indicates that SB 10 zoning amendments would be considered by December 2024. Why the delay? All these pieces need to be examined now. Is the City piecemealing this planning effort? The Housing Element needs to focus more on potential adaptive re-uses of existing commercial buildings and junior ADUs. They are mentioned but their actual potential is not really examined or prioritized. • How addressed: Jurisdictions are not required to adopt or evaluate SB 10. The timeframe stated for examining SB 10 is to allow sufficient time for analysis and community outreach should the City decide that its provisions would be beneficial for housing production.
unable to find the definition in the Housing Element. Location of such shelters are important and the zoning of them should be discussed now and not one year after the Housing Element is approved. • How addressed: BP refers to Business Park Zone.
Navigation Centers. This is a euphemism for half-way homes. The City is planning to revise the 3 - 453
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-100 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Municipal Code so that these homes can be placed without discretionary CEQA review in areas zoned for mixed use and non-residential zones permitting multifamily uses within two years after the adoption of the Housing Element. I know this is also a controversial topic, but it needs to be discussed now. All the “pieces” of the planning jigsaw must be available for people to understand, discuss, and voice their opinions.
• How addressed: Program 4.a includes a program to update the zoning designations for emergency and transitional housing. These amendments will occur after the Housing Element is adopted.
program also include those centers (i.e., half-way homes) in Program 4.b? • How addressed: Program 4.b includes a program to update the zoning designations for emergency and transitional housing. These amendments will occur after the Housing Element is adopted.
projects per the cited California Government Code needs to be available for us now to review and not by the end of the year when the Housing Element is already adopted. • How addressed: California Senate Bill 35 (SB-35) was signed by Governor Jerry Brown on September 29, 2017 and was effective January 1, 2018. SB-35 applies in cities that are not meeting their Regional Housing Need Allocation (RHNA) goal for construction of abovemoderate income housing and/or housing for households below 80% area median income (AMI). SB-35 amends Government Code Section 65913.4 to require local entities to streamline the approval of certain housing projects by providing a ministerial approval process. Please refer to the Government Code Section 65913.4 for more information.
Davis White (May 31, 2022)
To whom it may concern,
The California Department of Housing & Community Development (HCD) recently published a letter in response to Temple City’s implementation of Senate Bill 9 (SB 9) which has sweeping implications for other jurisdictions in this process. The letter focuses on the city’s ill-founded attempt to reduce the intensity of land use for SB 9 projects without any attempt to concurrently increase intensity elsewhere, as required by the Housing Crisis Act of 2019 (HCA). Any change in intensity of units or size without counterbalancing affects feasibility. HCD has found this violates state law. Temple City’s SB 9 ordinance—and HCD’s response—also contains a laundry list of don'ts which may affect a jurisdiction’s Housing Element compliance. Specifically, the letter called out Temple City’s use of square footage restrictions, height and story restrictions, courtyard requirements, parking limitations, LEED standards, underground requirements, and even affordability deed restrictions. All told, such requirements for SB 9-related projects which go beyond standards for other projects may be construed as governmental constraints.
Jurisdictions will have to identify and justify such constraints in their Housing Elements. Lastly, the letter stresses that a jurisdiction’s implementation of SB 9 is covered by state laws other than the HCA and State Housing Element Law. This includes, but is not exclusive to, 3 - 454
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-101 State ADU Law, AFFH, and Anti-Discrimination in Land Use Law. How a city implements SB 9 has wide-reaching considerations. Jurisdictions should be fully aware that SB 9-related projects are not separate nor exempt from their ordinary zoning laws and instead should be included within existing codes. The point of SB 9 is to give homeowners the means to increase the density of their properties.
It is not a dead-end in state law.
Attached to this email is HCD's letter to Temple City for reference.
Sincerely,
Davis White
--
Davis White he/him
yimbylaw.org
(415) 298-0788
• How addressed: The City plans to review the SB9 urgency ordinance adopted in December 2021. Such review will allow for review of the standards noted and an implementation process to be addressed. Although this process has been delayed due to other department priorities, a revised ordinance will be developed in consideration of more recently issued comments and interpretation of SB9's provisions.
Josh Albrektson (June 20, 2022) (Twitter Post)
South Pasadena is required to show they have enough zoning to allow 2,067 homes will be built over the next 7 years. They just released a Housing Element that shows where they claim the “Future homes” will be built. Me and @taxingainteasy are gonna take you so see them. ������ • How addressed: Sites included in the Housing Element must allow for and be suitable for residential development. Inclusion in the Housing Element is not a guarantee of residential units being built on a site.
To start with, South Pasadena claims that this entire mountainside will be redeveloped with homes.
They have no plans to actually do it and never actually would, but they still make the claim. (Blue dot is where I am standing for video)
In fact, in the Housing Element they even specifically state that it will always be open space at the same time they claim housing will be built on it. They had these same sites in October and were told to remove them by HCD, but they are still there.
You really don’t get a sense of how steep this mountain is until you actually go up there. This will be the first and last time I go up there. [He describes location of and road in relation to estimated "45 degree" slope and presents questions regarding feasibility of housing development on the hillside.
Implies 65 homes are going in this area (25+40)]
This is another place where they claim that homes will be built on a mountainside with a 60 degree incline road. Blue marks where I am standing for the video. [He describes location of housing sites in 3 - 455
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-102 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE relation to estimated "70 degree" slope and presents questions regarding feasibility of housing development on the hillside. Implies 11 homes are going in this area (7+4)] Here is the video for reference.
• How addressed: All APNs ending in 900, 901, 904, and 905 have been removed. APN 5308032902 has also been removed. 5312016015, 5312016014, 5301028036, 5301028035, 5301028034, 5301028054, 5301028053, 5301028052, 5301028051, 5301028050, 5301028049, 5301028055, 5306006024, 5306006025, 5306006053, 5306006048 have also been removed because they would have to have the road developed.
SoPas claims that every major grocery store will be turned into low income housing. This Ralphs which serves most of San Marino and Alhambra and is the only grocery store around will be 133 homes, even though the owner never responded to any e-mails from SoPas. (Sound on) Video says: "Does this Ralphs look like it's about to go out of business? Looks pretty busy to me" • How addressed: Ralphs and Vons have been removed from the inventory and Pavillions remains included and is counting the parking lot and not the whole building.
This SilverLake Ramen is actually about to open and at the last City Council meeting the mayor talked about how responsive the staff was to get the permits approved when it hit a snag. But According to South Pasadena this will be torn down in 7 years and turned into 263 homes.
Not only that, but this entire complex is planning to do massive renovations this year. In order to be included as a low income site you have to show that the current use is likely to be discontinued in the next 7 years. You don’t spend millions on buildings to tear them down.
Speaking of grocery stores undergoing renovations, SoPas was told to remove this Pavilions from the list. SoPas is claiming they talked to the owner and he now wants to tear it down and build housing.
SoPas will not give me any evidence of that conversation. • How addressed: Only the parking lot portion of Pavillions is being included in the land inventory. Development would include ground floor parking and residential above.
Here is HCD telling SoPas in December that these sites should be removed, but they are still there.
This was also featured in an amazing article by @RegJeffCollins with follow up articles by @publiceditor
On a related note, SoPas makes all kinds of claims in their Housing Element for communications with owners, but they don’t publish them and have repeatedly refused to show them when asked. I have even put in PRAS and 210 days later I have yet to get a response from SoPas See these power lines??? They are the main power lines that got from a power plant and supply most of the power to SoPas, San Marino, and Alhambra. South Pasadena claims that 15 homes will be built under these high voltage power lines.
But not only that, they also claim that they will move their Public Works yard here and build 34 units at that site. I am sure Edison is totally cool with storing heavy duty trucks under high voltage power lines.
We will just shut down power for a year when it is built. 3 - 456
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-103 • How addressed: This parcel is 2.73 acres and owned by the City. The southern portion of the parcel is not underneath the overhead lines. The 15 units assumed for this site were anticipated to be able to be developed on this southern portion of the site.
This is the parking lot for Rite Aid and other stores in a shopping complex. South Pasadena claims that the parking lot is not used for businesses. They would be shocked to learn there is a tunnel going strait from the parking lot to the businesses.
Rite Aid would also probably disagree with the assessment that the parking lot is not used for their business.
• How addressed: This site was removed from the inventory. Appendix A says the parking lot doesn't provide required parking for the commercial uses to the west meaning that parking doesn't address parking spaces required to be provided by the City.
See this McDonalds??? It is one of the nicest McDonalds I have ever been to. No response from the owner, but South Pasadena claims that they will be turned into 47 new homes. • How addressed: This site was removed from the inventory.
You might recognize a lot of these sites because they are almost unchanged from the sites that South Pasadena submitted over a year ago. They were told at the time most were not eligible, but they are still there.
Now, let's go to some of the little sites that SoPas claims will be housing. It is obvious that they just pulled these from a random computer program and never even looked to see if they were valid. This is my thread from the first draft they had.
They have lots that claim a driveway will be built on a 6 foot strip of land up into the hills.
Does this look like a future driveway up into the hills??? Random street next to high school is apparently going to be a home.
Street demonstration by @taxingainteasy
This home (red) and this persons backyard (blue) will be torn down and turned into homes.
I bet this home doesn’t know it is going to be torn down. 15 foot wide strips of land are apparently potential future homes.
Some dudes tennis court(red) and the main walkway connecting Monterey Hills and the High School (blue, called the snake trail) are both supposed to be housing.
This lot has approved plans for a pocket park that is supposed to be built this year. SoPas also claims it will be a home.
This thin strip of land is supposed to be a home.
Sometimes you have random strips on land in the middle of the mountain. 3 - 457
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-104 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Not Kobe!!!!! This building is half a block from the train station. SoPas claims it will be torn down and replaced with apartments at 70 DU/Acre. The only problem is there is a 25 foot height limit and one parking spot per bedroom minimum parking requirement.
• How addressed: From Appendix A: "Existing use is retail commercial buildings and parking lots behind. All four parcels have the same owner. The owner is interested in consolidating the four parcels, adaptive reuse of historic storefront, and developing residential uses on this site.
There is potential for redevelopment of the site based on underutilized surface parking, recent project trends and active economic reinvestment in the area. This site is centrally located near transit and services."
Finally, Krispy Kreme. This is not being torn down, we are just happy it is here.
This list is just some of the worst examples from the Housing Element. I don’t include how South Pasadena enacted the highest inclusionary housing ordinance in the state to make sure no buildings will be financially feasible, in part because you cannot take a picture of that.
BTW, if you are looking for who to blame for the Housing Crisis, @GVelasquez72 is in charge of @California_HCD. Under his leadership countless examples like the ones above have been approved. Like Vista being allowed to claim their 10 year old city hall.
You also have @Jason_Elliott and @CaHousingGuy who have yet to refer a single city for prosecution for a lack of compliant Housing Element, even ones that are openly defiant. Jason claimed that Newsom was going to hold cities accountable.
ADDITIONAL NOTES
Outreach to low income housing providers: Need to add reference to City outreach to Hollywood Community Housing Corporation to explore possibilities of partnerships and to understand the needs of LI housing providers.
Site 9 - (Yards): The site identified has been further examined and seems not to be feasible. Change on the notes to say that the current CIP includes a comprehensive assessment of City-owned facilities that may be suitable for relocation of the Yard, in order to vacate the property for an affordable housing project.
• How addressed: This site is a city owned site and the current CIP includes a comprehensive assessment of City-owned facilities that are be suitable for relocation of the public works yard, in order to vacate the property for an affordable housing project. The City will remediate any environmental constraints on this site prior to development for residential.
Josh Albrektson (June 21, 2022))
There are a lot of amazing claims made for the low income sites in this new Housing Element. In March before it was published I asked Angelica if she could share anything that will be used to claim a site is suitable and Angelica refused to send anything over (See below) The day after the new Draft Housing Element was published I asked Angelica for specific things related to the claims made in the Housing Element. She refused to send them over. I filed specific PRAS on May 11th for communications with the single family homeowners that they claim will develop in sites 14 and 15, any contact with Edison over the moving of the Public Works yard beneath the power lines for Site 9, the new communications 3 - 458
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-105 with Vons and Pavilions about owner interest in developing housing (sites 20 and 21), and communication with this YMCA board member for site 23. These were not broad PRAs and should have returned 1-3 documents each, documents that Angelica should have easy access to. South Pasadena has not filled a single one of these PRAs despite multiple requests. South Pasadena is making claims in their housing element about low income sites and deliberately making sure the public cannot examine the validity of these claims.
• How addressed: The commentor’s statements regarding the request to produce documents are disputed by the City. The City endeavors to comply with all PRAs through a process monitored by the Office of City Clerk. The city is unaware of any outstanding requests from the timeframe noted, and has provided all non-exempt, responsive documents to the respondent in this context in the city’s possession. Since this comment, the city has responded to several other PRA request from the commentor.
Angelica Frausto-Lupo (March 14, 2022)
From: Josh Albrektson <[email protected]>
Sent: Friday, March 11, 2022 8:00 AM
To: Margaret Lin <[email protected]>; Angelica Frausto-Lupo <[email protected]>
Subject: Can I get some information
CAUTION: This email originated from outside of the City of South Pasadena. Do not click links or open attachments unless you recognize the sender and know the content is safe. With the Housing Element release coming up I was wondering if I can get some information. I'm asking for it by e-mail because it would be much easier for you guys than more extensive PRAs. All of this information should be easy to obtain. 1. How many ADU building permits were issued in 2020 and 2021?? 2. Can you give me a list of projects that have turned in applications that the IHO would apply to since it was implemented?? I don't need anything extensive, just the address and number of proposed units in each project. 3. The evidence for each low income site in the Housing Element that you are using to claim as substantial evidence that the current use will be discontinued?? Margaret knows what I am talking about for this stuff. Thanks.
• How addressed: The City is following AB 215 requirements for releasing draft versions of the Housing Element for public comments.
Josh Albrektson (June 30, 2022))
South Pasadena just e-mailed a comment letter to residents 8 days before the HCD letter is due. It is an incomplete document and even being somebody who knows housing law it is hard to fully comprehend.
This is not real community outreach. Because I am off this week I should be able to provide a comment on some of the things in that letter that is misleading/false by the end of the week. I will include one thing here. " Proposed revisions in the section under Historic Land Development Patterns (approximately page 94) ahead of the sentences about the height limit initiative: The City does not have any growth control or management policies in place, and has not historically," This is just flat out wrong.
They enacted the 45 foot height limit in 1983 and also enacted a slow growth policy placing a cap on 60 new housing units a year. They did this in part because Asian people were moving to South Pasadena.
They also banned minorities from owning homes until 1965. Here are articles from the LA Times in the 1980's describing South Pasadenas growth restrictions. I have pulled out the relevant paragraphs and 3 - 459
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-106 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE italicized them. https://www.latimes.com/archives/la-xpm-1987-10-25-ga-16043-story.html Minorities, Growth Like other cities in the western San Gabriel Valley, South Pasadena, which covers less than 3 1/2 square miles, has experienced both a significant influx of minority residents and a drive to build. Almost a quarter of the city’s 24,400 residents are Asians, according to city officials. Fearing that South Pasadena is losing its character as a typical American small town of single-family homes, residents have battled plans for condominiums and major commercial projects. In 1983, voters rejected a proposed twin-tower office building that had been unanimously supported by the City Council. Then, after Simmons and Getchell petitioned for a ballot measure, voters imposed a 45-foot height limit on new construction. Now Simmons is leading a similar initiative drive to restrict minimall construction in the city. Cap on New Housing Last year, the council, under pressure from citizens’ petitions, voted to place a cap of 60 new housing units a year in the city. https://www.latimes.com/archives/la-xpm-1988- 11-28-me-363-story.html But city leaders say South Pasadena and its old-fashioned way of life are protected by a community-nurtured resistance to change. South Pasadena was one of the first cities in the region to adopt a slow-growth policy. In 1986, faced with a proliferation of condominium complexes and apartment buildings in the southern part of the city, as well as a voters’ revolt, the City Council imposed a 60-unit annual limit on new multifamily developments. “We’ve protected ourselves pretty well,” Woollacott said. Static Population The city’s reluctance to build is reflected in population statistics.
The population in neighboring cities has ballooned, mostly with new arrivals from Asia, but South Pasadena’s has increased by an average of only 84 people a year since 1970. While the city was keeping a lid on new apartment buildings, slowgrowth activists turned down a string of proposed commercial developments, using intense political pressure or the initiative process. For example, in 1983, when a local merchant proposed to erect two multistory office buildings, angry residents petitioned for a ballot measure limiting the height of new construction. The measure won, and the so-called “twin towers” died a sudden and unlamented death. In recent months, two major projects have also succumbed to slow-growth sentiment. First, developer Thomas Stagen withdrew a plan for a 150-suite hotel on Fair Oaks Avenue, citing the community’s “virulent opposition” to the project. Then, the City Council, acting as the Community Redevelopment Agency, scuttled a move to declare 74 acres of prime commercial area in the city a redevelopment area, after rebellious local merchants displayed signs portraying the council as a big octopus, seeking to control the city. In 1989 led by a local NIMBY Group SPRIG South Pasadena began implementation for a new general plan that downzoned the city from having a capacity of 60,000 to 25,000. LA Times article at the start:
https://www.latimes.com/archives/la-xpm-1989-08-27-ga-1552-story.html General Plan update that includes a excerpt from the Task Force from 1990:(page 13) https://www.southpasadenaca.gov/home/showpublisheddocument/220/636721709083330000 As the new decade begins, however, South Pasadena is faced with the twin threats of burgeoning multiresidential growth and continued deterioration of its commercial areas and business tax base. South Pasadena did not allow minorities to own houses. In 1964, a latino USC professor was allowed to buy a home because they mistakenly thought he was Native American. There is a TON more racist things in this article that South Pasadena did such as banning black children from the community pool and blocking off a street that connected them to the Latino El Sereno, but those were not housing related. https://www.coloradoboulevard.net/when-south-pasadena-was-a-sundown-town/ Housing In 1964, Manuel Servin, a Mexican-American professor at USC, managed to buy a house in South Pasadena, even though Mexican Americans were specifically restricted from doing so. Native Americans had no restrictions placed on them and City officials mistakenly approved his purchase in South Pasadena.
Shortly thereafter, in the mid-sixties the Federal government provided funding for affordable housing with the Altos de Monterey development which brought more racial diversity to the area. Many communities adjacent to South Pasadena did not share the same racist past. El Sereno, Highland Park and Alhambra were far more multi-racial. This created the basis of still more examples of racially divisive attitudes in residents and more law suits against the City of South Pasadena. 3 - 460
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-107 --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The City is following AB 215 requirements for releasing draft versions of the Housing Element for public comments.
Josh Albrektson (June 30, 2022)
I'm gonna send my comments as I write them because SoPas dropped this letter 8 days before the deadline for HCD to make their findings.
Comments on Responses to HCD Preliminary comments.
1A. City needs to remove all sites from Table VI-44 that have backyard tennis courts, current homes, plans to be a pocket park, sites that do not exist on the APN map, and ones that are trails that are used to get to the high school.
• How addressed: The sites included in Table VI-44 that are on slopes are all on slopes less than 20 percent and are developable in accordance with the City's hillside ordinance. Additional detail about projects approved on slopes in included on Page 168 in blue highlighting. 1B. The Los Altos housing development covering SouthWest South Pasadena was done in 1965. Since that time there has not been a single new road built in the mountains of South Pasadena. There have been lots developed, but all of these lots are on existing roads. All lots that do not have road access should be removed, regardless of the slopes.
Page one contains a list of all sites by APN which should be removed. https://docs.google.com/spreadsheets/d/1CZFzZM41DcAmVWgOUaFgaAU77Lrww9cSRwQ7GV JfWg/ edit?usp=sharing
You all have seen the videos but you can see how unrealistic it is to claim a road will be built down this hill.
https://twitter.com/JalbyMD/status/1538986717599830016?s=20&t=vn8iBXZzAb-xOVD-RgHHQ • How addressed: This site was removed from the inventory. 1C. More than 50% of RiteAids business comes from people who park in the parking lot. You cannot just claim “This will be resolved.” And the parking lot was not for sale, the whole site including the Rite Aid building was sold about 8 years ago. It was not just the parking lot.
See how many people are using the tunnel to get to the parking lot:
https://twitter.com/JalbyMD/status/1538992058236407808?s=20&t=vn8iBXZzAb-xOVD-RgHHQ 3 - 461
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-108 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: The Rite Aid sites has been removed from the inventory. 2A. IHO makes every building economically infeasible so they will not be built and SoPas cannot claim it will help spread affordable housing through the city. • How addressed: Program 2.e has been updated to address HCD comments. 2B. The City talks about the single family homes in the South West of the City and how ADUs would help increase housing on those sites. South Pasadena enacted a ADU ordinance that made that area a high fire zone and instituted many restrictions so that ADUs cannot be built in that area. There is a email from Reid Miller of the HCD ADU team to Liz Bar-El talking about and this included in the 5/21/21 e-mail sent out by Paul to the City. (see attached email) • How addressed: The City will comply with state ADU regulations and coordinate with. local fire and safety requirements for allowing future ADUs.
3A. Sent out different e-mail quoting the LA Times articles from the 1980’s about how “South Pasadena was one of the first cities in the region to adopt a slow-growth policy.” And banned minorities from buying homes until 1965.
• How addressed: Thank you for your comment.
3B. “The City will continue to include projects in the City’s Capital Improvement Program (CIP) that develop infrastructure which supports housing for lower-income residents, and provides transportation facilities for those without access to vehicles.”
• How addressed: The ongoing evaluation of CIP needs and the action taken on May 23, 2022 does not negate the program in 3B to pursue transportation facilities for people without vehicles.
On May 23rd South Pasadena decided against implementing bike lanes in the city and instead used the money to expand a one lane road of Orange Grove to a two lane road at a cost of $500k in order to make it easier for people to get on the freeway. As part of the Housing Element South Pasadena should commit to implementing the adopted 2011 master bike plan by 2025.
Link to them rejecting the bike plan for the road widening:
https://twitter.com/ActiveSGV/status/1528818927588937728 Adopted but not implemented 2011 Bike Plan.
https://www.southpasadenaca.gov/home/showpublisheddocument/1793/636721709083330000 • How addressed: The particular project made reference to on May 23, 2022 has a long history associated with it and the Council used their independent judgment as to that location, not as to bike lanes in general as the comment would suggest.
The bike plan is a more accurate reflections of the city’s commitment to multimodal transportation, and is properly referenced in other elements of the General Plan, rather than the housing element. It is included in the draft GP due to be released soon. 3 - 462
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-109 3C. Regarding Program 2.e and the IHO increasing the supply of affordable housing. IHO makes every building economically infeasible so they will not be built and SoPas cannot claim it will help spread affordable housing through the city.
• How addressed: Program 2.e has been updated to address HCD comments.
Josh Albrektson (July 1, 2022)
5A. Site 18 cannot be developed without destroying the McDonalds drive through in site 17. • How addressed: This site was removed from the inventory. 5B. Please ask to see the last contacts of the City with sites 3 and 6. What I have received from my PRAs implies both sites are not viable, with site 3 specifically telling the city that the IHO means his project can no longer work.
• How addressed: Owner is interested in the development of high-density residential housing and has submitted an application for a total of 8 market-rate units on the three parcels. 5C. Almost all sites are in locations where commercial projects can also be built and the probability of that happening is not taken into account at all. In the case of Vons and Pavilions, sites 20 and 21, that is actually happening with both undergoing extensive renovations in 2022. (Pavilions now and Vons planned)
• How addressed: Site 21 was removed from the sites inventory. Site 20 remains included due to the current renovations being minor in nature and would not preclude redevelopment of the sites. In addition, the only portion of Site 20 being counted is the parking lot and redevelopment of the parking lot would include ground floor parking with residential above. It was also stated by participants at the Developer Forum on August 15, 2022 that the City has sufficient parking and should reduce parking requirements where feasible.
5D. South Pasadena limited SB 9 so that all units can be a maximum size of 850 st ft. That guarantees a single family home is more likely to be built since they can build to 0.35 far. San Francisco did a feasibility study on SB 9 and determined that there was almost no sites in San Fran that a SB 9 project would be more feasible than a single family home, and that is without the 850 sq ft maximum SoPas does.
https://sfplanning.org/sites/default/files/documents/citywide/SB9_Summary_FinancialFeasibilityA nalysis.pdf
• How addressed: Program 3.m requires the City to develop guideless for SB 9 units by December 2022. There are no SB 9 units being counted towards meeting the City's RHNA. 6A. I think the numbers “consolidation on sites 10, 15, 19, 21 and 25” on the HCD letter is wrong.
There is no site 25.
• How addressed: That is correct.
3 - 463
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-110 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE 6B. Sites 10, 20, and 23 have the same owner. Sites 13 and 14 do not have the same owner. Site 14 the city met with an affordable housing developer and instead of developing decided to extend the lease of the playhouse located on the site.
• How addressed: In March 2022, the City Council modified its lease with the South Pasadena Theatre Workshop so that it would be a month to month lease to allow for the future development of the City-owned Site 14 without the constraint of a long-term lease. 7A. Paul told the city in May that the power lines are not a feasible site for anything. The Public works yard (site 9) should be removed from a list of viable sites. South Pasadena also counted the power lines sites for 15 moderate income sites on Table VI-44, line 6. This should also be removed. • How addressed: Site 9 is owned by the City and the unit assumptions were updated to address HCD comments.
7B. See comments 1A and 1B above. There has been no new roads built in the Los Altos (SouthWest SoPas) since 1965 and the only lots that have been developed since that time had access to a road. All sites without road access, the planned pocket park, the guys backyard tennis court, the snake trail, and sites that don’t exist should be removed.
Every site on page one of this spreadsheet:
https://docs.google.com/spreadsheets/d/1CZFzZM41DcAmVWgOUaFgaAU77Lrww9cSRwQ7GV JfWg/edit?usp=sharing
• How addressed: These sites inventory has been updated to reflect realistic capacity. 8A. They should only be allowed to claim the average ADU building permits for the last 36 months of whenever they get an approved housing Element. Other cities such as Los Angeles show there is a bump for two years due to pent up demand but then there is a drop in applications over time. • How addressed: ADU assumptions have been updated to address HCD comments in Table VI-46.
8B. SoPas does not address the fact it is one of the richest cities in the Los Angeles II category of the scag survey and that it is unlikely that any ADU will be affordable to a low income family or individual unless it is given to family. Also they do not factor in that about half of all ADU applications will not be used for new housing but is instead an expansion of the current living space. • How addressed: ADU affordability analysis has been updated on Page 231 with additional survey of ADU costs.
9A. They should never be allowed to have an “eight year objective” because that means it will never happen.
• How addressed: Thank you for your comment.
0A. Program 3.a is just a program that says sometime in the future they will study what kind of zoning is required to allow the density claims made in the Housing Element to be feasible. That kind of information should be done in the Housing Element itself. 3 - 464
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-111 • How addressed: Program 3.a requires the City to rezone to meet the City's RHNA requirement. 10B. The city forced 815 Mission to do a feasibility study for its density bonus. This feasibility study showed that the only way a 10% VLI housing project is feasible is if 57 feet is allowed, significant FAR increase, and almost every single open space and other requirement was waived. I would imagine a 10% VLI and 10% LI would require a much higher height and FAR limits than South Pasadenas base zoning has. You can find the feasibility study on page 104 and the concessions granted on page 120. https://www.southpasadenaca.gov/home/showpublisheddocument/29308/637855358954070000 • How addressed: The City has included Program 3.n – Zoning Changes, the City will review and revise development standards or updates to processes and procedures to address constraints identified in this Housing Element and facilitate increased densities in the updated General Plan and the Downtown Specific Plan (DTSP) currently undergoing public review prior to adoption hearings. In addition, comparable Zoning Code revisions outside of the DTSP area will implement this program. The types of standards and processes that will need revising include height limits, open space standards, parking requirements including variances and findings for design review.
11B. No mention of the Pre-Application or the times to get through Building. Mission Bell started the permitting process in August 2017. It received planning commission approval in Feb 2020. It still does not have building permits, almost 5 years since the first contact with the South Pasadena planning department.
https://southpasadenan.com/mission-bell-project-approved-planning-commission-tweaksconditionsauthorizes-venture/ • How addressed: The City is unaware of delays in this project attributable to the City, its staff, or its codified processes. The Mission Bell project has been moving through B&S, with many rounds of corrections to the developer-provided plans needed to get the plans to comply with building code. There is also delay related to their electrical connection (Edison), again as a result of developer design issues regarding compliance with state codes rather than the City code or staff related issues.
Published comments from various news sources often do not have the full picture of what has transpired. The ability to address that record here is appreciated. 12A. I told the city as they were implementing the IHO that it was the highest in the state. I have repeated this statement about 15 times over the past year so the city cannot claim they did not know it.
I provided them with examples of every local city IHO. I did math problems showing how it was nonviable.
They did a recent economic study this April that I sent in a different e-mail that showed that the IHO raised the prices by 11%. They implemented it with the purpose of shutting down development, as demonstrated by trying to backdate it illegally to apply to 815 Fremont. I sent in a report to HCD and Melinda Coy told South Pasadena this was illegal under SB 330 and they eliminated the backdating. • How addressed: "Program 2.m – Update Inclusionary Housing Regulations. 3 - 465
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-112 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Following results of the financial feasibility analysis of the existing Inclusionary Regulations, the City will update the Inclusionary Housing Ordinance to reduce the required percentage of inclusionary units from 20 to 15 percent. The City will also analyze the following parts of the regulations and will update them as needed to address constraints:
• 10 unit threshold
• In-lieu fees and cost of a comparable unit
• How the inclusionary regulations relate to state Density Bonus law" 12B. The economic report that they are doing is to show how feasible a density bonus project would be.
They are not examining if the IHO is feasible under the base zoning standards. On page 121 of the recent agenda packet the South Pasadena states “Building on the pro forma analysis completed in Task 2 and the understanding that the IHO will automatically trigger the State Density Bonus” https://www.southpasadenaca.gov/home/showpublisheddocument/29512/637879719642900000 Automatically trigger the state density bonus means that South Pasadena knows it makes any project under the base zoning infeasible. They also applied it to buildings under 10 units which are much more likely to be infeasible with the added costs.
Since it was enacted in April of 2021, there has been only one project submitted. That was site 11 where the developer purchased the site not knowing the IHO was going to be implemented. And if the 19 Moderate and 89 above moderate numbers are true, it means South Pasadena is not applying the IHO to this project.
We are one year into the cycle and South Pasadena has intentionally killed all housing projects with this IHO.
Because of this South Pasadena should have to provide excess zoning and programs to catch up from them shutting down all projects.
• How addressed: The City will update the Inclusionary Housing Ordinance as described in Program 2.m above.
12C. There were contacts with developers when the IHO was being implemented. You will find comments from the developers of sites 8 and 3 on page 29 and 41, respectively, on the agenda packet when South Pasadena was considering the ordinance. You will see them stating that their projects are no longer viable. Victor Tang even did the feasibility analysis and showed that the IHO would cost the developer $933,000. For site 3 there has not been any contact with Victor Tang according to my PRA requests since this letter.
https://www.southpasadenaca.gov/home/showpublisheddocument?id=25699 • How addressed: The City held a forum with local developers on August 15, 2022 to discuss development constraints, including the City’s Inclusionary Housing Ordinance. In attendance were numerous developers that have a history of working in South Pasadena or who are currently processing projects in the city, including Victor Tang. The Inclusionary Housing 3 - 466
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-113 Ordinance was not identified by the developers in attendance as a general constraint, but was identified as a constraint for projects less than five units.
Program 2.m, Update Inclusionary Housing Regulations requires that the City revise its Inclusionary Housing Ordinance to ensure that it is not a constraint for future development. 13B. See Comment 11B. There has not been a single recent project that has received building permits.
Ask the city for the dates between planning commission approval and building permits for Mission Bell, the Senior center on Fremont, and Seven Patios. All of these projects have taken over 2 years to get building permits and as of recently none of them have building permits per year. • How addressed: See above response.
18A. What the city describes as “Public outreach” is a combination of trying to talk to people who could give them more cover to claim that non-viable sites are actually viable. There were no meetings from November 17th until after this draft of the housing element was submitted. There was no effort to reach any residents, let alone renters or low income residents. • How addressed: The commentor’s position and opinion is noted. There is a record of the outreach efforts that were made over the past two years. As noted in Appendix B, prior to the release of the previous public review draft of the Housing Element, the City held public workshops on:
• May 30, 2020;
• June 2, 2020;
• September 23, 2020; and
• October 21, 2021.
In addition, the City held the public hearings on:
• July 21, 2020 at Planning Commission;
• August 5, 2020 at City Council;
• August 11, 2020 at Planning Commission;
• September 8, 2020 at Planning Commission;
• December 15, 2020 at Planning Commission;
• January 26, 2021 at Planning Commission;
• May 25, 2021 at Planning Commission;
• October 12, 2021 at Planning Commission;
• November 9, 2021 at Planning Commission; and
• November 17, 2021 at City Council.
During this time period, the City was operating under and emergency declaration due to the COVID-19 pandemic, which prevented most of the meetings from being held in person and required them to occur online.
19A. Appendix B explains why the city doesn’t think the comments are valid or applicable. It does not integrate any of the comments into the Housing Element. 3 - 467
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-114 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: Appendix B has been updated to include public comments received on the draft Housing Element and responses to comments in the draft Housing Element.
Matthew Gelfand (July 5, 2022)
Dear Mr. McDougall:
Californians for Homeownership is a 501(c)(3) organization devoted to using legal tools to address California’s housing crisis. Our organization is monitoring local compliance with Housing Element law.
We are writing to comment on the revised draft Housing Element submitted to HCD by the City of South Pasadena on May 11, 2022, as modified by the City’s June 29, 2022 responses to HCD’s anticipated comments.
