LA JOLLA CPA - JUNE 4, 2020
COMPLETE COMMUNITIES - HOUSING AND MOBILITY PROJECT
THE COMPILED INFORMATION WITHIN IS AVAILABLE TO THE PUBLIC AND MAY BE DISTRIBUTED.
INFORMATION COMPILED BY: MATT MANGANO - LCJPA TRUSTEE, CPC REPRESENTATIVE - [email protected]
CONTENTS (PAGE):
(2) COMMUNITY PLANNERS COMMITTEE AGENDA 5/26/20 - BRIEF DESCRIPTION AND LINKS TO THE CITY WEBSITE FOR INFORMATION ON THE PROPOSALS https://www.sandiego.gov/complete-communities-mobility-choices https://www.sandiego.gov/complete-communities-housing-solutions
(3) CC MOBILITY CHOICES & HOUSING SOLUTIONS PRESENTATION
(17) RANCHO BERNARDO CPB COMMENTS ON THE DRAFT PROGRAM EIR FOR CC
(20) KENSINGTON-TALMADGE CPG REVIEW AND RESPONSE TO PROPOSED CC HOUSING SOLUTIONS
(27) SAVE OUR ACCESS - REVIEW OF CC HOUSING SOLUTIONS BY TOM MULLANEY
(33) LETTER TO COMMISSIONERS RE: CC PROGRAM BY SDSU PROFESSOR EMERITUS, NICO CALAVITA
Page 1 of 43 Community Planners Committee Agenda: May 26, 2020
ITEM #7 – 6:35 COMPLETE COMMUNITIES: PLAY EVERYWHERE - PARKS MASTER PLAN AND GENERAL PLAN RECREATION ELEMENT AMENDMENT (Action Item) – 30 mins.
Presenters: Heidi Vonblum / Jonathan Avila – Planning Department
Description: The Parks Master Plan is a plan for an interconnected Citywide parks system with opportunities for everyone to get outside and play while fostering social interactions, cultural, activities, and exercise, as well as providing urban respite, enjoyable transportation options, and an increased tree canopy cover. A key component of the Parks Master Plan is equity and access- based goals that prioritize areas with park standard and park service gaps. The proposed amendment to the General Plan Recreation Element includes amendments to reflect the new policies in the Parks Master Plan.
Resource: https://www.sandiego.gov/planning/programs/completecommunities/play- everywhere
ITEM #8 – 7:05 COMPLETE COMMUNITIES: HOUSING SOLUTIONS AND MOBILITY CHOICES (Action Item) – 45 mins
Presenters: Heidi Vonblum / Brian Schoenfisch – Planning Department
Description: Complete Communities: Mobility Choices and Housing Solutions proposes amendments to the San Diego Municipal Code (SDMC) to provide incentives to increase housing production and expand the mobility network around transit hubs and existing development. The initiative removes regulatory barriers to housing at all income levels, especially low, very low, and moderate- income households, while investing in neighborhood and mobility amenities, such as recreational opportunities, street trees, linear parks, bicycle facilities, urban plazas, and promenades. These types of investments increase the quality of neighborhoods where new housing is proposed by creating more walkable, bikeable, and enjoyable spaces, which in turn helps the City meet its Climate Action Plan goals. Prioritizing these investments in areas where the investments are needed most are central to the intent behind the Complete Communities initiative.
Resources: https://www.sandiego.gov/planning/programs/completecommunities/housingsol utions https://www.sandiego.gov/planning/programs/mobility/mobilitychoices
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Complete Communities: Mobility Choices & Housing Solutions
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The City of San Diego is delivering on its vision of creating equitable, healthy, and sustainable neighborhoods that are diverse, walkable, connected, safe, and inclusive.
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Tailoring State Law to the City's Needs SB 375 • Locate land uses that result in reductions in greenhouse gas emissions SB 743 • Focus transportation analysis on increasing biking, walking, and transit options to reduce vehicle miles traveled CASA / AB 1763 • Provide incentives for adding affordable and market-rate housing to neighborhoods with access to transit and other amenities
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Achieving the City's Climate Goals
• Locating land uses in transit priority areas achieves the City's climate goals • Investing in biking, walking, and transit where they will be used the most leads to greater overall benefits for the entire City
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Investing Equitably in San Diego's Neighborhoods
• Provide variety of housing options, including smaller infill development • Promote cleaner air, safer streets, more vibrant neighborhoods, economic opportunities for all • Prioritize investments in Communities of Concern, which have received disproportionately less investment over the past several decades
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Mobility Choices
Mobility Choices aims to connect every San Diegan with safe and convenient mobility options that can reliably connect them to jobs, shopping, services, parks, open spaces and other amenities.
