required as no significant impacts have been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-than24.51
C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 23 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
significant impacts identified and analyzed in the certified General Plan EIR regarding cultural resources.
6. Energy. Would the project:
a) Result in a potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?
DEIR pp. 4.6-27 to 4.6-29, 4.6-45 to
4.6-46, 5-4 to 5-6
No No No NA
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency? No No No NA
Discussion: (a-b) Subsequent to certification of the General Plan EIR, the CEQA Guidelines were updated in December 2018 to include a separate section related to wasteful or inefficient energy use in Appendix G. The General Plan EIR reviewed energy use associated with development accommodated by the General Plan. The estimated energy demand was found to be within state per capita projections for the planning area, and the EIR concluded that overall, the future consumption of electrical and natural gas resources would not represent unnecessary, inefficient, or wasteful use of resources given the implementation of policies that address lighting and energy conservation measures.
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future development allowed under the proposed amendments, would not result in wasteful or inefficient energy consumption or conflicts with plans for renewable energy or energy efficiency as structures would be limited in use to agriculturally-related facilities. Therefore, the proposed project would not result in new significant impacts or substantially more severe impacts related to energy.
Mitigation Measures: None were identified in the EIR. No mitigation measures are required with the proposed project as no significant impacts have been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the General Plan EIR regarding energy.
24.52 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 24 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
7. Geology and Soils. Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving::
i. Rupture of a known earthquake fault, as
delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the
area or based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including
liquefaction?
iv. Landslides?
DEIR pg 4.10-6 to 4.10-14; 4.10-21
to 4.10-23
No No No
California
Building Code
Seismic Design
Criteria
b) Result in substantial soil erosion or the loss of
topsoil?
DEIR pg 4.10-16 to 4.10-19; 4.10-
25 to 4.10-26
No No No
City Municipal
Code section
24.16.060 and
Chapter 18.45
regarding
grading and
erosion control
plans
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in onor off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
DEIR pg 4.10-5 to 4.10-6; 4.10-15
to 4.10-16; 4.10-23 to 4.10-24
No No No
California
Building Code,
City Municipal
Code section
24.14.070 & GP
Actions HZ6.2.1
& HZ6.3.6
24.53 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 25 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
d) Be located on expansive soil, as defined in Table
18- 1-B of the Uniform Building Code (1994),
creating substantial risks to life or property?
DEIR pg 4.10-16 to 4.10-17; 4.10-
19; 4.10-24 to 4.10-25
No No No No
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative waste water
disposal systems where sewers are not available
for the disposal of waste water?
DEIR pg 4.10-16 to 4.10-17; 4.10-
19; 4.10-24 to 4.10-25 No No No No
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
DEIR pg 4.9-14 to 4.9-16; 4.9-21;
4.9-24 to 4.9-25 No No No GP EIR
Mitigation 4.9-2
Discussion: (a-d) There are no active fault zones or risk of fault rupture within the City (City of Santa Cruz, 2012-DEIR volume). The General Plan 2030 EIR identified less-than-significant impacts related to geology and soils. The EIR concluded that new development accommodated by the General Plan would be subjected to seismic and/or geologic hazards, including seismic shaking and liquefaction. Non-seismically induced hazards include slope instability, cliff retreat, and non-seismic settlement and landslides. However, with implementation of the General Plan 2030 policies and actions (including requirements for preparation of geotechnical reports when required) and adherence to Building Code and local regulations, the EIR concluded that future buildings would be designed to minimize damages and reduce exposure of people or structures to significant risks associated with seismic hazards, resulting in a less-than-significant impact. The General Plan 2030 EIR also concluded that future development accommodated by the General Plan could result in exposure of people and property to potential hazards associated with landslides, slope stability, and/or coastal bluff retreat, which was identified as a less-than-significant impact with adherence to City regulations and General Plan goals, policies and actions, which would prevent future development from being located on unstable areas related to slope instability, landslides or coastal bluff retreat.
The project site is relatively flat and is not identified as being in an area subject to landslides or steep slopes as shown on maps included in the General Plan 2030 and included in the General Plan EIR (SOURCE V.1b-DEIR Figures 4.10-3 and 4.10-). The eastern portion of the project site is potentially subject to liquefaction as shown on Maps included in the General Plan and as reported in the EIR (SOURCE V.1b-DEIR Figure 4.10-4). The General Plan EIR indicated that typically, standard geotechnical engineering procedures, soil testing, and proper design can identify and mitigate liquefiable soils. By using the most up-to-date standards, potential damage related to liquefaction, including subsidence and settlement, can be reduced to levels that are generally considered acceptable. Section 24.14.070 of the City’s Municipal Code requires preparation of a site-specific geotechnical investigation for all development, except less than four units, in areas identified in the General Plan as having a high liquefaction potential to assess the degree of potential liquefaction and recommend appropriate design/mitigation measures.
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
24.54 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 26 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
The proposed amendments and potential future development of agriculturally-related structures may be subject to geologic hazards. Under provisions of the proposed E-A zone district, potential structural development allowed as principal permitted uses, include: ranch and farm dwellings incidental to a principal agricultural use, stables, barns, silos, and windmills. However, future development would be subject to review and approval of a coastal development permit that would be subject to CEQA, at which time the appropriate level of review of cultural resources would be undertaken as required by the General Plan 2030 and as evaluated in the General Plan 2030 EIR. Any future development also would be required to comply with Building Code requirements, which include provisions for seismic design, and as indicated above, the with adherence to General Plan 2030 policies, Building Code requirements and local regulations, impacts would be reduced to a less-than-significant level. (e) Properties within the City are served by municipal wastewater treatment and are not on septic systems. The proposed amendments would not directly or indirectly lead to the use of septic systems. (f) The General Plan EIR identified potentially significant impacts to paleontological resources as a result of future development accommodated by the Plan. The General Plan EIR Mitigation 4.9-2 added General Plan Action HA1.2.3 which requires the City to notify applicants within paleontologically sensitive areas of the potential for encountering such resources during construction, and require the City to condition project approvals so that work will being halted and resources examined in the event of encountering paleontological resources during construction. If the find is significant, the City would require treatment in accordance with the recommendations of the evaluating paleontologist. Treatment may include, but is not limited to, specimen recovery and curation or thorough documentation. This provision was added to the City’s Municipal Code (section 24.12.431) and all projects are subject to this requirement, which is included as a project condition of approval. Such a measure would be included for any development project subject to a use or coastal development permit. Therefore, with implementation of the General Plan EIR mitigation measure, the proposed project would not result in significant paleontological resource impacts not otherwise addressed in the General Plan EIR.
According to maps developed for the City’s General Plan 2030 and included in the General Plan 2030 EIR, the project site is located within an area mapped as the Late Pleistocene Alluvium and Santa Cruz Mudstone unit (SOURCE V.1b-DEIR Figure 4.9-5), both of which are within the four geologic units in the City known to contain fossils. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site could indirectly result in potential future development of agriculturally-related structures. Any future development would be subject to review and approval of a coastal development permit that would include a condition of approval that specifies measures to be taken in the event paleontological resources are discovered as described above.
Mitigation Measures: Mitigation 4.9-2 is not applicable to the proposed project because the measure has been incorporated into the City’s General Plan and Zoning Ordinance and would be included as a project condition of approval, where applicable. No mitigation measures are required with the proposed project as no significant impacts have been identified.
24.55 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 27 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding geologic hazards and soils constraints.
8. Greenhouse Gas Emissions. Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
DEIR pg 4.12-13 to 4.12-17; 4.12-
21 to 4.12-28
FEIR pg 3-26 to 3-27
No No No No
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing
the emissions of greenhouse gases?