At the outset, we note that other commenters have extensively detailed the inadequacies in the City’s sites inventory, both in the context of the City’s first draft housing element and the revised draft that HCD is reviewing now. Our comments are intended to highlight some of the most egregious problems with the inventory. We encourage you to review the comments made by others, including the extensive documentation provided on Twitter by Josh Albrektson.
[https://twitter.com/JalbyMD/status/1538985994602459136?cxt=HHwWgMClqfbmydsqAAAA] We also note that although the City provided some information about planned changes to its housing element in its June 29, 2022 responses to HCD’s anticipated comments, the City did not provide specific information about which sites it intended to remove from its sites inventory.
Our comments here are based on the limited information provided by the City.
Non-Vacant Sites
The sites inventory in the City’s draft Housing Element does not meet the requirements in Government Code Section 65583.2(g). The inventory does not adequately account for the impediment created by the existing uses on the listed nonvacant sites, including the possibility that a site will be maintained in its current use rather than redeveloped during the planning period.
What’s more, the City’s draft housing element appears to rely on nonvacant sites to satisfy over 50% of the City’s lower income RHNA. But the inventory does not identify evidence that the existing uses on each of these sites will be discontinued during the planning period. For example:
HCD’s prior letter pointed to three specific examples of sites with existing uses to be further evaluated or removed. For two of the sites (the Pavilions site and YMCA site), the revised draft Housing Element adds only vague statements about owner interest and does not adequately address the impediment of existing use. No additional information is provided for the other singled-out site (the Vons site), which is purportedly able to accommodate the largest number of units of any site with 157 lower-income and 263 total units. The City should be required to remove these sites from its inventory. More generally, the inventory lists three of the five area grocery stores. Each existing grocery store is a vital existing use that is exceedingly unlikely to be discontinued within the planning period. But it is even more unlikely that more than one of these stores will be closed, as the remaining stores will be forced to shoulder the burden of additional demand once one store closes. Although in one case the City is treating the store’s parking lot as the area for development, the parcel includes the store itself and state law requires the City to show that the existing use (the store) will be discontinued in order to avoid the presumption that it will impede development; this makes good sense, as there is no way to 3 - 468
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-115 develop on the parking lot parcel without discontinuing use of the store for at least several years in the absence of parking. The City should be permitted to list no more than one existing major grocery store on its inventory.
The inventory includes a number of other sites containing existing uses for which the City acknowledges there is no evidence of developer or owner interest in redevelopment, and the City should be required to remove all of these sites from the inventory:
• How addressed: Vons and Ralph's grocery stores were removed from the inventory. Pavillions remains on the inventory and only the parking lot is being included in the inventory and any future development would include ground floor parking and residential above.
APN 5318-015-017 (900 Fair Oaks Ave.), purportedly able to accommodate 18 lower-income and 29 total units: This parking lot is leased to the Rite-Aid corporation through December 2035.2 [https://www.loopnet.com/Listing/900-Fair-Oaks-Ave-South-Pasadena-CA/14380777/] The draft Housing Element states that there is no interest from developers or the property owner. The fact that the property is not subject to a covenant with the adjoining property does not help the fact that it is encumbered by a lease until 2035 and cannot be developed within the planning period. The housing element notes that the site has been listed for sale, but conspicuously fails to reveal that it was listed as a parking lot to be used for income property through 2035, not as a development property. • How addressed: The Rite Aid site was removed from the inventory.
APN 5311-012-019 (301 Monterey Rd.), purportedly able to accommodate 19 lower-income and 31 total units: Commercial building with an existing use as a liquor store. The draft Housing Element states that there is no interest from developers or the property owner. • How addressed: Owner is interested in the development of high-density residential housing and has submitted an application for a total of 8 market-rate units on the three parcels. The sites inventory has been updated to reflect this information.
APNs 5318-004-012, 5318-004-019, and 5318-004-023 (716 Fair Oaks Ave.), purportedly able to accommodate 17 lower-income and 29 total units: Commercial property with an existing use as a relatively new McDonald’s restaurant. The draft housing element states that there is no interest from developers or the property owner.
• How addressed: This site was removed from the inventory.
APN 5311-004-010 (143-161 Pasadena Ave.), purportedly able to accommodate 50 lower-income and 83 total units: Commercial property with new tenants. Although the draft housing element suggests prior interest in development, it indicates that the current status (presumably since the new tenants) is unknown.
• How addressed: The City made contact with the property owner and they support rezoning for future multi-family development.
Undevelopable Vacant Sites
The sites inventory lists as sites for housing a large number of vacant parcels on mountainous terrain, not served by paved roads and with no access to utilities. Most of these sites have zero likelihood of 3 - 469
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-116 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE being developed and they are either publicly owned with no plans for sale or privately owned and considered undevelopable by the owners. In some cases, themaps included with the City’s housing element include references to roads that do not actually exist, such as “Harriman Avenue.” “Harriman Avenue,” as depicted in housing element (left) and the entrance to “Harriman Avenue” from the ground (right). In addition to having little or no likelihood of development, the City has not met the requirements of Government Code Section 65583.2(b)(5)(B) for these parcels.
Because these parcels are generally not served by a paved road, they should be addressed by requiring the City to remove all vacant parcels not served by an existing paved public roadway. • How addressed: Sites previously listed on Harriman Ave have been removed from the inventory.
Density Assumptions
The highest-density project identified in the City’s table of representative projects is a 50 unit/acre project that used 98% of the available FAR. Nevertheless, the City has used for some parcels an unrealistic assumption of 70 units/acre—a density that stands no chance of being achieved due to the City’s voter-mandated 45-foot height limit and its restrictive development standards for FAR, setbacks, open space, parking, etc.
To justify this assumption, the City has cited two projects from other cities with very different development standards. The first project, in Hercules, is above the South Pasadena’s height limit, so South Pasadena appears to have taken the absurd approach of simply omitting the unit count for the project’s top floor in calculating the project’s density without accounting for the feasibility and economies-of-scale differences between developing a four- versus three-story project. The second project is a smaller project in the City of Santa Monica. Both projects appear to be built up to the property line (indeed, the Hercules project appears to extend over the sidewalk) and have no visible parking. Nothing resembling these projects could be built in the City of South Pasadena.
The City should not be permitted to use a density assumption above 50 units/acre for any site on its inventory. In the alternative, the City could commit (in its rezoning program) to abandon its height limit or its FAR, setback, open space, and parking requirements on the 70-unit/acre parcels.
Thank you for considering these comments as you review the City’s draft housing element.
Sincerely,
Matthew Gelfand
• How addressed: The City has included Program 2.n Citywide Height Limit Ballot Imitative to facilitate destines above 50 dwelling units/acre on sites in the Housing Element.
Ross Silverman (July 18, 2022)
To all involved;
I believe it is imperative that the upzoning include all CG, M, and even R zones adjacent to commercial corridors in South Pasadena.
Thank you
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-117 Ross Silverman
1008 Mound Ave.
South Pasadena, CA 91030
How addressed: The analysis done as part of the housing element update process indicates that upzoning all CG, M and R zones adjacent to commercial corridors in South Pasadena is not necessary to meeting the City’s RHNA. However, upzoning is necessary in certain areas of the city, as shown in Program 3.a - Rezone and Redesignate Sites to Meet RHNA, The City will redesignating and rezoning the parcels listed in Table VI-50 and in the sites exhibits in Appendix A to address the shortfall of suitably-zoned sites to address the lower-income Regional Housing Needs Allocation (RHNA) once their General Plan land use and zoning is amended.
Josh Albrektson (Jul 18, 2022)
17 months ago South Pasadena enacted the highest IHO in the state. It was done to make sure that no housing could be built in South Pasadena and it succeeded. It killed every project except one. That is the schoolyard project where they purchased the land not knowing the IHO was about to be enacted.
In case the recent Housing Element letter wasn't clear, HCD actually wants housing to be built and doesn't care for bullshit fake "owner interest" and "Legal R1 lots" that housing will never get built. Here is one line:
"analysis on how given land use constraints such as height limits and the inclusionary zoning requirements may make development infeasible on sites"
After listening to the City Council meeting again I am certain that staff and Placeworks still don't know what the Housing Element law is in relation to the IHO. Amy Senheimer quoted the wrong law in the meeting and staff kept claiming this study proved the IHO to be feasible.
As I have said many times in public comment, you cannot use a density bonus to make anything possible for the Housing Element. It is at the bottom of page 14 of the June 10th 2020 HCD memo on Housing Elements.
" The analysis of “appropriate zoning” should not include residential buildout projections resulting from the implementation of a jurisdiction’s inclusionary program or potential increase in density due to a density bonus, because these tools are not a substitute for addressing whether the underlining (base) zoning densities are appropriate to accommodate the RHNA for lower income households.
Additionally, inclusionary housing ordinances applied to rental housing must include options for the developer to meet the inclusionary requirements other than exclusively requiring building affordable units on site. While an inclusionary requirement may be a development criterion, it is not a substitute for zoning. The availability of density bonuses is also not a substitute for an analysis, since they are not a development requirement, but are development options over the existing density, and generally require waivers or concessions in development standards to achieve densities and financial feasibility." Not only that, the city has to show that the IHO is not only barely feasible, but you have to show that it is LIKELY that the buildings will still happen with the IHO AT THE BASE DENSITY.
As I am writing this on Thursday I believe that SoPas will propose a 15% Low Income IHO. A 15% Low income IHO was not analyzed by EPS, but EPS did produce some great data that can be used to analyze IHOs in South Pasadena.
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-118 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE And this data shows that a 15% low income IHO is not feasible in South Pasadena with the current conditions at the base density (or even with significant upzoning). This would be very easy for me to prove to HCD using the data provided. It would also be obvious to anybody who has experience developing buildings or providing loans for buildings. It takes about $5 per sq ft rent to be feasible.
I want an IHO that actually means the buildings actually get built. For 17 months you had one that made sure that no buildings could get built despite my objections and proof it was the highest IHO in the state.
So if you want my support on this IHO this is what I propose:
1. 5% Very Low OR 10% Low OR 25% Moderate IHO
2. Buildings under 10 units fully exempted
3. In Lieu fee for fractions as described in the April Report. Builders can fully pay the In Lieu fee to opt out. (This is required by law)
4. If South Pasadena produces less than 200 units a year starting with the 2024 APR, then the IHO is eliminated.
Or you can enact a 15% Low Income IHO and wait for it to be rejected when I show HCD that it is not feasible using the data in today's report.
There is no developer or bank that would consider a 15% IHO feasible based on the data provided. I will also point out HCD told the City to reach out to developers in part so that the developers would tell them that the 15% is non-viable.
"Other Local Ordinances: While the element now describes the inclusionary housing requirement and local height initiative, it generally does not analyze the impacts on housing cost, supply and ability to achieve maximum densities, including densities proposed as part of this housing element. For example, the analysis of the inclusionary requirement should, among other items, address the 20 percent requirement and cost impacts, 10 unit threshold, in lieu fees and cost of a comparable unit and how the inclusionary relates to State Density Bonus Law. The City should engage the development community as part of this analysis. Please see HCD’s prior review for additional information." --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: "The City has included Program 2.m – Update Inclusionary Housing Regulations.
Following results of the financial feasibility analysis of the existing Inclusionary Regulations, the City will update the Inclusionary Housing Ordinance to reduce the required percentage of inclusionary units from 20 to 15 percent. The City will also analyze the following parts of the regulations and will update them as needed to address constraints:
• 10 unit threshold
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-119 • In-lieu fees and cost of a comparable unit
• How the inclusionary regulations relate to state Density Bonus law" Josh Albrektson (July 22, 2022)
The agenda packet has been published and I have read through it. Your staff still doesn't know the law/requirements of an inclusionary housing ordinance as it relates to the Housing Element, no matter how many times I have posted the paragraph at the bottom of page 14 of the June 10th, 2020 HCD memo.
All proposals guarantees a rejection of the Housing Element, so this entire meeting will be a waste of time.
• How addressed: "The City has included Program 2.m – Update Inclusionary Housing Regulations.
Following results of the financial feasibility analysis of the existing Inclusionary Regulations, the City will update the Inclusionary Housing Ordinance to reduce the required percentage of inclusionary units from 20 to 15 percent. The City will also analyze the following parts of the regulations and will update them as needed to address constraints:
• 10 unit threshold
• In-lieu fees and cost of a comparable unit
• How the inclusionary regulations relate to state Density Bonus law" Alan Ehrlich (August 11, 2022)
Hi Angelica,
A ''draft' ordinance originating from CHC was brought to my attention yesterday but I haven't been able to determine if it was in fact enacted. While the draft does not appear to outright ban demolition of older buildings, if it does exist, it might be seen as a constraint on developement.
To the extent Josh A (or HCD) has not mentioned anything about this, either he (they) is (are) not aware of it or, as it appears, is a lesser issue of concern. Could you please confirm is this draft, or something similar, was actually adopted and on the city's books.
thank you,
Alan
"Sunlight is said to be the best of disinfectants."
- Supreme Court Justice Louis Brandeis
-"Openness in government is essential to the functioning of a democracy." International Federation of Professional & Technical Engineers, Local 21 v. Superior Court California Supreme Court, 42 Cal.4th 319 (2007)
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-120 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE See #3 on Page 20. This is from 2017.
ORDINANCE NO (southpasadenaca.gov)
If this process is removed to allow for the development of affordable multi unit housing we could get more sites. There is nothing culturally or historically significant about most the buildings on Huntington or even those fourplexes on Brent and Park.
• How addressed: Thank you for your comment, the City will continue to explore all options to provide more housing in the City of South Pasadena.
Josh Albrektson (September 1, 2022)
These are the programs I would like to see South Pasadena adopt.
In the June 29th letter to HCD the City made a commitment to increase the transportation options to lower income residents without cars (Page 10). I know this was probably a bullshit throwaway line so that you could pretend to be doing something without actually planning to do anything. Here are the bike programs that need to be firm commitments with deadlines and not just some bullshit “We will look into it sometime in 7 years.” Of note, just last month 3 people were killed by a car on Marengo St, something that possibly would have been prevented if these changes were implemented. • How addressed: The Housing Element has been revised to include documentation of transportation network improvement, including Fremont/Huntington Mobility Active Transportation Project, North-South Corridor (Fair Oaks) Intelligent Transportation System Deployment, Rectangular Rapid Flashing Beacons at three locations in the City’s lower-income residential area, and the Mission Street Slow Street Pilot Program. Additional transportation network updates will be addressed in the forthcoming revision to the City’s General Plan and the Downtown Specific Plan.
1. The Mission Street Slow Street program is made permanent. (Bottom of page 9 of 6/29 letter).
Bike lanes and no more than one lane of car traffic in each direction would be implemented and remain implemented. Right now there are bike lanes on Mission Street East of Fair Oaks and Bike lanes on Marengo. This would allow the entire eastern half of the city to have a safe route to bike to the train station. This should be done by the end of 2023. • How addressed: The City’s Slow Streets Program is intended to provide space for residents to safely walk and ride, and to support local businesses’ use of outdoor space for dining or other purposes. The next step in this program is the installation of temporary program equipment purchased with grant funding for short-term installation, such as temporary striping, curb extensions using reflective delineators, and bicycle lanes using short-term paint/tape and signs.
Other placemaking elements are also incorporated like furniture, plants, art pieces, and parklet structures outside of businesses, to create usable street space. The temporary installation is planned for Spring 2023 and is expected to be in place for 6-months, after which an assessment of the design’s observable performance, and an evaluation of the community’s experience, will be conducted – this should inform the future consideration of potential permanent changes to Mission Street.
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-121
2. The Bike lanes and one vehicle lane is extended west of the train station to Pasadena Street where there are bike lanes that extend to the Los Angeles border. This would allow the west part of the city to safely travel to the train station. This should be done by the end of 2023. • How addressed: Bicycle lanes along Mission Street and Pasadena Avenue are included in the City’s adopted Bicycle Master Plan. Temporary bicycle lanes are expected to be implemented along Mission Street in 2023 within the Slow Streets Program, and the incorporation of bicycle lanes at the intersection of Pasadena Avenue and Mission Street are being evaluated in the current street resurfacing project, which is in the mid-design phase.
3. Monterey Road in Los Angeles has bike lanes. These lanes end at the South Pasadena border.
The bike lanes should be extended to the junction of Monterey Road and Pasadena Ave. This should be done by the end of 2024.
• How addressed: A Class 2 bicycle lane is proposed for this location in the City’s adopted Bicycle Master Plan.
4. South Pasadena schools are known as one of the best schools and there is no safe route for kids to bike to the 2 elementary schools on flat land. As mentioned about just last month 3 people were killed on Marengo Street.
• How addressed: City Council has directed staff to focus the next round of Metro Measure M Multi-Year Sub-Regional Program funding requests on bicycle facilities and pedestrian crossing improvements. Staff plan to focus this funding request evaluation on neighborhoods containing schools.
4A. Class one Bike lanes should be done on Marengo Ave from Garfield Park to the City of Alhambra. These would be two way bike lanes on the east side of the street where Morango elementary school is. Going from west to east, it would be Parking south, Traffic lane South, Traffic lane north, Parking north, Bollards, Bike lane south, Bike lane North. This should be done by the end of 2024.
• How addressed: A Class 1 bicycle lane is not proposed to replace the existing Class 2 bicycle lane along Marengo Avenue in the City’s adopted Bicycle Master Plan, however, a Class 1 bicycle path is proposed parallel and adjacent to Marengo along the Southern California Easement from Garfield Park to the City of Alhambra.
4B. Class one Bike lanes should be done on the South Side of El Centro extending from Orange Grove to Pasadena Ave where Arroyo Vista Elementary school is. Going from North to South it would be Bike lane going east, Bike lane going west, bollards, Parking going east, traffic going east, traffic going west, parking going west. This should be done by the end of 2024. • How addressed: A Class 2 bicycle lane is proposed for this location in the City’s adopted Bicycle Master Plan.
4C. The El Centro bike lanes should be extended from Orange Grove east to the train station.
The South Parking lanes would be removed. Of note EVERY home on the south side of El Centro in this stretch has a garage and driveways that could fit at least 4 cars. From south to north it would be Bike lane going east, Bike lane going west, bollards, traffic going east, traffic going west, parking going west. This should be done by the end of 2025. Timeline: For the 3 - 475
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-122 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE last 4 multifamily projects South Pasadena has not had a single project get building permits, even though the earliest project was initiated in 2018. Extensive changes need to be made in the manner that South Pasadena processes housing. These are just some of the changes that should be implemented.
• How addressed: A Class 3 bicycle lane is proposed for this location in the City’s adopted Bicycle Master Plan.
5. A total of 5 planner equivalents are required to be employed at all times. This could be 4 full time employees with 2 part time. This should be implemented immediately. • How addressed: The City currently has 1 planning manager, 3 associate planners, 1 assistant planner and 1 planning counter technician FTE positions funded this fiscal year. The assistant planner began employment on Sept. 6 and the city is currently recruiting for the Planning Counter Technician position. In the meantime, a part-time planning management intern assisting until the Counter Technician position is filled.
6. The pay for entry level planners, both currently hired and for all job postings, should be the average of Pasadena and Los Angeles plus 2% and benefits. This should occur immediately. For the last 7 years there has been EXTENSIVE turnover with the average person lasting 1 year in South Pasadena. There is currently only 1 part time planner who was employed by South Pasadena who was present a year ago.
• How addressed: The city recently completed a compensation study and in the coming months will begin a classification study. The compensation study used comparable cities to South Pasadena in terms of overall organizational structure, size, and budget.
7. The Community Development Director has her Salary immediately changed to the Average salary of the directors of the Pasadena, San Marino, Alhambra, and San Gabriel. • How addressed: The city recently completed a compensation study and in the coming months will begin a classification study. The compensation study used comparable cities to South Pasadena in terms of overall organizational structure, size, and budget.
8. The pre-application is eliminated, effective immediately. • How addressed: The pre-application is intended to be a tool for developers and it is optional.
The Pre-Application process helps streamline the overall entitlement process by helping the applicant and staff identify and resolve critical issues very early in the process.
9. The program where a project has to pay for a planner that does the work of the city is immediately ended. South Pasadena can pay for this consultant if it chooses to. • How addressed: The City remains committed to allowing project planners to be hired by applicants willing to expedite their projects. Such process does not affect the remining projects in the queue as no staff members are used to review such projects to the detriment of non-expedited projects.
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-123 To ensure that no delay occurs due to this project opportunity, the City will facilitate special meetings of the planning commission and city council (as applicable) to ensure sufficient time for projects to be considered without delay.
10. All multifamily housing projects 10 units or greater are automatically moved to the front of the line and heard immediately.
• How addressed: City is unaware of the ability and feasibility to create such automatic advancement of projects through the planning process. City will adopt a process of placing such housing projects at the beginning of each meeting on which such item is considered to ensure that the widest exposure to public comment is gathered and that the project is not unduly delayed.
11. All multifamily projects between 2 and 9 units are moved to the front of the line after 2 months.
• How addressed: City is unaware of the ability and feasibility to create such automatic advancement of projects through the planning process. City will adopt a process of placing such housing projects at the beginning of each meeting on which such item is considered to ensure that the widest exposure to public comment is gathered and that the project is not unduly delayed.
12. Removal of CUP for all projects under 50 units.
• How addressed: The requirement for a CUP has not been identified previously as a constraint on development and has not been included as one of the specific policies in the Housing Element. However, this comment will be considered when developing the Downtown Specific Plan’s requirements for residential development.
13. All multifamily projects that are under 50 units and in the downtown specific plan, Ostrich Farm, or an identified Moderate or Low income site are not required to perform a Transportation study, Noise Analysis, or Climate Change and Energy analysis. These would be deemed acceptable and would automatically qualify for a class 32 exemption. If required, South Pasadena could perform a citywide analysis of Traffic, Noise, and Climate Change for all sites as described above at 30% over the claimed units in the Housing Element. • How addressed: Developments in these areas of the city will need to comply with CEQA, including analysis for transportation, noise, climate, and utility impacts. Developments will be considered for categorical exemptions if they are eligible.
14. All housing applications are posted online once a week and updated when their status weekly so that it could be determined when the application was deemed complete, when the CEQA analysis was done, and that every part of the Permit Streamlining, SB 330, and AB 2234 act are being followed.
• How addressed: Such requirement is a undue burden on the City and staff, and would cause delays in other aspects of duties by the planning division, while providing only marginal benefit towards the production of additional housing opportunities. City will continue to monitor ways other agencies are updating such information and evaluate if new technologies can be employed to address this issue.
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MAY 2023 CITY OF SOUTH PASADENA
Page B1-124 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE
15. It is required that the first planning commission, Design Review, or Cultural Historical committee happen within 6 months of the application being deemed complete for all multfiamily housing projects.
• How addressed: The City is required to follow the requirements of the Permit Streamlining Act with respect to public hearing dates once a complete application has been filed.
16. All commission hearings are completed within 90 calendars of the first commission hearing for all multifamily housing projects. If not done within 90 days, the application is deemed complete. This includes all chair reviews.
There are extensive charges and requirements for all multifamily housing that make it infeasible.
Of note, South Pasadena produced a feasibility study that showed that nothing is viable.
The following changes should be made immediately to make multifamily housing viable in South Pasadena.
• How addressed: The City is required to follow the requirements of the Permit Streamlining Act with respect to public hearing dates once a complete application has been filed.
17. The FAR requirements as stated in SB 478 are implemented immediately. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a.
18. Multiple Story exception of a 45 degree from the front to posterior is eliminated. (Page 114 of 2nd Housing Element)
• How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan. This will be considered as part of that amendment.
19. Private open space required for all projects changed to 75 sq ft per unit • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
20. Common Open Space required cut in half for all projects. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
21. Removal of all requirements for how the private open space is accessed from the apartment. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
22. Removal of all dimension requirements for the common open space. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan. 3 - 478
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2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-125
23. Elimination of all open space requirements of elevation • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
24. Removal of all uncovered area requirements
• How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
25. Open Space, either common or private, can be on the roof of the building. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
26. Removal of all parking requirements within half a mile of a transit stop for multifamily projects.
• How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
27. Removal of all commercial parking requirements within the downtown specific zone. • How addressed: New development standards will be included as part of the Downtown Specific Plan.
28. The city cannot require a development to provide public parking. (There are multiple previous housing projects where this was required and the parking lots are empty. The Mission Meridian parking garage across the street from the train station is at 41% capacity on a weekday and 18% on a weekend. It is the lowest % of any parking lot on the Metro Gold Line. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan.
29. Single family parking requirements lowered to one spot. • How addressed: The City’s zoning ordinance will be amended as part of Program 3.a. New development standards will be included as part of the Downtown Specific Plan. This will be considered as part of this amendment.
30. Signage made by the city for all public parking lots. This should be done by 2025. • How addressed: This comment does not relate to the Housing Element. It will be addressed in other parts of the General Plan.
31. Immediate removal of the Inclusionary Housing Ordinance. The city knows the current IHO makes every project infeasible and both the planning commission and City Council directed the staff to change the IHO. The Staff decided to make it as a program for removal meaning that extensive time will pass with no housing being financially viable. 3 - 479
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-126 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: Changes to the Inclusionary Housing Ordinance will be made as part of Program 2.m.
32. The city is proposing that there be a ballot initiative in 2024 to remove some of the height limit. This is COMPLETELY unacceptable. The height limit was identified as a significant constraint in the 12/21/21 HCD letter and the staff chose to not do anything about it. This should be required to be done in March 2023 and the Housing Element should not be deemed compliant until the height limit is officially repealed. • How addressed: The height limit will be considered consistent with the court order and Program 2.n.
33. Removal of the following fees for multifamily housing: Tentative Parcel Map, Tentative Tract Map, Lot line adjustment, CHC Appropriateness, Environmental impact report, Zoning text and map amendments, Specific plan application, Specific plan amendment, Development agreement review, Planned development, Technology Surcharge, General Maintenance fee. • How addressed: At this time the City is unable to commit to such project. The City will create a program to annually reevaluate alternative funding sources for such project requirements for multifamily housing projects.
34. Removal of the Public Art Fee
• How addressed: At this time the City is unable to commit to such project. The City will create a program to annually reevaluate for multifamily housing projects.
35. Water connection and Sewer connection should be at cost. • How addressed: At this time the City is unable to commit to such project. The City will create a program to annually reevaluate for multifamily housing projects.
36. Removal of all fees for ADUs.
• How addressed: At this time the City is unable to commit to such project. The City will create a program to annually reevaluate.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
Yvonne LaRose (September 9, 2022)
The Housing Element considerations that are to be finalized by September 15, have a number of issues that are of concern and need to be addressed. Affordability is one of those issues. Some of the very indirect impacts of that issue are addressed in some research I did in April of this year. The research was related to the bills signed by Gov. Newsom regarding restrictive covenants, to wit:
Governor Newsom Signs Bill Requiring Redaction of Unlawful Restrictive Covenants - California Land Title Association
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-127 A quote from the below article subtly reminds one of South Pasadena's Sundown standards and how the residual effects of that era still exist in many tenuous ways and are accepted as the community standard.
“We need to provide wealth, building opportunities for those individuals and those families who were left out,” Flores said. “We need to provide those wealth building opportunities in communities where the land has a higher value, not because it’s fair, but because of laws in the past that made it so and continue to make it so.” We are challenged with creating more housing for a projected drastic increase in population that does not parallel our neighboring cities of similar size and constituency. The issue of how to create that housing goal with a limited amount of space is definitely a challenge, yet using San Gabriel as an example, the challenge appears to be reachable. The next question is how the vision can be attained while also making inclusion and equity part of the actualization.
The conclusion of the article provides food for thought as we strive to create a strategic housing plan that makes our city legitimately and in reality one of inclusiveness.
Because whether people choose to remove racially restrictive covenants, like Beatty and Zak, or keep them as evidence, like Dew, the goal seems to be the same — to remember the past in order to build a more equitable future.
Let us not use zoning laws to substitute for enactment of a thinly veiled practice of indirectly defaulting to what should be part of our dark history in the form of restrictive covenants couched under some new terminology.
Viva
Yvonne LaRose
Organization Development Consultant: Diversity/Title VII, Harassment, Ethics Cell: 626-606-4677
• How addressed: The Housing Element has been updated to more fully address the City’s history of using land use controls as a way to make South Pasadena an exclusive community.
The goals and programs throughout the Housing Element are intended to open South Pasadena up and expand the housing opportunities throughout the City.
Victor Tang (September 10, 2022)
Hi,
This is Victor Tang, developer for site 3. We have already submitted plans to build 8 market rate units on three parcels. Per 6th Housing Elements, my site will be zoned Affordable Housing Overlay Zone.
There is conflicting information regarding the rezoning date:
1. On page 14 under “Program 2.k”, it says “Amend zoning to include overlay by Oct 15, 2024.”
2. On page 17, under “Program 3.a”, it says “The rezoning of the vacant parcels must be completed within one year of the beginning of the 6th Cycle Housing Element planning period, which is October 15, 2022. Sites that are planned to receive the Affordable Housing Overlays in the General Plan and Zoning Code are also addressed by this program.” 3 - 481
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-128 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE If the rezoning date is Oct. 15, 2022, does it mean I can submit another plan with 50+ units right after Oct. 15, 2022? Do you have the zoning code and development standard of the Affordable Housing Overlay Zone for me to do a feasibility study? If it is the Oct 15, 2024 date, we have no interests in waiting.
• How addressed: These two dates are for different programs. Site 3 is not a vacant site, and is therefore addressed as part of Program 2.k. The Housing Element currently anticipates the construction of 8 above moderate income units on the site, which is consistent with the application the developer has submitted to the City for this site.
For Table VI-41 on page 144, Tree Removal Application is missing. If a lot for development has native trees, there will be a public hearing by Natural Resources and Environmental Commission. It uses subjective standard and will stall the development for several months. For my past projects, the planning commission asked my architect to redesign so that one oak tree could be preserved. We had to spend a few months to have an alternative design to prove to the planning commission that alternative design to preserve the tree was not feasible.
I hope city attorney can review the Permit Processing carefully from page 141 to page 144 to make sure that the city has satisfied the requirements of SB330 (Housing Crisis Act of 2019). Summary of SB330 can be found here:
https://www.smwlaw.com/2022/01/13/applying-sb-330-in-real-life/ Here are some keys points of interests:
1. Permit Streamlining Act provision requiring completeness determination within 30 days
2. Local agencies must notify an applicant of any inconsistencies with objective standards within 30 days of the full application being determined to be complete if the project has 150 or fewer units, or within 60 days, if the project has more than 150 units. The local agency must include all inconsistencies in this notification; any inconsistency that is not noted in a timely way cannot be used as the basis for denying a project.
3. A single residence can count as a “housing development project.”
4. Only projects with two or more residences are “housing development projects” for purposes of Government Code section 65589.5, which prohibits cities and counties from denying or making infeasible “housing development projects” that comply with objective development standards, unless specific findings are made Based on item 4 above, the city needs to stop using discretionary review on multifamily development immediately instead of waiting for “the updates to the General Plan and zoning are complete and the Downtown Specific Plan is adopted’ (page 141). City can offer developers incentives to subject their projects to discretionary review voluntarily.
30-day deadline for item 1 and 30/60-day deadline for item 2 are critical. For example, a developer can submit a project with 60-ft height. If the city doesn’t notify the developer that 60-ft is not allowed by the zoning code before the deadline, city can’t deny the project height later.
I talked to other developers and architects. Many are frustrated with the long entitlement process time.
I was told there were 60-80 projects in the pipeline and I am not sure how many are qualified “housing development project”. As the planning department is short on staff and it may not be aware of the significance of the deadlines in item 1 and 2 above, deadline for notifications may have been missed for many projects. Therefore the city has very limited basis to deny these projects. The city needs to give these projects entitlement quickly to clear the backlog and avoid possible lawsuits. 3 - 482
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-129 As the planning department is short on staff, many developers are willing to pay external planners to expediate the review process.
• How addressed: Program 3.b requires that the City adopt objective development standards for mixed-use and adaptive re-use projects within 120 days of the adoption of the Housing Element. Additionally, Program 3.e requires that the City develop an electronic permitting system to help streamline the approval process and address many of the issues raised by this comment.
I have another project in Alto de Monterey Overlay District. The zoning code requests 15ft first floor setback and 35ft second floor setback. Even second floor ADU requests 35ft setback. I hope the city can update zoning code and ADU Ordinance in this district to make development feasible.
Best,
Victor Tang
• How addressed: Program 3.f requires that the City to review its ADU ordinance within six months of receipt of comments from HCD regarding the ordinance.
Josh Albrektson (September 10, 2022)
You guys performed a feasibility study that showed that all buildings are not feasible under your current IHO.
This feasibility study did not include carrying costs or the costs to tear down the structure that is on the property.
This feasibility study also used prototypes that are not allowed to be built in South Pasadena.
This feasibility study used a return on cost of 5% and without the carrying and demolition costs claimed that ther prototypes that cannot be legally built in South Pasadena are feasible at 5.2% Yield on cost.
West Hollywood uses a 12% yield on cost for viability. San Francisco says 15-24% is marginal and 25% is feasible.
Using your numbers, a fully market rate project with no inclusionary units would have a 6.8% Yield on cost, again using a prototype that cannot be built in South Pasadena and without carrying or demolition costs.
How exactly can you guys say any inclusionary housing ordinance doesn't affect feasibility when 100% market rate projects (Like Mission Bell) do not pencil out today? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: Program 2.m requires that the City update its Inclusionary Housing Ordinance within six months of adoption of the Housing Element. Program 2.i requires that 3 - 483
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-130 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE the City monitor the effectiveness of the Inclusionary Housing Ordinance and to make changes by the end of 2023, then annually thereafter as revisions are needed.