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Mobility Choices Goals:
• Provide San Diegans with more mobility options for moving around • Mobility options that are safe and convenient • Promote healthier, more active lifestyles • Reduce greenhouse gas emissions and support clean air for all
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SB 743: Moving from Level of Service (LOS) to Vehicle Miles Traveled (VMT)
LOS: can encourage VMT: encourages additional vehicle investments to travel; limited reduce the amount opportunities to and length of vehicle reduce the need for trips; focuses on vehicle trips investments in biking, walking, and transit VMT = number or trips x length of trips
trips AND/OR distance = VMT
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Climate Action Plan Implementation
• Greatest opportunity to reduce GHG emissions related to transportation sector
• CAP sets ambitious goals for more people walking, biking, or using transit
• Mobility Choices implements the CAP by supporting infill development and investments in walking, biking, and public transit
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Mobility Choices includes:
1. Land Development Manual Amendments 2. New Mobility Choices Regulations 3. Active Transportation In Lieu Fee 4. VMT Fee Calculator
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Mobility Zone 4 Option to mitigate VMT with fee based on improvements that reduce VMT in Mobility Zones 2 and 3
Mobility Zone 3 VMT Reduction Measures 8 points
Mobility Zone 2 (TPA) 5 points Multi-family residential development complies with TPA Parking Amenities requirements
Mobility Zone 1 No measures
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VMT Reduction Measures Mobility Zones 2 and 3
• Pedestrian Scale light along public walkways • High visibility crosswalks striping • Pedestrian refuges and raised crosswalks • Shade trees • Pedestrian resting or recreation areas • Sidewalk widening • Transit stop updates • Car-share or carpool vehicle parking • Electric bicycle charging stations
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Mobility Choices Active Transportation In Lieu Fee
Mobility Zone 4 Optional Mobility Zones 2 and 3 in lieu of VMT Reduction Measures
• Investing in VMT reducing infrastructure in Mobility Zone 4 can be limiting
• Greater return on investment for VMT reducing facilities in Mobility Zones 1, 2, and 3
• Provide certainty and save time in project approval process
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Mobility Choices & Equity
• Supports investments in biking, walking, and transit in Communities of Concern
• Provides safe and convenient transportation options for commuting and enjoyment
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Page 16 of 43 Rancho Bernardo Community Planning Board 12463 Rancho Bernardo Road #523, San Diego, CA 92128 www.rbplanningboard.com
March 10, 2020
Oscar Galvez, Environmental Planner City of San Diego, Planning Department 9485 Aero Drive, MS 413 San Diego, CA 92123 [email protected] (Complete Communities Draft PEIR)
SUBJECT: Comments on the Draft Program Environmental Impact Report for Complete Communities: Housing Solutions and Mobility Choices San Diego, California
Dear Mr. Galvez:
On February 20, 2020, the Rancho Bernardo Community Planning Board (Planning Board) reviewed the Draft Program Environmental Impact Report (PEIR) for Complete Communities and identified the following concerns related to the adequacy and accuracy of the information provide in the Draft PEIR. The Planning Board approved a motion by a vote of 9-0-0 to forward the following comments and concerns related to the Draft PEIR. We respectfully request that the City inform the Planning Board when the responses to comments are completed.
Project Description
1. The project description in the draft PEIR does not provide adequate information regarding the various proposals, making it difficult to understand the extent of the impacts to the environment that would occur as a result of implementing the “complete communities” program. The term affordable housing units is not defined, and the description of neighborhood-serving infrastructure improvements is lacking the details necessary to understand how the Mobility Choices Program will result in reductions in citywide per capita vehicle miles traveled (VMT), particularly in suburban communities with minimal transit options.
2. What specifically is intended to occur in Mobility Choice Program Improvement Areas and why do they extend outside the TPA areas?
3. We concur that developing housing near transit will reduce VMT for those who live in a TPA if they can get to work, shop, and recreate using transit, but this is not currently possible in many of the TPAs throughout the City due to limited service routes and schedules. The draft PEIR does not acknowledge such difference throughout the City.
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4. Page 3-6 states: “The proposed project areas are generally developed, urbanized areas with access to high-quality transit. The approximately 20,538 acres of the Housing Program project areas are located within Transit Priority Areas (TPAs) throughout the City.” This statement implies that all TPA provide similar transit opportunities, however, this is not the case. As a result, increasing density in areas where adequate transit is not available to serve the needs of new development will only increase VMT with no mitigation provided to address traffic congestion and the associated impacts to air quality.
5. Table 3-2 requires additional explanation. Where are the 78 areas within Rancho Bernardo that are considered Housing Program Eligible Areas and the 394 areas identified for Mobility Choices Program Improvements?