DEIR pg 4.12-18 to 4.12-20; 4.12-
29 to 4.12-31 No No No NA
Discussion: (a) The General Plan 2030 includes goals, policies and actions on climate change, including reducing community-wide greenhouse gas emissions 30 percent by 2020 and by 80 percent by 2050 (compared to 1990 levels). The General Plan specifically calls for implementation of a Climate Action Plan that is also considered in the General Plan EIR analysis as part of General Plan measures to reduce greenhouse gas emissions. A Climate Action Plan was subsequently adopted by the City Council in October 2012, and an updated CAP was adopted in 2022 as discussed below. The General Plan EIR concludes that new development accommodated by the General Plan would result in greenhouse gas (GHG) emissions that contribute to global climate change impacts. However, the amount of estimated GHG emissions are generally within future forecasts, and the addition of emissions resulting from General Plan buildout would not substantially change per capita emission rates within the City, and would, in fact, slightly reduce them. Both the 2005 and 2030 City per capita GHG emission rates were found to be below the per capita rate that has been determined necessary to successfully implement the State’s AB 32 reduction goals statewide. Thus, the EIR concluded that the indirect GHG emissions resulting from the General Plan would not make a cumulatively considerable contribution to substantial adverse physical effects on the environment related to global climate change.
In September 2022, the City adopted the 2030 Climate Action Plan (CAP) that updates the previous 2020 CAP that was adopted in 2012 and outlines measures and actions that are intended to reduce GHG emissions, per capita, by approximately 40 percent below 1990 levels by 2030, meeting the SB 32 target for 2030 to reduce total GHG emissions 40 percent below 1990 levels. The CAP also seeks to achieve a carbon neutrality goal by the year 2035 prior to the State’s target carbon neutrality goal by 2045 (SOURCE V.2a). The CAP includes 31 measures with 152 associated individual actions, intended to reduce GHG emissions throughout the City. The measures include those related to building energy use and reduction, transportation, public infrastructure, and other climate restoration and sustainable government measures. Through implementation of its measures and actions, the CAP aims to reduce building energy consumption, vehicle miles traveled, solid waste generation, and increase carbon sequestration (SOURCE V.2a).
24.56 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 28 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
Agricultural uses on the portion of the project site proposed for agricultural land use and zoning designations would generate limited daily vehicular traffic and would not result in stationary sources of emissions. Therefore, the proposed project would not result in new significant impacts or substantially more severe impacts related to GHG emissions. (b) The General Plan EIR concluded that implementation of the General Plan and future buildout would not conflict with adopted plans related to GHG reduction. The City’s Climate Action Plan addresses citywide GHG emissions and reduction strategies. The CAP outlines the actions the City and its partners may take pertaining to reduction of greenhouse gas emissions to meet the goals and implement the policies and actions identified in the General Plan 2030. The CAP provides City emissions inventories, identifies an emissions reduction target for the year 2020, and includes measures to reduce energy use, reduce vehicle trips, implement water conservation programs, reduce emissions from waste collection, increase solar systems, and develop public partnerships to aide sustainable practices. Measures are outlined for the following sectors: municipal, residential, commercial, and community programs. The CAP included 12 climate action milestones, addressing energy use, renewable energy, sustainable transportation, waste diversion and increasing tree canopy, and these milestones were tracked through 13 indicator metrics. Four of the 13 indicator targets were achieved by the sunset of the CAP 2020. The City is developing a Climate Action Plan 2030 that is anticipated to be adopted in August 2022 and will include updated climate goals and the strategies the City will implement to achieve them.
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site would not result in conflicts with an applicable plan, policy or regulation adopted for the purpose of reducing GHG emissions.
Mitigation Measures: None were identified in the EIR. None are required with the proposed project as a significant impact has not been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding greenhouse gas emissions.
24.57 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 29 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
9. Hazards and Hazardous Materials. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?
DEIR 4.14-9 to 4.14-10
No No No No
b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
DEIR pg 4.14-5 to 4.14-7; 4.14-9 to
4.14-11
No No No No
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
DEIR pg 4.14-5 to 4.14-7; 4.14-12
No No No No
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
DEIR pg 4.14-5 to 4.14-7
No No No No
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project result in a safety
hazard or excessive noise for people residing or
working in the project area?
Not Applicable
No No No NA
f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
DEIR pg 4.6-2 to 4.6-5; 4.6-33 to
4.6-37 No No No No
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
DEIR pg 4.6-3 to 4.6-4; 4.6-34 to
4.6-35 No No No No
Discussion: (a-f) The General Plan 2030 EIR identified less-than-significant impacts related to transport, use and/or disposal of hazardous materials
24.58 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 30 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
and/or exposure to contaminated sites or release of hazardous materials with compliance with and adherence to federal, state and local regulations related to hazardous materials. The City of Santa Cruz is not located near an airport or air strip.
The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site would not lead to uses that would typically transport, use, dispose or accidentally release hazardous materials. It is noted that the existing agricultural uses consist of organic farming practices without use of pesticides or herbicides. There are two schools, University of California Santa Cruz (UCSC) Coastal Sciences Campus and Pacific Collegiate School, that are located within one-quarter mile of the project site. the UCSC Coastal Campus is located to the west of the project site and Shaffer Road, and Pacific Collegiate School on Mission Street is located within 0.25 miles (approximately 1,000 feet north) of the project site. However, the proposed amendments and potential future agriculturally-related development would not result in stationary sources that would result in hazardous emissions.
The project site is not included on the California Department of Toxic Substance Control and State Water Resources Control Board list of hazardous materials sites (SOURCE V.8a-f). Existing and proposed access to the project site is from Delaware Avenue via Shaffer Road. The project would not include any changes to existing public roadways that provide emergency access to the site. Thus, the proposed amendments and potential future development of agricultural support structures would not result in impacts related to hazards or hazardous materials. (g) The General Plan 2030 EIR found that none of the major vacant sites are within identified fire hazard zones. Areas targeted as “likely” to have a wildland fire include the Arroyo Seco/Meder Canyon, DeLaveaga, Pogonip, Moore Creek area and Arana Gulch. The General Plan EIR concluded that regulation of development in and adjacent to fire hazard areas would require adequate siting, design, and emergency access to reduce potential hazards and facilitate emergency response in accordance with General Plan policies; these requirements would reduce hazards related to wildland fires, which would also be applicable to any development permitted in these areas as a result of the proposed project. See also subsection 20 below for further discussion of wildfire risks.
According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located in a fire hazard area (SOURCE V.1b-DEIR Figure 4.6-1). Natural Bridges State Beach, located approximately 200 feet south of the project site, is designated as an area of high fire hazard (SOURCE V.1b-Figure 4.6-1).
Mitigation Measures: None were identified in the EIR and none are required with the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding hazards and hazardous materials.
24.59 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 31 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
10. Hydrology and Water Quality. Would the Project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or groundwater
quality?
DEIR pg 4.6-22; 4.7-8 to 4.7-12
No No No None
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?
DEIR pg 4.5-6 to 4.5-7; 4.5-39 to
4.5-42
o No No
General Plan
2030 Action
CC3.3.8
c) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river, in a
manner which would:
i) result in substantial erosion or siltation onor off-site; ii) substantially increase the rate or amount of
surface runoff in a manner which would
result in flooding on- or offsite;
iii) create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
iv) impede or redirect flood flows
DEIR pg 4.7-5 to 4.7-8; 4.7-22 to
4.7-25
No No No
General Plan
2030 Action
CC5.1.8 and
Municipal Code
Chapters 16.19,
18.45, and 24.14
regarding
drainage, BMPs,
grading, and
erosion control
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
DEIR pg 4.7-15; 4.7-25 to 4.7-26;
4.10-14 No No No None
e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
DEIR pg 4.5-6 to 4.5-7; 4.5-39 to
4.5-42 No No No None
Discussion: (a, c, d) The General Plan 2030 EIR identified less-than-significant impacts related to water quality degradation, stormwater runoff and
24.60 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 32 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
exposure to flood hazards with implementation of General Plan policies applicable to site-specific developments and adherence to City regulations regarding project-level drainage control, drainage design, measures to protect water quality, and flood hazards, including General Plan actions that require new development to maintain pre-development runoff levels (CC5.1.8). The General Plan EIR indicated that General Plan Policy 7.4 seeks to minimize impacts of future sea level rise, consistent with policies in the General Plan. Future site-specific development projects would be subject to sitespecific environmental review as well as permit and design review, including review for compliance with City plans and regulations, which include the City’s Storm Water Management Plan.