John C. (September 11, 2022)
I believe we can raise height the limit in a way were more than 50 percent of the residents voters would have no problem with it. The way to do that is making a bipartisan deal with the residents of South Pasadena. I will use an example. Example, South Pasadena City height limit is 45 feet what if we say we raise the height limit by 5 feet. Will the residents of South Pasadena make a big deal out of this? In my opinion, no, I do not next South Pasadena resident would have issue. Also, if you put that on the ballot in election it would pass easily because the majority of residents thinking logically will not being making a big fuss over it. I know there will be the minority of the few resident will definitely make an issue out of raising the height limit by 5 feet, but remember not everyone is going to agree with this and also those resident are the minority. But, if you go the other way by saying you want to raise to 110 feet than the majority of residents will say no. I read in the 3rd housing element draft from a previous person comment that the height limit will have be raised by 12 feet. I believe most resident will have no problem with that or even if you ask to raise by 15 feet they still will have no problem. For this to happen the residents need to know how high the city need to raise the height limit and that question has not been answer.
From, John
Sent from Mail for Windows
• How addressed: Program 2.n and the court order require that the City place a measure on the ballot by December 31, 2024 to remove or amend the height limit to allow for the densities necessary to meet the City’s RHNA requirements under this Housing Element. As part of this ballot measure, the City will work with developers and community members to determine an appropriate height limit and to build support for the ballot measure.
Elizabeth Anne Bagasao, South Pasadena Tenants Union (September 14, 2022) To Whom It May Concern:
South Pasadena Tenants is attaching our comments on the Third Draft Housing Element that was released for public review on September 8, 2022. It is our understanding that the deadline for the city to submit the third draft to HCD is September 15 however after review of the draft we feel strongly comment is warranted.
We thank you for your consideration of our comments and would welcome any discussion of our response to the Third Draft Housing Element.
Best regards,
Anne Bagasao on behalf of SPTU
SPTU Third Draft Housing Element Comments:
In the July 8 HCD encouraged “the City to revise the element as described…, adopt, and submit to HCD to regain housing element compliance.”
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-131 After comparison of the HCD letters from December 2021 and the most recent of July 2022, we are concerned that the City has not sufficiently responded to the HCD’s comments enough to satisfy compliance.
The July 8, 2022, letter states the following:
Local Data and Knowledge: While the element now includes some discussion of historical development patterns and racial exclusion for significant portion of the 20th century, it should include additional discussion of land use practices including zoning, growth controls, height initiatives and any other practices that affect housing choices since the latter half of the 20th century. This information should complement the discussion of the socio-economic patterns within the City and the City relative to the region and based on a complete analysis, the element should formulate appropriate policies and programs to combat past patterns and impacts on inclusive communities.
The third draft fails to demonstrate strategies to combat past patterns of impacts on inclusive communities.
We assert that building ordinances, based in preservationist practices, create exclusivity and deter inclusion of very low- and low-income individuals, the disabled, and people of color. As stated in Section
6.4.6 on page 101, South Pasadena admits to adopting zoning and housing policies as recently as the 1998 General Plan with intent of limiting inclusivity if not keeping people out. This attitude continues to influence building and zoning ordinances in South Pasadena. A sampling of statements that reflect these attitudes are found in the comments from the Second Draft Housing Element are found within the Third Draft Housing Element
South Pasadena Tenants Union believes that those commenters are in the loud minority and do not represent the many who aspire to achieve a racially, culturally and economically diverse South Pasadena.
During the WISPPA presentation on 9/12, comments like “protect our neighborhoods” and “we are afraid” were responded to by City staff, not with a can-do attitude of encouraging enthusiastic cooperation with the State but a mood that supported the culture of exclusivity indicative of NIMBY culture.
• How addressed: The draft housing element acknowledges past exclusionary practices and states commitment through policies to ensure that there are housing opportunities for all current and prospective residents, regardless of income. (pages 76-77).
A History of Exclusion
In Section 6.4.6, the Housing Element describes decades of planned exclusion. As per the text referencing the 1963 General Plan,
“The first three objectives of the Land Use Plan were stated as:
• To protect the amenities of single family areas from encroachment of inharmonious uses, including higher density residential, where stability and exclusiveness are desired” Three and a half decades later, South Pasadena doubles down on its protectionist land use policies.
From The Vision Statement for the 1998 General Plan the influencers pull back the drapes of their goal of maintaining a community of historic exclusivity.
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-132 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE “ In order to preserve our small-town feeling and to flourish in the 1990’s and beyond, South Pasadena must be committed to the goals of revitalizing its commercial areas and preserving its single-family residential character… We are committed to maintaining a balance between our existing single and multi-family housing units which honors our traditional values and evolving cultural diversity. (emphasis added) We see phrases in the above passage, that we also hear today in public forum and on social media:
“preserve our small-town feeling”, “preserve its single-family residential character”, “honors our traditional values”. This rhetoric, which is elitist, remains the impetus for all things related to building, transit, and most recently wildlife in South Pasadena.
The problem with the fetishization of the past in the form of “cultural heritage preservation”, is that it perpetuates systemic bias.
We refer the City to this excerpt from an article written by preservationists, Franklin Vagnone and Samantha Smith and posted a blog to Twisted Preservation, A Cultural Assets Consulting Group. If you can recognize how the existing building code, zoning laws and cultural heritage ordinance reflect the list below, then it is incumbent upon City to do more than what is stated in response to the HCD comment at the top of this discussion.
1. Preservation is essentially an elitist, class and racially divisive activity whose result is a form of economic bias and segregation.
2. History sites can perpetuate a divisive form of nostalgia that supports and validates racism and exclusion.
3. Preservation can limit inclusion and perpetuate racial & social bias by regulating cultural narratives to simple themes.
4. Historical regulations, district codes, and Preservation restrictions can be latently economically restrictive and culturally exclusionary, benefiting only those individuals who can afford the added costs, thus ensuring a form of aesthetically gated communities that reflect the dominant culture.
5. Historic districting and preservation code requirements can be a contemporary form of “redlining” which excludes a diverse economic group of people from land ownership.
6. Preservation is susceptible to the harshest form of capitalism in that only those historic sites that are targeted with money actually get preserved. Preservation choices are a matter of economics, not just history. The most revealing, unglamorous sites have rarely survived, nor have they been preserved.
7. As Preservation has become more professionalized and can require a four-year degree, college has become more expensive and thus constricts the possibility of a racially, culturally, and economically equitable pool of professional practitioners. As a result, professional practices are sometimes biased.
8. Preservationist, right now today, need to stop fetishizing the built environment and begin considering how preservation itself is part of the problem. 3 - 486
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2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-133
9. Look at the money in Preservation. A budget reflects our priorities. Money goes where it is told. There is nothing natural about the market economy or what gets preserved. Wealth Preserves Wealth.
10. Language as a tool of bias in Preservation with a weak notion of the appearance of diversity rather than full systemic representation. *
We will direct you to the City webpage for the Cultural Heritage Ordinance. This is the very first paragraph:
“South Pasadena prides itself on the quality and historic character of its neighborhoods and its small-town ambiance.
Maintaining these qualities is considered key for retaining residents…” The ordinance was re-established in 2017 and contains a section that reads:
“To stabilize and enhance neighborhoods and property values…” It appears that this ordinance, in its entirety, consciously serves to maintain and increase the upper income level status quo. This ordinance, by its own admission, is counter to any inclusive housing growth in South Pasadena.
We ask that the City state within the Housing Element a commitment to analyze the Cultural Heritage Ordinance for any and all language, policies and requirements that impede affordable housing development and promote exclusivity. It is not enough to condemn past practices. You must correct them.
Many of these caveats in the Cultural Heritage Ordinance impede the development of new housing.
Without amending the ordinance, the City will run into a plethora of issues when actually trying to achieve the goals set forth in the Housing Element.
Example: Ordinance #2315 effective August 18, 2017, 2.6.5 E.3 states that property owners wishing to demolish any property built “at least 45 years prior to application” will have to undergo an approval process by the Cultural Heritage Commission. The procedure requires the property owner to contract incur expense related to the following:
“The determination as to whether a property is a Cultural Resource shall require a deposit by the applicant to cover City costs associated with hiring a historic consultant and/or an Architectural Historian; and/or a deposit to cover the costs associated with the preparation of an Initial Study, Environmental Impact Report, Mitigated Negative Declaration or Negative Declaration.”
The ordinance goes on to describe a multitude of hoops through which the for the property owner will need to jump. The Cultural Heritage Commission is a volunteer body that meets once a month. How long does the process to receive sign off form the CHC to demolish a building built in 1978 take? How much investment of time and money is that costing any properties owner who may want to develop more efficient housing on their property?
This one rule alone is a tremendous impediment to the very work you propose in the Housing Element.
A “45 year” rolling benchmark would mean that the multiunit complex at 1700 and 1720 Mission Street would have to undergo CHC scrutiny for redevelopment. How does the City justify 1978 construction requiring historical review?
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-134 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: The recent reorganization of the Community Development Department includes creation of a housing division and additional Planning staff (Programs 2.b, 3.l), with a senior analyst to focus on housing program implementation. City staff will work with the SPTU to review the CHO to address any barriers to affordable housing that could be removed through updates to the CHO.
SB 381
We encourage the City to follow the guidelines of SB 381. Opponents of SB381 argue that the conversion of the CalTrans houses to private ownership would create affordable home ownership.
However, the investment that will be needed to rehabilitate the homes to the standards required by preservation guidelines (there is that word again) would not qualify these homes as “affordable”.
We ask that the City act on SB381 , and that any surplus houses be converted to affordable rentals.
Those structures deemed to be beyond repair should be demolished and the land utilized by the City in partnership with affordable housing developers to build 100% affordable housing as per Program 2.1.
Further regarding the CalTrans properties, we request that the City cease its efforts in blocking the transfer of 626 Prospect to Friendship Pasadena Baptist Church. Not only is that property not ours to control, this legal wrangling looks like a taxpayer funded effort to keep certain people out of our city.
Friendship Pasadena Baptist Church is the oldest African American congregation in the area, established in 1893. One would say “an historic black church”. The city, bending to the will of a small group of residents, has resulted in two legal attempts to block the transfer to Friendship Baptist Church that would provide housing to low-income families. The bad optics of this story should be of more concern to the City of South Pasadena then it currently is.
• How addressed: As detailed in Program 1.b, existing state law (SB 381) requires that the California Department of Transportation (Caltrans) sell the surplus residential property it owns in South Pasadena for use as affordable housing. The law requires that Caltrans offer the unoccupied surplus residential properties to the City of South Pasadena first, and then to the Los Angeles County Development Authority (LACDA) and then to housing related entities. The City of South Pasadena has expressed interest to Caltrans to purchase all of the unoccupied surplus properties in the city, and is currently analyzing the feasibility of purchasing the properties for use as affordable housing. Whether the City or another entity purchases the surplus properties, any entity purchasing the properties will be required to maintain them as deed restricted affordable properties.
Tenant Protections, Homeless Prevention and Preserving Existing Affordable Housing The Housing Element Third Draft in its effort to demonstrate an understanding of how best to obtain certification has included a couple of programs that, while seeming practical, are incomplete. There is not one mention in the Housing Element regarding programs meant to protect existing very low, low income and moderate income South Pasadena tenants from displacement.
We reference Program 1.c and Program 3.c.
Program 1.c would trigger substantial renovation evictions of which we currently have one ordinance on the books that minimally protects tenants from renovictions. Without protections in place that would allow tenants to be able to stay in the units during construction or to return to units after construction is complete, at the same rate of rent they had been paying when enforcement was issued, the City puts 3 - 488
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-135 tenants at displacement risk. Renters are the root of our community and to relocate them outside of South Pasadena, where their children go to school, where they may work, congregate, worship and obtain community services such as recreational classes or senior meals, is 100% irresponsible. They are not the peacocks.
We propose that the City adopt an ordinance that would require landlords to accommodate their tenants during required updates and repairs either by allowing them to remain in the units or paying their rent to live in a comparable or market rate unit still within South Pasadena. Once the property is up to code, the tenant would be able to move back in at the same rate of rent they were paying. The same ordinance should include language to protect tenants from actions by landlords that would trigger evictions or prevent the landlords from concocting ways of getting more money out of tenants such as imposing amenity fees.
SPTU is seeing incidents of landlords now tacking on “amenity fees”. While rent can only be increased by 8% under AB1482, landlords are now charging arbitrary fees that are to cover “amenities” such as use of the laundry facilities, landscaping, etc. These fees are uncontrolled so not considered part of the rent, much like the resort fees at hotels. One tenant reports that her rent was increased this year by 8% and her amenity fee was increased by 100% put her monthly payment to the landlord well over the allowable amount under AB1482.
Program 3.c similarly displaces tenants without the benefit of local protections. Again, keeping existing tenants housed in South Pasadena should be our goal not relocating them to other communities.
Additionally, any properties that the City might expedite for demolition, that are currently occupied, are most likely affordable. Therefore, in pursuit of acquiring 10 new units of affordable housing we could potentially be losing 20 and in the process displacing the very South Pasadenans who need them most.
We request that South Pasadena include in its Housing Element proactive and concrete actions to adopt tenant protections that would ensure that tenants displaced as a result of Program 3.c are given the best fighting chance of remaining in South Pasadena. This would include, but not be limited to, a local ordinance for relocation fees required for any no cause evictions. We refer the City to that of the City of Pasadena and Los Angeles as models for such an ordinance. As a reminder the City now defers to AB 1482 which requires that landlords only provide one month’s rent as moveout fee to tenants who are evicted without cause. That is not helpful in the very least. It’s actually insulting. • How addressed: South Pasadena implements State law regarding tenant protections.
Program 1.c states the intent "to reduce displacement risk of tenants living in currently substandard housing." When implementing a proactive program based on the survey conducted (Table VI-26), those units that have substantial violations or are dilapidated will be prioritized. It should be noted that these units are all single-family properties, and do not include multi-unit rental properties. The protection of any tenants will be included as part of this program. Program 3.c confirms replacement of lower-income housing units when new construction is proposed, in addition to the creation of new affordable housing units through the inclusionary housing program.
Maintaining Affordable Housing Inventory
Program 3.f-3.k regarding ADUs, it’s our understanding that the ordinance was revised to be in compliance with state law to increase the availability of long term housing, some of which could be affordable rentals.
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Page B1-136 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE In the aforementioned program sections, we don’t see much about enforcement particularly of the use of ADU’s as short-term rentals. It is common knowledge that the housing crisis in Southern California can be partially a result of the proliferation of commercially managed full time AirBnb properties. As far back as 2015, the community of Venice lost upwards of 10,000 units of affordable housing to Airbnb operators.
Without a local short term rental ordinance there is no way to monitor the use of all these new ADU’s or to prevent them from being utilize as money makers for already high-income households as opposed to housing for family members or as affordable rentals. We therefore request that the Housing Element include a short-term rental ordinance.
• How addressed: SPMC Section 36.350.200.K (ADUs) currently prohibits renting out ADUs for a period of less than 30 days. The City has the option to require a deed restriction to enforce this regulation.
Homelessness
Program 2.f shows no change to what South Pasadena is currently offering as homeless services under the County Measure H funding. We expected that an increase in services would be more responsive to the HCD comments especially since South Pasadena lost its only direct homeless service provider earlier this year. Shower of Hope, which was formerly serving unhoused individuals with mobile shower facilities in District 3 at Holy Family Church was also a site where homeless case managers from Union Station could regularly locate and identify individuals in need of services. Currently, South Pasadena offers no city funded services other than outreach and resource distribution to the homeless community. • How addressed: The most updated data that the City has in regard to unhoused people is discussed in the Housing Needs section (page 56). However, after publication of this draft of the Housing Element for public review, the County of Los Angeles published the 2022 Point in Time count numbers, which showed that South Pasadena's homeless population increased from 15 in 2020 to 50 in 2022. The City's response system, detailed in Program 2.f responds to the data from recent County homeless counts and reflects the City's partnerships to address the issues regionally.
Lastly, we see that the City references expanding the contract with Housing Resource Center for provision of services to tenants and those seeking information and assistance with housing programs, outreach and education. Since HRC has had the contract with South Pasadena, (2016) we have yet to see outcomes of said contract.
HRC proposed that their programs services would achieve the following:
“…will improve and expand affordable housing options, improve services to the homeless or specials groups, and increase access to resources for low to moderate -income residents in a variety of ways” As two volunteer organizations, SPTU and CareFirst who work closely with tenants in crisis and the homeless population of South Pasadena, are not aware of any indication that HRC successfully achieved this goal. For example in 2020, HRC poorly advised tenants who had received no cause evictions during the LA County Eviction Moratorium telling them that their evictions were legal. This caused at least one family to self-evict from an affordable unit. HRC only responded when contacted by then Councilmember Rick Schneider. It was with the assistance of Code Enforcement and the City Attorney 3 - 490
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-137 that SPTU was able to prevent the renovictions from going forward and stop the evictions. This action led to the Renoviction ordinance that was adopted later that year.
Additionally, the contract states that HRC will provide educational workshops within the City of South Pasadena. To our knowledge, there has not been such a workshop since 2020.
Because the outcomes of the 2016 cannot be quantified, we recommend that the City release an RFP for the future provision of those services mentioned in the Housing Element that refer to HRC as the provider. It’s been six years and it’s time for a review and refresh. • How addressed: The new Housing Division will be reviewing the contract with HRC, which is pending renewal, and will confer with the SPTU to ensure that the revised contract, as well as its oversight, improves service to the public and meets the needs of tenants.
Citywide Height Limit Ballot Measure Repeal
We request that a repeal is citywide and not limited to specific areas of the city. A limited repeal would not help us to move the needle on our RHNA obligation. If we are going to do it, do it with the intent of achieving the goal of increasing affordability not protecting exclusivity of certain neighborhoods. • How addressed: The details of the ballot initiative will be developed with significant community outreach, as discussed in Program 2.n., with the goal of facilitating the densities needed to implement the RHNA.
Lastly, we would like to point out that the General Plan Draft action items that provide for affordable housing incentives for “creatives” may not align with fair housing practice and is counter to the goals of the State to increase housing opportunities for all people. Frankly, it’s just another legal attempt to keep some people out while encouraging others to come in. We look forward to the public review and comment period for the General Plan and hope that its congruent with the Housing Element, housing equity and inclusion
We thank you for your consideration of these comments and look forward to the implementation of a Housing Element that reflects our values of inclusion, diversity, compassion and equity. We, as South Pasadenans, want to see our City contribute a housing crisis solution by being good Californians and generally decent people.
Sincerely,
Anne Bagasao on behalf of South Pasadena Tenants Union
Comments on the 3rd Draft Housing Element
Yvonne LaRose (November 11, 2022)
The Wednesday night joint Council-Planning Commission meeting brought out and discussed a number of issues in relation to a state mandated 2,065 dwelling units increase. We struggle to meet that requirement.
However, after the meeting, Alan Erlich and I talked. He pointed out that San Marino (which has a smaller population than South Pasadena) is only required to increase its dwelling units by 100. Similarly, 3 - 491
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-138 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE I think Alan mentioned Alhambra, which also has a smaller population than South Pasadena, is being required to increase its dwelling units by 200.
Alan also pointed out the reason for the drastically different requirements of the three cities. It is because South Pasadena is considered to be a transportation rich city due to the fact that the Gold Line passes through it.
While it is definitely true that the Gold Line is part of a reliable rail system of public transportation that's available on a 24-hour, 7 days a week, at 15 to 20 minute intervals, and the line does, indeed, pass through an area near the heart of the city, it deposits passengers at a public transportation bus stop (MTA Line 258) that is essentially an afterthought.
Line 258 runs every 60 minutes along Mission Street, Monday through Friday. It is not operational on Saturday or Sunday. It has 29 stops; among them are CSULA, where it appears it only stops two times, at 9:23 PM and 10:23 PM. Of the three routes it offers, one terminates at Avenue 63 and York Bl. as it passes along South Pasadena via Mission Street.
South Pasadena also has the benefit of MTA Line 260 which runs the length of Fair Oaks from the Alhambra border, through South Pasadena (past Huntington Hospital), and then into Pasadena. That line runs every everyday, starting from the Artesia Station at 4:21 AM and ends at 10:31 PM. at approximately 15 to 20-minute intervals.
South Pasadena offers its residents who are seniors and/or disabled transportation five days a week (Monday through Friday) from 8:30 AM to 4:00 PM via Dial a Ride. We have learned through the Community Services highlight during a Council meeting that the new scheduler considers all passengers are interested in getting to medical appointments or shopping, typically for groceries. The scheduler will confirm a reservation but makes an independent, subjective determination as to whether the reservation should be honored and will (sometimes without notice to the passenger) cancel or change a reservation, leaving the client without transport and needing to change their business itinerary and appointments for that day unless they are able to use an alternative transportation service.
Dial a Ride has become a dismally unreliable means of transportation in and around South Pasadena.
While there are other transportation alternatives such as Uber, Lyft, Access, or taxi, the above three public transportation systems constitute the "rich transportation" of South Pasadena. Given the limited availability of the City's staple transportation, it can be said with accuracy that South Pasadena is definitely not a transportation rich city.
Based on this analysis, the City should challenge the requirement to develop 2,065 units. The burden on a city of 2.5 square miles is too great. The "rich transportation" is imaginary. What does exist can barely support the 25,000 residents; to add even 2,000 additional people (let alone dwelling units) would overtax all of the City's resources.
Viva
Yvonne LaRose
Organization Development Consultant: Diversity/Title VII, Harassment, Ethics Consultant's Desk - http://consultantdesk.blogspot.com
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-139 The Desk - http://thedesk.wordpress.com
Cell: 626-606-4677
• How addressed: There are many different factors that are taken into account when determining a City’s Regional Housing Needs Assessment, including the proximity to jobs and transit access.
The City was allocated 2,067 units after the reallocations by SCAG after several agencies made various appeals and many factors were weighted. The City is addressing the full amount of its share of housing needs as determined through the RHNA process, and this Housing Element has been drafted to meet those housing needs.
Yvonne LaRose (November 12, 2022)
It seems Agenda Items 3.3 and 3.4 had exhibits to be used with them. Those exhibits were not in the Council chamber when the meeting started. Perhaps they were available at the booth in the lobby of City Hall. The lack of such exhibits for the public made grasping all of the proposed details difficult to navigate. Some members of the audience had questions about the proposed changes but were unable to present those questions and concerns. Frustration was the result.
One of the properties involves Foremost Liquor at Monterey Rd. and Pasadena Ave. The proposition is to remove that structure and convert the property into a different type of use, possibly residential.
The issue with that prospect is that is the only convenience store in the area and appears to generate more business and revenue than the small businesses on the west side of Monterey Road. Perhaps there are other alternatives to removing that business. Interpretation of the proposed change seemed to be tear out the liquor store and rebuild with a multi-use/family dwelling. • How addressed: Foremost Liquor (Site 5 in Appendix A) will be rezoned as part of the larger Ostrich Farm Mixed-Use area to remove barriers to and incentivize the production of housing units. The City is not “tearing out” the liquor store. This mixed-use area will include additional retail opportunities for the west side of the city, which may include a liquor store.
There was also discussion of the Pavilion's parking lot. The proposal is to resurface the parking lot (which was recently completed), install additional parking, as well as build a residential building on the lot. No one in the audience could envision a dwelling unit on that lot that would aesthetically blend in with the area. There also seems to be quite limited space for a proposed dwelling unit in that location.
The proposed changes do not appear to be feasible.
• How addressed: The Pavilions parking lot (Site 16 in Appendix A) is approximately 2.67 acres of flat land within a transit rich area. As discussed in the letter from the property owner, the owner intends to redevelop the entire site with a new store which would include a housing component. It is anticipated that the new store will be approximately the same size as the existing store, leaving an area equivalent in size as the parking to for development of parking and residential uses. Appendix A has been updated to reflect this additional information.
Moving just one-half block to the south of the Pavilion's site is Golden Oaks Restaurant, which is also proposed as a site for demolition and erection of a multi-unit dwelling, plus parking spaces. Again, the aesthetics of that type of change is questionable, not to mention there is scant space to make those types of changes.
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-140 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: Aesthetics are not an issue that is considered or addressed under state law in the Housing Element. Such issues are addressed through zoning regulations such as the Downtown Specific Plan that will come after the Housing Element indicates were to locate housing resources. Parking is not required in this area due to recently enacted state law under AB 2097 prohibiting cities from imposing minimum parking standards for residential and commercial projects within one-half mile from public transit. Program 3.b has been revised to commit the City to updating its zoning code to conform to the parking standards set by state law.
It sounded as though the Public Works yard is also being planned for renovation and demolition. It's troubling to try to understand where Public Works will be located if their base is removed. Perhaps what was missed in the interpretation of the proposal is that the yard will somehow be upgraded (perhaps with more energy refueling pumps) and remain in the same location. • How addressed: The City’s existing Capital Improvement Program includes a list of sites suitable for relocation of the activities currently conducted at the Public Works yard. The City intends to vacate the Public Works Department from this site so it can be redeveloped as affordable housing with no Public Works activities remaining on the site.
These are the proposals that more significantly stand out in my recollection of Wednesday's meeting.
Viva
Yvonne LaRose
Cell: 626-606-4677
Josh Albrektson (November 21, 2022)
For APN 5308034015 this is on a mountain and has no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5308034015 has been removed from the Housing Element.
Josh Albrektson (November 21, 2022)
1131 El Centro St is a 3 story condo complex built in 1988. You guys cite it as an example of buildings recently built in South Pasadena. What is the substantial evidence the current use will be discontinued as required for low income sites??? Are they going to tear down new condos for new condos?? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-141 Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1131 El Centro St. is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1131 El Centro St. is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that these 34 year old builds are redeveloped during the planning period.
Josh Albrektson (November 21, 2022)
700 Orange Grove Ave is a 3 story Condo Complex built 20 years ago. You guys are claiming there is a chance that this 3 story Condo Complex might be torn down for a replacement 3 story apartment building. Can you guys point to a place where this has happened somewhere else?? What is the substantial evidence the current use will be discontinued as required for low income sites??? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 700 Orange Grove Ave. is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 700 Orange Grove Ave. is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process, including a voter approved modification of the citywide height limit to allow for the construction of buildings on this site taller than three stories. The possibility exists, and that the Housing Element programs make it more likely, that these 20 year old builds are redeveloped during the planning period.
Josh Albrektson (November 21, 2022)
For APN 5314020007, this is in the middle of the block and there is no street access --
Josh Albrektson MD
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MAY 2023 CITY OF SOUTH PASADENA
Page B1-142 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Neuroradiologist by night
Crime fighter by day
• How addressed: There is an existing public driveway that provides access to APN 5314020007 Josh Albrektson (November 21, 2022)
715 Prospect Ave and 807 Prospect Ave are 2 story apartment buildings. You guys are claiming there is a chance that they might be torn down for 3 story apartments. Can you guys point to a place where this has happened somewhere else?? What is the substantial evidence the current use will be discontinued as required for low income sites??? And you are required to subtract the current apartments from the proposed apartments for your counting of units. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 715 Prospect Ave. and 807 Prospect Ave. are not identified sites for affordable housing production. 715 Prospect Ave. and 807 Prospect Ave. are part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process, including a voter approved modification of the citywide height limit to allow for the construction of buildings on this site taller than three stories. The Housing Element simply says that the possibility exists, and that the Housing Element programs make it more likely, that these sites will be redeveloped during the planning period.
Josh Albrektson (November 22, 2022)
Every single house in the next two pictures are single family homes that South Pasadena claims will be torn down and replaced with a low income unit. By law, south Pasadena is required to subtract the current unit count from any potential future unit count, so for all of these they should not be able to claim any housing.
• How addressed: Images were not provided as part of this comment. It is unclear which single family homes are being discussed in this comment.
For every current housing site in the downtown specific plan South Pasadena didn’t subtract the current units on the site as required by law. For example at 820 Mission there is a 38 unit condo complex. South Pasadena is claiming 17 units at this site and not subtracting any of the current condos.
This is the case for 50 of the sites claimed in the Downtown Specific Plan.
Sent from my iPad
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-143 Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The projected number of units for 820 Mission St. does subtract the existing dwelling units from the calculation of the projected net increase in housing units on the site.
The site is an approximately 1.75 acre and is located in the proposed Downtown Specific Plan area. This area will allow for a maximum of 70 du/ac, which means the site will accommodate up to 122 dwelling units. As mentioned in the comment, there are currently 38 existing units on the site, which would net 84 housing units if it were to be redeveloped. The analysis of the Downtown Specific Plan anticipates there is a 20% likelihood that a parcel in the Downtown Specific Plan is redeveloped. Twenty percent of 84 housing units is 16.8, which was rounded to 17 as the number of net new housing units anticipated on the site prorated for the likelihood of redevelopment of the site.
Josh Albrektson (November 22, 2022)
All page numbers refer to the 3rd draft page numbers
For APN 5315021008 on page 191 South Pasadena claims 27 units on a 0.57 lot. This is the southern part of the mission meridian complex built in 2006 and there are already 23 units on this lot.
For APN 5315021031 on page 191 SoPas claims 20 units on a 0.45 lot. This is the middle part of the Mission Meridian complex built in 2006 and there are already 20 units on this lot.
For APN 5315021051 on page 188 SoPas claims 24 units on a 0.65 acre lot. This is the north part of the Mission Meridian complex built in 2006 that already has 23 condos on the lot.
For APN 5315007055 on page 185, SoPas claims 22 units on a 0.91 acre lot. This is a 21 unit condo complex built in 1988.--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: Each of these lots are located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 22, 2022)
On page 193 it is claimed that the realistic capacity is based on 20% of the sites being developed at 100% capacity.
The total acreage is 54.95 acres with a density of 50 DU/acre. This is a maximum capacity of 2748. 3 - 497
Appendix B
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Page B1-144 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE 20% of 2748 is 550 units, not 642 units as claimed.
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Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The maximum density of the Downtown Specific Plan is 70 du/ac, not 50 du/ac. Table VI-51 has been corrected in the Fourth Draft to reflect the corrected maximum density. Table VI-51 does identify the total acreage of the Downtown Specific Plan area that has the potential to be redeveloped as 54.95 acres. At a density of 70 du/ac, the maximum capacity of this area is 3,846 units. Twenty percent of 3,846 is 769, which is more than the 642 units that is anticipated to be developed in the Downtown Specific Plan area during the planning period.
Josh Albrektson (November 22, 2022)
For APN 5310016028, this is a 15 foot wide lot that is somebody's garden. https://twitter.com/JalbyMD/status/1538996186765348864?s=20&t=5E2YvbfAPxR8AN1ULAtR6 Q
https://twitter.com/JalbyMD/status/1538996243224924160?s=20&t=5E2YvbfAPxR8AN1ULAtR6 Q
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Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5310016028 has been removed from the Housing Element.
Josh Albrektson (November 22, 2022)
1522 Mission Street is the historic Fair Oaks Pharmacy that has been operating for over 100 years. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? What is the substantial evidence the current use will be discontinued as required for low income sites??? It made it 100 years, it is going to close in the next 7?? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-145 • How addressed: 1522 Mission Street is not an identified site for affordable housing production. 1522 Mission Street is a part of the Downtown Specific Plan area and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 22, 2022)
1401 Mission Street is a 3 story condo complex built in 2006. What is the substantial evidence the current use will be discontinued as required for low income sites??? Are they going to tear down new condos for new condos?? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1401 Mission Street is located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 22, 2022)
At 820 Mound Ave the city is about to install electric panels and have a long term lease with SoCal Edison. This was just voted on 3 months ago. Is South Pasadena planning on breaking this lease?? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 820 Mound Ave. is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 820 Mound Ave. is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period. 3 - 499
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-146 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson (November 22, 2022)
For Site 16 you guys claim that only the parking lot will be developed and not the newly renovated grocery store that had a grand re-opening on August 3rd.
You can hear the city council and planning commission trying to explain possible ways that the parking lot could be developed without disrupting the grocery store from 27:00 to 31:00 of the November 9th meeting. They were discussing what they would say that HCD would find acceptable. It is pretty obvious that the owner is not themselves considering developing just the parking lot. http://www.spectrumstream.com/streaming/south_pasadena/2022_11_09.cfm How can you guys claim there is substantial evidence that the parking lot will be developed when it is clear from the meeting that the owner is not actually considering it?? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The property owner of Site 16 has provided a letter expressing their intention to redevelop the entire site with a new store within the 6th Cycle. It is anticipated that the new store will be approximately the same size as the existing store, leaving an area equivalent in size as the parking to for development of parking and residential uses. Appendix A has been updated to reflect this additional information.
Josh Albrektson (November 22, 2022)
For Site 14 the owner is getting a new foundation for one home and once that homes foundation is finished he is planning on moving on and doing the foundation of the second home. This site is 2 blocks from city hall. You guys can go down and see the Foundation Repair LA INC sign in front of 1508 El Centro right now. Attached to this e-mail is a picture of this sign if it doesn’t make it into the comments section of the Housing Element.
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-147 How can you guys claim there is substantial evidence that the current use is being discontinued when the current owner of these single family homes is getting two new foundations at this time?? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The property owner of Site 14 has confirmed with the city that they are interested in redeveloping the site with multifamily housing.
Josh Albrektson (November 22, 2022)
802 Fair Oaks is the Fair-Hope building and is one of the few remaining early twentieth century structures in South Pasadena Fair Oaks Corridor. This is South Pasadena designated cultural heritage landmark number 49. Are you going to allow it to be torn down?? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-148 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: 802 Fair Oaks is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 802 Fair Oaks is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 22, 2022)
For APN 5308002059 this is a front yard and driveway
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Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5308002059 has been removed from the Housing Element.
Josh Albrektson (November 22, 2022)
The following APNS do not exist in the Los Angeles County Records and if claims that homes could be built on them they should have APNs that actually exist:
5308023004
5317009909
5310034900
5310018903
5314017901
5314016044
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Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The APNs identified in this comment have been updated in the Housing Element to reflect the new APNs given to these parcels since the Housing Element was first drafted.