6. The footnote for Table 3-2 states: “Actual improvements would be limited to existing road rights-of-way and within the development footprint of future development projects.” How will VMT be substantively reduced by only making these limited improvements? Although page 3-19 provides addition information and a list of improvements that would encourage people to walk and ride bikes in denser areas where work, play, and commercial needs are all located in proximity to housing, this is not the case in all areas of the city. The project description should acknowledge these differences throughout the City.
7. Figure 3-2 Area D identifies as a “housing program eligible area” a large area in Bernardo Heights that is already fully developed with multiple family units. The project description does not include any discussion of eliminating existing development to achieve the goals of the Mobility Choices Program. Based on the information provided in the project description, we do not understand why this area is included for consideration. Please expand the discussion in the Final PEIR to address the potential displacement of existing residents.
Transportation Analysis
1. An explanation is required to support the conclusion that the proposal will not conflict with adopted transportation plans. Funds are being moved around to address specific areas of the City, leaving other areas with little or no funding for transportation improvements.
2. The PEIR does not adequately address the increases in traffic volumes on the regional transportation system that will occur as a result of increased densities in areas that may be identified as TPAs, but do not have adequate access to transit to meet the transportation needs of existing and future residents. Additionally, there is no analysis of the impacts to the transportation system of providing additional housing without also ensuring adequate nearby job opportunities, recreational facilities, and food and other shopping needs that are required to minimize total VMT.
3. The feeder bus system in Rancho Bernardo and other “suburban” areas is essentially non- existent, so additional units in these areas are likely to increase, rather than reduce, total VMT. The PEIR does not provide adequate analysis of the short- and long-term effects to existing transportation facilities of the Mobility Choices Program in communities where
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accessibility to regional transit options is limited. 4. The PEIR analysis of the effects to total VMT throughout the City associated with reducing and in some cases eliminating DIF requirements in exchange for improvements related to pedestrian access and bicycle facilities is inadequate and should be expanded, as these improvements will do little to address the much larger transportation needs of the region.
Land Use
1. An explanation is required to support the conclusion that the proposal will not conflict with existing community plans. Moving DIF funds away from some communities in order to support increased densities in others, as well as reducing/eliminating park standards is likely to result in conflicts with the proposals/recommendations presented in many community plans. The PEIR should acknowledge these conflicts.
Conclusion
The deficiencies in the City’s current transportation system must be acknowledged in the PEIR and reasonable solutions for reducing VMTs must be identified, otherwise, the goals of the Climate Action Plan will not be achieved. Limiting mobility improvements to existing road rights-of-way, wider sidewalks, and bicycle repair spots will not sufficiently reduce VMT. Complete communities require that employment, commercial, and adequate recreational opportunities are located in proximity to residential development. Increasing density without considering all of the needs of the future residents will necessarily result in increased VMT. Not everyone can walk or ride a bike to address their daily needs, so to increase housing densities and also reduce VMT, the Mobility Choices Program must address funding for measures, such as providing feeder buses to serve major transportation hubs, that will effectively accommodate the transportation needs of all residents within the City.
The Planning Board appreciates this opportunity to provide comments on the Draft PEIR.
Sincerely,
Robin Kaufman
Robin Kaufman, Chair Rancho Bernardo Community Planning Board cc: Councilmember Mark Kersey, District 5
Page 19 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions
ZONING & FAR
These comments are respectfully submitted for the Planning Commission’s consideration in response to issues of concern raised by the proposed Complete Communities Housing Solutions Regulations. The proposal is opposed by the Kensington-Talmadge Planning Group as it violates long-standing tenets of good planning, and disrupts the driving purpose of our 1998 community plan to focus high intensity development directly onto transit corridors such as El Cajon Boulevard.
It ignores local site conditions and the ability of local infrastructure to support high density.
It reintroduces “Spot Zoning” and will juxtapose incompatible uses.
It is the effective end of Transitional Zoning.
Its 8.0 FAR for our area is the functional equivalent of the RM-4-11 zone.
Therefore, in RM-1-1 and RM-1-2 zones it creates inappropriate islands of very high density inside medium-low density communities. Our illustrations below are examples of actual sites within our community where this measure would apply. Resolving a badly placed Huffman apartment is not done by amplifying the mistake 6 fold. See below: Winona & Monroe illustrations.
In RM-1-3 zones and higher, when coupled with By-Right lot consolidation, it opens the entire zone, not just individual sites to the highest densities without consideration of local site conditions such as narrow streets, sidewalks, or the adequacy of local infrastructure. Even if funds are collected to address these conditions they will not be accompanied by an actual plan to implement remediation. What role is left for good planning? See below: Meade Illustration.
Please also note, the glaring mismatch between Mid-City’s 8.0 FAR, and the 4.0 FAR for most of our major centers of job growth over the past 75 years: Sorrento Valley & Mesa, Rancho Bernardo, Kearney Mesa, and Mission Valley.