The project site is located adjacent to Antonelli Pond, a human-constructed pond that is fed by Moore Creek that flows into the pond from the north. The proposed project includes minor revisions to General Plan Action LU1.1.4, but does not change the development standards contained in the action that direct placement of parking areas away from Antonelli Pond. The proposed amendments would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site would not result in new development, except for potential future agriculturally-related structures that would subject to compliance with City policies and regulations regarding erosion control and stormwater management as evaluated in the General Plan 2030 EIR.
It is also noted that subsequent to certification of the EIR, amendments to the State CEQA Guidelines were approved in December 2018 that changed some of the recommended questions on the Environmental Checklist (Appendix G) regarding flooding. The revised questions focus on whether a project would impede or redirect flood flows or release pollutants due to project inundation from a flood hazard, tsunami or seiche. The proposed amendments and potential agriculturally-related development occurring as result of the amendments, would have no effect on flood flows and would not release pollutants as stormwater would be pre-treated on the project site prior to discharge into the City’s storm drain system as the project site is not subject to flood hazards, although the area adjacent to Antonelli Pond is adjacent to flooding. Nonetheless, any further structural development would be reviewed as part of the coastal development permit process to ensure compliance with applicable regulations regarding flooding and designed to prevent release of pollutants as a result of flooding. Therefore, the project would not result in a significant impact related to flooding. (b) With regards to groundwater, the General Plan 2030 EIR concluded that potential future development would be connected to the City’s public water system and would not include the use of groundwater. The General Plan EIR includes Action CC3.3.8 that encourages the City to provide a reliable production of groundwater of million gallons per day (mgd). The project site is currently provided an irrigation water service connection by the City of Santa Cruz, but as further discussed in Section 19 below, water provided to this part of the City’s water service area is not obtained from groundwater sources.
(e) It is also noted that subsequent to certification of the EIR, amendments to the State CEQA Guidelines were approved in December 2018 that changed some of the recommended questions on the Environmental Checklist (Appendix G) regarding consistency with water quality and groundwater management plans. Water quality objectives are included in the Water Quality Control Plan for the Central Coastal Basin (Basin Plan) for protection of
24.61 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 33 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
surface water and groundwater quality in the Central Coast Region. This Basin Plan lists beneficial uses for surface waters and describes the water quality objectives that must be maintained to allow those uses. Antonelli Pond is identified as an inland surface water, and identified beneficial uses include: water and non-water contact recreation; groundwater recharge; freshwater, wildlife, rare species and spawning habitats; and commercial and sport fishing. The General Plan EIR concluded that the General Plan is consistent with provisions of the RWQCB Basin Plan with policies that protect water quality, and stormwater water and water quality control requirements would be required of new development in accordance with City stormwater plans and regulations. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site could result in potential future agriculturally-related development, which would be required to comply with the City’s stormwater requirements that include protection of water quality, and thus would not result in conflicts with the Basin Plan. A sustainable groundwater management plan for the area in which the project is located has not yet been prepared. Therefore, the project would not conflict with adopted water quality or groundwater plans, and would not result in a significant impact under the current questions in Appendix G of the State CEQA Guidelines regarding conflicts with regional water quality and groundwater plans.
Mitigation Measures: None were identified in the EIR and none are required with the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding hydrology and water quality.
11. Land Use. Would the Project:
a) Physically divide an established community? DEIR pg 4.1-21 to 4.1-22 No No No No b) Cause a significant environmental impact due to
a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or
mitigating an environmental effect?
DEIR pg 4.1-9 to4.1-14; 4.1-25 to
4.1-27
No No No No
Discussion: (a-b) The General Plan EIR found no impacts related to the potential physical division of an established community or conflicts with adopted land use plans or policies. The EIR found that new mixed-use land use designations would not result in new land uses that would be considered incompatible with other adjacent or nearby land uses. The General Plan 2030 includes goals, policies and actions related to land use location, density/intensity, and areas of mixed land uses. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and any future agriculturally-related development on the project site, would not physically divide an established community. The proposed amendments do not conflict with General Plan policies and actions that serve to avoid or mitigate an
24.62 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 34 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
environmental impact.
Mitigation Measures: None were identified in the EIR and none are required with the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding land use and planning.
12. Mineral Resources. Would the Project:
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the state?
DEIR pg 4.15-3 to 4.15-4; 4.15-6
No No No NA
b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan or
other land use plan?
DEIR pg 4.15-3 to 4.15-4; 4.15-6
No No No NA
Discussion: (a-b) The General Plan 2030 EIR concluded that there would be no impacts to mineral resources as a result of future development accommodated by the General Plan as there are no designated mineral resources within the City, its existing Sphere of Influence, or the General Plan 2030 planning area. Therefore, development accommodated by the General Plan, and as an indirect result of the proposed project, would have no impact to mineral resources.
Mitigation Measures: None were identified in the EIR and none are required with the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding mineral resources.
13. Noise. Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in the
vicinity of the project in excess of standards
established in the local general plan or noise
ordinance, or applicable standards of other
DEIR pp. 4.13-4 to 4.13-8, 4.13-10
to 4.13-22
No No No
GP Actions
HZ3.1.1,
HZ3.1.2,
HZ3.1.3 &
HZ3.1.5
24.63 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 35 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
DEIR pp. 4.13-10
No No No None
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or,
where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project expose people residing or
working in the project area to excessive noise
levels?
Not Applicable
No No No None
Discussion: (a-c) The General Plan 2030 EIR identified less-than-significant impacts related to noise exposure and ambient noise level increases. The EIR concluded that with implementation of General Plan policies and actions, future development accommodated by the General Plan would not result in significant impacts related to noise with implementation of General Plan policies and actions to require new development to be sited and designed to meet land-use noise compatibility standards set forth in the General Plan and EIR. At the end of 2018, amendments to the State CEQA Guidelines were adopted by the State of California that included changes to the Appendix G environmental checklist, including elimination of a question related to exposure to noise. The questions focus on the potential permanent and temporary noise generated by a project. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. Residential land use typically is not associated with substantial permanent increases in ambient noise levels, and future residential development on the project site was evaluated in the General Plan 2030 EIR. As indicated in the General Plan 2030 EIR, the General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts regarding exposure to noise. In particular, noise-land use compatibility standards would be applied to all new residential projects (HZ3.2.1), and the General Plan seeks to ensure that noise standards are met in the siting of noise-sensitive uses (HZ3.2). The policies also establish an interior noise level of 45 dBA for all residential uses, consistent with state law. The General Plan indicates that exterior noise levels to 65 dBA are normally acceptable for new multi-family development; noise levels to 70 dBA are considered conditionally acceptable and typically require an acoustical study to determine whether additional insulation or window treatments are required.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, could result in temporary increases in noise levels at times of operation of heavy equipment, which would be intermittent and short-term and would not result in a significant impact. The General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts of increased noise resulting from construction or operation of development projects (HZ3.1.1, 3.1.2, 3.1.3, and 3.1.5). The General Plan EIR concluded that with implementation of General Plan policies and adherence to City regulations, noise impacts from future development would be less than significant.
24.64 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 36 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
The General Plan 2030 EIR indicated that areas adjacent to the major roadways in the City were projected to be exposed to noise levels exceeding 65 decibels (dBA), the normally acceptable maximum level for residential uses in the General Plan EIR, and in some cases would be exposed to 70 dBA.