3 - 502
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-149 Josh Albrektson (November 22, 2022)
For APN 5311001018, at the Design review board meeting of Sept first a plan was approved for a new commercial building. This site is not eligible to be considered for housing. https://www.southpasadenaca.gov/home/showpublisheddocument/30612/638000752592000000 --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5311001018 has been removed from the Housing Element.
Josh Albrektson (November 22, 2022)
The following is a list of single family homes and duplexes that South Pasadena is claiming will be new housing in the 3rd Housing Element/Downtown Specific Plan. In every case you guys are claiming the homes would be torn down and replaced by a low income unit in this planning period without subtracting the original home from your calculations. Sometimes you guys have a duplex that would turn into one low income unit, which is a net -1 home.
You are required to subtract out the original housing and only claim NET housing for RHNA.
Single family homes
515 Mission st
519 Mission St
802 Orange Grove Ave
815 Magnolia
821 Magnolia
827 Magnolia
805 Prospect
700 Prospect
704 Prospect
909 Magnolia
913 Magnolia
806 Meridian
3 - 503
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-150 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE 808 Meridian
810 Meridian
1007 Hope St
808 Fairview
806 Fairview
804 Fairview
1103 Hope st
1107 Hope St
1111 Hope St
803 ½ Fremont Ave
807 Fremont Ave
812 El Centro
1011 Mound Ave
825 Brent Ave
Duplexes
706 Prospect
521 Mission St
1115 Hope St
1117 Hope St
1123 Hope St
833 Brent Ave
817 Adelaine
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
3 - 504
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-151 • How addressed: All of these properties are located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 23, 2022)
1100 El Centro is the South Pasadena Unified School District. They just purchased this building last year and moved all of their offices into this building. What is the substantial evidence the current use will be discontinued as required for low income sites??? Have you talked to anybody at the school district?
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1100 El Centro is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1100 El Centro is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 23, 2022)
For APN 5314018010 it is in the middle of the block and no access. https://twitter.com/JalbyMD/status/1538994198770339843?s=20&t=5E2YvbfAPxR8AN1ULAtR6 Q
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5314018010 is a flag lot that has access to Bank Street.
Josh Albrektson (November 23, 2022)
1050 Fremont Ave is Calvary Presbeterian Church. It is one of the oldest churches in the city, at least 4 stories tall, and probably the best looking church in the city. Would South Pasadena allow this building to be torn down?? What is the substantial evidence the current use will be discontinued as required for 3 - 505
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-152 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE low income sites??? Have they talked to the church? It also has a preschool Monday to Friday which is one of the more popular pre-schools in the city but they are COVID deniers. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1050 Fremont Ave is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1050 Fremont Ave is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 23, 2022)
The building at 1019 El Centro is the South Pasadena Bank Building. It is the first bank in the city and is South Pasadena designated cultural heritage landmark number 8. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? Is there substantial evidence the current use will be discontinued??
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1019 El Centro is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1019 El Centro is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 23, 2022)
For Site 16, Can you guys point to examples of grocery stores that have had their parking lot turned into housing while the grocery store remained open??
--
3 - 506
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-153 Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The property owner for Site 16 has provided a letter expressing their intention to redevelop the entire site with a new store. It is anticipated that the new store will be approximately the same size as the existing store, leaving an area equivalent in size as the parking to for development of parking and residential uses. Appendix A has been updated to reflect this additional information.
Josh Albrektson (November 23, 2022)
1023 Fair Oaks Ave is the historic Rialto Theater. It was built in 1925 and is one of the most historic theaters in San Gabriel Valley. There currently is a lease by Mosaic Church for another 20 years. It is South Pasadena designated cultural heritage landmark number 25. Would South Pasadena allow this historic theater to be torn down?? What is the substantial evidence the current use will be discontinued as required for low income sites???
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1023 Fair Oaks Ave is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1023 Fair Oaks Ave is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 23, 2022)
For APN 5311010065 this is someones front yard
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5311010065 has been removed from the Housing Element. 3 - 507
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-154 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson (November 24, 2022)
1000 Mission Street is the Century House. It is also where Micheal Myers lived in the movie Halloween.
It is the second oldest building In South Pasadena built in 1888 and was South Pasadena designated cultural heritage landmark number 34. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? Is there substantial evidence the current use will be discontinued?? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1000 Mission Street is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1000 Mission Street is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 24, 2022)
1500 to 1518 Mission Street were all built over 100 years ago and considered to be part of the historic business district. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? What is the substantial evidence the current use will be discontinued as required for low income sites??
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The buildings at 1500 to 1518 Mission Street are not a part of a designated historic district, although they are eligible to become part of a historic district. The buildings at 1500 to 1518 Mission Street are not identified sites for affordable housing production. The buildings at 1500 to 1518 Mission Street are a part of the Downtown Specific Plan area. An areawide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The Housing Element simply says that there is a chance that this site is redeveloped during the planning period.
Josh Albrektson (November 24, 2022)
3 - 508
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-155 For APN 5314016030, this is in the middle of the block and there is no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5314016030 has been removed from the Housing Element.
Josh Albrektson (November 24, 2022)
815 Fairview is a 3 story condo complex built in 2006. What is the substantial evidence the current use will be discontinued as required for low income sites??? Are they going to tear down new condos for new condos?? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 815 Fairview is located in the Downtown Specific Plan area, where an areawide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 25, 2022)
For APN 5317011025, this is in the middle of the block and there is no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5317011025 has been removed from the Housing Element.
Josh Albrektson (November 25, 2022)
For APNs 5308034018, 5308034018, and 5306006001, these are on a mountain and has no street access --
3 - 509
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-156 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APNs 5308034018, 5308034018, and 5306006001 have been removed from the Housing Element.
Josh Albrektson (November 25, 2022)
1501 Mission Street was built in 1923 and is South Pasadena designated cultural heritage landmark number 37. What is the substantial evidence the current use will be discontinued as required for low income sites??? It also has an apartment on top and you are required to subtract the current apartments from the proposed apartments for your counting of units. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1501 Mission Street is located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 25, 2022)
804 to 810 fairview and 1103 to 1123 Hope street contained multiple single family homes and apartments. You are required to subtract the current unit count from any proposed unit count. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 804 to 810 Fairview and 1103 to 1123 Hope Street are located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 25, 2022)
954 Mission Street is the Mission Hotel and one of the oldest buildings and is considered historic by South Pasadena. It is South Pasadena City Landmark number 26. Is South Pasadena going to allow a 3 - 510
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-157 by right housing project on this site if it is 20% low income????? Is there substantial evidence the current use will be discontinued??
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 954 Mission Street is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 954 Mission Street is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 25, 2022)
For Low Income site number 3 there are 8 above moderate income units. This is clearly stated on A1-
15. There is a duplex on one APN, a duplex on one APN, and a 4 plex on the 4th APN. On Page 183 Table VI-50, instead of putting 2, 2, and 4 as the unit count for Site three, you guys put 8 on one APN and then claimed 7 and 14 low income units on the other APNS that you shouldn’t be able to claim. So there are actually 21 low income units you are claiming on Site 3 that you cannot claim. Please remove these 21 units from your calculations.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: Table VI-50 has been updated to correct reflect what is shown in Appendix A.
Josh Albrektson (November 26, 2022)
1001 Fremont Ave is the South Pasadena Post Office. It is a historic building and the main Post Office of South Pasadena that includes all sorting for delivered mail. What is the substantial evidence the current use will be discontinued as required for low income sites??? Have you guys talked to anybody at the United States Postal Service??
--
Josh Albrektson MD
3 - 511
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-158 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Neuroradiologist by night
Crime fighter by day
• How addressed: 1001 Fremont Ave is not included in Table VI-51 of the Housing Element.
The map in Figure A-3a has been updated to properly reflect the parcels identified in Table VI51.
Josh Albrektson (November 26, 2022)
For APN 5320018022 this is a silver of land with a homes garden on it. https://twitter.com/JalbyMD/status/1538998300530970626?s=20&t=5E2YvbfAPxR8AN1ULAtR6 Q
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5320018022 has been removed from the Housing Element.
Josh Albrektson (November 26, 2022)
820 Mission street is a group of Condos that were built in 2017. You actually site them as representative examples of recent building. What is the substantial evidence the current use will be discontinued as required for low income sites??? Are they going to tear down new condos for new condos?? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: See discussion of 820 Mission Street in response to comment dated November 22, 2022.
Josh Albrektson (November 26, 2022)
For APN 5311017018, there is half a home on the land
--
Josh Albrektson MD
3 - 512
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-159 Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5311017018 has been removed from the Housing Element.
Josh Albrektson (November 26, 2022)
For APN 5320030038, this is in the middle of the block and there is no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5320030038 has been removed from the Housing Element.
Josh Albrektson (November 26, 2022)
For APN 5311006068 there is a home on the land
https://www.redfin.com/CA/South-Pasadena/1250-Oak-Hill-Ave-91030/home/7003471 --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5311006068 has been removed from the Housing Element.
Josh Albrektson (November 27, 2022)
For the following APNs there is no street access:
5311010028
5311010029
5311010030
5311010033
5311010034
--
3 - 513
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-160 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: As noted in Notes 3 to Table VI-44, These parcels are part of a potential project to develop duplexes and townhouses on all of these parcels by the same developer who has purchased all of the parcels. The City has confirmed that there is access to this set of parcels.
The parcels include 10 vacant parcels and one nonvacant parcel.
Josh Albrektson (November 27, 2022)
For APNs 5308034017 and 5308034003 these are on a mountain with no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APNs 5308034017 and 5308034003 have been removed from the Housing Element.
Josh Albrektson (November 27, 2022)
913 Meridian Street is the historic Meridian Iron Works Building. It was a Japanese history museum but when South Pasadena kicked their Japanese residents out of the city in 1942 it was confiscated. It is now the home of the South Pasadena Preservation Foundation. It was built in 1887 and is City Landmark number 5. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? Is there substantial evidence the current use will be discontinued as required for a low income site?? Will South Pasadena allow it to be torn down? --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 913 Meridian Street is not included in Table VI-51 of the Housing Element.
The map in Figure A-3a has been updated to properly reflect the parcels identified in Table VI51.
Josh Albrektson (November 27, 2022)
For APNs 5312016016 and 5308021009, these are on a mountain and has no street access --
3 - 514
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-161 Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APNs 5312016016 and 5308021009 have been removed from the Housing Element.
Josh Albrektson (November 27, 2022)
920 Fremont Ave is Grace Brethren Church. The building was built in 1907 and is City Landmark number 22. Would South Pasadena allow this building to be torn down?? What is the substantial evidence the current use will be discontinued as required for low income sites??? Have they talked to the church?
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 920 Fremont Ave is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 920 Fremont Ave is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 27, 2022)
Baranger Studios at 729 Mission St is one of the oldest buildings in South Pasadena and considered Historic by South Pasadena standards. It is South Pasadena designated cultural heritage landmark number 27. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? Is there substantial evidence the current use will be discontinued?? https://www.pasadenanow.com/weekendr/historic-iconic-baranger-studios-building-in-southpasadena-is-sold-for-6-8-million/ --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
3 - 515
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-162 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: 729 Mission St is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 729 Mission St is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 28, 2022)
812 Fremont is a 3 story condo complex. What is the substantial evidence the current use will be discontinued as required for low income sites??? Are they going to tear down condos for new condos?? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 812 Fremont Avenue is located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element.
Josh Albrektson (November 28, 2022)
For APN 5308002064, this is in the middle of the block and there is no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5308002064 has been removed from the Housing Element.
Josh Albrektson (November 28, 2022)
For APN 5317009903, the actual APN is 5317009033 and this is someone's garden. --
Josh Albrektson MD
3 - 516
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-163 Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5317009903 has been removed from the Housing Element.
Josh Albrektson (November 28, 2022)
824 FairOaks is the Comerica Bank Building. It is one of the oldest buildings in South Pasadena. What is the substantial evidence the current use will be discontinued as required for low income sites??? Would South Pasadena allow it to be torn down??
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 824 Fair Oaks Avenue is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 824 Fair Oaks Avenue is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 28, 2022)
For APN 5308022009, there is a home on the land (real APN of 5308022043 --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5308022009 has been removed from the Housing Element.
Josh Albrektson (November 28, 2022)
For APN 5312031029 there is a home on the land
https://www.redfin.com/CA/SOUTH-PASADENA/20-SHORT-WAY-ST-91030/home/7004227 --
3 - 517
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-164 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5312031029 has been removed from the Housing Element.
Josh Albrektson (November 28, 2022)
For APN 5308019034 this has a home and backyard on it
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5308019034 is a developable lot between two existing homes. Currently it contains a patio structure for one of the neighboring homes.
Josh Albrektson (November 28, 2022)
812 Orange Grove, 810 Orange Grove and 802 Orange Grove are all 2 story apartment buildings. You guys are claiming there is a chance that they might be torn down for 3 story apartments. Can you guys point to a place where this has happened somewhere else?? What is the substantial evidence the current use will be discontinued as required for low income sites??? And you are required to subtract the current apartments from the proposed apartments for your counting of units. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 812 Orange Grove, 810 Orange Grove and 802 Orange Grove are not identified sites for affordable housing production. 812 Orange Grove, 810 Orange Grove and 802 Orange Grove are a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The Housing Element simply says that there is a chance that this site is redeveloped during the planning period. The Downtown Specific Plan will allow for heights at least six stories or 60 feet, in accordance with Program 2.n.
Josh Albrektson (November 28, 2022)
3 - 518
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-165 For Low income site number 12 the city only owns 0.19 acres (35%) of the site. This is not large enough for a low income site. If the city does not have ownership of the whole site by Jan first, 2026, would it be willing to remove it as a low income site?
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: Program 3.o requires the City to evaluate the effectiveness of identified sites and make adjustment as necessary such as increasing densities, modifying development standards, removing sites and rezoning additional sites no later than December 31, 2024 and December 31, 2026. Site 12 will be part of this review and evaluation.
Josh Albrektson (November 28, 2022)
The block surrounded by Meridian, El Centro, Diamond, and Mission street is a national historic district and has been since 1983. These buildings cannot be torn down. https://catalog.archives.gov/id/123859524
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: While some of the building on this block are identified in the National Registrar of Historic Places with local historic significance, some of the buildings in this block have been deemed to not contribute to the historic character of the district. Furthermore, buildings identified as historic identified in the National Registrar of Historic Places can be adaptively reused (see Program 3.b) and added on to so long as the character defining features of the existing structures remain.
Josh Albrektson (November 28, 2022)
1200 Fair Oaks is an Arco station that was recently sold. In the listing brochure it mentioned that Arco has a 15 year lease on the property. What is the substantial evidence the current use will be discontinued as required for low income sites???
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
3 - 519
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-166 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: 1200 Fair Oaks Avenue is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1200 Fair Oaks Avenue is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 29, 2022)
For APN 5308034016 and 5308021008 this is on a mountain and has no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APNs 5308034016 and 5308021008 have been removed from the Housing Element.
Josh Albrektson (November 29, 2022)
700 Orange Grove Ave is a 3 story apartment building. You guys are claiming there is a chance that this 3 story apartment building might be torn down for a replacement 3 story apartment building. Can you guys point to a place where this has happened somewhere else?? What is the substantial evidence the current use will be discontinued as required for low income sites??? And you are required to subtract the current apartments from the proposed apartments for your counting of units. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: As addressed in the response to comment dated November 21, 2022, 700 Orange Grove Ave. is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 700 Orange Grove Ave. is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process, including a voter approved modification of the citywide height limit to allow for the construction of buildings on this site taller than three stories. The 3 - 520
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-167 possibility exists, and that the Housing Element programs make it more likely, that these 20 year old builds are redeveloped during the planning period.
Josh Albrektson (November 29, 2022)
For APN 5308002072, this is in the middle of the block and there is no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APN 5308002072 is a buildable lot that has existing driveway access through APN 5308002060.
Josh Albrektson (November 29, 2022)
The former bank at 901 Fair Oaks Ave just underwent an extensive renovation changing it from a Bank to 5 commercial units including Chiptole and Habit Burger (which I eat at 4 times a week). An ATT store just opened and Rice and Nuri is about to open in the next couple of months. What is the substantial evidence the current use will be discontinued as required for low income sites??? https://southpasadenan.com/fairoaksmission-project-chipotle-coming-to-south-pasadena/ --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 901 Fair Oaks Avenue is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 901 Fair Oaks Avenue is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 29, 2022)
Lewis Markey building at 634 Mission Street is the South Pasadena designated cultural heritage landmark number 31. It was built in 1928 and was designated a landmark 35 years ago. Is South Pasadena going to allow a by right housing project on this site if it is 20% low income????? Is there substantial evidence the current use will be discontinued??
3 - 521
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-168 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE https://calisphere.org/item/e5794b9f06005a528fedab717bb7332b/ --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 634 Mission Street is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 634 Mission Street is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 29, 2022)
The Trader Joes at 613 Mission is the second Trader Joes in history. It is also one of the most active grocery stores in the city. What is the substantial evidence the current use will be discontinued as required for low income sites??? And you also removed this site in previous drafts because you didn’t believe the current use would turn over.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 613 Mission Street is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 613 Mission Street is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 30, 2022)
For Low Income Site number 8 you describe an underground gasoline tank and soil contamination.
How much would it actually cost to remediate the site?? Can you find costs or similar sites that have been used for housing?? And there is no 0.71 acres of extra land in South Pasadena that the public works yard could be moved to. Is South Pasadena willing to state that there will be a RFP issued by Jan first, 2025 and if there is no plans for housing by Jan 2026 than the site would be removed as a possible site?
3 - 522
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-169 --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: Appendix A has been revised with additional information regarding the environmental constraints for Site 8. Program 3.o has been modified to require the City to “evaluate the effectiveness of identified sites and make adjustment as necessary such as increasing densities, modifying development standards, removing sites and rezoning additional sites” no later than December 31, 2024 and December 31, 2026.
Josh Albrektson (November 30, 2022)
For APNs 5311010027 and 5308006024 these are on a mountain with no street access --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: APNs 5311010027 and 5308006024 have been removed from the Housing Element.
Josh Albrektson (November 30, 2022)
For Low income site Number 2 there is a claim that Bullseye Glass and Judson studios are relatively new tenants. If you label the 6 buildings from west to east, these are buildings 1 and 2.
Those Bullseye and Judson have been there since November 2016 as shown in this google image:
https://goo.gl/maps/s95ehqP1Z7uUU8ZBA
It is actually the entire second floor of building number 3 and the entire building number 5 that just were leased in the past year to Yellow Pike Media and Elementary. How can you guys claim there is substantial evidence that the current uses will be discontinued when there were just new leases signed at the site??
Loopnet Brochure for the listings for buildings 3 and 5. https://images1.loopnet.com/d2/NjuUcEIzCBdbskuj3g5Mj_3zqct3H2jyorx1Mu5ckGw/149161Pasa denaSouthPasadenaBrochure.pdf
--
3 - 523
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-170 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: As stated in Appendix A, Site 2 is an under-utilized commercial building that will be redesignated as mixed-use. The land owner has expressed interest in redeveloping the site under the new land use, once adopted.
Josh Albrektson (November 30, 2022)
707 to 809 Meridian is a 3 story condo complex built in 2006. You guys cite it as an example of buildings recently built in South Pasadena. What is the substantial evidence the current use will be discontinued as required for low income sites??? Are they going to tear down new condos for new condos?? And you are required to subtract the current apartments from the proposed apartments for your counting of units.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 707 to 809 Meridian is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 707 to 809 Meridian is a part of the Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period.
Josh Albrektson (November 30, 2022)
1124 Fair Oaks Ave is a 3 story Freemason building. It is one of the oldest buildings in South Pasadena.
What is the substantial evidence the current use will be discontinued as required for low income sites??? Would South Pasadena allow it to be torn down??
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: 1124 Fair Oaks Ave is not an identified site for affordable housing production and therefore the Housing Element does not need to show there is substantial evidence that the existing use will discontinue during the planning period. 1124 Fair Oaks Ave is a part of the 3 - 524
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-171 Downtown Specific Plan area. An area-wide analysis was conducted of the Downtown Specific Plan where it is expected that some portion of the area will be redeveloped during the planning cycle due to the adoption of the new Downtown Specific Plan and policies implemented as part of the Housing Element update process. The possibility exists, and that the Housing Element programs make it more likely, that this site is redeveloped during the planning period. 3 - 525
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-172 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Sam Shink, The Albertsons Companies (December 1, 2022)
• How addressed: Appendix A has been updated with additional information from property owner.
3 - 526
A AJ.bertsons
Companies
Angelica Frausto-Lupo
Community Development Director
City of South Pasadena
1414 Mission Street
South Pasadena, CA 91030
December 1, 2022
W1mE1<.'s THLEl'HO~E NLMBHR: (7 l4) 300-6727
\VRTTER'S E-J\l[AIT.: SAf-,.,f.SIITT\TJ< l @ .<:;AFE\VAY.CO'M Via Hand Delivery
Subject: Pavilions #2228· 1213 South Fair Oaks Avenue. South Pasadena Dear Ms. Frausto-Lupo:
I am writing in response to your request related to the City's draft General Plan Housing Element to advise you that ACI, parent company of Pavilions, is considering redevelopment of the subject property sometime prior to 2029. The plans being considered include redevelopment of the entire site and would consist of a new store, residential uses, and parking. We look forward to continuing to serve the residents of South Pasadena.
Very truly yours,
SAMSHINK
Director of Real Estate
Jetter to city of SP regarding reckvefopment plans
Working together to be the fwndi, ~~~
i'.migos IE~ l:d±ffl@. Albertsons SAFEWAY(,_ f@ffl PAVILIONS.
ACME star. CARRSI" . ) ~ VONS @ !:.'!?..~ ~ A eJ.~\1!1Uns- ~-~ Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-173 Mark Gallatin (December 5, 2022)
I would respectfully like to suggest the following alternate language for that found on page 216 of the September 2022 Draft Housing Element:
Program 1.b. - Convert Caltrans Homes to Affordable Housing The City will leverage the 68 Caltrans surplus properties that have resulted from the State's cancellation of a proposed route to extend the 710 freeway through South Pasadena to generate capital to create new and rehabilitated, deed restricted, affordable housing units throughout the city. The City has initiated a property sales program for the 710 freeway surplus properties. The City worked with Senator Portantino to pass SB 381 and the emergency rulemaking regulations were released on March 28, 2022. The City will have priority to purchase the surplus properties after the existing tenants. The City has been working with Caltrans to obtain property files and to schedule inspections in order to evaluate the surplus properties. SB 381 also requires that any proceeds from historic properties purchased by the City at Caltrans minimum (acquisition) price and then subsequently sold at Fair Market Value be used to generate affordable housing at a ratio of 3 to 1. Funding has been secured for a feasibility study on the surplus properties that are available to be converted to permanent affordable housing.
Eight-year Objective: Complete a feasibility study and use the recommendations to support decisionmaking regarding possible strategies, including but not limited to, partnerships with non-profit affordable housing developers, to expand housing mobility opportunities for lower-income households and revitalize underused areas.
Funding Source: Measure H
Responsible Agency: Community Development Department/City Manager’s Office Timeframe: Conduct feasibility study in 2022; technical assistance and work with nonprofits at least annually throughout planning period. More specific timing pending State implementation processes. • How addressed: As detailed in Program 1.b, the City is complying with the acquisition process authorized by SB 381 for the acquisition of the surplus Caltrans properties. The City has not made any determinations regarding the eventual dispensation of the Caltrans homes. Currently, the City is doing its due diligence regarding the condition of the homes and the possible financing mechanisms for rehabilitation of the properties. This analysis includes researching possibilities regarding increasing the number of units on Caltrans home sites, where feasible. However, since the due diligence work is ongoing, it is not possible for the City to commit to any course of action regarding these homes at this time.
Comments on the Public Review 4th Draft Housing Element Josh Albrektson (December 5, 2022)
Page A1-11 has an outdated picture
--
Josh Albrektson MD
Neuroradiologist by night
3 - 527
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-174 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Crime fighter by day
• How addressed: The map on page A1-11 has been updated.
Josh Albrektson (December 5, 2022)
The following APNS you are claiming 100% chance of 100% development in the downtown specific plans, including the Mission Meridian condos:
units
5315007055
The following 3 are the mission meridian Condos that you are claiming a 1 for 1 replacement with low income units.
5315021051
5315021008
5315021031
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: As addressed in the response to the comment dated November 22, 2022 regarding these same parcels, each of these lots are located in the Downtown Specific Plan area, where an area-wide analysis was conducted. As discussed above for 820 Mission St., the number of existing units was removed from the projected calculation of net new units being claimed in the Housing Element..
Delaine Shane (December 6, 2022)
To the Housing Element Consultant and City Management:
Enclosed are my comments pertaining to the red-lined version of the Draft Housing Element, Version
4. Frankly, I didn’t read your recent document—just skimmed it. No realistic time was given to us to allow for a thoughtful read through. In addition, while I appreciated the City’s turnout at our most 3 - 528
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-175 recent walk through in the Meridian neighborhood that has several of the vacant Caltrans properties, having the Consultant snap a picture of us and marking that check box as being part of public engagement is a false narrative.
A mindset at City Hall continues to exist, as exhibited in this draft document, that the non-legislative alternative to SB 381 and the Caltrans properties is either non-existent or illegal. It is NOT illegal. I and others have already provided you with information readily available on the internet that it has been done and can be done in California by government entities.
Nothing in Caltrans’ regulations prevents that agency from implementing the non-legislative alternative that the South Pasadena Preservation Foundation has so clearly prepared and presented to the City on numerous occasions. Just because Caltrans says NO? So, why aren’t our City officials meeting with our state legislators to convince Caltrans otherwise? This wouldn’t be the first time that Caltrans is misusing its powers to the detriment of our community. I and my neighbors expect that our City management and Consultant support us and not dictate a choice that they themselves would not appreciate if they lived in our community.
All we want are for the vacant properties to be sold to qualified buyers (be they present/former Caltrans tenants or other qualified buyers) who will fix up their homes, live in them, pay their fair share of property taxes, and contribute to our wonderful and diverse neighborhood. This can still happen if the Housing Element is revised to include the very viable non-legislative alternative to SB 381, i.e., side-byside escrow agreements. These properties were what the Freeway Fighters were fighting to preserve for over 60 years. It would be a harsh and cruel irony if the houses were torn down not by Caltrans but by the City or its designees (HREs).
Sincerely,
Delaine Shane
2003 Meridian Avenue
[Continued on next page]
3 - 529
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-176 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
1 2-3 “SB 381 requires that Caltrans
offer unoccupied homes for
sale to the City of South
Pasadena. If the City does not
purchase the properties,
Caltrans will offer them for
sale to the Los Angeles
County Development
Authority (LACDA), and if
LACDA does not purchase
the homes, they will be
offered to a Housing Related
Entity (HRE).”
This statement does not include the non-legislative
approach on the disposition of vacant Caltrans
housing that the South Pasadena Preservation Plan
(SPPP) has been presenting to the City of South
Pasadena (City). That is, the more efficient,
economic, and expeditious process of side-by-side
escrow agreements for unoccupied homes. Yes, this
section of the Housing Element is on legislation;
however, MANY discussions between the City and
the public also concerned a parallel track involving a
viable non-legislative track in conjunction with SB
381.
The City did agree to consider this non-legislative
approach during previous discussions between the
City Council and Ad Hoc Committees. This process
is legal and is done by other governmental entities.
If Caltrans is not interested in such an approach, why
isn’t our City Council seeking relief on this matter
with our newly elected State Assembly Member
Michael Fong or other prominent state legislators?
Getting entangled in a large real estate portfolio and
process could result in the City Council not meeting
its other mandates to its residents. As a reminder,
here is a slide from the City Council Agenda, Item
No. 14, July 21, 2021 (though I vehemently disagree
that this is a “perceived problem”):
SB 381, which the City supported,
provides a framework for Caltrans
to sell its surplus property in South
Pasadena. If the City does not
purchase the properties, it is
expected that Caltrans will offer
them to the Los Angeles County
Development Authority and then
on to other parties identified in the
law. Caltrans must offer these
homes for sale in accordance with
SB 381, other options do no exist
under existing law.
3 - 530
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-177 Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
The City should behave as a pass through to allow
current/former tenants and/or qualified home
buyers and not get into the real estate developer’s
market nor sell to HREs. Our community want the
homes to be returned to homeowners that meet the
criteria of the Roberti Act so that these properties
return to the tax roll. Sixty plus years of these
Caltrans homes have yielded NO PROPERTY
TAXES! It is time for this situation to be changed
by relying on side-by-side escrows. THEY ARE
NOT ILLEGAL!!! Specific text should be added to
the fourth version of the Housing Element that
includes the option of side-by-side escrows.
2 3 “AB 2011, the Affordable
Housing and High Road Jobs
Act of 2022, was signed into
law on September 28, 2022.
AB 2011 allows for
ministerial, by-right approval
of affordable housing on
commercially-zoned lands,
and allows for mixed-income
How does the City intend to be a good steward of
our precious historic resources in light of AB 2011?
What protections will there be for the City’s
approved historic landmarks and potentially historic
structures have in commercially zoned lands?
It is difficult to view specifics in Appendix A as to
which structures would fall under AB 2011, but I
have been told that the Kaldi’s Coffee building could
AB 2011 does not apply to projects
where, “the development would
require the demolition of a historic
structure that was placed on a
national, state, or local historic
register.”
3 - 531
Perceived problems
~
1. South Pasadena Preservation Foundation (SPPF
Subcommittee provided a revised proposal on
April 14th and welcomes the opportunity to
discuss priorities.
2. SPPF believes there is a non-legislative solution
and would like to see the City work with the
Senator to transfer managing control of the
program to the local level.
3. Viability of the side-by-side escrow concept
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-178 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
housing along commercial
corridors so long as the
project meets certain labor
and environmental criteria.”
be vulnerable to being torn down. This is the City’s
first bank and still retains its integrity, association, and context from a historic perspective. Does that
mean that many of our landmarks whether on the
City’s list or not, can be destroyed?
Also, what is meant specifically by the phrase
“…certain labor and environmental criteria?’ This is
a legal document and one which will be available to
the public. The residents do not necessarily have the
time or the opportunity to cross check AB 2011 with
other documents to understand what this means or
what the ramifications are for them and for the City.
3 5 Program 1.b - Convert
Caltrans Homes to
Affordable Housing
“The California Department
of Transportation (Caltrans)
is obligated by State law to
offer unoccupied Caltransowned surplus residential
properties located in South
Pasadena for sale to the City
of South Pasadena. The City
has expressed interest to
Caltrans in purchasing these
twenty (20) unoccupied
surplus properties through
this State program, which
contain twenty-two (22)
Please clarify the text -- will this conversion program result in rental property or home ownership? My
neighbors and I support affordable home ownership
for these vacant homes where the owners will fix the
houses up and live in them and contribute to the well
being of our neighborhood, which is quite
diversified. The homeowners, like us, will then be
paying property taxes. Currently, Caltrans pays zero
in property taxes.
The vast numbers of these vacant houses are in the
southwestern portion of the City. If they go to
HREs, then the houses will continue to not be on
the tax rolls. The neighborhood will continue to be
disproportionately impacted due to the legacy of the
SR 710 Extension Project.
These decisions regarding whether
the homes will be for-sale or rental,
or whether an HRE will be involved
in the renovation or other aspects
of the project, have not been made
by the City at this time.
3 - 532
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-179 Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
housing units. If the City does
not purchase the properties,
Caltrans will offer them for
sale to the Los Angeles
County Development
Authority (LACDA), and if
LACDA does not purchase
the homes, they will be
offered to a Housing Related
Entity (HRE). State law
requires Caltrans to place a
deed restriction on these
surplus properties ensuring
that they are made available
for purchase by moderateincome households or for
rent to lower income
households to moderate or
lower income households.
Through this Program, if
economically feasible, the
City will preserve and
rehabilitate these properties,
and make them available to
moderate and lower income
households.”
This program is biased and not equitable where
affordable housing should be distributed throughout
the City. The City Council has already approved
several large mixed-use developments with NO
affordable units (except for Mr. Odom Stamp’s
project at 625 S. Fair Oaks Avenue). Yet, these
Caltrans homes that have been allowed to
deteriorate over the decades are being considered as
affordable rentals rather than as affordable home
ownership that will put these properties back on the
tax roll. The City should NOT be involved with
rehabilitating these homes. Our streets have not
been paved for decades, the failing West Side
Reservoir is a human disaster waiting to happen, we
don’t have decent street lighting, we deal with
speeders that don’t even live in our neighborhoods
but wear out our pot-holed and ever deepening
cracks (which in turn will impact existing
substructures embedded below the streets), etc.
How can the City consider funding this program
through the General Funds or relying on HREs?
Why not provide the residents who live here now
with the services that we deserve. As mentioned in
Comment No. 1, the City should employ the nonlegislative approach, i.e., the side-by-side escrow agreements.
The City has had issues with HREs in the past who
don’t take responsibility in managing their
properties, not to mention the loss in tax revenues
to the state and City. There is also nothing
3 - 533
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-180 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
mentioned about providing security of the Caltrans
houses between the times of the purchases by the
City and the properties eventual sales. We have been
living in fear with the brazenness of squatters and
more importantly the danger that these decrepit
houses pose, including faulty electrical wiring, mold,
asbestos, sewage spills/leaks, etc. that could be
released should the squatters inadvertently initiate a
catastrophic event. Our houses are so close together
that we fear our homes would suffer whatever
happens to the nearby Caltrans homes caused by
squatters. There is nothing here in this document
that alleviates our concerns about our safety.
4 62 “Development may have also
been hindered by the City’s
decades-long struggle to
reverse the planned 71
Freeway extension, which
was finally cancelled by
Caltrans.”
The “71 Freeway”? I’ve noticed a lot of spelling
errors throughout the document. We are paying the
consultants a lot of money to write properly.
“Cancelled by” Caltrans? A number of individuals,
organizations, and municipalities rose up and fought
against this useless project and Caltrans for decades.
This statement makes it seem as if Caltrans just
changed its mind. Revise this statement to interject
reality and accuracy.
The identified typo has been
corrected.
5 63 “These incentives include
height increases and waivers
from setbacks, floor area
ratios, parking, and other
requirements for eligible
residential projects.”
The author was originally correct by stating
“concessions” rather than the revision to
“incentives.” What are the eligible residential
projects? List specifics and how much is the City
giving away to the developers? Will there be any
yards in the future for new housing? Where will the
cars be parked since most residents will still be using their own transportation, whether gas powered or
The identified changes to
development standards are
incentives for projects to include
affordable units. These incentives
are required by State law.
3 - 534
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-181 Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
electric powered? How tall will the height increases
be? Does our Fire Department have the capability to
put out fires on high rise buildings?
6 209 “Caltrans has initiated a threephased property sales program for the 710 surplus
properties. Staff continues to
work with representatives of
Caltrans, California
Department of Housing and
Community Development,
and the California State
Transportation Agency to
discuss potential affordable
housing strategies. The City
is also working on a plan to
take advantages of
opportunities provided in
SB381 to procure surplus
properties in order to enable
affordable housing
development. A new housing
division is being established
in the Community
Development Department to
develop and administer
affordable housing including
these efforts.
“Funding has been secured
for a feasibility study on
Same comment as in Comment No. 1. No mention
about the non-legislative and legitimate approach of
relying on side-by-side escrow agreements. And just
what will the Housing Division do when
“administrating affording housing?” Will the City or
its designee, an HRE, manage the affordable units,
collect the rent, and maintain the units? How can
that be when so much of our neighborhood needs
vital services and maintenance activities now? The
City is not qualified to handle this major endeavor
and to pass it to an HRE will just be a repeat of
Caltrans’ past behavior.
SB 381, which the City supported,
provides a framework for Caltrans
to sell its surplus property in South
Pasadena. If the City does not
purchase the properties, it is
expected that Caltrans will offer
them to the Los Angeles County
Development Authority and then
on to other parties identified in the
law. Caltrans must offer these
homes for sale in accordance with
SB 381, other options do not exist
under existing law.
3 - 535
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-182 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Comment
Nos.
Page
Nos.
Statements of Concern in
Red-lined Version
Public Comments on Draft Housing Element’s
Statements (Version 4-Red-lined)
City Response
surplus Caltrans properties
available to be converted to
permanent affordable
housing ($30,000 – Measure
H).”
7 219-
220
Discussion related to
Program 1.b - Convert
Caltrans Homes to
Affordable Housing
Same comment as Comment No. 3.
Security costs will be excessive with respect to the
program and to date those costs have not been
estimated. Occupancy by October 2024 is also
overly optimistic. Given the bureaucratic processes
of both agencies, the costs and distribution of
supplies and equipment, labor availability, the
unanticipated repairs that are yet to be discovered
until rehabilitation occurs, and the requirement that
if HREs are involved that they can pay prevailing
labor wages is naïve thinking at best when dealing
with renovation projects of this magnitude. Selling
these properties immediately in side-by-side escrows
will substantially alleviate the risks to the City and
will enable the City to focus on existing and urgent
City matters and services.
As yet again a reminder, just look at the snail’s pace
of the City in turning two vacant former Caltrans lots
into pocket parks. Several years have passed and the
City is still working with designers/engineers with
no results at this time. Imagine if security was
focused on those sites? Such costs would be
astronomical.
The City has not made any
determinations regarding the
eventual dispensation of the
Caltrans homes. Currently, the City
is doing its due diligence regarding
the condition of the homes and the
possible financing mechanisms for
rehabilitation of the properties.
This analysis includes researching
possibilities regarding increasing
the number of units on Caltrans
home sites, where feasible.
However, since the due diligence
work is ongoing, it is not possible
for the City to commit to any
course of action regarding these
homes at this time.
3 - 536
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-183 South Pasadena Tenants Union and Care First (December 8, 2022) City of South Pasadena
Community Development Department
[email protected]
[email protected]
CC: California Housing and Community Development
[email protected]
[email protected]
Regarding: South Pasadena Housing Element, Fourth Draft Dear Ms. Frausto-Lupo,
Care First South Pasadena and the South Pasadena Tenants Union write jointly to provide feedback about South Pasadena’s third draft of the Housing Element.
Executive Summary
• South Pasadena should develop affordable housing throughout the City to create income diverse neighborhoods and promote fair housing. We want the City to:
o Use the 20 vacant Caltrans house sites,1 which the City will purchase in the coming months, to develop a blend of duplexes, triplexes, quads, and denser multi unit buildings for affordable ownership and rental opportunities. A number of the vacant houses are
0.25-0.50 acres and could accommodate multi-unit development. o Pilot an affordable ADU program, like the Backyard Homes project in Northeast Los Angeles (https://www.mas.la/affordable-adus).
o Recruit 100% affordable developments through non-profit low-income housing developers, identify at least four (4) viable locations for 100% affordable developments, and identify potential financial and regulatory incentives the city could offer such developers.
• South Pasadena should take more steps to support and protect renters and maintain availability of existing below-market units, including:
o Enact an urgency ordinance before January 1, 2023 to amend South Pasadena’s no-cause eviction ordinance to require landlords to pay tenants increased relocation assistance if they are being evicted.
o Offer financial assistance to low- and moderate-income tenants and prospective tenants, including Section 8 voucher holders, for security deposits and rent. o Enact a rent control ordinance.
o Fund improvements at below-market rental units in exchange for landlords’ covenants not to evict existing tenants or raise rents excessively.
I. Promoting Affordable and Fair Housing Development
The Housing Element determined that the City’s “prior race and ethnicbased socio-economic discrimination had a long-term impact on racial diversity in the City” which is only 3.6% Black or African 1 For a sites inventory of the vacant Caltrans properties, see a map we created at https://www.google.com/maps/d/viewer?mid=1nt13dEdP-7ddQxN85ewo35xhQEKD-kc&ll=34.11207520783854%2C118.1570014&z=15 (last updated Dec. 7, 2012). 3 - 537
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-184 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE American and only 18.5% Latinx. (Redline of Fourth Draft Housing Element at 39). Limiting multifamily development has made South Pasadena unaffordable, which contributes to the City’s lack of diversity. Zoning data from August 2021 revealed that approximately 75% of all residentially zoned land in South Pasadena is zoned exclusively for one or two dwelling units per parcel that do not allow for higher density housing such as apartments or condominiums (Id. at 104). Jurisdictions with the highest proportion of exclusively single-family zoning have the highest percentage of White residents and lower rates of diversity generally. (Id.).
During the last housing element cycle, only 10 affordable units were permitted out of 93 new units. The City has not tracked whether any affordable units have, in fact, been developed.
Despite these deeply concerning data, the City’s Fourth Draft Housing Element falls far short of what is needed.
Vacant Caltrans Houses. Under SB 381, the City will soon acquire 20 vacant houses currently owned by Caltrans.2 The houses are dilapidated from years of vacancy and lack of maintenance. They are in residentially-zoned areas. Under SB 381, the houses must become deed-restricted affordable housing for low- or moderate-income people for a period of 45 or 55 years, depending upon whether they become owner occupied housing units or rental units, respectively.
The vacant Caltrans houses represent a monumental opportunity for South Pasadena to expand affordable multifamily housing in South Pasadena, yet they are scarcely mentioned in the Housing Element. The City proposes Program 1b to “preserve and rehabilitate” the vacant houses and make them “available to moderate or lower income households.” This program was modified from the Third Draft, but in the wrong direction by committing to “preserve and rehabilitate” the houses.3 Care First and the Tenants Union implore the City to:
• Add the vacant Caltrans houses to the site inventory, including data regarding the lot size, year constructed, and historic designation (or not), and maximum potential number of affordable units that could be made available at each site for rental and/or ownership.4 • Upzone residentially zoned areas in South Pasadena, including along the 710 corridor, to accommodate denser housing.
• Implement SB 9 and SB 10 at the vacant Caltrans sites by clearing a path for multifamily housing in the form of duplexes, triplexes, quads, and 10-unit buildings where possible.5 2 Following this first phase of acquisition, the City will likely have future opportunities to purchase more Caltrans homes if they are refused by current occupants. To prepare for this near future, the City should apply a similar framework as we propose here for the conversion of these properties into multi-unit affordable housing, while preventing displacement or meeting the housing needs of current tenants. The City should account for these plans in the Housing Element. 3 The significance of this change, though seemingly minor, is that the South Pasadena Preservation Foundation has been lobbying the City to bypass SB 381 and sell all 20 vacant Caltrans properties at fair market value to private buyers who would restore them as single-family houses. At a City Council meeting on December 7, 2022, the Chair of the City’s Cultural Heritage Commission told the City Council that he has petitioned to add all the Caltrans houses to the national historic registry. The City Council is capitulating to the demand that it “preserve and rehabilitate” the houses. The vacant houses are dilapidated; each will cost hundreds of thousands of dollars to restore. In other words, these houses are teardowns but for the primacy of “historic preservation” in our town. We recognize that South Pasadena is home to beautiful architecture. But valuing historic preservation above all else is backward in the midst of a severe housing crisis. 4 Given that the City has included a number of non-vacant sites in its sites inventory, it follows that the City should add the tenant-occupied Caltrans houses to its sites inventory as well as potential sites for affordable housing development. 5 The Housing Element claims that South Pasadena is built out, and that “[i]t is too early to tell how many single-family property owners with parcels that are not within historic districts will opt to build two units or subdivide their lots to build more, but the City will review and approve applications under the new regulations in compliance with both State and local 3 - 538
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-185 • Develop auxiliary dwelling units as affordable rental units at as many of the houses as possible.
We ask the City to explore denser development with the larger houses, such as:
• 535 Meridian St. (21,920 sq. ft., ~ 0.5 acres),
• 530 Orange Grove Ave. (7500 sq. ft.) and 534 Orange Grove Ave. (10,010 sq. ft.) (adjacent parcels that represent 17,510 sq. ft., ~0.40 acres),
• 1131 Columbia St. (16,998 sq. ft., ~ 0.39 acres),
• 529 Prospect Ave. (15,419 sq. ft., ~0.35 acres),
• 540 Prospect Ave. (11,505 sq. ft., ~0.26 acres),
• 217 Fremont St. (13,310 sq. ft., ~0.31 acres)
• 216 Fairview Ave. (13,240 sq. ft., ~0.30 acres),
• 1110 Glendon Way (11,250 sq. ft,. ~0.26 acres).
Compare these lot sizes to the lot sizes in Table VI-49 (at 182), Representative Projects on Small Sites in Region. In Pasadena and Santa Monica, developments on comparable lots accommodate 15-53 units.
Conservatively assuming 20 units per parcel on the large lots listed above, the City could add 160 affordable rental units on these parcels alone.
The Fourth Draft Housing Element slates virtually all of the housing affordable to very low- and lowincome people in areas zoned as Business Park, Commercial, Community Facilities, Mission Street zoning areas save for one site in the Estate and Very Low Density Residential area (335 Monterey Rd.). (Table VI-50).
The Housing Element’s allocation of all low-income housing to transit corridors, outside of residential single-family neighborhoods, does not comply with principles of fair housing. Concentrating dense lowincome housing in certain limited areas is antithetical to affirmatively furthering fair housing. It undermines meaningful housing integration in this exclusionary town. The City should rezone singlefamily areas within the City, including along the 710 freeway corridor, to allow for more affordable housing. The vacant Caltrans houses could provide housing to low-income people within single-family home residential areas, and further the City’s goal of creating income-diverse neighborhoods.
SB 381 allows the City to sell seven (7) houses designated as historic “as-is” at market rate to private buyers, so long as it uses the funds to develop affordable housing at a 3:1 ratio. The City should not opt for this route. There is no scarcity of large estate houses in South Pasadena. There is an acute shortage of affordable housing. The City should develop multi-unit housing on the historic and nonhistoric Caltrans parcels alike.
If the City does sell the historic houses, the Housing Element should reflect its plans to commence construction of affordable units within three years, as required by statute. As evidenced in this draft of the Housing Element, the City is short on available sites for affordable housing development and has identified no potential affordable housing projects that will start or be completed within this short time frame. The Housing Element should identify where those units will go, how they will be financed, what type of housing it will build, etc.
No matter what, the City should not aim to “preserve and rehabilitate” these homes by pursuing historic designation of new properties. These were strategies used once to prevent the building of the 710 codes.” (143). But South Pasadena is in the driver’s seat regarding these 20 properties. It must start leading on implementing the state laws rather than passively wait to see what homeowners do. 3 - 539
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-186 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE freeway, which is no longer at issue. Historic designation, starting with the commencement of nomination to historic and endangered listings, is antithetical to affirmatively furthering fair housing in South Pasadena. Historic designation of homes would make them unaffordable and environmentally unsustainable to maintain, cementing the city’s 20th century redlining policies into the future.
South Pasadena must complete another draft Housing Element that fully accounts for the vacant Caltrans houses it will buy in the near future, with concrete proposals about how to use these parcels to expand affordable housing. Since the City intends to purchase the vacant homes in the coming months, thus making these City owned properties, we expect to see these parcels listed on the Inventory Site list in the next draft.
100% Affordable Developments. Care First urges the city to actively recruit 100% affordable developments through non-profit low-income housing developers (i.e. bolster its commitment to Program 2.h).6 We recognize that the City has identified two City-owned sites (9 and 14) as candidates for 100% affordable. (229 & Table VI-50). We propose that the City Council double down on its efforts to identify two more viable locations for a total of four (4) for 100% affordable developments, excluding the Caltrans properties discussed above (which are all slated for affordable housing anyway by statute).
Additional sites should be for very low, low and moderate income households combined and provide housing opportunities for families.
Auxiliary Dwelling Units. The Housing Element relies heavily on ADUs to create affordable housing and to further fair housing. But the evidence is thin that encouraging ADUs will be anywhere close to sufficient.
South Pasadena has no system in place to ensure that the ADUs it permits actually become rental units, much less affordable ones. The code states that ADUs are not to be rented for a period less than 30 days, but the City currently has no enforcement mechanism in place to monitor the use of ADUs.7 It is just as likely that ADUs will become short term rentals listed on apps like airbnb, home offices, and guest houses for visitors. The existing ordinance does not go far enough to ensure homeowners who take advantage of a program designed to increase housing opportunities for those who need housing are using the dwelling as intended by the spirit of State law Even when ADUs are rented, the data emerging so far suggests that these units are not affordable. (176).
Finally, the whole endeavor relies on homeowners investing large sums of money to build these ADUs.
Rising inflation may dampen ADU construction.
We recommend that the City pilot an affordable ADU program, like Backyard Homes in Los Angeles.
Affordable ADU programs offer free or heavily discounted ADUs to homeowners in exchange for covenants to charge below-market rental rates. The Backyard Homes project, run through LA Mas, offers a few model ADU options and charge discounted construction and design fees in exchange for 6 The city’s previous position was that it would simply work within the San Gabriel Valley Housing Trust to build affordable housing in the region. Care First is encouraged to see that the third draft of the housing element takes a more proactive approach.
7 It is common for short term rental operators in our city to rent their units for two months at a time. While that complies with the letter of the code, the owners are benefiting financially via an unlicensed commercial short term rental at market rates.
3 - 540
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-187 renting to a Section 8 voucher holder.8 Piloting an innovative model like that could spur ADU construction and support affordable housing and income-diverse neighborhoods.
II. Protections for renters
South Pasadena residents are more than 50% renters. Renters account for most of the demographic and economic diversity in South Pasadena. More than two-thirds of renter-households are rent-burdened, with 64% spending more than 30% of their household income for housing.
The Housing Element sets conservation of existing housing stock as a prominent goal, and contains some general provisions aimed at protecting renters. (220). But monitoring affordable units, offering technical assistance to landlords, and vague commitments to vouchers will not be enough to prevent dislocation and erosion of existing below-market rental units. (220-221). The City cannot accomplish a goal of preventing tenant displacement without enacting more tenant protections. Currently, South Pasadena relies almost entirely on Statewide protections set in AB1482. These have proven not to go far enough in protecting tenants from evictions or self evictions due to unbearable rent increases due to current inflation.
The landlords and homeowners have “rent control.” When they buy the apartments, the mortgage payment they pay is set for 30 years. It does not change even if inflation happens. Renters are demanding, not even the same stability, just something where their rent remains close to inflation, and the right to stay in their home if they pay their rent.
Landlords are making massive profits on rent. Most "mom and pop" landlords in South Pasadena purchased their apartments 20 to 30 years ago. Over the past year, 13 apartment buildings have sold in South Pasadena at an average of $1.6 million. Meanwhile, the average original purchase price of these 13 apartments was $256,000. Most “mom and pop” landlords are realizing massive profits off people struggling to stay in South Pasadena.
Renters love South Pasadena and want to make it their home just like homeowners. Tenants have a right to be a part of this long-term community and not have to worry if the housing crisis means someone richer will take their place.
No cause eviction protections. South Pasadena Tenants Union and Care First South Pasadena request an urgency ordinance to stem the tide of no-cause evictions expected in early 2023. Building on the progress advocates made with its just cause eviction ordinance in 2019 and its substantial renovations ordinance in 2021, we ask that the City update the law to require landlords effectuating no-cause evictions to provide relocation assistance that goes beyond AB1482.
The relocation amount should be equal to two (2) times the daily pro-rata portion of the tenant’s current rent. All units removed for owner occupancy must be held off the market for no less than three years.
If an owner evicts a tenant for no-cause because that unit will be taken off the market for owner occupancy, the owner must register the unit with the City as “owner occupied.” If the owner violates the ordinance and puts the unit back on the market within the three year period, a $50,000 fine will be levied. Funds collected from fines would support Housing department staff and enforcement staff. 8 Sam Lubell, Los Angeles Times, March 5, 2021, “Well-designed rentals that L.A. can afford. That’s the mission of the Backyard Homes Project.” https://www.latimes.com/entertainment-arts/story/2021-03-05/backyard-homes-project-adulos-angeles 3 - 541
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-188 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE For evictions due to justified substantial renovations, the ordinance should include a first right of return for tenants who do not want to relocate out of South Pasadena. The owner should cover the rent or cost of housing during renovation up to what the tenant was paying for rent at the unit undergoing renovation. The tenant should be allowed to return to the unit at the same rate as was being charged prior to renovation. If temporary relocation due to verified substantial renovation exceeds 120 days, the landlord may terminate the tenancy with the additional payment of relocation assistance as follows: (1)
2.5 times the monthly Fair Market Rent (published by HUD) plus (2) a Moving Expense Allowance of $1,338 (if all occupants are adults) or $4033 (if any of the occupants are minors, a senior, or a person with a disability.
These protections would provide much more support to South Pasadena renters than the municipal code currently provides, and prevent displacement.
Rental assistance. The City currently allocates its CDBG funding to meals on wheels for seniors and sidewalk repairs. We demand that the City initiate a rental assistance program with some of the CDBG funding plus allocate yearly amounts from its General Fund to provide low- and moderate-income residents and prospective tenants to pay security deposits and rent. The program should also offer rental assistance to moderate-income rent-burdened residents. Additionally, the City should pay partial rent for Section 8 voucher holders to make up the difference between rent and the voucher. Because many Section 8 voucher holders in Los Angeles County are unable to secure housing in time and lose their vouchers as a result, the City should help ameliorate this problem by incentivizing and assisting landlords within the City to join the Section 8 program. At present, there is an abysmally low number of Section 8 voucher holders residing in the city (10 total according to the Housing Element). Referring residents to the County (224-25) will not help anyone get into affordable housing when there are no voucheraccepting units in South Pasadena.
Rent control. The City should adopt a rent stabilization ordinance. A local rent control ordinance would give low income and moderate income families, seniors, the disabled and students and workers a fighting chance to stay in South Pasadena. The bleeding out of affordable existing rentals is gradually affecting the diversity of our schools, local culture and economics. South Pasadena being almost an exclusively high rent community, means more transient households that are less likely to support our community health through civic participation and investment in our churches, nonprofits, and schools. With a lack of enthusiasm for building new affordable housing, the City needs do more to maintain the little existing affordable housing we have and protect all tenants from further displacement because of ever increasing rents and cost of living that does not mirror increases in incomes.
This would include, but not be limited to, provisions such as limiting rent increases to no more than 2- 6% based on inflation, with the ceiling set at 6%. The ordinance would maintain a floor of 2% allowable regardless of percentage of inflation. If inflation is 1%, rent can be raised 2% The ordinance would apply to all buildings as allowed under Costa Hawkins. If Costa Hawkins is repealed or modified to allow newer buildings, then rent control in South Pasadena automatically applies 20 years after certificate of occupancy.
The ordinance would require a lease term of one year (12 months), and 60-day notices for rent increases.
If a unit become available due to an eviction, rent on the unit can only be raised up to 20% of what the landlord was charging the previous tenant. The ordinance should also include the establishment of a local rent control board to establish yearly rent increases, monitor enforcement, and adjudicate tenant and landlord disputes, among other duties
3 - 542
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-189 Funding improvements in exchange for affordability covenants. Policies 1.1-1.3 in the Housing Element are focused on improving energy efficiency and bringing older housing units up to code (218). There is a real risk, however, that requiring owners to make financial investments to update older units will result in rent increases, evictions for substantial renovation, and dislocation of low- and moderate income renters in South Pasadena.
We ask that the City provide funding to make needed improvements to make housing units habitable and safe for tenants contingent upon the landlords’ covenants not to evict tenants or raise rents excessively once the units are improved. The City has already identified potential funding sources for such improvements. (220).
Thank you for the opportunity to provide feedback. We look forward to participating in the process as it proceeds.
Best regards,
South Pasadena Tenants Union & Care First South Pasadena • How addressed: The City has not made any determinations regarding the eventual dispensation of the Caltrans homes. Currently, the City is doing its due diligence regarding the condition of the homes and the possible financing mechanisms for rehabilitation of the properties. This analysis includes researching possibilities regarding increasing the number of units on Caltrans home sites, where feasible.
However, since the due diligence work is ongoing, it is not possible for the City to commit to any course of action regarding these homes at this time. It is the intention of the City to preserve these homes as affordable housing, not as historic resources. The Housing Element has been updated to more clearly make this point.
The Housing Element focuses on encouraging the development of new housing throughout South Pasadena. It is anticipated that sufficient new housing will improve the housing market for both renters and buyers looking to live in South Pasadena.
As shown in Program 2.l, the City has committed to issuing an RFP to affordable housing developers for one of the city-owned affordable housing sites no later than December 2024, and other RFPs in 2026 for the development of housing on these city-owned site.
Program 3.g commits the city to monitor the number of ADUs built, and to survey ADU owners annually to collect data on rental rates to determine how many moderate- and lower-income units have been produced. Program 3.h commits the city to modify its zoning code or identify additional affordable housing sites if it is determined that the affordability of ADUs is less than expected in the Housing Element. This survey is scheduled to begin in 2023.
Comments on the 4th Draft Housing Element
Mark Gallatin (December 5, 2022)
I would respectfully like to suggest the following alternate language for that found on page 216 of the September 2022 Draft Housing Element:
Program 1.b. - Convert Caltrans Homes to Affordable Housing 3 - 543
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-190 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE The City will leverage the 68 Caltrans surplus properties that have resulted from the State's cancellation of a proposed route to extend the 710 freeway through South Pasadena to generate capital to create new and rehabilitated, deed restricted, affordable housing units throughout the city.
The City has initiated a property sales program for the 710 freeway surplus properties. The City worked with Senator Portantino to pass SB 381 and the emergency rulemaking regulations were released on March 28, 2022. The City will have priority to purchase the surplus properties after the existing tenants. The City has been working with Caltrans to obtain property files and to schedule inspections in order to evaluate the surplus properties. SB 381 also requires that any proceeds from historic properties purchased by the City at Caltrans minimum (acquisition) price and then subsequently sold at Fair Market Value be used to generate affordable housing at a ratio of 3 to 1.
Funding has been secured for a feasibility study on the surplus properties that are available to be converted to permanent affordable housing.
Eight-year Objective: Complete a feasibility study and use the recommendations to support decisionmaking regarding possible strategies, including but not limited to, partnerships with non-profit affordable housing developers, to expand housing mobility opportunities for lower-income households and revitalize underused areas.
Funding Source: Measure H
Responsible Agency: Community Development Department/City Manager’s Office Timeframe: Conduct feasibility study in 2022; technical assistance and work with nonprofits at least annually throughout planning period. More specific timing pending State implementation processes. • How addressed: Program 1.b has been revised to substantially match the proposed language in this comment.
Josh Albrektson (December 19, 2022)
South Pasadena comments:
Downtown Rezoning
They are going to 70 DU/ACre and 60 ft/6 stories which is good. Of note, most buildings need 7 stories to get 70 DU/Acre.
They have a TON of bullshit sites that would never be developed. When Los Angeles did their analysis they got rid of these sites. It is one thing to claim 20% of developable sites will be developed at 100% capacity. It is quite another to claim 100% of a complete downtown would be developed when 30% of the downtown has zero chance of actual redevelopment.
I will be doing a twitter thread on it and there will be EXTENSIVE complaints if these bullshit sites are allowed to be counted. These include multiple official South Pasadena historical monuments, multiple condo complexes that are 15 years old, Historic theaters, Micheal Myers House from halloween, single family homes on 4,000 sq ft lots, 100 year restaurants, 10 foot alleys, historic banks, etc, etc.
Every condo complex built in the last 22 years, every historical monument, all buildings over 70 years old, and all single family homes under 0.2 acres should be removed from the calculations and only the 3 - 544
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-191 buildings that ACTUALLY has a chance of development should be counted as 20% likely to be developed.
Inclusionary Housing Ordinance
Their own study shows that 15% is not viable in South Pasadena. They also believe that they can make the 15% Very Low or 7.5% Very low and 7.5% Low.
I have attached an e-mail from the Mission Bell owner to the planning director on Sept 29th stating that his fully market rate project is not currently financially viable. If their fully market rate project is not viable then a 15% IHO is not viable.
South Pasadena should be required to change their IHO to 10% Low OR 5% Very Low and if housing is actually built using the IHO, then they can increase it if they find housing is actually being built, rather than go the other way around.
Especially since they intentionally killed all projects with their 10% Low and 10% Very low which is currently still in place.
Realistic Development Capacity
They are claiming that almost every non-vacant low income site will be built out at 95% Capacity, even though every one is on a primarily commercial street. You rejected Santa Monicas draft for this reason and you have cited multiple cities for this.
Here is Danville:
https://twitter.com/JalbyMD/status/1602454496822497282?s=20&t=qjjmEng2_VMCWagab4n-dw [twitter.com]In May 2021, before Chris Holden called your director, you had a problem with South Pasadena claiming 80% RDC.
It is completely unacceptable that you guys are allowing South Pasadena to claim a ridiculously high number.
Processing Timelines
South Pasadena has had 4 mid level projects proposed from 2018 on. As of yet, none of them have building permits. It is absolutely unacceptable that you guys say that they can be by right at 20% affordability in order to avoid these processing times.
Santa Monica committed to making all projects that fit the zoning under one acre by right. And they have actually historically produced housing. South Pasadena has not.
I even sent you information about how they required a preliminary application a year before a real application and how they forced 815 fremont to undergo TWO complete redesigns.
In the Housing Element you have a letter from Victor Tran about how he submitted applications in March of this year that South Pasadena hasn’t even acknowledged they have been turned in. 3 - 545
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-192 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE South Pasadena was one of two cities to receive a grant from SCAG to pay for objective design standards for all it’s multifamily housing. They need to be required that all projects with 10% low be by right.
Something needs to be explicitly written out in the Housing Element with actionable measures to ensure projects are processed. They also need to commit to following the law on the permit streamlining act which they currently regularly violate.
Low Income Sites
You will receive separate more in depth individual e-mails where Gustavo and Megan are CCed with these low income sites and the exact part of the law that are being ignored if these sites are approved.
I want to be sure that they will not be able to claim they didn’t know that the laws are intentionally being ignored when this comes up in the future.
I did a twitter thread, which I will also submit as a different comment:
https://twitter.com/JalbyMD/status/1602435712846290944?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]
Site 2
Just to be clear, two of the biggest buildings JUST GOT LEASED:
https://twitter.com/JalbyMD/status/1602449467042430976?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]And I just want to say it is fucking bullshit that Paul thinks I have to prove they are not short term leases. South Pasadena gets to lie about what is leased and that is okay, but when I show that buildings that make the site undevelopable are lease, I am required to get teh leases to show they are not short term leases…..
This is a copy of the exact part of AB 1397 talking about leases that you are choosing to ignore the actual legislation passed by the legislator and signed by the governor and not to apply to this site. https://twitter.com/JalbyMD/status/1602450748377370624?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]
Site 8
There is no replacement site, if they had a replacement site they would have pay millions for the site, they would have to pay millions to build a new public works yard, then they would have to pay to tear down the building and remove the gas tanks, and then after the multi-millions spent, only then could it be offered for an affordable housing project.
3 - 546
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-193 Before Chris Holden called your director you actually cared about this site. When I posted it on twitter a developer told me he estimated it would cost “Tens of Millions” just to replace the site and make it available for house.
https://twitter.com/JalbyMD/status/1602444291711844353?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]Site 12:
The City doesn’t own most of the site. They own 0.19 and do not have plans to buy he rest. Also see Site 15 comment for sites under 0.5 Acre.
Site 13:
The City has a lease going through 2024 for this site. They actually turned down someone who wanted to build affordable housing on this site. They added a single family home that they do not own to get over 0.5 acre.
Site 14:
You ignored almost all the actual laws passed by considering this site.
Link to video:
https://twitter.com/JalbyMD/status/1602446669571727360?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]Just to be clear, both homes are getting brand new foundations. They have hired an architect to renovate the homes (Harvest Architecture). This site is under 0.5 Acres. I sent you an email from the owner stating his plans were to renovated the home s(which is actually happening right now.)
This is a link to the part of AB 1397 which was passed by the legislature and signed by the governor that you are choosing to ignore by saying South Pasadena has substantial evidence the current use will be discontinued in the planning period.
https://twitter.com/JalbyMD/status/1602438163506794498?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com] This is a link to the part of AB 1397 which was passed by the legislature and signed by the governor that you are choosing to ignore by allowing a under 0.5 Acre site to be considered a low income housing site:
https://twitter.com/JalbyMD/status/1602447693690720256?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]
Site 16:
Newly renovated grocery store with grand Re-Opening August 3rd. You can read my tweets on it here:
3 - 547
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-194 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE https://twitter.com/JalbyMD/status/1602439866897211393?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]They first claimed it was the whole grocery store, then it was just the parking lot, then you guys told them how to lie to you so that the parking lot would be acceptable. Here is a link to the mayor spitballing ideas of how they could lie to you about the parking lot:
https://twitter.com/JalbyMD/status/1602443223150256129?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com]They got a letter from the owner in the Housing Element which I am sure they wrote what SoPas asked them to write.
Site 17:
I recently received all e-mails from South Pasadena and the site owner. In the e-mails the owner is asked if they are considering housing on the site and he says “I think we are good.” When asked if they want to still be on the Housing Element site list, he replies “I guess” Along with the brand new lease signed this year this is pretty damn good evidence that the owner has no interest in developing housing in the planning period.
Please refer to the above link to the law talking about how leases should be considered.
Programs:
South Pasadena needs specific objective circuit breakers in their Housing Element programs. As mentioned in the call, you can pay a consultant to produce a study proving the highest inclusionary housing ordinance in the state is viable even when it is blatantly not, and that is exactly what South Pasadena did. They cannot be trusted to evaluate their sites in 2024, update the inclusionary housing ordinance, look into reducing parking and open space requirements, or do a realistic rezone if the ballot measure fails. These things need to be spelled out in this housing element so they are enforceable.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been substantially revised to address these comments, including increasing the height limit, removing identified sites, and revising the analysis of the DTSP sites to account for additional constraints such as historic designations.
Josh Albrektson (January 2, 2023)
This e-mail is about a South Pasadena low income site on their housing element, and the exact laws that Paul McDougall and Megan Kirkeby are ignoring in allowing South Pasadena to claim this site as 3 - 548
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-195 a possible low income site on their Housing Element. I am sending this to you so you cannot claim you did not know this was happening at HCD in the future.
Site 14 is two single family homes. Paul McDougall has an e-mail that the owner sent to the city in 2020 stating he was planning on flipping the homes and selling them.
That renovation is happening right now and Paul McDougall KNOWS that the homes are being renovated. They are currently getting brand new foundations by Foundation Repair LA (https://foundationrepairla.com/ [foundationrepairla.com]). These are the same people who repaired my foundation.
They also have an architect, Harvest Architecture based in South Pasadena that are designing the interiors. https://www.harvestarchitecture.com/
[harvestarchitecture.com]Here is a video where you can see the signs for both of these companies and one of the single family homes getting the foundation as it is being filmed. https://twitter.com/JalbyMD/status/1602446669571727360?s=20&t=wZi8cbwbgVUhWvxqQIHvA [twitter.com] Here is the part of AB 1397 that Paul McDougall is choosing to not enforce:
(g) (1) For sites described in paragraph (3) of subdivision (b), the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.
These single family homes are literally being renovated to be BETTER single family homes and Paul McDougall knows this and doesn’t care.
But not only that, these sites are below 0.5 Acre. THIS IS SPECIFICALLY OUTLAWED BY AB 1397.
Again, citing the law passed by the legislators and sign by the governor:
(A) A site smaller than half an acre shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site is adequate to accommodate lower income housing.