However, new development would be required to meet land-use noise compatibility standards set forth in the General Plan and interior sound levels established by state law, consistent with the conclusions of the General Plan EIR. The proposed project site is not located along a major roadway as evaluated in the General Plan EIR, and is approximately one-quarter mile south of Highway 1 (Mission Street) and outside of the 65 dBA sound contour.
It is also noted that agricultural uses supported as a result of the amendments are not considered noise sensitive uses.
Mitigation Measures: None were identified in the EIR and none are required with the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding noise.
14. Population and Housing. Would the Project:
a) Induce substantial unplanned population growth
in an area, either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?
DEIR pg 4.2-2 to 4.2-6; 4.2-12 to
4.2-14
No No No NA
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
DEIR pg 4.2-14 to 4.2-15
No No No NA
Discussion: (a-b) The General Plan EIR identified a less-than-significant impact related to population growth and displacement of housing or people. The EIR concludes that population resulting from development accommodated by the General Plan would be within historic growth levels and would not result in a significant impact. It is noted that the City’s current population of 62,776 (SOURCE V.5) is within the existing AMBAG population forecast of 68,845 for the year 2025.
The proposed amendments would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in construction of residences or increased population.
Mitigation Measures: None were identified in the EIR as no significant impacts were identified.
24.65 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 37 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the less-thansignificant impacts identified and analyzed in the certified General Plan EIR regarding population and housing.
15. Public Services.
Would the project result in substantial adverse
physical impacts associated with the provision of new
or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the public services:
a) Fire protection? DEIR pg 4.6-2 to 4.6-4; 4.6-33 to
4.6-36
FEIR pg 3-19 No No No No
b) Police protection? DEIR pg 4.6-4 to 4.6-5; 4.6-36 to
4.6-37
No No No No
c) Schools? DEIR pg 4.6-20 to 4.6-21; 4.6-40
to4.6-41
No No No No
d) Parks? DEIR pg 4.6-5to 4.6-20; 4.6-37 to
4.6-40
FEIR pg 3-20 to 3-22
No No No No
e) Other public facilities? Not Applicable No No No No
Discussion: (a-e) The General Plan 2030 EIR identified less-than-significant impacts related to fire and police protection services, schools, parks, and other public facilities. The EIR identified a potentially significant impact regarding elementary school capacity potentially being exceeded under the General Plan buildout; however, the EIR concluded that no mitigation measures were required beyond payment of school impact fees that would fund needed school facility expansion and additions in conjunction with potential reuse of the former Natural Bridges Elementary School. As previously indicated, the proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan
24.66 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 38 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in new population or demand for public services.
Mitigation Measures: None were identified in the EIR and none are required for the currently proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to public services.
16. Recreation. Would the Project:
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would occur
or be accelerated?
DEIR pg 4.6-5 to 4.6-20; 4.6-37 to
4.6-40
No No No No
b) Does the project include recreational facilities or
require the construction or expansion of
recreational facilities which might have an
adverse physical effect on the environment?
DEIR pg 4.6-10 to 4.6-11
No No No No
Discussion: (a-b) The EIR identified less-than-significant impacts related to recreation. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in new population or increased demand or use of parks and recreational facilities.
Mitigation Measures: None were identified in the EIR and none are required for the currently proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to recreation.
24.67 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 39 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
17. Transportation. Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities?
DEIR pg 4.4-2 to 4.4-27; 4.4-31 to
4.4-46
No No No
GP Actions
M3.1.3, M3.1.4,
M2.3.2
regarding traffic
improvements
and Traffic
Impact Fee
Program
b) Would the project conflict or be inconsistent with
CEQA Guidelines section 15064.3, subdivision (b)? NA
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
DEIR pg 4.4-45 to 4.46
No No No No
d) Result in inadequate emergency access? DEIR pg 4.6-33 to 4.6-37 No No No No Discussion: (a) The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4-acre area proposed for agricultural designations, would not directly or indirectly result in new development that would create conflicts with policies, plans or programs regarding circulation system facilities. Therefore, the proposed project would result in no impact. (b) The EIR identified significant unavoidable impacts related to traffic as a result of development accommodated by the General Plan. Subsequent to certification of the General Plan EIR, amendments to the State CEQA Guidelines were approved in December 2018 that changed required review of transportation impacts. CEQA Guidelines section 15064.3, subdivision (b) codifies the switch from level of service (LOS) to vehicle miles traveled (VMT) as the metric for transportation analysis pursuant to state legislation adopted in 2013. The State CEQA Guidelines amendments gave all agencies until July 2020 to adopt their own VMT standards, and the City of Santa Cruz adopted a VMT threshold prior to this deadline. In adopting its threshold, the City developed VMT Guidelines to determine how to review projects for impacts and includes a screening process whereby certain types of projects have been determined to result in less-than-significant VMT impacts. This includes small projects that generate less than 110 trips per day.
The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site could result in potential future agriculturally-related structures on this portion of the project site, and would not be expected to result in a significant VMT impact given the nature of the use. However, future development would be subject to review, including VMT impacts, at the time a development project is proposed. The City’s VMT Guidelines include screening criteria that may be applicable to future proposed development that would show that
24.68 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 40 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
a project’s VMT impact is less than significant, and also includes measures to reduce VMT. It is noted that the proposed amendments to establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. Therefore, the proposed project would not conflict with provisions in the amended CEQA Guidelines regarding transportation impacts related to VMT. (c-d) The proposed amendments and potential future agricultural uses that would be permitted as a result of the amendments do not directly include geometric design features, involve incompatible use, or impact emergency access. General Plan Action LU1.1.4 requires access to the project site be provided from Shaffer Road, and this provision remains unchanged with the proposed General Plan amendments. Therefore, the project would not result in increased hazards related to project design and would not provide inadequate emergency access.
Mitigation Measures: The General Plan EIR identifies General Plan policies and actions that seek to reduce vehicle trips, encourage alternative transportation modes, and support infill and mixed-use development that would reduce trips. No additional mitigation measures are required as no significant impacts have identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to transportation.
18. Tribal Cultural Resources.
a) Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code
section 21074 as either a site, feature, place,
cultural landscape that is geographically defined
in terms of the size or scope of the landscape,
sacred place, or object with cultural value to a
California Native American tribe, and that is:
i) Listed or eligible for listing in the California
Register of Historical Resources, or in the
local register of historical resources as
defined in Public Resources Code Section
5020.1(k), or
ii) A resource determined by the lead agency, in
its discretion and supported by substantial
NA
No No No NA
24.69 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 41 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying the criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1, the lead agency shall
consider the significance of the resource to a
California Native American tribe.
Discussion: (a) Subsequent to certification of the EIR, State Assembly Bill (AB) 52 was passed and became effective on July 1, 2015. The law establishes a new category of resources in the California Environmental Quality Act called “tribal cultural resources” that considers the tribal cultural values in addition to the scientific and archaeological values when determining impacts and mitigation. Public Resources Code section 21074 defines a “tribal cultural resource” as either: (1) sites, features, places, cultural landscapes, sacred places and objects with cultural value to a California Nature American tribe that is either listed, or determined to be eligible for listing, on the national, state, or local register of historic resources; or (2) a resource that the lead agency chooses, in its discretion and supported by substantial evidence, to treat as a tribal cultural resource. The California Public Resources Code section 21084.2 now establishes that “[a] project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment.” AB 52 requires that California lead agencies consult with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of a proposed project, if so requested by the tribe. AB 52 also specifies that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource (TCR) is a project that may have a significant effect on the environment. The City of Santa Cruz received formal requests for notification on proposed projects pursuant to Public Resources Code (PRC) section 21080.3.1 from two Native American tribes traditionally and culturally affiliated with the City. The City received the requests from the Amah Mutsun Tribe in April 2022 and from the Costanoan Rumsen Carmel Tribe in May 2024. Both of these tribes requested notification of development projects within the City pursuant to AB 52 requirements codified in Public Resources Code section 21080.3.1.