Sites 12 (0.19 acre owned by city) and Site 13 (0.42 owned by the city) Both fall under this category. --
3 - 549
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-196 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: Site 14 has been removed from the Housing Element. Site 12 is 0.56 acres.
Josh Albrektson (January 2, 2023)
This is one of a few e-mails you will be getting where I am going to cite a “low income site” that South Pasadena is claiming could be turned into low income housing this cycle and the exact law that specifically outlaws these sites.
Every one of these sites Paul McDougall said was okay in our November 15th meeting.
I just want to be sure that Jason and Gustavo cannot say in the future that they did not know that Paul McDougal and Megan Kirkeby are intentionally not following the laws passed by the legislator and signed by the governor.
I will be sharing these e-mails with every legislator if South Pasadena is allowed to claim these sites, along with the hundred other examples of illegal low income sites that I personally e-mail Paul McDougall about and he approved.
I get that Chris Holden had a personal and urgent phone call with Gustavo to discuss the South Pasadena Housing Element, but that does not mean that HCD should decide not to enforce the laws that are the actual laws.
Site two is a businesspark in South Pasadena. They literally just leases two new businesses this year and these two businesses occupy the entire buildings for two of the 6 buildings.
Check out the leasing brochure. This is high quality offices:
https://images1.loopnet.com/d2/NjuUcEIzCBdbskuj3g5Mj_3zqct3H2jyorx1Mu5ckGw/149161Pasa denaSouthPasadenaBrochure.pdf [images1.loopnet.com]
3 - 550
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-197 This is from the summary of AB 1397:
This bill would require the methodology to consider, among other things, the city’s or county’s past experience with converting existing uses to higher density residential development, the current demand for the existing use, and an analysis of existing leases or other contracts that would perpetuate the existing use or prevent redevelopment, as specified.
And here is the actual text from the law:
(g) (1) For sites described in paragraph (3) of subdivision (b), the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.
Paul McDougall knows these buildings were JUST leased, and he doesn’t care. When I told him again that they were leased this year, he asked me to prove they were not month to month leases. 3 - 551
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-198 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE The job of HCD is to enforce Housing Laws, and Paul McDougall should not be allowed to just ignore the laws at his will, and that is currently what is happening under Gustavo's leadership. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to increase the allowable density for Site 2 to further encourage the redevelopment of the site. Furthermore, development standards for this site, as well as all mixed-use parcels, will be revised to encourage redevelopment.
Josh Albrektson (January 2, 2023)
This e-mail is about a South Pasadena low income site on their housing element, and the exact laws that Paul McDougall and Megan Kirkeby are ignoring in allowing South Pasadena to claim this site as a possible low income site on their Housing Element. I am sending this to you so you cannot claim you did not know this was happening at HCD in the future. Site 8 is the Public Works yard for South Pasadena. You can see a video of the yard in this tweet:
https://twitter.com/JalbyMD/status/1602444291711844353?s=20&t=U_d2X2e5GgNUrylao7D03w [twitter.com]Let me be clear about what South Pasadena is claiming for this site. Sometime in the next 7 years, they will find a replacement site. They do not have any open land right now for this replacement site, but they will find one somewhere. They will then build a brand new public works yard on this replacement site. They will then tear down the old public works yard. They will then remove the gas tank that has been there for decades. They will then remediate any toxins in the soil from this being a public works yard for 40 years.
We are talking about tens of millions of dollars spent before this site could even be considered for low income housing. This site is the kind of bullshit sites that will NEVER be housing but cities like to claim it so they don’t have to zone for housing somewhere else.
In the last letter from Paul McDougall, HCD actually explains how the city should lie to HCD in a manner they would be willing to accept.
“For Site 8 (Public Works Yard), the element should discuss the impacts of the underground gasoline tank and filing station and soil contamination on the timing and cost of development in the planning period.”
Here is the part of AB 1397 that Paul McDougall is choosing to not enforce:
(g) (1) For sites described in paragraph (3) of subdivision (b), the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis 3 - 552
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-199 of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to further describe where the existing uses of Site 8 will be relocated and to address the potential environmental constraints on the site.
Josh Albrektson (January 9, 2023)
I have come across this information from a respected individual. They believe that the density that can be built at 45 feet is about 40 to 44 DU/Acre. The is under 1 DU/Acre per ft of height.
If a City such as South Pasadena wants to claim 70 DU/Acre, they need to have a height limit of at least 75 ft.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to increase the height limit of the mixed-use zones.
Josh Albrektson (January 12, 2023)
Please consider this thread on the downtown rezoning and the extensive number of buildings that could NEVER be developed included in their calculations. https://twitter.com/JalbyMD/status/1613662763473342465?s=20&t=YWu-t552VhhJiPuR8JBnXA [twitter.com]
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
3 - 553
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-200 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: The analysis of the DTSP area has been extensively revised to address this comment. Revisions include removal of many of the identified parcels from the analysis, and additional considerations regarding the probability of redevelopment of parcels within the DTSP area.
Josh Albrektson (January 31, 2023)
Please consider the following separate comments:
1. Glendon and Meridian from Monterey to the 110 freeway should be included in the Downtown Specific plan and significantly upzoned, especially since they are touching the train station.
2. Monterey Road from Pasadena Ave Southwest should be significantly upzoned. This abuts a mountain, and has very close access to parks and an elementary school and has a lot of run down single family homes that can be upzoned.
3. I like the idea of SB 10 around Fair Oaks and Huntington
4. Consider upzoning Fremont Ave from Monterey to the 110 freeway.
You are actually further away from compliance than you think. HCD has not certified a Housing Element that doesn't have a significant buffer (They recommend 15%) and I doubt you will be the first.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to increase the zoning capacity in all of the areas identified in this comment.
Josh Albrektson (February 1, 2023)
I just read through the staff report for tonight's meeting. After reading through it, I expect that your next draft will also be rejected.
There are two major issues.
In the 4th draft for low income units you were required to have 1155 and you showed 1178 for 23 total excess. That is a 2% buffer. Some of the sites you have will not be allowed, so once you remove those sites you will actually be under the required amount.
To date HCD has not allowed a Housing Element to be accepted without a significant buffer. Most accepted Housing Elements have a minimum buffer of 10% or greater. In their memo on the bottom of page 22 they state you should have a 15 to 30% buffer. https://www.hcd.ca.gov/community-development/housing-element/housing-elementmemos/docs/sites_inventory_memo_final06102020.pdf I sent a separate e-mail noting the 4 places I would upzone. If you guys do choose to try to submit another Housing Element without a buffer it will be the first issue I raise with them. 3 - 554
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-201 The second problem is that you actually need to create programs to affirmatively further fair housing (part 3 in the letter). South Pasadena has yet to actually propose an AFFH program and what is described in the staff report definitely would not be good enough.
San Marino and Santa Monica both legalized 2 to 4 plexes for their AFFH program. If you guys don't want to do that, you can probably get by implementing rent control and stating that allows people to stay in their homes.
And I hope after having been told many many many times that they need to put firm data and specific information in the Housing Element, your staff will realize they need to:
1. Spell out exactly what development standards will be relaxed in what manner
2. Specify what fee reductions and streamlining will be implemented
3. The exact IHO percentage
4. The number of units the IHO applies to
5. The hard trigger that would show if the IHO is effective or not with the change that will be made if the trigger is not met
6. If the city will remove the height limit completely or change the height limit to 84 ft and 7 stories One thing to note about the height limit. As it stands SB 828 will give South Pasadena another 2,067 units in 2030. If you do a limited height restriction removal, you will have significant problems at that time. And I doubt HCD would give you 2 years to put it on the ballot since you will end up with plenty of warning in the years leading up to it.
Also note that because you are including a lot of historic properties in your Housing Element (Specifically downtown), and your ability to stop a development on these properties is going to be very limited. Anybody who wants to buy the Fair Oaks pharmacy or Rialto Theater and tear it down for apartments can.
I strongly suggest you guys consider what buildings you want off limits, remove them, and upzone a different part of the city you do not care as much about. This could probably even be done after you have a compliant Housing Element.
--
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to increase the zoning capacity to account for a 15% buffer for lower income units and more than a 30% buffer across all income categories.
Josh Albrektson (February 6, 2023)
I cannot make the meeting do that previous commitments. I want to put this comment in the public record. I support all of the zoning changes and programs mentioned on the February 1 city Council meeting by city Council and staff with one exception. I think great progress is being made.
I do believe the historic downtown properties should be completely removed from the zoning so that they cannot be re-developed. I will have a much more extensive letter in support of the housing element once I get back.
3 - 555
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-202 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE It would be great if this meeting was recorded and published.
Also, the staff does not need to respond to my comments on the previous draft due to the fact, I think there will be significant changes on the draft. Please refer to this paragraph and not waste any time responding to previous comments.
• How addressed: The zoning changes and programs mentioned during the February 1st City Council meeting have largely been implemented in the Housing Element, as refined during the City Council meetings held on February 9th and 15th.
Josh Albrektson (February 6, 2023)
Just to be specific.
Please withdraw all comments from me that were received after the last housing element was published. If they need to be included in the record please do not feel to respond and refer to this comment saying SoPas does not need to respond.
• How addressed: The previous comments are included in this Appendix with brief responses.
Josh Albrektson (February 13, 2023)
I got back from my cruise and listened to the Thursday meeting. I think you guys are doing a great job and I'll do whatever I can to help you get compliance with the zoning.
So this is what I have for my letter that would give you substantial evidence. Once you guys finish your plans, I will add onto it.
https://docs.google.com/document/d/1WJf1YEmjngsUVDaCq3lcy9SIMGxE3q80K6tCtWeBPU/edit?usp=sharing I fully believe that with either citywide 4 plexes with right of return OR Transit 4 Plexes with right of return and rent control, you will pass AFFH. I have talked to Anne and you heard from John. If you guys include a program for rent control, you will have a strong letter from the SPTU asking HCD to find you in compliance.
With my letter and SPTU's, I think you should get compliance. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to allow for four-plexes citywide, expect in high fire hazard areas, and to include a right to return policy (Program 6.b.).
Josh Albrektson (February 13, 2023)
So I talked to Matt Gelfand (CCed on email) and told him about my idea for a grocery overlay zone.
It would be to give Ralphs and Vons the same zoning that Pavilions requested, but since they are much less likely than Pavilions to develop in the planning period, only counting 25% realistic development capacity of the maximal density.
So for Vons it would be 3.96 Acre x 140 DU/Acre x 0.25 chance of development for 139 units 3 - 556
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-203 Ralphs would be 3.09 acre x 140 DU/acre x 0.25 chance of development for 108 units.
Matt is okay with removing those sites from the banned sites for this kind of zoning and calculation.
It is part of your agreement, not stipulation, so it would just require you guys signing a piece of paper.
I also don't think HCD would have a problem with it since the calculation is just like what they have on the top of Page 22 and I will be including it in my letter providing you with substantial compliance. https://www.hcd.ca.gov/community-development/housing-element/housing-elementmemos/docs/sites_inventory_memo_final06102020.pdf --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
• How addressed: The Housing Element has been revised to increase the allowable density for these parcels, along with all of the parcels adjacent to Fair Oaks Ave., to 110 du/ac.
Alan Ehrlich (February 14, 2023)
Hi Angelica, Armine,
Like you and many others, I would like to see the city submit a HE that can be accepted by HCD with this next go. My general sense from the questions and comments of the special council meeting last week is that members of the council finally seem to 'get it" and are (mostly) ready to accept the additional changes which will be necessary in So Pas's 5th draft submittal.
With that it mind, and in spite of pushback I expect you would receive from certain members of the community, please accept these suggestions for inclusion in this next draft. Like you, I believe we would all like to see this phase of the HE to be done so we can get on to the next part of our lives. 1) Remove the 45 year CHC review from the planning code. According to Mark Gallatin, state law permits the same review and in the 6 instances where a property was reviewed during Mark's term on CHC, all have been approved. This is a gimme.' Effectively, the city is giving up nothing, but to HCD it will appear the city is removing a constraint. CHC will squawk, but by Mark''s own statements, there is no there there.
2) Mark Gallatin corrected a public comment I made about SB 381 requiring 3 housing units for each CT property sold. Mark clarified that this only applies to the 7 historic properties of the 67 lots within our city. In my comment I had said that if the city committed to 3 AFFH for all properties, that would provide a minimum of 60 units, giving the HE the cushion needed for this section. HCD is obviously very aware of the CalTrans properties and the potential they represent to meeting the city's AFFH and RHNA targets. Instead of continuing to battle HCD on this point, allow me to suggest that the 5th draft commits to adding a minimum 3 AFFH for every CT property, regardless of whether the city redevelops the site, partners with an HRE, or sells the site to a private buyer. If the requirement exists for the 7 historic properties, it is not a stretch to apply the same condition to the 20 non-historic properties as well. It does not prevent the city from acquiring and selling the 20 properties, it just provides HCD an assurance that the sale of public land will be used for public housing purposes. Standardizing the rule, respectfully, this is also a gimme, a no-brainer. 3) As a practical matter for the elected members of the city council (and feel free to share this with them), this is perhaps the optimal time to go for broke and submit the plan that HCD will approve. 2022 elections are over, so anything submitted/approved now would not affect Michael or Janet in 3 - 557
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-204 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE 2026 and we are stilll far enough from the 2024 elections for it to concern Jon, Evelyn or Jack. On the other hand, if the city continues to fight HCD by submitting bad HEs, there will no doubt be several builder remedy projects filed before 20024 and the voters will remember that when they had the chance, Jon, Evelyn and Jack did nothing and will be held to blame. 4) One final recommendaion, please add a slide to the presentation showing the number, names and $$$ of grants available to provide, restore and rehabilitate AFFH. HCD, SCANPH and SCAG send NOFA's out regularly announcing new programs, many of which I have forwarded to you Given the estimated costs of what it will take to rehabilitate the CT homes, it is only appropriate that the council and members of the community know how many hundreds of millions of dollars the city is leaving on the table by not having an approved HE and not being eligible to apply. It would be the understatement of the year to say the city has neither the funds, staffing or expertise to manage any of the CT properties.
As I've suggested to both of you before, I don't know what the perfect plan is, or even if one exists, but I do know, and you know, that there are a variety of options out there that could work. Its time to get off the crazy train. If the city needs to be engaged with lawsuits over the HE, I'd rather it against the neanderthals holding the city back than CA Homeowners and Chris Suttons of the world. Let the Urquharts, Shanes, Takedas, Carlsons, Gallatins, Nuckols and thier ilk put their money at risk fighting state mandates, rather than making the rest of the city's taxpayers assume the cost of their NIMBYism.
I'm looking forward to seeing you both at tomorrows council meetings. I do not have Grant's email address, otherwise I would have included him as well.
best, Alan
"Sunlight is said to be the best of disinfectants."
- Supreme Court Justice Louis Brandeis
-
"Openness in government is essential to the functioning of a democracy." International Federation of Professional & Technical Engineers, Local 21 v. Superior Court California Supreme Court, 42 Cal.4th 319 (2007)
• How addressed: The Housing Element has been revised to further address the Caltrans homes and to greatly increase the zoning capacity throughout the city.
Care First (February 15, 2023)
Re: Special Joint Meeting of the City Council and Planning Commission, February 15, 2023
Comment, Agenda Item No. 2, Receive Housing Element Presentation and Provide Direction on 5th Draft
Dear Mayor, City Councilmembers, Planning Commissioners:
Care First South Pasadena is pleased to submit the following comments on the fifth draft of the City of South Pasadena’s Housing Element. At this critical juncture where the city stands to lose local control over the development of the city, we strongly recommend the city to adopt the following policies to affirmatively further fair housing, encourage the development of more affordable housing in an equitable manner, and preserve existing affordable housing. 3 - 558
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-205 Care First continues to demand:
• A commitment to use the 20 vacant Caltrans house sites, which the City will purchase in the coming months, to develop on site a blend of duplexes, triplexes, quads, and denser multi-unit buildings for affordable ownership and rental opportunities (A number of the vacant houses are 0.25-0.50 acres and could accommodate redevelopment with even more housing units.); • A pilot affordable ADU program, like the Backyard Homes project in Northeast Los Angeles (https://www.mas.la/affordable-adus); and
• Recruitment of 100% affordable developments through non-profit low-income housing, developers for at least four (4) clearly identified and viable locations for 100% affordable developments, plus spelling out specific financial and regulatory incentives the city could offer such developers.
The City should also adopt the following policies as ordinances with accompanying budget allocations as needed to implement the programs, within six (6) months from the date the Housing Element is adopted:
• Rent stabilization with an 8 percent annual cap for all apartment complexes that have ten or more units;
• Provide tenants the right of return in the event they must vacate their rental units to accommodate substantial renovation or redevelopment; and • Increase relocation assistance for tenants subject to no-cause evictions. o Landlords would be required to pay households at or below 140% of median income for Los Angeles County a relocation allowance equal to two (2) months fair market rent as established by the U.S. Department of Housing and Urban Development (HUD).
o In addition to the relocation allowance, a landlord must also pay the tenant a moving expense allowance in the amount of $1,120 for adult households or $3,364 for households with dependents, disabled or senior members. • Offer financial assistance to low- and moderate-income tenants and prospective tenants, including Section 8 voucher holders, for security deposits and rent, by committing to evaluate the city’s available funds during each budget cycle and to dedicate a reasonable amount to achieve this goal; Fund improvements at below-market rental units in exchange for landlords’ covenants not to evict existing tenants or raise rents excessively.
We incorporate the details of these tenant protections from the South Pasadena Tenants Union comment, dated February 14, 2023.
Additionally, to further the goals of fair housing, the City should” • Eliminate historic preservation policies and practices—including in ordinances, the Historic Preservation Element, and duties entrusted to the Cultural Heritage Commission—that impede development of affordable housing in the city, especially those impacting the city’s transit corridors and Caltrans property sites;
• Review all properties that have been nominated for or placed on the city’s Inventory of Historic Resources and/or designated as historic under the city’s historic preservation policies; • Codify the city’s Sundown Town Resolution by adopting an ordinance that prohibits the use of historic preservation policies and practices that would cause discrimination or disproportionate economic harm on the basis of race, ancestry, national origin, color, religion, sex, or sexual orientation;
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-206 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • Upzone currently zoned R-1 (single-family only) to R-4 (allowing for fourplexes) in the city’s transit corridors, as identified in previous presentations delivered by the city this month; • Implement Senate Bill 9 to encourage lot subdivisions and higher density in single-family neighborhoods rather than impede its use.
Best regards,
Care First South Pasadena
• How addressed: The Housing Element has been revised to address this comment by: 1) revising the program related to the surplus Caltrans homes and committing the City to add additional units to these properties as ADUs or Missing Middle housing where feasible; 2) adding a new goal and programs related to tenant protections, including a rental registry, right to return, relocation assistance, and rent stabilization; and, 3) committing the City to allow for Missing Middle housing citywide, except for in high fire hazard areas.
Comments on the 5th Public Review Draft Housing Element South Pasadena Preservation Foundation (March 3, 2023)
Let it be stipulated and acknowledged at the outset that the process for the acquisition and disposition of Caltrans surplus properties in the City of South Pasadena created as a result of that agency’s decision not to build a northerly extension of State Route 710 through the city is governed by myriad state laws and regulations, including but not limited to, SB 381 (2021). The purpose of providing the following alternative language for Program 1.b. of the Housing Element is not to circumvent or ignore the requirements of SB 381, an amendment to the Roberti Law, but rather to seek to prevent some very real externalities that perhaps were not contemplated when the legislation was drafted and signed into law, but which nevertheless will cause implementation of the letter of that law to undermine whatever well-intentioned spirit brought it into existence in the first place. These externalities include the inflation of rehabilitation costs created by requirements placed on the City or other Housing Related Entities that private individuals and families are not subject to, making acquisition and rehabilitation by those entities financially unfeasible. Another example of an unintended consequence of the existing law would be the concentration of affordable housing in one or two neighborhoods of the city where the surplus properties are located, rather than a more equitable and dispersed concentration throughout all parts of the city. The South Pasadena Preservation Foundation wishes to see the City promote creation of new affordable housing with as few constraints as possible, so that it has the flexibility to respond creatively and nimbly to a dynamic housing market and evolving community needs.
Program 1.b - Maximize the proceeds from the sale of the Caltrans surplus properties to create new affordable housing throughout the city
The California Department of Transportation (Caltrans) currently owns 68 surplus properties that have resulted from the State's cancellation of a proposed route to extend the 710 freeway through South Pasadena. The City will leverage the 20 unoccupied Caltrans surplus properties, two vacant lots and those of the remaining 46 occupied Caltrans surplus properties that are not purchased by former or existing tenants and use the proceeds from the sales of such properties to generate capital to create new, deed restricted affordable housing units throughout the city, whether on city-owned land, or on privately owned property. These proceeds can serve as a "force multiplier", by unlocking the combined equity of those properties and leveraging it to maximize funding for affordable housing creation and housing element implementation. Several alternatives exist within State law and Caltrans regulations for the City to partner with Caltrans to maximize the proceeds from the sales of the 3 - 560
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-207 Caltrans properties and place them directly into a restricted account (i.e. the SR 710 Rehabilitation Account) dedicated solely for the use of the City of South Pasadena to create affordable housing.
Some other alternatives, after further study, may be financially infeasible so in order to promote affordable housing in South Pasadena all alternatives, including that proposed here, must be considered.
Eight-year Objective: To facilitate the acquisition and disposition of the maximum number of Caltrans surplus properties to individuals and families and to leverage the proceeds from the sale of these properties to generate capital for the creation of deed-restricted affordable housing units throughout the city to expand housing mobility opportunities for lower-income households and revitalize underutilized areas.
Funding Source: SR 710 Rehabilitation Account
Responsible Agency: Community Development Department/City Manager’s Office Timeframe: Begin implementation of sales program in 2023 and at least annually throughout the planning period until disposition of all surplus properties is complete. • How addressed: The City Council has made no determination regarding the purchase of any of the surplus Caltrans properties or the specific use of any of the properties. The City is still analyzing the financial feasibility of purchasing the properties and the various options for converting them to affordable housing. The City cannot commit to a specific course of action for the surplus Caltrans properties until that analysis is complete. Furthermore, selling all of the surplus Caltrans homes at market rates to generate capital for the creation of deed-restricted affordable housing elsewhere in the city is not an allowable action under SB 381. Staff will explore possible solutions.
Josh Albrektson (March 3, 2023)
Love the Housing Element and I am pretty sure it will be accepted.
I think you guys accidentally didn't include that the IHO would not apply to buildings under 10 units.
I would add that.
On the South side of Monterey Road you have Victor Trans Site 3. He has mentioned before that he would like to put about 50 units on the site. I would consider making that half of the road Residential High Density zoning instead of Residential Medium Density. You could also then count Site 3 as 1.26 acres*45 units/acre rather than the 8 above mod units you are counting now. I'm not gonna complain about this but he is going to reach out to you.
The right of return program is also not quite right but that is something that could be worked on later.
Here is a LA Times article on it.
https://www.latimes.com/opinion/livable-city/la-ol-gaisford-right-to-remain-gentrification20180212-story.html I've read the rest of it and I could not find anything else missing. --
Josh Albrektson MD
Neuroradiologist by night
Crime fighter by day
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Page B1-208 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: The Housing Element has been revised to include an exemption to the IHO for developments under 10 units. Site 3 is included in the Ostrich Farm mixed-use area as shown in Figure A-3.b (Page A1-15). This area will allow for densities of up to 70 du/ac. While this site could yield significantly more units once rezoned, the City currently has an application in for this site which indicates that the property owner intends to construction eight (8) above-moderate income units on the site. Therefore, the Housing Element reflects the current development application submitted by the property owner. The property owner will have the option to submit a new development application for a greater number of units once the site has been rezoned. If the property owner chooses to do that in the future, it will increase the City’s housing buffer beyond what is included in the Housing Element. Proposed tenant protection programs will be further researched and refined.
Victor Tang (March 5, 2023)
Hi Angelica,
This is Victor Tang, the developer for 181, 185, 187 Monterey Road with 1.25ac land and site #3 in city’s site inventory. Our site is vacant and ready for development.
In the special joint meeting on 2/15/2023, Housing Element consultant Mr. Grant Henninger had proposed an Extended Ostrich Farm Zone with 70u/ac density that included Monterey Road. It had the support of planning commission members as Monterey road was wide with all the utilities available. However this zone was not implemented in the latest Housing Element Draft.
Although we have submitted a development plan for 8 market rate units, we are interested in a new development for 50-80 units including low income housing. Current Housing Element’s density for our site is 30u/ac. We need a higher density (probably 50u/ac) for a new development to be financially feasible. If the city can give our site a higher density, we can withdraw existing 8-unit plan and the city can count additional RHNA from our site.
Best regards,
Victor Tang,
• How addressed: Site 3 is included in the Ostrich Farm mixed-use area as shown in Figure A3.b (Page A1-15). This area will allow for densities of up to 70 du/ac. While this site could yield significantly more units once rezoned, the City currently has an application in for this site which indicates that the property owner intends to construction eight (8) above-moderate income units on the site. Therefore, the Housing Element reflects the current development application submitted by the property owner. The property owner will have the option to submit a new development application for a greater number of units once the site has been rezoned. If the property owner chooses to do that in the future, it will increase the City’s housing buffer beyond what is included in the Housing Element.
John Lawrence (March 6, 2023)
The proposal to allow mult-unit housing anywhere in South Pasadena is a terrible proposal that would ultimately destroy the character, uniqueness and quality of life in South Pasadena. I understand there are concessions that are going to have to be made to the state housing plan but to simply say, “well OK, we will abdicate all control, all ability to self-manage our own destiny is irresponsible and destructive.
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CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-209 Who supports it his dystopian vision of South Pasadena? I’d really like to know. I suspect it is a purely political position being pushed by people who have no history, no investment, emotional or otherwise, and life connection at all to the city. Must be nice to look in from outside and advocate destruction when it doesn’t affect you.
• How addressed: The comment misstates what is being proposed as there is not a proposal to allow “multi-unit housing anywhere” in the city. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023.
Samuel Lin (March 6, 2023)
Dear whomever it may concern:
My wife has grown up in South Pasadena since she was a young little girl and I have since just moved been a resident for about 5 years. South Pasadena has always been known to be as a quaint small town everyone knows each other.
Until recently, there's been a lot of traffic, kids have been stuffed in schools. Even our own small elementary school in Marengo has a waiting list for the very same people who would live on the same street.
This proposal is not only going to bring in more congestion and traffic, it is going to change the very nature of our small city. We don't have the capacity to fit medium density because we eliminated the 710 freeway, we have a lot of traffic on Fremont. Also, you're going to turn our small beautiful city in a dense packed traffic, terrible place. I strongly urge you to reconsider the elimination of single family zoning, we do not need dense housing in this city, we cannot handle the traffic and we don't have the resources.
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies and programs in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023.
Ed Donnelly (March 6, 2023)
City Planning staff,
It has come to my attention that the latest draft of the Housing Element includes the elimination of zoning for single family homes citywide as well as a proposed building height limit increase to seven stories.
This will significantly impact the very things that define living in South Pasadena. Over the past several years I have worked side by side with fellow residents to secure city revenue through the UUT and the increased local sales tax. We have worked diligently to secure and sustain funding for our schools and our public library. Those campaigns, while a tremendous amount of work, were ultimately personally rewarding for our volunteers because what we were truly campaigning for was sustaining our way of life here in South Pas. And voters here in 91030 overwhelmingly agreed with us 3 - 563
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-210 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE in every case. This is much the same as the generation before us fought tooth and nail to prevent the 710 freeway from tearing the town asunder. And despite all of this an existential threat now looms unnecessarily.
I fully support responsible development and the building of affordable housing here in South Pasadena. There are sensible options. In addition, I completely understand the demands of the HCD and the consequences of not complying with them as we are already seeing with the project on the Shaker’s property. Embracing strategies that will immensely impact our police and fire departments, infrastructure and schools while drastically reducing tax revenue due to diminished property values isn’t just simply foolish, it’s irresponsible governance.
I urge you to find another way to realistically meet the RHNA numbers without destroying the fabric of our way of life here and dooming the city to be just another banal concrete wasteland on the edge of Los Angeles.
Ed Donnelly
1935 Edgewood Dr.
SOUTH PASADENA
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies and programs in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023.
Delaine W. Shane (March 7, 2023)
Dear Community Development Department Staff and Management:
The fifth version of the Housing Element is insufficient. Furthermore, it does not adequately address legitimate questions and concerns that I brought up in my earlier comments on the previous versions.
As a professional environmental planner with decades of experience, I know when I’ve been “blown off.” So, my original comments stand and are part of today’s comments to you. My intent is for you to reconsider some of the policies and make them more nuance or simply more limited in your approach and understand the underlying ramifications of them including financial burdens that will be placed on our city.
This whole process has been messed up. The housing element should have been part of the general/specific plan update. Now, it is not. When the CEQA process (environmental review) is finally undertaken for the plans, it’s very essence has been destroyed. Since the housing element will be approved, it can not be modified during the general/specific plan environmental analysis. Even if the housing element causes significant environmental impacts as determined in the general/specific plans EIR, there is little recourse of modifying the housing element to lessen such impacts unless the council modifies the housing element itself. And that of course will not happen. The council won’t do it and who will be paying for potential mitigations? It won’t be the developer that’s for sure. “Little things” like upgrading the Fire Department’s capabilities to reach high rise fires, new and/or more expensive water supply sources to meet the needs of new housing units not to mention how water pressure can be created for such high rises, etc. It will be on the residents and businesses of this small city.
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-211 You can say that the issues of infrastructure, traffic, water supply, etc. is not a requirement of the housing element. That it will be part of the plan updates. But, really, they are all interrelated. So, maybe HCD doesn’t care about our aging and inadequate infrastructure and public services, but the City governance needs to address these issues and plan on how to fix them NOW. And, that includes the financing of such improvements! “Kicking the can” down the road is irresponsible. What happened to the wishes of over 1,000 residents who initially participated in the general/specific planning process when David Watkins was the Planning Director? Residents had participated in that process for months and brought up reasonable growth scenarios of somewhere between 700 and 1,000 new housing units that could be accommodated in the next 20 years. The delays and the petty politics created what we now face. Credit of this latest fiasco is given to the planning consultants (all including the current one) that have failed to please HCD several times before. This version will probably be the one that HCD approves of because the consultant has given everything that the agency demands. The consultant should be responsive to our community and not have hidden YIMBY agendas. He doesn’t even live in this region.
He indicated that we must accept SB 381 (Program 1.b-page 254). That is misinformation.
Documented evidence has already been supplied to you that the side-by-side escrow can work and has been done before without implementing SB381. Many of my neighbors and I continue to support the return of the Caltrans housing to current/former Caltrans tenants or qualified buyers who will purchase these properties, fix them up, and live in them, and thereby add to the property tax base and contribute to the neighborhood’s charm. Our neighborhood already has dense housing and our existing infrastructure is in terrible condition. Affordable housing as described in the housing element needs to be distributed in various areas throughout the City. It is also states that the City WILL construct ADUs on these parcels. First, it should be the homeowners’ decisions as well as the practicality of building anything on some of these small parcels. Second, the “City WILL build” presumes the City owns the properties outright, and that would be a terrible mistake. Where is the funding for this? There are many problems with our existing infrastructure that equally need to be addressed but have been ignored due to a lack of funding. Or, at least that is what we have been told over the years.
For the special needs program (Program 2.h-page 263): The housing element states: “Eight-year Objective: Encourage construction of at least 50 accessible units, 50 units with three or more bedrooms, and 50 units affordable to lower-income households to reduce displacement risk and expand mobility opportunities in areas in close proximity to transit systems, commercial uses, services and amenities on appropriately designated sites within the Downtown Plan area, the Fremont Avenue/Huntington Avenue/Meridian Avenue neighborhoods, within properties identified for mixed-use potential, vacant higher density residential sites, City-owned sites, and underutilized nonresidential properties.” Are these related to the Caltrans housing? Or is this separate? There is no Huntington Avenue, it’s Huntington Drive (it figures for a consultant that doesn’t live here). Why isn’t Fair Oaks/Mission/El Centro considered as well?
He indicated that we must comply with SB 10. Page 268 has a policy that states: “Policy 3.5: Provide objective standards and ministerial application processes to implement 2021 State housing legislation (SB 9 and SB 10) that requires the City to permit construction of two dwelling units on single-family lots and allows density increases for multi-family properties up to 10 units with a CEQA exemption.” SB 10 is strictly voluntary and it is my understanding that the council had publicly backed away from supporting this previously. Why, therefore, is it in this housing element version? 3 - 565
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-212 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE For the height limitations policy (Program 2.n-page 267), why is the City so inclined to place so many limits on itself at this time? By having so many YIMBY restrictions and conditions, the will of the people that live in this City is being curtailed. This is clearly undemocratic and thwarts local control.
Clever architects and innovative developers can create smaller housing units within our currently defined building height limit. But, apparently that isn’t even considered in this version of the housing element.
For rezoning (Program 3.a-page 268), do the residents really know that you are proposing to rezone their properties in this fashion? The way this housing element has been advertised, you must know that most residents are unaware. As a cautionary aside, I remember traveling to Sedona, Arizona to view the red rocks over the years. Just before the pandemic, my husband and I took our then teenage daughter to Sedona. It was a disaster! Where once it was a sweet town with some tourists, it was now a complete zoo and utter chaos. Turned out that the State of Arizona had permitted opportunities for the Airbnb-type businesses and there would be no local control. In time, developers had bought up many, many houses and used each bedroom to rent short term to tourists. Local schools were impacted and at least one had closed because the population had shifted from residents to tourists.
And the sites themselves had been compromised by such heavy influx. We can’t correct a national crisis in housing by destroying our community. It’s just a 3 ½ square mile city. The rezoning needs to be more nuanced than what is now being proposed. It is too much.
For mixed use (Program 3.b, page 268) developments and adaptive re-use, such tall buildings and limited to no parking, we might as well become either Glendale or Pasadena Annex. The height of the buildings alone question the ability of the Fire Department to respond to high rise fires, as well as the necessary water pressure to support fighting fires or having operational fire water sprinklers. Parking availability? Most people do not rely on the Gold (L) Line to get anywhere except perhaps to go to special events. The Mission/Meridian garage was noted years ago in a L.A. Times article that people were parking there from elsewhere to do shopping. Few to none were actually parking to use the Gold Line for work outside of South Pasadena. Families with kids or elderly relatives will still need cars whether gas- or electric-operated. Parking is going to be worse (not a CEQA issue but a real life experience nonetheless).
For demolition of vacant properties (Program 3.c, page 270), how does this program relate to the Caltrans housing? Does the program mean that automatically if a vacant Caltrans housing is “viewed” as not fixable, it will be torn down and replaced with three units at that site? Many of the Caltrans vacant properties are small and located on hills where soil stability may be an issue.
I do not support Program 3.d, page 271 (Enable Parcel Assemblage) as currently written. It emphasizes a strong and lopsided City-developer partnership when maybe the homeowner doesn’t want to sell their property. There has to be support for the property owner as well. Forcing the property owner to sell their property would in turn create hardship for that resident. Home prices and mortgage rates are too high now and in the foreseeable future and so that property owner would not be able to resettle elsewhere in South Pasadena. That is outrageous. And your consultant never answered my question as to whether eminent domain would be invoked if the property owner was unwilling to sell.
Program 3.h, page 274, states that if the ADU numbers fail to materialize that MORE rezoning will take place! There are many reasons why people don’t want to or are unable to build an ADU. But, regardless, if this magical number doesn’t happen, we will be further rezone? Just how many people are we going to have here in a 3½ square mile area? Has that been calculated? Again, the financing for this unlimited rezoning journey? The schools? The streets? The water? This is ridiculous. Why 3 - 566
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CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-213 not just obliterate the zoning and put out the welcome mat for hordes of people? Watch the tax base shrink further because there will actually be fewer property owners. Floating bonds? Reducing municipal services? But, yes, make the YIMBYs happy. Whatever happened to responsible planning and considering possible future scenarios and costs?
I could go on, but I end with a plea. Look at the policies, each one very carefully. Are they really helpful to the residents and can they be financed and monitored in a productive and positive way by the City? Or, are they just offerings to appease YIMBYS? The financing must also be considered seriously.
Most of us agree to responsible and sustainable growth in the next eight years. I personally witnessed that with the individuals I met at the planning charettes years ago. Before you rush off this version to HCD, please review the policies individually and responsibly. Edits are needed to ensure sustainable growth.
Thank you,
Delaine W. Shane
2003 Meridian Avenue
• How addressed: The lawsuit brought against the City for failure to comply with State Housing Law caused environmental evaluation to be completed pursuant to Government Code Section 65759. The Housing Element is not subject to environmental review at this time. The City is preparing an Environmental Assessment that will be considered at the time of Housing Element adoption in accordance with applicable laws.
• How addressed: The City must follow SB 381 regarding the purchase and dispensation of the surplus Caltrans properties. The other options suggested in the comment are not legally valid. Per the March 7th draft, Staff will explore possible solutions. • How addressed: Affirmatively Furthering Fair Housing (AFFH) is a requirement of the Housing Element under state Planning Law. The City is not opting into SB 10 citywide, but instead is using the framework of the law to create the Missing Middle Housing program to achieve the AFFH goals. The program will have specific objective design standards to allow certain housing types that are consistent with existing residential character.
• How addressed: The current height limit is a constraint on development. The City must eliminate identified constraints on development. HCD has questioned whether a building could be designed at 70 du/ac or more with a 45 foot height limit. The action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review. • How addressed: The City held three public meetings, on February 1st, February 9th, and February 15th to discuss the proposed zone changes to allow for missing middle housing.
Kristine Kwong (March 7, 2023)
I am requesting the City change the section of the housing element to limit the area that allows fourflex parcels on major traffic corridors only or near the Metro station. Since the City has a voter imposed height limit, I suggest removing the mention of 7-10 story building that are above the current limit until the time the voters have had a chance to consider this issue. 3 - 567
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-214 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE • How addressed: The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023. A revised height limit must be stated for certain parcels that allow for 50 du/ac or more must be included in the Housing Element to state what the minimum new height limit will be if the voters elect to remove the existing height limit. The recommended height limit change only applies to those specific areas. The action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review.
Peter Giulioni (March 7, 2023)
Dear Armine,
Hopefully this finds you and your family continuing to be safe and healthy.
This is an out-reach from a SoPas community member, rather than a commissioner, so, please consider it through that lens.
Recently, it has come to my attention that the latest draft of the Housing Element includes the elimination of zoning for single family homes citywide as well as a proposed building height limit increase to seven stories. Is my understanding correct? While I'm a relative new-comer to SoPas (I moved here with my family in 1996) I believe this will significantly impact the very things which define living in our community.
Over the past several years I have worked side by side with fellow residents to ensure passage of the UUT and the increased local sales tax. We worked to secure and sustain funding for our schools through SPEF initiatives, and even our public library. While a tremendous amount of work, it was/is personally rewarding for us as volunteers because we were truly campaigning for sustaining our way of life here in SoPas. And please note, I used the word "sustaining" not "protecting" - I am a proponent of thoughtful and conscious growth and expanded thinking. The advocacy of many of my SoPas neighbors can be seen as a continuation of the spirit shown by the generation before us who fought to prevent the 710 freeway from bisecting our town.
While not completely conversant around the demands of the HCD and the consequences of not complying with them; embracing potential solutions that will impact our police and fire departments, infrastructure and schools while potentially reducing tax revenue due to diminished property values seems counterproductive at best and irresponsible at worst.
Please consider this a "formal" request that you direct the city staff to find another way to "meet the numbers" without negatively impacting the very nature of our way of life here in SoPas. I believe we are special in so many ways, and don't want to see us become yet another "characterless" wasteland on the edge of Los Angeles.
As always, please feel free to reach out for more information or clarification.
Stay safe and healthy, warm regards, Pete
3 - 568
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-215 • How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies and programs in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023.
Leonard Mlodinow (March 7, 2023)
To whom it may concern: I just heard that the latest draft of the Housing Element includes the elimination of zoning for single family homes citywide as well as a proposed building height limit increase to seven stories. I feel strongly that this would have an enormous negative impact on our community and that it is not in character with what I and my neighbors understand and appreciate as South Pasadena. I hope you can illuminate those changes from the plan.
Leonard Mlodinow
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies and programs in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the City. This revision was released for public review on March 7, 2023. The recommended height limit change applies only to specific areas. The action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit.
The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review.
Brian Bright (March 7, 2023)
Hi Council,
Living in South Pas has been a great experience. This city has a long history of preserving its identity, history, and way of life. South Pasadena was bisected in the 40's by the 110 and the people said "never again" to be pushed around by Sacramento, so they fought when the 710 expansion was going to decimate the city by splitting it into fourths with the 110. South Pasadena prevailed, thankfully, or this city would have been split up.
Now the overlords in Sacramento want to control our town again, adding an unreasonable amount of new construction due to a blanket law that pays no attention to the amount of apartments vs single family homes in each community. South Pas is almost evenly split with rentals vs single family homes, unlike many of our neighboring cities (looking at you San Marino). To make things worse, we have paid shills for the development industrial complex who have infiltrated our town and are on social media complaining about a lack of housing ad nauseum, all the while living in their affluent single family homes. How this expansion of units effects our schools, infrastructure, and way of life is never discussed in a logical debate.
3 - 569
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-216 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Unfortunately, city council did not fight hard enough against the state punching down a few years ago, and here we are. 10 story buildings in South Pas, our of historic homes being able to be 4 plex apartment buildings...seriously? Lets fight now to preserve our town, we owe it to those who fought the good fight in years past and to every homeowner in this city! Sincerely,
Brian Bright
• How addressed: The City has a requirement to address issues related to Affirmatively Furthering Fair Housing and to accommodate the number of homes allocated to it through the Regional Housing Needs Allocation process. The policies in the Housing Element fulfill those requirements.
Donna Scott (March 7, 2023)
To whom it may concern:
The new zoning proposal for South Pasadena is unacceptable.
Eliminating zoning for SFRs, as well as increasing building heights to 7-10 stores will completely change the character of our town.
Also, there seems to be a movement to push through this HUGE change without much discussion, or publicity.
I would request slowing the process down, making details known through local papers etc.,in order to get more input and allow for the proposal of different options.
Thank you.
Donna Scott
1970 La France Avenue
South Pasadena
626 840 7189
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies and programs in the Housing Element fulfill those requirements. Since May 2020, the City has held several community input sessions and recently held three: City Council meetings, on February 1st, February 9th, and February 15th (Joint Meeting with the Planning Commission) to discuss these changes. The City has a court-imposed timeline for responding to HCD’s comments, which necessitates the speed with which the City is acting on these policies. Additionally, the City has a page dedicated to the Housing Element where all updates have been posted.
Bruce A. Finstead (March 7, 2023)
We are writing you because we fear that South Pasadena’s approach to the state mandated Housing Element requirements may destroy the small-town atmosphere of the city where our family has lived since 1971. We are well aware of the NIMBY potential of our comments and the difficulties you have in balancing the desires of our small community with the societal need to provide additional affordable housing for California residents. We further realize the frustrations of dealing with regulations that may well not take into account the divergent needs and desires of small vs large communities.
3 - 570
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-217 Of paramount concern to us is the proposal to eliminate single family residential zoning throughout the city. Among the many characteristics of our city that make it special are its neighborhoods of people living next to one another in single family homes. Neighborhoods have people with bonds developing over years; this cannot occur if multifamily dwellings with relatively short-term residencies are intermingled with homes of families living there for years, or even generations. Expanding the areas or corridors where multifamily residences are allowed is not the ideal situation, and may be necessary, but to eliminate single family residential zoning for the entire city should not even be under consideration.
South Pasadena does not have much undeveloped land; it may well be necessary to go up rather than out to obtain more developable space; raising the building height limits may be aesthetically undesirable, but it may be a necessary concession to the state. It might be more tolerable if mixed use buildings were required with businesses on the ground floor and residences above. Is it possible to provide financial incentives to current “tall” building owners to convert their buildings to mixed business/residential use?
Thank you for your consideration. If you wish additional input from us, we would be pleased to provide it.
Bruce A. Finstead, M.D.
Melissa Finstead
1947 La France Avenue, South Pasadena
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the highquality transit areas within the City. This revision was released for public review on March 7, 2023.
Michael Girvigian (March 7, 2023)
Hello,
As a longtime resident of South Pasadena, I urge the city staff to significantly re-think the latest draft of the city's housing element.
I understand there is a statewide mandate to increase housing, which is several years old now.
This statewide mandate, however, was made at a time when the projected state population by 2040 was 50 million people.
The population growth has stopped, and the state population is shrinking.
The state's population could remain stagnant for the foreseeable future.
There are a number of reasons for this, which include: increased out-migration, reduced immigration, low birth rates.
Future mass transit ridership adjustments are already underway based on new projections of shrinking population growth.
3 - 571
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-218 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE High speed rail update gets closer to reality, but major risks remain https://www.masstransitmag.com/rail/news/53027098/ca-how-many-people-will-use-californiasbullet-train-planners-lower-ridership-estimates High speed rail update gets closer to reality, but major risks remain Thus, destroying the quality of life of the people in small towns, in the name of an outdated mandate, is not fair or equitable.
I urge the city staff to re-think this latest draft of the housing element.
Sincerely,
Michael Girvigian
310 Meridian Ave.
South Pasadena
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
Cathleen Hoadley (March 7, 2023)
I've been made aware that the latest draft of the Housing Element includes the elimination of zoning for single family homes citywide as well as a proposed building height limit increase to seven stories.
I can't even imagine South Pasadena suddenly having a skyline with buildings higher than four stories; it will completely change our little town. The other issue is that we have neighborhoods with single family homes, and also certain parts of town with high density apartment buildings, and then there are some areas with a healthy mix of both, but none are higher than four stories.
My neighborhood of Buena Vista/Foothill/Prospect/Meridian/Highland/Fairview, nestled between Fremont on the east, Orange Grove on the West, and just north of the 110 freeway (Foothill) and bordered by Columbia on the north, has no apartment buildings at all; if someone were to purchase a home, and raze it, and put up a multi-unit apartment building, that would completely change the nature of the neighborhood I have been fortunate to live in for the past nearly 23 years. I have neighbors on all sides who have lived on Buena Vista for coming up on 50 years. These are the people who fought the 710 extension which would have ruined South Pasadena forever. I know many people are creating ADRs, which are welcomed, but perhaps not enough.
Please be mindful of how being able to construct a new apartment building with four units in the middle of a solely single family neighborhood will drastically impact the nature of these traditionally single family home neighborhoods.
Thank you,
Cathleen Hoadley
1109 Buena Vista St.
South Pasadena, CA 91030
3 - 572
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-219 • How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
Sandy Kitto (March 7, 2023)
To: The City of South Pasadena
As long-time residents of the city, we reviewed the current draft of the City of South Pasadena (City) 2021-2029 General Plan Housing Element with concern. The elimination of single-family zoning, and the height limitations for multi-family residential units reaching 7-10 stories would negatively impact the appearance and personality of the city that attracted so many residents like us.
These concerns are as follows:
• The universal elimination of single-family zoning is short-sighted in allowing up to four units being built on a single parcel anywhere in the city. Many parcels in the city, such as our house on Bonita Drive, would be challenging if not impossible to accommodate four units, yet that would be permitted. The construction would create unimaginable chaos for the neighborhood, and a parking nightmare afterwards.
We suggest that a parcel size requirement be included that would limit this expansion to parcels that could reasonably accommodate the units and parking for the residents. • The current plan eliminates the requirement for parking for any construction within a half-mile of mass transit, most likely the Gold Line at Mission Street and Meridian Avenue. Imagining multiple seven story buildings in that neighborhood, would create mammoth parking issues. Just because people live near the Gold Line does not mean they work in an area serviced by the Metro. And even if that were the case, it does not eliminate the necessity of having a car in the Los Angeles metro area for errands and weekend travel. Even the grocery stores on Fair Oaks Avenue may exceed the resident’s willingness to remain pedestrians while carrying groceries.
So many of these residents will still have vehicles clogging the limited parking available. This potentially would impact the merchants along Mission Street by blocking customers from accessing the area.
We suggest reducing the height restriction (and thereby the number of units), AND requiring parking accommodation be part of the project.
• From an aesthetic point of view, allowing new construction of 7-10 stories is a dramatic change from the current situation in the city. A sudden influx of 7-10 story buildings would forever alter the landscape of South Pasadena; blocking mountain views, casting huge shadows on adjacent parcels, and reducing the charm of the neighborhood. The Eclectic Music Festival, and semi-annual Arts Crawl would be a completely different “vibe,” as would daily living.
We suggest limiting the height maximum to a more reasonable 4 stories to maintain the City’s appeal.
For these reasons, we urge the City leaders to reconsider the plan as currently proposed. 3 - 573
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-220 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Sandy Kitto and Joe Walters
911 Bonita Drive
South Pasadena, CA
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements, as well as incorporate other state requirements such as elimination of parking requirements in close proximity to transit. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the City. This revision was released for public review on March 7, 2023.
Sally Kilby (March 7, 2023)
To Whom it May Concern:
One change I would request is that buildings of up to a fourplex be limited to parcels on such major traffic streets as Fair Oaks, Huntington, and Fremont, and to those near the Metro South Pasadena station. I would also recommend excluding mention of 7-10 story buildings since South Pasadena has a voter-imposed building height limit. Citizens can be asked to vote on this at an upcoming local election.
Sally Kilby
City Clerk, Retired
1000 El Centro Street
South Pasadena
• How addressed: The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023. A revised height limit for parcels that allow for 50 du/ac or more must be included in the Housing Element to state what the minimum new height limit will be if the voters elect to remove the existing height limit. As to the actions regarding the height limit, indeed the action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review.
Linda Poore & John Poore (March 7, 2023)
I have lived in South Pasadena for 47 years and taught many years at all 3 elementary schools. This community is filled with many creative innovative people who have solved many problems over the years including The 710 freeway corridor , library funding, numerous tax raises to improve services, etc. It's time to find solutions that involve input from many residents, including reviewing how other small communities are complying to the new requirements. Please feel free to contact me at any time.
Linda Poore & John Poore
1964 La France Avenue
South Pasadena, CA 91030-4608
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-221 1-626-390-0059
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
Mike Mitchell (March 7, 2023)
As a new owner of a single family home in South Pasadena I have serious concerns about the changes being suggested by local and state government. I am understanding of the need for more units and lower income housing to create more access to housing for a wider range of individuals, but the changes are too extreme and will have deleterious effects on the community.
As someone who has spent over a year waiting to get planning permission, I understand that the city takes very seriously the cohesiveness of neighborhoods and how that cohesiveness affects home ownership for us all. Suggesting that it is acceptable to go from areas entirely comprised of single family homes to suddenly giving large investors the right to build complexes over 7 stories high is incredibly extreme. Even tempering this suggestion to complexes of 3-4 stories would have an impact, but would be understandable given the state mandate for increased housing. People have invested huge sums of money in their home here to live in what feels like a special community. We want more people to have access to it, but not at the expense of damaging those people's investments.
It may seem callous to talk about investment in a community in financial terms, but those investments are people's future stability, and in Southern California represent a huge portion of a person's material wealth. It is even more callous to wantonly disregard how difficult home ownership is in this state by diminishing people's values and subsequently their future stability.
Change is needed in order to bring new, lower income families into this city, and more of them.
Change should however, be brought about in ways that do not damage the existing balance in the community but rather improve it. I would like to think that the very intelligent members of our local government can find a way to bring about the changes we need while preserving what drew people to this community to begin with.
thank you,
-Michael Mitchell
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
Keith Tsang (March 7, 2023)
Hello,
I would request the city change the following section of the housing element to limit the area that would allow up to a four-plex to parcels on major traffic corridors only, like Huntington, Fremont and Fair Oaks or near the Metro station. Also, since the city currently has a voter imposed height limit, I 3 - 575
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-222 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE would recommend removing the mention of 7-10 story buildings that are above the current limit until such a time when the voters have had a chance to weigh in on this.
Keith Tsang
1440 Indiana Ave
• How addressed: The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023.
Nicholas Greco (March 7, 2023)
The city’s infrastructure cannot handle the additional volume of residents should the four Plex allowance be authorized. Homeowners pay the majority of taxes and this will lead to an undue burden on the homeowners of South Pasadena and a decline in the quality of schools and city services that we all cherish. State mandated ADU add ons that are rentable will bring in additional residents while also allowing for increases in property tax revenue by the homeowner. Please don’t disrupt our way of life and diminish the quality of our quaint town. We hope that the City Council considers this as they were elected to protect the way of life that South Pasadena homeowners and residents have come to appreciate.
Sincerely,
Nicholas W Greco MD, FACEP
Operations Director
Emergency Department
Huntington Hospital
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
South Pasadena Tenants Union (March 8, 2023)
Dear Ms. Becker and Ms Fausto:
South Pasadena Tenants Union leadership are pleased to have reviewed the March 2nd, 5th Draft of the Housing Element. It was/is a bold and expansive housing element, one which might even be the best in the Southland. We applaud staff for the inclusions of the tenant protections and the acknowledgment that preserving affordable housing is a priority in this process. We look forward to working with the City, the residents of South Pasadena and the Council to ensure that these policies are the best that they can be and are enacted effectively and within a timeframe that is beneficial to those whom they are intended to protect: the 53.5%.
We are however surprised to learn that as of last night, the original draft of March 2nd has already been substantially revised and without any published responses/comments indicating public input. In reviewing the March 7 redline version, we are disappointed to see that the proposed program addressing the fate of the CalTrans homes and the implementation of SB381 has changed drastically from the March 2 version. It is our understanding that there are no legal alternatives to SB381 and therefore we are stymied by this latest change.
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-223 With regard to the revision indicated by the March 7 version for citywide fourplexes, also significantly different from the March 2nd draft, we find that we can remain wholly supportive of the current proposed change with a modification. We can support triplexes and fourplexes being limited to the high transit areas but we will need the City to commit in the Housing Element to a rent stabilization ordinance that is fully enacted no later than June 2024. Therefore, our one public comment regarding the most recent March 7 version of the 5th Draft Housing element is below:
For program 6.d, SPTU asks that you include within the 5th draft a deadline of no later than June 2024 for implementation of a rent stabilization ordinance.
South Pasadena Tenants Union looks forward to seeing our input included with the expediency that other revisions have been made in the last few days so that we can comfortably and wholeheartedly commit our support of the 5th Draft to HCD. We appreciate and trust that staff will do as proposed, but will need to see good faith that the City weighs our input equally to that of other influencers in the community by including our abovementioned request.
If you have any questions or would like to discuss, I look forward to hearing from you. I can be reached Anne Bagasao at [email protected] or by phone at 626-660-8837.
Sincerely,
Anne Bagasao, Co-Founder
• How addressed: The timeframe for Program 6.d requires that City Council consider a rent stabilization ordinance no later than December 2023.
Jenny Bright (March 8, 2023)
Very well said!! I am in agreement that we need more affordable units. It is the heavy hand of Sacramento overriding local control with threats that is not in the spirit of South Pasadena. Rezoning is the wrong direction. There are still locations in town to add affordable housing that we can support financially without having to erode the entire character of the City. We already have >50% rentals here so it is not as if we are out of balance.
On Wed, Mar 8, 2023 at 8:15 AM richard schneider <[email protected]> wrote:
I am certainly in favor of the city having a mixture of housing for different income levels. We need more units for low and moderate income levels. When I and my wife moved here years ago we were low income renters. But I think the provisions suggested for the new Housing Element, however well intentioned, are going in the wrong direction. What is needed is state subsidies for affordable units distributed throughout the city. Some of that subsidy money could be obtained by market rate sale of Caltrans properties. There are thousands of Caltrans properties around the state which could be utilized.
The current housing crisis was not caused by the City of South Pasadena nor its residents. And responsibility for crisis solution should not be transferred from the state to local communities.
Yours very truly,
Richard D.Schneider, MD
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable 3 - 577
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-224 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
Dan Evans (March 8, 2023)
Ladies and Gentlemen:
I believe it may be a mistake to treat this issue as normal, administrative “compliance” with properlyenacted state law. In reality, we do not face normal legislation in SB 9, SB 10, etc. What we face is an attack on the way of life we choose to live in South Pasadena. Big-government social activists have seized the single-party government in Sacramento for a social revolution – to eliminate the middle class by removing our choices on how we live. We choose to live in single-family homes with gardens, not in massive housing projects as the social revolutionaries in Sacramento insist.
Confronted with a social revolution, “compliance” is a weak, conciliatory approach which will further empower the social revolutionaries. South Pasadena led the way against big-government plans to build a freeway through town, we should also lead resistance to these Big Brother housing efforts. Our resistance will lead to litigation; eventually cooler heads in court will see that SB 9, SB 10, etc. constitute a “taking” of property without due process. (fyi – I have taught Constitutional law.) We must stand up for the way of life we choose to live, not cave to big-government activists! Dan Evans
[email protected]
(626) 403-0575
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements.
Felix Gutierrez (March 8, 2023)
Dear South Pasadena City Leaders:
I understand that an elimination of Single Family zoning in South Pasadena has been proposed and is being considered by the city government.
Please register my strong support for continuing Single-Family Housing Zoning in the range of zoning options available to the city and residents. Other options should also be included and new ones added without eliminating one that has served the city well over the years and is needed for the future.
Single-family homes are a defining characteristic of some of our neighborhoods. Eliminating that zoning option could lead to overcrowded lots, schools, streets and parking spaces, not to mention additional demands on police, fire and other first responder services. We have already seen these overcrowding impacts on nearby cities.
I strongly urge you to keep South Pasadena's best long-ranges interests in mind as you contemplate possible changes.
Sincerely,
3 - 578
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-225 Félix Gutiérrez
632 Milan Avenue
South Pasadena, CA 91030
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The Housing Element includes policies that commit the City to allow for missing middle housing types along high-quality transit corridors, if property owners so choose.
Laurie Chatham (March 8, 2023)
Dear All Concerned,
The DRAFT Housing Element has come to my attention via my concerned neighbors. I wanted to give my input as a concerned community member, having lived in South Pasadena for 26 years, and having visited my Great Aunt in this city since 1958.
Is it true that the DRAFT includes elimination of zoning for single family homes throughout the entire city? Is it true that there is a proposed height limit for buildings being increased to seven story structures? These proposals will have a negative impact on South Pasadena and are extreme. We have seen how other neighboring communities have allowed higher density development on lots that previously contained a single family home. There is significantly more traffic and the community atmosphere is negatively impacted. Please consider limiting the change in zoning to the high transit corridors (not city-wide) and elimination of references to seven or more story buildings in South Pasadena.
Thank you for your consideration,
Laurie Chatham
1915 La France Ave.
South Pasadena, Ca. 91030
How addressed: No, it is not true that zoning for single-family homes throughout the City is being proposed. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023. It is also not true that the height limit is being increased. The action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review.
Deni Sinnott (March 8, 2023)
I am writing to comment before today's deadline on South Pasadena's plan to build affordable housing.
I am confused by the fact that the city wants to march forward on the plan to supply affordable housing but has decided the Golf Course is off limits.
From Appendix B:
3 - 579
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-226 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Has the City looked at the Arroyo Seco Golf Course as a suitable housing site for affordable housing? - City staff responded that converting the golf course into homes is an option, but one that is not politically popular and therefore not proposed as part of the Housing Element at this time.
Who is the council affiliated with that they need to back off from using this piece of land for the plan? It would seem to be ideal and could be used to create housing in the Arroyo which is idyllic compared to some of the sites proposed, in particular, JAMMING housing on smaller parcels or even in between current houses that exist on residential streets.
I am in favor of lifting height restrictions on buildings but those newer, taller buildings would need to be built on major thoroughfares.
We do need to build more housing and there are some buildings/parcels that I just know could be purchased to accomplish this tasks are:
• Crash Champions Body Shop on 300 Fair Oaks- two large lots could accommodate 1 building each.
• 1499 Huntington Drive office building at Fair Oaks (old and needing rehab) Occupancy is not 100%. I believe this is taller than 4 stories already!
• Bargain Market and adjacent retail could also be used for new homes/apartments/condos.
I am sure there are many more places in the city that could be repurposed without disturbing the streets where we have mostly single family homes. If ADU is a desired route, the city should subsidize the building of those to homeowners who would like to participate and STREAMLINE the permitting process to be less onerous.
--
Deni Sinnott
Homeowner, 2066 Fletcher Avenue, South Pasadena
CLPF, NCG, MBA
626-233-4128
• How addressed: The golf course was considered as a housing site during the February 1st City Council meeting. The City Council directed staff to find alternative to accommodate the city’s housing needs that did not remove recreational open space from the City. The Housing Element does consider these other parcels as potential candidates for redevelopment, but the City does not have substantial evidence that they will be redeveloped during the planning period. As the Housing Element is part of the General Plan, it must be consistent with other General Plan elements, including the Open Space Element which requires sufficient recreational space for the residents of the City.
However, the City is committed to continue to analyze additional sites, including potential sites in the Arroyo in the future.
Mary Urquhart (March 8, 2023)
The recommendation to repeal the current 45-foot height limit on any residential or mixed-use project is in opposition to the vast majority of residents. The minimum requirements of 84 feet and 7 stories or 110 feet and ten stories, depending on whether the project is in an area with a density of 50 or 100 units per acre, respectively, is unacceptable.
3 - 580
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-227 However, the approach of layered zoning in major corridors has the potential to be a bonus to our City. Mixing affordable housing with middle and higher-income housing options along with retail in major corridors that have a much higher traffic flow, such as Huntington Drive, should be listed as an option. Once the HE is approved, we can explore ways to work with our community to do this where this may be a bonus to our community. Areas that may apply to this concept are located on Huntington Drive and Arroyo, which are currently not offered in the current HE.
The second area that is of deep concern in the 5th draft is the implementation of SB9 and SB10, the Missing Middle Housing (MMH). SB10 is NOT a mandate and our City and our City were not considering this. Why was this included? Can you imagine this being allowed in our historic Bungalow Heaven? This language should not appear in our HE.
I do applaud the hard work that our City Planning Department has done in the past few months to pass an acceptable HE.
• How addressed: The action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review. The City has a requirement to address issues related to Affirmatively Furthering Fair Housing (AFFH) and to accommodate the number of homes allocated to it through the Regional Housing Needs Allocation process. Removing or increasing the current height limit is the only way to accommodate the RHNA requirements without upzoning the existing low-density residential zones. The City is not opting into SB 10 but instead is using the framework of the law to create the Missing Middle Housing program. The program will have specific objective design standards to allow certain housing types that are consistent with existing residential character. The policies in the Housing Element fulfill the requirements of AFFH.
Mary Farley (March 8, 2023)
There was given no time for working people in South Pasadena to respond to this proposal. We are being railroaded and this needs to be litigated. The impact on our tiny town is wildly disproportionate compared to contingent communities.
When my family moved to South Pasadena from Boston forty three years ago, we asked my husband’s employer, USC, what would be a good place for a mixed race family to relocate near the medical school, and the suggestion was South Pasadena.
The introduction of racial elements into this battle over development is bogus and there should have been adequate time in which to challenge it.
• How addressed: Since May 2020, the City has held several community input sessions and recently held three: City Council meetings, on February 1st, February 9th, and February 15th (Joint Meeting with the Planning Commission) to discuss the Housing Element revisions. State law requires that all housing elements address racial wealth and homeownership gaps as part of the Affirmatively Furthering Fair Housing (AFFH) analysis.
Eric Hausner (March 8, 2023)
Dear City of South Pasadena,
3 - 581
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-228 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE As a home owner and resident of South Pasadena, I wanted to provide feedback on the proposed General Plan Housing Element. In particular, I am concerned with allowing duplexes, triplexes or fourplexes throughout the city.
This change will fundamentally harm the fabric of South Pasadena that makes it so unique and special.
Instead, I would suggest limiting these changes to major traffic corridors only, such as Huntington, Fremont, Fair Oaks, Mission (near downtown) or near the Metro station.
I also think it's a good idea to wait on revising the height limit until voters have had a chance to cast their votes on the matter.
I understand the enormous pressure the city is under to make these changes. However, hopefully we can find a way to be compliant while also preserving the character and history of this amazing city.
Respectfully,
Eric and Emily Hausner
1722 Milan
• How addressed: The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the high-quality transit areas within the city. This revision was released for public review on March 7, 2023. The Housing Element does not change the height limit, it commits the City Council to bring forth a voter initiative to consider repealing or replacing the height limit and provides a new height limit if it is replaced.
Helen Mendoza / Pamela Privett (March 8, 2023)
To the City Council:
While we are in favor of increasing and diversifying housing within the city of South Pasadena, we believe the new draft of the Housing Element is at best, extreme and out-of-line, and at worst, thoughtless and irresponsible. As we understand it, the new draft 1) eliminates zoning for Single Family Homes 2) allows for development of up to 4 units on any property city-wide and 3) raises building height limits to 7-10 stories.
These are outrageous rules and will 1) negatively impact the property values for all residents in the city 2) severely encumber a school district already stretched to the limits on space and resources and 3) destroy the very character and quality of life that has made South Pasadena the kind of community people want to live and raise their families. In addition, we feel you have failed to consider that the city’s infrastructure is neither designed nor capable of dealing with the increased need for resources should these new rules go into effect.
Yes, we need to find a solution for affordable housing for the city’s residents and those who want to move here. However, doing so by creating rules that will make it possible to fundamentally change the fabric of our town and destroy the value of historic neighborhoods like Buena Vista in the northside or Edgewood/Milan/Stratford to the south side or those in Monterey Hills would be irresponsible and negligent.
South Pasadena’s “calm” within the “chaos” of Los Angeles is what brought us here. We wanted to raise our children in good schools and live in a diverse and welcoming community. It was the history of the old house we got to restore, and the small town neighborliness we love that have kept us here. 3 - 582
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-229 There is a saying about buying real estate — don’t purchase a single family home that has a multiple family unit on the block. The city’s new plans will make it possible to put multi-unit apartments on ANY property… and that would devalue all the property for all residents.
These new Housing Elements would fundamentally destroy the face and skyline of the city, and it would in turn dismantle South Pasadena’s character and heart.
Every city is having difficult conversations about how to deal with their fluctuating population densities. The draft presented, however, is short-sighted and misguided. Surely the city can find more creative solutions to these issues than what has been put forward.
Helen Mendoza / Pamela Privett
Buena Vista Neighborhood
201 Beacon Avenue
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals.The policies in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the highquality transit areas within the city. This revision was released for public review on March 7, 2023.
Jenny Bright (March 8, 2023)
South Pasadena is a wonderfully unique City with a balanced housing stock of owners and renters and also a balanced and diverse population of residents. Eliminating single family zoning would erode the entire character of the City that attracted its diverse population in the first place. It would make the City indistinguishable from every other community just outside of LA. Raising the height limit of buildings would be an irreversible step and make this City that has been so thoughtfully preserved for the last 135 years unrecognizable. We can and should add affordable housing units but we can do this without destroying the City.
-Jenny Bright
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals. The policies in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the highquality transit areas within the city. This revision was released for public review on March 7, 2023. As to the actions regarding the height limit, the action taken through the Housing Element adoption does not eliminate the existing height limit or create a new height limit. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review.