No known tribal cultural resources have been identified at this time. Future development that may be proposed as a result of the proposed amendments would be subject to City approvals, including review and approval of a coastal development permit that would be subject to CEQA, at which time potential impacts to tribal cultural resources would be assessed, including notification to the tribes that have requested notification of pending development projects as may be required by law.
Mitigation Measures: None were identified in the EIR, and no new mitigation measures are required with the proposed project modifications as no new significant impacts have been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4-
24.70 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 42 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts related to tribal cultural resources than the impacts identified in the certified EIR.
19. Utilities and Service Systems. Would the project:
a) Require or result in the relocation or construction
of new or expanded water, wastewater treatment
or storm water drainage, electric power, natural
gas, or telecommunications facilities, the
construction or relocation of which could cause
significant environmental effects?
DEIR pg 4.5-29 to 4.5-38; 4.7 -7 to
4.7-8; 4.6-21 to 4.6-25; 4.6-41 to
4.6-43; 4.7-22 to 4.7-24
FEIR pg 3-2 to pg 3-19
No No No No
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
DEIR pg 4.5-3 to 4.5-42
FEIR pg 3-2 to pg 3-19 No No No No
c) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
DEIR pg 4.6-21 to4.6-25; 4.6-41to
4.6-43
No No No No
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment
of solid waste reduction goals?
DEIR pg 4.6-25 to 4.6-27; 4.6-43 to
4.6-44
FEIR pg 3-22
No No No No
e) Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
DEIR pg 4.6-25 to 4.6-27
No No No No
Discussion: (a-c) The General Plan EIR identified significant unavoidable impacts related to water demand and water supply as a result of development accommodated by the General Plan, and less-than-significant impacts related to wastewater and solid waste disposal.
Subsequent to the City’s General Plan 2030, the City prepared and adopted the 2015 Urban Water Management Plan (UWMP) and the 2020 UWMP in November 2021. The 2020 UWMP reports that water demand in the City’s water service area has decreased over the past 20 years, and current demand is approximately 2.6 billion gallons per year (City of Santa Cruz 2021). The adopted 2020 UWMP forecasts that water use over the next 25
24.71 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 43 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
years, including projected population growth, will increase at a very slow rate to reach approximately 2.8 billion gallons per year by 2045 (Ibid.).This 20- year water demand is reduced from the estimated 3,500 MGY forecast in the 2010 UWMP that was used in the General Plan EIR analysis and also less that the forecast 3,200 MGY forecast in the 2015 UWMP.
The General Plan 2030 EIR predicted that water supplies would be adequate in normal years to serve estimated growth within the City of Santa Cruz water service area. The General Plan 2030 EIR concluded that impacts to the City’s water supply would be significant and unavoidable during times of drought and potentially during normal years by the year 2030 with growth and development within the City’s water service area. Measures are identified in General Plan policies and actions to further conserve water, reduce demand and implement a supplemental water supply during droughts.
The current adopted 2020 UWMP predicts that the City will have sufficient water available in normal years and single dry years to serve anticipated demand to 2024 with implementation of the proposed water rights modifications and water augmentation strategies that are being implemented (SOURCE V.2d), but there would be shortfalls during multi-year droughts (SOURCE V.2d).The City is making substantial progress in pursuing and implementing its Water Supply Augmentation Strategy (WSAS) and Water Supply Augmentation Implementation Plan and developing augmented water supplies as set out in the 2015 WSAS and 2020 UWMP and refined/updated with the City’s adopted Securing Our Water Future (SOWF) and WSAIP.
Planned ASR facilities in the Santa Cruz Mid-County Groundwater Basin are being completed on two wells, with others being evaluated. The City also is pursuing water transfers/exchanges as part of its water supply augmentation strategy and other water system improvements and continues to evaluate recycled water options.
As previously indicated, the proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses of this portion of the project site, would continue to use water for irrigation. The project site currently has an irrigation water meter that has been used by the existing Homeless Garden Project. Thus, the proposed project would not result in significant impacts related to availability of water supplies not otherwise addressed in the General Plan EIR. (c) The General Plan EIR concluded that the City’s wastewater treatment facility would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in generation of wastewater. (d-e) The General Plan EIR concluded that the City’s landfill would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth. The EIR analyses concluded that impacts of potential development and buildout accommodated by the General Plan would be less than significant for solid waste disposal. The proposed amendments also would
24.72 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 44 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in generation of solid waste.
Mitigation Measures: The General Plan EIR identifies General Plan policies and actions to reduce water demand, as well as the City’s efforts to supplement existing water supplies. No new mitigation measures are required as a result of the proposed project.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to water and utilities.
20. Wildfire. If located near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
DEIR pp. 4.6-2 to 4.6-5, 4.6-33 to
4.6-37
No No No
NA
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose
project occupants to, pollutant concentrations
from a wildfire or the uncontrollable spread of
wildfire?
NA
No No No NA
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines, or
other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?
NA
No No No NA
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
NA
No No No NA
24.73 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 45 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Discussion: Subsequent to certification of the General Plan EIR, the State CEQA Guidelines were amended in December 2018, which requires evaluation of a new section on wildfire. Some of the steep-sloped areas in the City also are within wildland fire hazard areas. As indicated in subsections 7(a-d) and 9(g) above, the project site is not located in areas of steep slopes or designated high or extreme fire hazard areas, respectively, in the City’s General Plan 2030. The project site is not located in or near a state responsibility area, but is located in a local responsibility area. Local responsibility areas are located within incorporated city limits. The City of Santa Cruz adopted a Wildland Urban Interface (WUI) Ordinance in 2019 (Title 19.05.270 of the Municipal Code) that identifies properties considered to be at risk. The adoption of this ordinance allows the Building Division to utilize this information to enforce the provisions of 2019 CRC R337, Materials and Construction Methods for Exterior Wildfire Exposure, and 2019 CBC Chapter 7A (SFM), Materials and Methods for Exterior Wildfire Exposure, for properties these properties. The Fire Department also reviews any projects located in a WUI area.
The proposed amendments would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, would not result in new development, except for potential agriculturally-related structures as permitted in the E-A zone district. All potential future development resulting from the proposed amendments would be required to comply with state and local regulations included in building and fire codes, including provision of adequate access, which would be reviewed by the City’s Fire Department as part of any future coastal development permit applications. As discussed in subsection 7(a-dc) above, the project site is not location on steep slopes. Potential future development of agricultural structures would be designed to avoid erosion or drainage impacts and would not be expected to result in downslope post-fire flooding or slope instability as a result of stormwater runoff. Therefore, the project would not result in a new significant impact.
Mitigation Measures: None were identified in the EIR, and no new mitigation measures are required with the proposed project modifications as no new significant impacts have been identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts related to wildfire.
21. Mandatory Findings of Significance. Would the project:
a) Have the potential to degrade the quality of the
environment, substantially reduce the habitat of a
fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels,
threaten to eliminate a plant or animal
DEIR pg 4.8-13 to 4.8-21; 4.8-24;
4.8-26 to 4.8-30; 4.8-41; 4.8-38 to
4.8-45; 4.8-48 to 4.8-51; 4.9-10 to
4.9-12; 4.9-19 to 4.9-23
No No No
GP Action
NRC2.2.1 &
Project
Assessment
Protocols for
24.74 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 46 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
community, substantially reduce the number or
restrict the range of an endangered, rare or
threatened species or eliminate important
examples of the major periods of California
history or prehistory?
FEIR pg 3-22, 3-25 to 3-40 Special Status
Species; GP EIR
Mitigation 4.9-1
and Municipal
Code section
24.12.430
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a project
are considerable when view in connection with
the effects of past projects, the effects of other
current projects, and the effects of probable
future projects)?
DEIR pg 5-8 to 5-36
FEIR pg 3-27 to 3-31
No No No No
c) Does the project have environmental effects
which will cause substantial adverse effects on
human beings, either directly or indirectly?
DEIR pg 4.13-4 to 4.13-8; 4.13-10
to 4.13-20 No No No No
Discussion: (a) As discussed above in subsections 4-Biological Resources and 5-Cultural Resources, no new significant impacts were identified as a result of the proposed project. Thus, the General Plan buildout would not threaten wildlife populations or eliminate an important example of California history or prehistory.
(b) The EIR identified significant unavoidable cumulative impacts related to traffic, water supply, population growth, and noise as a result of cumulative development. The proposed amendments also would establish an agricultural General Plan and LCP land use designation and zone district for the northern 4 acres of the site, which would result in a reduced area of future development on the remaining 6.3 acres from what was evaluated in the General Plan 2030 EIR. The proposed agricultural General Plan and Zoning Map amendments and action to obtain LCP certification for the northern portion of the project site, and potential future agricultural uses on this portion of the project site, could result in non-residential, agriculturally-related accessory structures. Therefore, the proposed project would not change the density or intensity of use considered in the certified EIR and would not substantially increase the severity of impacts analyzed in the EIR. Therefore, the proposed project would not result in new significant cumulative impacts or substantially more severe cumulative impacts. (c) Potential adverse effects on human beings were considered in the Noise section of the General Plan EIR as discussed above in subsection 12-Noise.
The project would not result in additional environmental effects than those identified in the certified EIR; therefore, no new significant or substantially more severe effects on human beings would occur.
24.75 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 47 A p r i l 202 5
Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Mitigation Measures: The EIR identifies General Plan policies and actions to reduce the City’s contribution to significant cumulative impacts, and no additional mitigation measures are required as no significant impacts have identified.
Conclusion: The proposed General Plan 2030 amendments, and corresponding Zoning Map amendment and action to obtain LCP certification of the 4- acre area proposed for agricultural designations, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to topics requiring a mandatory finding of significance.
24.76 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 48 A p r i l 2025
V I I . R E F E R E N C E S
1. City of Santa Cruz General Plan 2030 and EIR
a. Adopted June 26, 2012. General Plan 2030. Available online at https://www.cityofsantacruz.com/government/city-departments/planning-andcommunity-development/long-range-policy-planning/general-plan. b. April 2012. City of Santa Cruz General Plan 2030 Final EIR. SCH #2009032007.
Certified June 26, 2012. Includes Draft EIR document, dated September 2011.
Available online at: https://www.cityofsantacruz.com/government/citydepartments/planning-and-community-development/long-range-policyplanning/general-plan. c. July 2018. “Cultural Resources Background Report Update with Policies, Programs, and Maps, City of Santa Cruz, Santa Cruz County, California.” Prepared by Dudek.
2. Other City of Sana Cruz Adopted Plans and Studies.
a. 2022. City of Santa Cruz 2030 Climate Action Plan Update, Resilient Together.
Adopted September 2022.
b. Adopted June 14, 2022. SB 743 Implementation Guidelines, City of Santa Cruz. May 12, 2022.
c. City of Santa Cruz Environmental Checklist Form/Initial Study. Antonelli Pond Accessible Trail Project. August 2021.
d. Adopted November 2021. 2020 Urban Water Management Plan. Prepared by the City of Santa Cruz, Water Department. Available online at:
https://www.cityofsantacruz.com/government/city-departments/water/urbanwater-management-plan-2020. e. June 2020. Resolution of the City Council of the City of Santa Cruz Adopting the Use of Vehicle Miles Traveled as the New Transportation Measure of Environmental Impacts. June 9, 2020 with Draft SB 743 Implementation Guidelines (May 27, 2020).
f. 2018. City of Santa Cruz Climate Adaptation Plan Update 2018-2023. g. Adopted August 2016. 2015 Urban Water Management Plan. Prepared by City of Santa Cruz Water Department.
h. October 25, 1994 as amended. The City of Santa Cruz General Plan and Local Coastal Program 1990-2005. [Local Coastal Program portion] Available online at: http://www.cityofsantacruz.com/government/about-us/general-plan.
3. AMBAG.
a. Adopted June 15, 2022. “2022 Regional Growth Forecast.” b. Adopted June 2022. Monterey Bay 2045 Moving Forward, 2045 Metropolitan Transportation Plan / Sustainable Communities Strategy. c. Adopted June 11, 2014. “2014 Regional Growth Forecast”.
24.77 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 49 A p r i l 2025
4. California Air Resources Board (CARB)
a. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. November 2022.
Available online at https://ww2.arb.ca.gov/sites/default/files/2022-12/2022- sp.pdf.
b. 2022. 2022 Scoping Plan—Appendix D, Local Actions. November 2022. Available online at
https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-localactions.pdf.
5. California Department of Conservation. 2025. Farmland Mapping and Monitoring Program. Santa Cruz Santa Cruz County Important Farmland Data Availability-2022.
Available online at: https://www.conservation.ca.gov/dlrp/fmmp/Pages/SantaCruz.aspx.
6. California Department of Finance. 2024. Population and Housing Estimates for Cities, Counties, and the State — January 1, 2023, and 2024. Available online at:
https://dof.ca.gov/forecasting/demographics/estimates-e1/.
7. California Department of Forestry and Fire Protection (CAL FIRE). 2024. Fire Hazard Severity Zones in SRA Map. Available online at: https://osfm.fire.ca.gov/what-wedo/community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones.
8. California Hazardous Materials Database Reviews
a. California Department of Toxic Substances Control (DTSC). 2023. Waste and Substances Site List (Cortese List). Accessed on September 11, 2023 at https://dtsc.ca.gov/dtscs-cortese-list/.
b. California Environmental Protection Agency (CalEPA). 2023. Cortese List Data Resources. Accessed on September 11, 2023 at
https://calepa.ca.gov/SiteCleanup/CorteseList/.
c. CalEPA. 2023. Sites identified with Waste Constituent Above Hazardous Waste Levels Outside the Waste Management Unit. Accessed on September 11, 2023 at https://calepa.ca.gov/wp-content/uploads/sites/6/2016/10/SiteCleanupCorteseList-CurrentList.pdf. d. CalEPA. 2023. Hazardous Waste Facilities Subject to Corrective Action.
Accessed on September 11, 2023 at
https://calepa.ca.gov/sitecleanup/corteselist/section-65962- 5a/?emrc=63e1903569867.
e. California State Water Resources Control Board (SWRCB). 2023. List of Leaking Underground Storage Tank Sites from the State Water Board’s GeoTracker database. Accessed on September 11, 2023 at
https://geotracker.waterboards.ca.gov/search?CMD=search&case_number=& business_name=&main_street_name=&city=&zip=&county=&SITE_TYPE=LUFT &oilfield=&STATUS=&BRANCH=&MASTER_BASE=&Search=Search
f. SWRCB. 2023b. List of Active Cease and Desist Orders and Cleanup and Abatement Orders. Accessed on September 11, 2023 at
24.78 C I T Y O F S A N T A C R U Z GENERAL PLAN, ZONING AND LCP AMENDMENTS GENERAL PLAN 2030 EIR ADDENDUM 50 A p r i l 2025
https://www.waterboards.ca.gov/waterrights/water_issues/programs/enforce ment/compliance/.
9. Monterey Bay Air Resources District.
a. Adopted March 15, 2017. 2012-2015 Air Quality Management Plan. Available online at: http://www.co.monterey.ca.us/home/showdocument?id=62318. b. February 2008. CEQA Air Quality Guidelines. Available online at:
https://www.mbard.org/files/f665829d1/CEQA_full+%281%29.pdf. c. Adopted April 1996-Revised February 2016. Guidelines for Implementing the California Environmental Quality Act.