Jim Tavares (March 8, 2023)
I believe there is general consensus that it is the right thing to create more housing within South Pasadena; the concerns are how that housing is created, what it looks like, and ensuring it does not 3 - 583
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-230 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE create unintended consequences of congestion and loss of South Pasadena's community feel. If South Pasadena simply becomes a place, and no longer a community, the process will have failed.
I don't think that has to happen.
I think roundly rejecting SB 10 is a must, as is rejecting the idea of a ballot measure for unlimited building heights at 50 du/acre. It will create endless disharmony between opportunistic developers and residents and break the character of our community. An 8,000 sf lot with ten units on it will accomplish the density needed to exceed 85 feet in height and shadow a residence next door.
Market rate sale of Caltrans properties can go a long way for Los Angeles as well as South Pasadena to fund more affordable housing projects vs. repurposing of these homes and the costs to do so--private owners can purchase and rehabilitate the homes with the sale profits going to other projects throughout the city, retaining the character of existing neighborhoods.
I think it is folly to have any properties that do not supply parking at a rate below one per unit, and higher form 2+ bedroom units, despite proximity to public transportation. While I hope public transportation will be used and ease congestion, ridership has trended down over the past 5 years, and while it has recently been on the upswing among certain demographics, safety concerns and reliability/destination proximity will likely force many into their cars, no matter where they live, straining surface streets for parking access.
Lastly, massing at the street and a provision for length of unbroken wall in a given plane and raking of massing from the street, with some green space around structures can go a long way to preserving the community feel so many have come to South Pas to experience. these details need to be ironed out in the Housing Element to ensure development that people want to stay within and around.
Very truly yours,
Jim Tavares
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals.The policies in the Housing Element fulfill those requirements. The City is not opting into SB 10 but instead is using the framework of the law to create the Missing Middle Housing program. The program will have specific objective design standards to allow certain housing types that are consistent with existing residential character. Per a Court Judgement, the City must place a measure on the ballot to repeal or amend the current height limit.
How addressed: SB381 has state-mandated requirements on how to acquire, utilize, and transfer homes currently owned by Caltrans. The City Council has made no determination regarding the purchase of any of the surplus Caltrans properties or the specific use of any of the properties. The City is still analyzing the financial feasibility of purchasing the properties and the various options for converting them to affordable housing. The City cannot commit to a specific course of action for the surplus Caltrans properties until that analysis is complete. Furthermore, selling all of the surplus Caltrans homes at market rates to generate capital for the creation of deed-restricted affordable housing elsewhere in the city is not an allowable action under SB 381. Staff will explore possible solutions.
Mark Gallatin (March 8, 2023)
3 - 584
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-231 The City of South Pasadena has made tremendous progress under unprecedented circumstances toward the development of a housing element that can satisfy the rigorous requirements of state law.
Now however, with a court-appointed deadline for completion looming, this progress could be endangered by two proposed programs in the 5th draft of the element that, as presently constituted, do not yet reflect the most creative approaches to the issues they seek to address and will quite likely provoke opposition from many residents.
The first of these is Program 2.n, the Citywide Height Limit Ballot Initiative. This program calls for a referendum on repeal of the current 45-foot height limit on any residential or mixed-use project on which the housing element anticipates a base density in excess of 50 units/acre. It proposes to replace the current height limit with either no height limit or a minimum requirement of 84 feet.
The reason for essentially doubling the current maximum height to a new minimum height is ostensibly to accommodate the greater densities planned in localized areas to stated density goals in order to help the City meet its RHNA target and to achieve the densities identified in the Downtown Specific Plan (DTSP). Despite being revised to reflect a lower minimum height limit, the current language of Program 2.n still tracks with that from the State of California’s Department of Housing and Community Development. As such, it does not yet reflect a locally developed solution created with input from community members, appointed and elected officials seeking to maximize compliance and minimize harm, a thoughtful, more nuanced approach that better aligns with the tradition and character of the city’s built environment.
What might such an approach look like? For starters, it would restate the modest proposal made by the City’s original general/specific plan consultant to consider raising the height limit along Fair Oaks Avenue frontage properties within the DTSP from 45 feet to 50 feet to facilitate well designed and proportioned four-story buildings on Fair Oaks Avenue.
Second, it would draw on the incredible depth of talent, expertise and experience of design and architectural professionals that call South Pasadena home, as well as interested laypeople, to fashion a strategy that de-emphasizes governing metrics such as minimum height in feet or number of stories and instead focuses on standards such as floor area ratio (FAR) and unit size to create a “building envelope” capable of accommodating the desired densities within the confines of the existing height limit or a modesty increased one. That such an approach can yield the densities contemplated in the DTSP or in overlay zones on arterial corridors has already been demonstrated by projects completed in cities across the region, in locations as diverse and different as Santa Monica and San Gabriel. The inclusion of some of these standards in the latest draft of Program 3.b is a good beginning but it is hoped they are just the starting points for further discussions rather than faits accomplis, as the real work will begin when drafting new zoning provisions to implement the adopted element. Creative approaches to density, such as the “layered zoning” approach on major corridors, as recently presented at a WISPPA forum on the housing element, should be given serious consideration and embraced, lest we become consigned to monolithic housing blocks with minimal setbacks and amenities. Density simply doesn’t have to be done that way, as history both here and abroad should have taught us.
The second program of concern in the 5th draft is Program 3.m, Implement SB 9 and SB 10. Missing Middle Housing (MMH) is a key strategy in helping the City meet its housing goals but it should in no way be conflated with SB 10. MMH was being successfully implemented in California and other states long before SB 10 was even dreamed of. SB 10 is not a mandate to be blindly followed by cities under threat of penalty but is in fact legislation that requires that cities opt into it voluntarily. Our City Council wisely voted not to opt into SB 10 when presented with the opportunity to do so. MMH can 3 - 585
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-232 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE be implemented with greater flexibility without choosing to opt into SB 10. By placing the very valuable strategy of MMH under the aegis of SB 10, Program 3.m unnecessarily stokes fear in residents to the detriment of acceptance of the housing element as a whole.
The key policy question for the city as regards the implementation of MMH is whether to apply it only in selected areas of the city or allow it citywide as what planners refer to as a “floating” zone. Such a zone is not tied to a specific area, but rather would make MMH a possibility on any residential property that meets certain objective design and development standards. The latest draft of Program
3.m favors the former approach by establishing a nexus between the location of MMH housing types and proximity to high-quality transit corridors and/or transit stops. Such a nexus is logical, given the importance high-quality transit corridors and/or transit stops played in determining the City’s RHNA allocation. Suffice it to say that perhaps preliminary criteria, such as minimum lot size, can be established to screen out areas where MMH might be infeasible, being mindful of the fact that some neighborhoods have a preponderance of lots less than 5,000 square feet in size.
In conclusion, the shortcomings of Programs 2.n and 3.m not withstanding, the latest update of the 5th draft of the Housing Element is appreciated and raises hopes that the conversation around implementation changes from one about terms like density, multi family and upzoning and instead begins to focus on form, scale and housing types. The first version of the 5th draft was representative of a philosophical approach which has dogged the preparation of the housing element from the beginning. That is, whether to craft a creative comprehensive and inclusive grassroots approach to housing policy that reflects and respects the will of the people or to place trust in the community’s future with an all-knowing, all-powerful state government dictating and mandating from on high. With the element so close to completion now, it is sincerely hoped that the choice will be the former, rather than a community vision of the state, by the state and for the state. • How addressed: The new height limit in Program 2.n is not a minimum height, it a revised maximum height limit to allow for the densities identified in the Housing Element. If the height limit is replaced, the new height limit shall be no less than 84 feet. Nothing in this would prevent a land owner or developer from proposing and constructing a building that is less than 84 feet. The Housing Element establishes a program for the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoning-based measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review. • How addressed: The City is not opting into SB 10 but instead is using the framework of the law to create the Missing Middle Housing program. The program will have specific objective design standards to allow certain housing types that are consistent with existing residential character. The Housing Element is specific about which housing types the city is going to consider as part of its missing middle housing implementation, as well as the areas of the city where missing middle housing will be allowed.
Delaine W. Shane (March 8, 2023)
Dear Community Development Department Staff and Management:
Thank you so much to be willing to making last minute text edits on the proposed housing element. I will limit my response in this email to Program 1.b concerning the fate of the Caltrans housing. Some of your yellow highlighted text I get are meant to be a compromise, but they are so wishy washy that 3 - 586
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-233 “explore” means nothing. There is no real commitment. Here are my suggested revisions, based on the latest version online
If
financially feasible and demonstrated as such in writing by a qualified financial expert, the City will leverage the Caltrans surplus properties that have resulted from the State's cancellation of a proposed route to extend the 710 freeway through South Pasadena to generate capital for the rehabilitation and creation of deed restricted, affordable housing units throughout the city by an experienced, qualified development partner in the affordable housing construction industry. The Caltrans and the City have initiated a property sales program for the 710 freeway surplus properties. The City worked with Senator Portantino to pass SB 381 and the emergency rulemaking regulations were released on March 28, 2022. The City will have priority to purchase unoccupied Caltrans surplus properties, as well as occupied Caltrans surplus properties if the existing tenants do not purchase the properties. The City has been working with Caltrans to obtain property files and to inspect the properties in order to evaluate the surplus properties. It is anticipated that the City may purchase some of the Caltrans surplus properties once Caltrans provides purchase and sale agreements to the City. To ensure the financial feasibility of acquiring the unoccupied properties and in turn leveraging them to expand housing opportunities in South Pasadena, staff will prioritize and pursue alternative solutions, including the side-by-side escrows or double escrows, outside of SB381 that respond to the cost constraints of particular properties.
Acquire, if financially feasible, and as a last measure, convert unoccupied, Caltrans-owned properties, that are not sold at fair market value to deed-restricted affordable housing units to expand housing mobility opportunities for lower-income households and revitalize underused areas, so long as the neighborhoods of the remaining Caltrans properties are not overly represented. Expanding housing mobility opportunities shall be shared equally and distributed throughout the City.
The statement in the right column at the bottom states: “Units will be available to occupants by October 2024.” Seems to be overly optimistic. Recommend deleting it or saying X months after work has been completed that the units will be fit for occupation. You have no control over construction/rehab contractors, supply distribution systems, and actual materials. Delays are unfortunately part of our new normal post pandemic. Why box yourself in a corner with HCD by setting an unrealistic and really naïve date?
Thanks again for allowing input by the public in this manner. 3 - 587
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Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-234 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Sincerely,
Delaine W. Shane
2003 Meridian Avenue
• How addressed: The City Council has made no determination regarding the purchase of the surplus Caltrans property or the specific use of the properties. The City is still analyzing the financial feasibility of purchasing the properties and the various options for converting them to affordable housing. The City cannot commit to a specific course of action for the surplus Caltrans properties until that analysis is complete. Furthermore, selling all of the surplus Caltrans homes at market rates to generate capital for the creation of deed-restricted affordable housing elsewhere in the city is not an allowable action under SB 381. Staff will explore possible solutions.
Ed Elsner (March 9, 2023)
Dear Director Frausto-Lupo,
Avoiding displacement of existing residential tenants should be a higher priority in the City's housing element.
The 5th draft housing element proposes to include Huntington Drive as part of the Downtown Specific Plan, change the zoning of medium and high density residential parcels to mixed-use, and increase density to 70 du/ac -- a higher increase than the 30 du/ac and 45 du/ac proposed for medium and high density residential zones elsewhere in the City.
This proposed rezoning of Huntington Drive would promote displacement of existing tenants residing in multi-unit apartment buildings along Huntington Drive, and while the housing element's proposed tenant protections may help mitigate the displacement, as a practical matter the displacement will be permanent.
Displacement most acutely affects families with children (who may have to be pulled out of school mid-year), the elderly, and the disabled, and the impacts can be devastating.
In my experience representing residential tenants in eviction cases off and on for 30 years, the "right of return" is illusory in most cases.
This is primarily because two moves are required. While the landlord would be required to pay relocation assistance to the tenant on the way out, the right of return typically does not include a requirement for the owner to pay moving expenses for the return move. The right of return depends on the landlord giving the displaced tenant a written offer, and the tenant typically has a limited period of time (typically, 30 days) to accept the offer. The mailed notice may or may not be received, whether because of problems with mail delivery, a property owner who is a bad actor who does not follow the notification rules, a tenant who has moved and neglected to provide a forwarding address, etc.
If the notice is received, it may come years after the tenant was evicted. The tenant may have moved out of the area and established roots in another community, the tenant may not be able to afford the return move, the tenant may be in the middle of a fixed term lease that the tenant cannot break, etc.
A successful tenant must be vigilant in monitoring the construction process and may have to hire an attorney to enforce their rights. But most importantly, the tenant's personal situation must be flexible enough that the tenant can make a quick decision at some uncertain time in the future to make the return move, and the tenant must have the financial resources to do so. 3 - 588
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-235 A 2018 Los Angeles Times article illustrates the practical reality of the right of return in a City with a well-funded, fully staffed housing department.
The 5th draft housing element also appears to understate the number of existing units on Huntington Drive that would be affected by redevelopment.
To take a random example, parcel 5319037001 (1170 Huntington Drive) is identified in the draft housing element as high density residential parcel with 0 existing units. However, this is actually a 20- unit apartment building. There are many other examples of parcels identified in the draft as medium or high density residential parcels having 0 or 1 existing units when the parcels actually have multi-unit apartment buildings.
Rezoning of medium and high density residential parcels on Huntington Drive should be the same as for medium and high density residential parcels elsewhere in the City.
The "missing middle housing" program in the pre-March 7th draft had good potential to increase housing production while minimizing displacement of existing residential tenants. This is because eligible properties would be single-family parcels occupied in most cases by the property owner, who would be making a voluntary decision to participate or to sell the property to a developer and relocate.
However, the March 7th update may have effectively gutted the program. Before the March 7th update, the missing middle housing program would have applied citywide in all residential zones except high fire hazard areas, and there was a commitment to implement the provisions of SB 10. In the latest update, only parcels in "low-density residential zones along high quality transit corridors and/or transit stops" (and not in a high fire hazard area) would be eligible, and the scope of the program is yet to be determined "by the community, Planning Commission, and City Council." It is unclear which low-density residential zones would be considered to be "along" the City's high quality transit corridors, identified in SCAG's Data/Map Book as Fair Oaks Avenue and Huntington Drive east of Fair Oaks, as there is no low-density residential zoning actually on either street, and the March 7th update does not identify parcels or zones that would potentially be eligible (subject to a future scope determination).
The housing element should include a more robust missing middle housing program.
Thank you for your consideration,
Ed Elsner
[email protected]
• How addressed: Goal 6 and the policies within that goal will be developed after further research to mitigate the potential for and impacts of displacement. The number of existing units was pulled from building permit data. The data was spot checked, but may be incomplete for some parcels.
Ed Elsner (March 9, 2023)
Dear Director Frausto-Lupo,
I’m writing to describe a possible alternative to program 2.n. in the 5th draft housing element (as updated on March 7, 2023), the Citywide Height Limit Ballot Initiative. The alternative would be a general plan amendment modifying the forty-five foot height limit established by local initiative in 1983.
3 - 589
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-236 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE This general plan amendment could be implemented on the same 120-day timeline as the housing element’s other rezoning programs (which include other amendments to the land use element of the general plan), and with more certainty than the proposed 2024 ballot measure.
Recognizing that this alternative program may not be viable politically, I’m hoping this comment at least provides additional perspective that may be useful as the City works towards achieving its housing element goals.
The General Plan and the Land Use Hierarchy
The state Planning and Zoning Law establishes the authority of local governments to regulate the use of land. Gov’t Code § 65000 et seq.; Neighborhood Action Group v. County of Calaveras (1984) 156 Cal.App.3d 1176, 1182. Each city must adopt a general plan for the physical development of the city.
Gov’t Code § 65300. The general plan takes precedence over other local zoning laws:
The general plan is atop the hierarchy of local government law regulating land use. It has been aptly analogized to “a constitution for all future developments.” [Citation omitted.]...Subordinate to the general plan are zoning laws, which regulate the geographic allocation and allowed uses of land. Zoning laws must conform to the adopted general plan. [Citations omitted.] These enactments provide the authority and the criteria for the regulation of land uses.
Neighborhood Action Group, 156 Cal.App.3d at 1183; Gov’t Code § 65850 (authorizing cities to adopt zoning ordinances).
Local Initiatives and General Plans
Although a city’s general plan may be amended by local initiative (DeVita v. County of Napa (1995) 9 Cal.4th 763), the electorate must have adequate notice of the purpose of the initiative:
We cannot at once accept the function of a general plan as a “constitution,” or perhaps more accurately a charter for future development, and the proposition that it can be amended without notice to the electorate that such amendment is the purpose of an initiative. Implied amendments or repeals are disfavored in any case [citation omitted], and the doctrine may not be applied here.
Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540-541. “Since we cannot presume the existence of such intent [to amend the general plan], it must be found, if it exists, in the ballot measure itself or the explanatory material in the ballot pamphlet.” Id. at 542. Stated another way, in order to amend the general plan, the text of the local initiative or the explanatory ballot materials must provide notice that the measure is something “other than an ordinance in the nature of a zoning ordinance.” Id. at 544.
The 1983 Height Limit Initiative
In a 1983 special election, South Pasadena residents voted to approve a local initiative establishing a citywide height limit of forty-five feet (Reso. 5642):
The initiative did not identify a provision of the general plan that it would amend, nor did it state that it was adding to the general plan; therefore, absent some other basis in the ballot materials to conclude that its purpose was to amend the general plan, the 1983 initiative has the status of a zoning law subordinate to the general plan in the land use hierarchy. Lesher Communications, 52 Cal.3d at 541. 3 - 590
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-237 Amending the General Plan to Modify the Height Limit
Section 9217 of the Election Code generally provides that local initiatives may not be amended or repealed except by a vote of the people, and program 2.n. assumes that the City's forty-five foot height limit cannot be modified without voter approval.
However, if the 1983 initiative is subordinate to the general plan, section 9217 would not restrict the City Council’s authority to amend the general plan to modify the height limit, and once amended, the general plan would prevail over the inconsistent subordinate law:
The Planning and Zoning Law itself precludes consideration of a zoning ordinance which conflicts with a general plan as a pro tanto repeal or implied amendment of the general plan.
The general plan stands....The Planning and Zoning Law does not contemplate that general plans will be amended to conform to zoning ordinances. The tail does not wag the dog. The general plan is the charter to which the ordinance must conform.
Lesher Communications, 52 Cal.3d at 541.
For similar reasons, the 1983 initiative cannot be interpreted as superordinate to the general plan. The local electorate’s right to initiative is co-extensive with the legislative power of the local governing body (DeVita, 9 Cal.4th at 775), so if the City Council cannot enact a land use law above the general plan in the land use hierarchy -- which it has no authority to do under the Planning and Zoning Law -- neither can the electorate via local initiative. Legislature v. Deukmejian (1983) 34 Cal.3d 658, 674-675 (initiative power is subject to the same limitations as legislative action).
The Housing Accountability Act provides additional support for the suggested general plan amendment. If a proposed housing development project is consistent with objective general plan standards and criteria, but the zoning for the project site is inconsistent with the general plan (for example, because a zoning ordinance includes a lower height limit), the project will be deemed “not inconsistent” with applicable zoning standards and criteria for purposes of approval of the project's land use application. Gov’t Code § 65589.5(j)(4).
The 1983 initiative could have included clear language that it was amending the general plan, but as written, it left the door open for the City Council to modify the height limit through a superseding general plan amendment.
Noncompliance with the Housing Element Law
The City has been out of compliance with the housing element law since October 2021, and because it missed the October 2022 deadline to adopt a housing element and to obtain certification from HCD, the City will remain out of compliance until the City adopts a compliant housing element and completes the related rezoning programs.
Given recent media attention, there is more widespread awareness of the consequences of noncompliance with the housing element law, including the loss of authority to disapprove land use applications for housing projects that are inconsistent with the City’s zoning laws, also known as the “builder’s remedy.” Gov’t Code § 65589.5(d)(5). As a result, the electorate has a better understanding why South Pasadena needs to obtain housing element compliance sooner than later, and anyone following the progress of the City’s housing element should understand how a modified height limit in designated higher-density zones is critical to achieving that goal while avoiding a radical upzoning of the the entire city.
Thank you for your consideration,
Ed Elsner
3 - 591
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-238 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE [email protected]
• How addressed: The Housing Element proposes a program to amend the zoning code height limit which was adopted by the voters. Any ordinance enacted by the voters may only be amended by the voters. The Housing Element establishes a program to put this question to the voters to decide whether to establish a new height limit to achieve the densities required to meeting the RHNA housing goals. If the voters do not increase the height limit in certain areas, other zoningbased measures (such as conversion of current low density areas into higher density areas) will need to be analyzed and submitted to HCD for review. Per a Court Judgement, the City must place a measure on the ballot to repeal or amend the current height limit.
Julie Pearson (March 9, 2023)
To our city staff,
As a resident of the city for 25 years, married to a resident of over 50 years, who is the child of a resident of nearly 60 years, we oppose the city’s intention to remove all single-family zoning requirements, city wide. We also oppose the city’s intention to allow structures in the city to rise more than 6 stories.
These proposed changes in our opinion would change the feel of our town as well as the neighborhoods, and be detrimental to the family friendly environment that is central to our city.
Thank you for considering my comments.
Sincerely,
Julie Pearson, Keith Pearson and Margie Pearson
1749 Via del Rey
• How addressed: The City is required by the State of California to address issues related to Affirmatively Furthering Fair Housing, and in addition to accommodate the number of affordable homes and total number of homes allocated through the Regional Housing Needs Allocation (RHNA) process. The City must then demonstrate plans which can accommodate these three housing goals.The policies in the Housing Element fulfill those requirements. The Housing Element was revised to reduce the area where missing middle housing will be allowed from citywide to the highquality transit areas within the city. This revision was released for public review on March 7, 2023.
Bill Kelly (March 9, 2023)
Public Comment on Second Draft of Draft 5 (March 7, 2023) of South Pasadena’s Housing Element
(Submitted March 9, 2023)
Greetings:
Thank you for the opportunity to comment on the second draft (March 7, 2023) of the fifth draft (March 2, 2023) of South Pasadena’s proposed Housing Element in my hopes that it will result in a third draft of the fifth draft.
The comments below first cover general concerns with the latest draft. The second part covers various concerns reflected in previously published and verbalized community comments regarding state housing requirements, as well as an email sent by a resident to unspecified individuals aimed at 3 - 592
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Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-239 prompting comments and complaints to City management and Councilmembers, which you have no doubt received.
Specifically, I urge you to:
• End R-1 zoning throughout the city (except in areas with wildfire and geologic hazards); and • Get started with affordable housing by committing in the City’s housing element to seeing that denser affordable housing is built on as many of the unoccupied Caltrans properties as possible. (The well documented need for affordable housing amid the widely discussed housing crisis need not be amplified here. It is a well-established feature of the landscape.) In submitting the next draft of the Housing Element to the state, foremost please remember that zoning does not build housing, only investment does, and the vacant Caltrans properties at this point represent the only palpable prospect the City can increase its stock of desperately needed affordable housing in the next few years. Moreover, change will not come overnight with rezoning. Change will come only over a decade or more. Indeed, many of us who are debating housing will be dead and gone before any appreciable change.
General Concerns
First of all, South Pasadena is not alone among cities that to date have failed to see their housing elements approved. It is clear that cities are dealing with relatively recently passed laws and emotional divisiveness among their residents as change rarely is easily accepted. Nowhere, perhaps, is that more true than in South Pasadena, one of the few communities across the nation that stopped the extension of a freeway. That said, much of the traffic the freeway would have conveyed now travels on city streets, including Fair Oaks and Fremont that are regularly gridlocked. Meanwhile, polluting diesel trucks hauling containers from the region’s ports don’t pass through South Pasadena to reach logistical centers on the periphery of the region, but instead travel along the 60 and I-10 freeways through less affluent communities, many of which are predominantly of color. At the same time, the City has been essentially unable to agree and carry out any significant effort to use available funds for traffic calming, active transportation facilities, and surface street projects, as other cities move forward.
When it comes to housing, some City residents have fought any efforts or plans to allow for increased density, instead seeking to shoehorn density into narrowly prescribed strips along commercial streets and major arterials. In addition, the city’s planning and permitting process is lengthy and tedious. As a result, there has been relatively little change in the landscape in the more than thirty years I’ve lived here. Indeed, residents—including freeway fighters, historical preservationists, and many prosperous owners of large single family homes on large parcels, aided by others prone to fear of change—have managed to keep South Pasadena more or less the way it has been since the post-World War II era, a quaint bedroom community that celebrates the days of Route 66, classic cars, good schools, and beautiful gardens, a community that many residents view as charitable and charming. And no doubt all these things contribute to South Pasadena’s much locally celebrated and revered “neighborhood character.”
Personally, I must admit that I was drawn to the community upon returning to Southern California in 1988 due to its neighborhood character. However, a lot has happened since then and as I’ve witnessed the changes—hollowing out of the middle class, offshoring of manufacturing, stagnation of wages, growing inequity, increasing social and racial tension, rampant drug addiction and social 3 - 593
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-240 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE dysfunction, growing homelessness, overcrowding, housing insecurity, a wave of mental illness, and the astronomical cost of housing, and rapidly accelerating climate instability—my view of what it means to live here in South Pasadena, in the region, and in the world has changed dramatically.
Today, it’s become increasingly apparent that the magnitude of change needed to address this complex of interrelated problems has become so great that over the next ten to 20 years just about everything around us must change, including here in South Pasadena. However, this view is assuredly not shared by apparently influential residents who say they support “thoughtful and conscious growth and expanded thinking” as long as it’s not next door. They complain about any proposal to add much needed housing, grasping at any potential plausible objection, such as lack of water, lack of power, traffic, burdens on schools and services, lack of open space, and mostly the perception that growth will diminish their property values. They dispose of anything that’s seemingly proposed, yet never articulate on their own what a housing element, or general plan should include. And history has shown their tendency is to get the city to legally contest many state requirements aimed at solving these problems, and then slow roll any local actions developed to meet the requirements once legal actions play out. This pattern clearly is based on the view that South Pasadena is exceptional and should be left to manage its own affairs without regional and state oversight. Yet, this is despite that the source of the wealth here stems from proximity to the second largest metro area in the nation situated on the rim of trans-Pacific trade and in the heart of a state with one of the world’s biggest economies. Indeed, the message seems to be: I’ll enjoy the personal wealth the region offers, but don’t ask me to contribute much toward solving the region’s problems. Moreover, don’t call us irresponsible, because we supported local tax measures and contribute to local charities that are “truly . . . sustaining our way of life here in SoPas.” In this case sustaining is a substitute for “not changing.”
However, as city officials and Councilmembers it is incumbent on you to lead, rather than to cater to such provincialism. Just imagine that the story is much the same in small cities across the region and the state when it comes to the state’s housing requirements. Note too that such attitudes have prevailed for decades, while problems have mounted and festered. Indeed, it’s the lack of any local effort to address the housing crisis that led lawmakers in Sacramento to enact new state requirements.
So now, it’s reckoning time. Unless we look in the mirror as a community and make the change, the problems that everyone seems to acknowledge and agree must be solved, won’t be solved by doing the same as we have done in the past.
Addressing Specific Contentions Voiced in the Community City-wide R-4 zoning will diminish property values
Don’t tread on me and my property value by continuing to maintain R-1 zoning. Numerous studies cited below show that increasing density, particularly everywhere, will result in rising property values and likely check rising rents and housing costs. In addition, the city’s inclusionary housing ordinance will require more affordable units.
https://masslandlords.net/gentle-density-increases-nearby-property-values-evidence-shows-contrary-to-popular-belief/ https://www.strongtowns.org/journal/2022/1/18/what-would-mass-upzoning-actually-do-to-property-values https://voiceofoc.org/2021/08/jamieson-increasing-densities-in-single-family-neighborhoods-would-increase-landvalues-make-housing-more-expensive/ 3 - 594
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-241 https://voiceofoc.org/2021/08/jamieson-increasing-densities-in-single-family-neighborhoods-would-increase-landvalues-make-housing-more-expensive/ Also, increasing allowable density city-wide will open better housing opportunities to all and destigmatize affordable housing residents. It will address the baked in ongoing classism in the City and its racist legacy during the Sundown Town era.
We don’t have the water or power to add additional housing units Housing not lawns is the rejoinder. Indeed, half or more of the water is used outside to water lawns. If the lawns had housing on them, water use would not increase. Indeed, more than half the people dwelling in multi-unit housing in South Pasadena use only half the water used by the less than half that live in single family homes. That’s because half the water use at the average-sized single family residence is used to water lawns.
From: https://www.southpasadenaca.gov/home/showpublisheddocument/27639/637738897658270000 In fact, one study shows that on R-1 lots in the area, as much as 70 percent of water use is for lawn irrigation.
https://deeply.thenewhumanitarian.org/water/community/2017/08/09/city-wide-study-shows-how-much-water-urbanlandscaping-really-uses Lack of Power
3 - 595
Table 4-1 Demands for Potable and Non-Potable Water -Actual Submittal Table 4-1 Retail: Demands for Potable and Non-Potable1 Water -Actual Use Type 2020 Actual
Drop down r1s1:
May selec:teach use mu Level of Treatment lllple tlmes Additional Description These a re the only l.lse Types that wll I be When Delivered Volume2 recognized by theWUEdata cmll ne (as needed) Drop down list subrnl tlll I tool
Add addltl anal rows as needed
Si ngle Family Drinking Waiter 1,962
Mul'rr-Family D~inking Water 992
Co mmercial Drinking Waiter 450
I nstitutio na 1/Governm enta I D~inking Waiter 85
Landscape Drinking Waiter 4
Losses D~inking Water 46
Other Fire Protection Drinking Waiter 7
TOTAL 3,546
Appendix B
MAY 2023 CITY OF SOUTH PASADENA
Page B1-242 2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE California utilities are in the midst of major distribution circuit upgrades to increase capacity to deliver power. The California Public Utilities Commission and California Independent System Operator require utilities to show they have enough power for each coming year by performing a “resource adequacy study.” To pass the test, the utilities must show they have adequate power purchase contracts for a one-in-ten-year weather event. Utilities also are subject to long-term transmission planning requirements, as well as power procurement requirements.
Overwhelming Transportation Infrastructure
Look Ma, no traffic. A Montreal residential neighborhood at rush hour in fall of 2022.
Contrary and seemingly counterintuitively, density does not necessarily result in increased traffic.
Instead, low density single-family development increases traffic. Montreal is a case in point. The four million who live within the city limits there get around by walking, biking, and riding the clean, well maintained, and extensive subway system. Retail, including supermarkets, drug stores, etc. are scattered throughout the city. This has enabled Montreal to minimize the space it allocates for the auto compared to the typical U.S. city, particularly in suburban areas. That has opened up public spaces, which are distributed throughout the city.
Indeed, a new study conducted at U.C. Davis recently showed that increased density will help meet greenhouse gas and other air pollution reduction goals by minimizing the need to drive, even in electric cars. This will help reduce dependence on foreign metal mining for batteries, magnets, etc. used in electric vehicles.
https://www.theguardian.com/us-news/2023/jan/24/us-electric-vehicles-lithium-consequences-research https://www.climateandcommunity.org/_files/ugd/d6378b_3b79520a747948618034a2b19b9481a0.pdf Impact on Schools & Open Space
Schools have the ability to expand by building up. Schools also can cooperate with the City to close streets to expand playgrounds and athletic fields. In fact, SPUSD did this when South Pasadena Middle School was rebuilt more than 15 years ago. Moreover, even South Pasadena freeway fighters who support maintaining R-1 zoning have touted closing the 1-710 stubs in Los Angeles and Pasadena, respectively, to expand the Cal State Los Angeles campus and to create new park space in Pasadena. Why not expand elementary school campuses by closing or narrowing adjacent streets where possible.
3 - 596
Appendix B
CITY OF SOUTH PASADENA MAY 2023
2021-2029 DRAFT GENERAL PLAN HOUSING ELEMENT UPDATE Page B1-243 In addition, areas in Garfield Park under the SCE lines and also areas around the periphery of the fields in the Arroyo could be used to site local basketball courts, etc., or additional community gardens. They are not well maintained and are under-utilized. At one point the updated general plan, which still is pending years later, contemplated placing a walking trail under the SCE lines paralleling Fair Oaks in the Marengo District. It hasn’t been done or pursued as the general plan remains in limbo after years of discussion.
Conclusion
To conclude, we are only limited due to our limited way of viewing the world, despite that those voicing opposition to density claim they back expansive thinking. By increasing allowable density citywide and by beginning with seeing that quads, triplexes, etc. are built on the vacant Caltrans lots where feasible, South Pasadena can begin to address the complex of interrelated problems that we all want to solve. However, if South Pasadena and hundreds of other cities continue to do what they have in the past, the problems will continue to grow and make life—with its traffic, pollution and climate change, homelessness, and social inequity—worse and worse. We can either be part of the solution or part of the problem. That’s why we must look ourselves in the mirror and decide to truly bring about the change that is so clearly is needed and so long forestalled.
Bill Kelly
South Pasadena Resident
• How addressed: The City Council has made no determination regarding the purchase of the surplus Caltrans property or the specific use of the properties. The City is still analyzing the financial feasibility of purchasing the properties and the various options for converting them to affordable housing. The City cannot commit to a specific course of action for the surplus Caltrans properties until that analysis is complete. Staff will explore possible solutions. The remainder of the comment does not include any proposed changes to the Housing Element, but supports many of the policies already contained in the Element.
Jeremy D (March 6, 2023)
I would request the city change the following section of the housing element to limit the area that would allow up to a four-plex to parcels on major traffic corridors only, like Huntington, Fremont and Fair Oaks or near the Metro station. Also, since the city currently has a height limit, I would recommend removing the mention of buildings that are above the current limit until the time when the voters have had a chance to weigh in on this.