24.79 Brittany Inclan
From: Garrett <[email protected]>
Sent: Friday, May 9, 2025 4:23 PM
To: City Council
Subject: Agenda Item #24 The bad more density, less single family housing idea Agenda Item #24 The bad more density, less single family housing idea Dear Council,
Mostly I don't see the need for this at all, the areas is just fine the way it is.
The HGP is fine the way it is. How is it not?
This will make it possible to increase density and reduce single family zoning, which should not continue. It is not neutral to density since HGP property seems to be happy with not building., and density built up next to Anatoli pond will ruin it. If there is building there, let it be single family and preserve as much open space-buildings ratio as possible.
Is this some sort of back room "deal"? Do tell.
Garrett Philipp
24.80 Brittany Inclan
From: Doug King <[email protected]>
Sent: Saturday, May 10, 2025 8:57 AM
To: City Council; Darrieg
Subject: HGP permeant site
Attachments: IMG_1887.jpeg; IMG_1938.jpeg
Dear City Council,
My name is Douglas King, I work at HGP, I have been there for three years. I started as a trainee, and I am now a fulltime employee. I have experienced first hand the transformation HGP has had on the community. Not only for the trainees who receive all the tools they need to become productive members of society, but also our volunteers who want to help our cause, and find the farm to be grounding, a place where they connect with nature.
HGP has changed my life, being homeless I put up barriers, I was jaded, and always felt a sense of impending doom. I was not a part of the community, and could not find a way out of my situation. HGP embraced me when no one else would.
Soon after I started as a trainee my barriers, and sense of doom started to fade away. I worked with my social worker, did sixteen weeks of the job training classes, and learned new skills while working on my resume. I achieved all my goals, and my life was transformed.
I get to see the same transformation in all of the trainees who become members of the society they once rejected. People who have very little in the way life skills, get jobs, and housing, literally saving them from oblivion.
The permanent site would increase our positive impact on the community, not only with local organic produce, and the beauty of the farm, but providing a way for more community members to enjoy the space. Santa Cruz is a wonderful place with outstanding people and we aim to meet the needs of the many.
Thank you, and I hope you will move us on to the next step to serve the community.
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24.83 Brittany Inclan
From: Kaki Rusmore <[email protected]>
Sent: Saturday, May 10, 2025 9:28 AM
To: City Council
Subject: Homeless Garden Project
Dear Council members,
I encourage you to support the changes to zoning and the City's General Plan that would support the Homeless Garden Project's efforts to establish a permanent farm at the site they are using now (plus a bit more). As you are well aware, HGP is an incredibly successful, compassionate and innovative program that provides the support homeless people need to transition into a working environment. Securing their place in Santa Cruz would be a feather in the City's cap, as well as a vote of confidence for this beloved, effective program.
Respectfully,
Kaki Rusmore
24.84 Brittany Inclan
From: Ginny Aragon <[email protected]>
Sent: Saturday, May 10, 2025 9:31 AM
To: City Council
Subject: Support for Homeless Garden Project plan
Dear Mayor Keeley and Santa Cruz Council Members,
I am writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project site at 2394 Delaware. I enthusiastically support the City’s proposed changes allowing agricultural uses on the 4 acres that the HGP endeavors to purchase. The HGP has a long relationship with the City and it is more than time to finalize a permanent home for this significant Santa Cruz organization with far reaching influence.
I am a long time donor, volunteer, customer and ‘in awe’ community appreciator. The HGP Programs, vision and mission inspire me on a personal level and also seem to ‘ground’ the community on workable solutions to homelessness. After all the ups and downs of getting a promised permanent home for life changing HGP projects, this is the one that makes the most sense and is most doable for right now. Trainees and the community are stronger as a result of having this westside farm. Please do what is necessary to expedite next steps.
Thank you,
Ginny Aragon
24.85 Brittany Inclan
From: Naomi Brauner <[email protected]>
Sent: Saturday, May 10, 2025 9:54 AM
To: City Council
Subject: Item 24 on the May 13, 2025 agenda - Homeless Garden Project site Dear Mayor Keeley and Council members,
As a volunteer with the Homeless Garden Project, I’ve seen firsthand the profound changes that this program makes. In the course of just one year, the project helps men and women completely turn their lives around. Nearly 100% gain stable housing and a steady income. Moreover the program supports organic agriculture, environmental stewardship, and healthy food distribution.
I urge your support for Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware. I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.
Thank you for your consideration.
Sincerely,
Naomi Brauner
325 High St.
Santa Cruz, CA 95060
24.86 Brittany Inclan
From: Gary Peixoto <[email protected]>
Sent: Saturday, May 10, 2025 9:58 AM
To: City Council
Subject: Rezoning for HGP
Hello City Council members,
My name is Gary Peixoto. I am writing in support of the plan for rezoning the property off Shaffer Road for the permanent home for the Homeless Garden Project.
The company I run, Pajaro Valley Irrigation, has supported the HGP for years. I was part of the initial stages of the planning for Pogonip. When that project fell through, the management of the HGP could have folded, and said we're done.
That's farthest from the truth, they have been diligent about securing a safe and permanent home for the organization.
I hope you will vote in favor of changing the zoning ordinances so this upright organization can plant its roots and be a safe and restorative home for those who are trying to regain their lives. Thank you. Gary Peixoto
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(831) 722-2283 Office
24.87 Brittany Inclan
From: [email protected]
Sent: Saturday, May 10, 2025 10:41 AM
To: City Council
Subject: Homeless Garden Project
10 May 2025
Dear Mayor Keeley and Council members,
I'm writing to comment on item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project's site at 2394 Delaware. I support the City's proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City's efforts on behalf of the Project.
I wholeheartedly support the Homeless Garden Project's mission and programs and their long-term efforts to build a permanent home. I'm a donor to HGP and a CSA member, and from all that I've seen, it's a total win-win of a program: valuable, transformative work experience for the trainees and a real benefit to the community. It would be wonderful to see the city ensure the project's continued success and growth with a well-deserved permanent home.
Thank you for your consideration.
Sincerely,
Kathy Chetkovich
185 Westview Ct.
Santa Cruz, CA 95060
24.88 Brittany Inclan
From: Andy Carman <[email protected]>
Sent: Saturday, May 10, 2025 11:46 AM
To: City Council
Subject: Support For Homeless Garden Project
___________________________________________________________________________________ May 10, 2025
To: City of Santa Cruz City Council
Dear Mayor Keeley and Council members,
I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware. I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.I support the Homeless Garden Project’s mission and programs and their long-term efforts to build a permanent home.
I have been a past volunteer for the HGP, helping patch the roof of their office and rebuild the kitchen when it burned down years ago. I am a big supporter because I’ve seen how effective the program is in empowering the unhoused to rebuild their capabilities to succeed in our community.
Thank you for your consideration.
Sincerely,
Andy Carman
231 Sunset Ave
Santa Cruz, CA 95060
24.89 Brittany Inclan
From: Cathy Calfo <[email protected]>
Sent: Saturday, May 10, 2025 11:48 AM
To: City Council
Cc: Darrieg
Subject: Homeless Garden Project
Dear Mayor Keeley and Council members,
I’m writing in strong support of proposed amendments to allow agricultural use of the 4 acre Natural Bridges site that the Homeless Garden Project aspires to make its permanent home.
I am a former chair of the Homeless Garden Project board of directors, and served as cochair of the successful capital campaign to raise $3.5 million to purchase a permanent project site. I can speak firsthand to the enormous community support for this model project that has made a difference in so many lives in our community.
Thanks to you and all of the city staff who have worked so hard for so many years to make the project’s dream of having a permanent home a reality.
It feels like we’re finally almost there!
Again, thank you for your support and consideration of the proposed amendments.
Sincerely,
Cathy Calfo
24.90 Brittany Inclan
From: Ann Baier <[email protected]>
Sent: Saturday, May 10, 2025 12:48 PM
To: City Council
Subject: Support for the Homeless Garden Project
Dear Mayor Keeley and Council members,
I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware. I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.
I am a donor, and have been a volunteer off and on over the past three decades. I support the Homeless Garden Project’s mission and programs, and their long-term efforts to build a permanent home. I am grateful for the work the HGP has done, and is continuing to do contribute to our community. They treat people with dignity, help trainees get the work experience and support they need to live productive and contributing lives. The HGP also does a lot for the wider community by hosting events like Pie for the People, events with interesting speakers, meaningful presentations and volunteer service days. I have participated in these with my sons. These experiences benefit all kinds of people, helping us appreciate food, work, and the benefits of building stronger community relationships.
Thank you for your consideration.
Sincerely,
Ann Baier
425 Olson Road
Soquel, CA 95073
24.91 Brittany Inclan
From: [email protected]
Sent: Saturday, May 10, 2025 2:25 PM
To: City Council
Subject: Homeless garden project item on your agenda
Please support the item on your agenda regarding the Homeless garden project. Thank you, Enda brennan, treasurer, homeless garden board
24.92 Brittany Inclan
From: MICHELE ESTRIN-GELBLUM <[email protected]>
Sent: Saturday, May 10, 2025 5:32 PM
To: City Council
Subject: Homeless Garden Project
May 10, 2025
To: City of Santa Cruz City Council
Dear Mayor Keeley and Council members,
I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware. I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.
I support the Homeless Garden Project’s mission and programs and their long-term efforts to build a permanent home. We have attended many events at the HGP where their trainees have spoken about how profoundly the HGP has changed their lives. We fully believe in the Homeless Garden Project and their mission and have donated to them for many years. They are not just growing fruit and vegetables they grow productive members of our society.
I believe the garden adds so much of value to the community and that the community is stronger with the garden’s presence on the Westside of Santa Cruz.
Thank you for your consideration.
Sincerely,
Michele Estrin-Gelblum
13525 West Park Ave
Boulder Creek, CA
24.93 Brittany Inclan
From: Peter Gelblum <[email protected]>
Sent: Sunday, May 11, 2025 8:07 AM
To: City Council
Subject: Item 24 on May 13 Agenda - HGP - Support
Dear Mayor Keeley and Council members:
I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware. I support the City’s proposed changes, allowing agricultural uses on the four acres that the Homeless Garden Project wants to purchase, and I appreciate the City’s efforts on behalf of the Project.
I support the Homeless Garden Project’s mission and programs and their long-term efforts to build a permanent home. I’m a donor, volunteer, and Downtown Store customer. I do all this because I believe in the HGP’s programs and mission, because I have seen trainees go through profound transformations and get jobs and housing in the community; it's a unique, extraordinary, and impactful program, one of the few that puts a dent in our severe homelessness problem.
Thank you for your consideration.
Sincerely,
Peter Gelblum
24.94 Brittany Inclan
From: Colin Jessop <[email protected]>
Sent: Sunday, May 11, 2025 8:46 AM
To: City Council
Subject: Homeless Garden Project: Item 24 on the May 13, 2025 agenda 5/11/25
To: City of Santa Cruz City Council
[email protected]
Dear Mayor Keeley and Council members, I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware.
I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.
I support the Homeless Garden Project’s mission and programs and their long-term efforts to build a permanent home.
My home is in Santa Cruz. Others in my community have no home. I love that the level of community compassion for those less fortunate in the City of Santa Cruz can produce such a quality organization as HGP and provide so much real, needed support for homeless people.
Every single person living in the City of Santa Cruz is a member of our community. HGP works to keep our community integrated. That makes our community stronger.
Thank you for your consideration.
Sincerely,
Colin Jessop
209 Linden St,
Santa Cruz, CA 95062
24.95 Brittany Inclan
From: Lisa Mazzei <[email protected]>
Sent: Sunday, May 11, 2025 7:57 PM
To: City Council
Subject: HGP Supporter
Sunday, May 11, 2025
To: City of Santa Cruz City Council
Dear Mayor Keeley and Council members,
I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware.
I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.
I support the Homeless Garden Project’s mission and programs and their long-term efforts to build a permanent home.
I’m and have been a donor, volunteer, Downtown Store customer, CSA member, Farm Stand customer, and participatant in many HGP events for many years.
I am a supporter because of the HGP programs and mission have been successful in helping lower homelessness in our community.
I have seen trainees go through profound transformations and get jobs and housing in the community; I also believe the community is stronger with this urban farm on the westside of Santa Cruz.
Thank you for your time and consideration.
Sincerely,
Lisa Mazzei
136 Dufour Street
Santa Cruz, CA 95060
Sent from my iPad
24.96 Brittany Inclan
From: Brendan Miele <[email protected]>
Sent: Monday, May 12, 2025 7:21 AM
To: City Council
Subject: Homeless Garden Project’s - 2394 Delaware
05.12.25 To: City of Santa Cruz City Council
[email protected]
Dear Mayor Keeley and Council members,
I’m writing to comment on Item 24 on the May 13, 2025 agenda related to proposed amendments to the Homeless Garden Project’s site at 2394 Delaware. I support the City’s proposed changes, allowing agricultural uses on the 4 acres that the Homeless Garden Project aspires to purchase, and I appreciate the City’s efforts on behalf of the Project.
I support the Homeless Garden Project’s (HGP) mission and programs and their long-term efforts to build a permanent home. I started my involvement with the HGP in 1995 as a UCSC intern. Through my internship at the projects farm at 2394 Delaware I laid the foundation for a 20 year career in commercial organic farming. I have stayed active in the project as a volunteer helping to develop long term operational plans for the project and now serve as the chair of the board of directors.
I support the project because of the impact the organization has on the community of Santa Cruz. As a father and homeowner in the city I value the work the project is doing to create a positive community hub, bringing together the community to solve our homeless crisis. My children have been able to learn the value of volunteering while working side by side with people they might otherwise not interact with and ostracize as "other". HGP is one of the most effective organizations in our community, with impacts that go beyond the social services they offer. This nationally recognized organization requires your support to put down its roots permanently.
Thank you for your consideration.
Sincerely,
Brendan Miele
110 Younglove Avenue
Santa Cruz Ca
--
Brendan Miele
[email protected]
24.97 Brittany Inclan
From: Vince Cantore <[email protected]>
Sent: Monday, May 12, 2025 8:57 AM
To: City Council
Subject: Please Support Homeless Garden Project !!!!
Dear Santa Cruz City Council Members,
I am writing to express my strong support for the Homeless Garden Project’s efforts to secure a permanent home at Natural Bridges Farm.
This project has proven to be a vital part of our community — offering job training, healing, and hope to individuals experiencing homelessness while also providing meaningful engagement for volunteers and the public. Establishing a permanent site at Natural Bridges will ensure that HGP can continue its transformative work for years to come.
I urge you to approve the necessary amendments to the general plan and Local Coastal Program to allow HGP to move forward. This initiative represents not only responsible land use but a lasting investment in the wellbeing and resilience of our entire community.
Thank you for your leadership and your consideration of this important matter.
Vince Cantore
HGP Board of Directors
24.98 2394 Delaware Ave
Amendments to General Plan, Zoning, and Local Coastal ProgramDepartment of Planning and Community Development City CouncilMay 13, 2025
24.99 24.100
Issue Summary
• Homeless Garden Project seeks permanent home• Prior Council direction: redesignate northern four acres to Agriculture/Grazing, obtain site certification from California Coastal Commission • State Law: Must maintain no net loss in citywide
housing capacity when reducing the housing capacity on a site.
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