ZONING REMEDY
The Kensington Talmadge Planning Group recommends removing the RM-1-1, RM-1-2, and RM- 1-3 zones from this proposal to remediate some of these harsh impacts.
Page 20 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions
WINONA AVENUE 4500 Block (looking north) Area shown is zoned RM-1-1. The area behind the tall structure (not seen) is zoned RS-1-7.
Page 21 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions
MONROE AVENUE 4600 BLOCK (looking west) The houses are zoned RS-1-7. The area behind the tall structures is zoned RM-1-3.
Page 22 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions
MEADE AVENUE 4600 BLOCK (looking east) Area shown is zoned RM-1-3 With lot consolidation by right, all RM-1-3 lots effectively have FAR of 8.0
Page 23 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions
INFRASTRUCTURE AMENITIES
The following public comments are respectfully submitted for the Planning Commission’s consideration in response to Issues of Concern raised by the Proposed Complete Communities Housing Solutions Regulations. Infrastructure Amenities as proposed within these regulations are meant “to create a sense of place, facilitate pedestrian circulation, improve connections to transit, and promote the livability and vitality of such development and the community. Investing in neighborhood infrastructure that creates destinations and encourages walking, biking, and use of transit, particularly within Transit Priority Areas, is also critical to be City’s Climate Action Plan goal to reduce greenhouse gas emissions.”
Developers who take advantage of these new Supplemental Development Regulations must do one of two things regarding the provision of infrastructure amenities: 1) Pay a Fee, or 2) Provide the on-site amenities
In the first option as proposed, all fees would go into a Neighborhood Enhancement Fund to be used for design, construction, and/or maintenance of neighborhood enhancing infrastructure projects. The fees would be divided with 50% invested within the same community planning area as the development, and 50% invested in infrastructure improvements within “communities of concern”, as determined by the City Manager.
It is unknown what defines “communities of concern”, or why the funds would be divided if the subject community where the development exists is deficient in infrastructure. Also, the idea that the fees could be spent entirely on maintenance (as written) which provides no new infrastructure to accommodate the new residents, is unacceptable.
The second option proposes to allow the development of on-site public amenities in the form of a public promenade of at least 20 feet wide, and adjacent to a public right-of-way, when the subject housing development property is a minimum 25,000 square feet in area, with at least 200 linear feet of street frontage. This option should be the preferred option for any community that is already deficient in infrastructure amenities, provided that they are restricted to Major Commercial Streets, and not on side streets.
The draft regulations contain 3 pages of requirements that a public promenade would have to adhere to. The major areas of concern revolve around adequacy and usability of the public promenade as neighborhood-serving infrastructure.
Essentially, the public promenade would function as a mini park, and should be considered supplemental to needed park space and not a substitute for a neighborhood park. Proposed public parks of any size are currently required to solicit community input for design and development pursuant to Council Policy 600-33, PUBLIC NOTIFICATION AND INPUT FOR CITY- WIDE PARK DEVELOPMENT PROJECTS. However, the proposed regulations exempt these public promenades from this important community input policy. In the absence of a Community Plan Update which would identify the specific park and recreation needs and proposed solutions for
Page 24 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions a deficient community, the public input process is essential to ensure that quality recreational amenities are provided.
In terms of usability, there are a few questionable permitted uses and amenities within the proposed regulations, but those with the most negative impact include: 1) The allowance of stormwater facilities (BMPs) within the landscaped areas; and 2) The allowance of commercial tenants on up to 50% of the usable space.
Stormwater facilities (BMPs) would basically take up flat, usable areas that could be available for recreational purposes, with structures that would divert and capture rain runoff in recessed planting areas, or potentially, retention basins. Commercial uses of the promenade area would also take up valuable flat area and impede recreational activities.
To address these Issues of Concern, the following proposed revisions are recommended as remedies:
FUND REMEDIES
1) All Neighborhood Enhancement Funds collected shall be spent within the subject community planning area, unless the community is not deficient in park and recreation facilities; and 2) Neighborhood Enhancement Funds shall be used ONLY for design and construction of capital infrastructure within the public promenade.
PROMENADE REMEDIES
1) Any public promenade placement shall be consistent with the parks and recreation infrastructure criteria specified in an updated Community Plan; 2) Require public input on design and development in accordance with Council Policy 600- 33, in the absence of an updated community plan; and 3) Reduce the allowable space for commercial tenants to 25% to maximize available open public use area.
Page 25 of 43 ITEM #3 – San Diego Planning Commission May 14, 2020 From: KENSINGTON-TALMADGE PLANNING GROUP Subject: Proposed Complete Communities Housing Solutions
KENSINGTON TALMADGE PLANNING GROUP – March 11, 2020 ACTION ITEM: To Support/Not Support proposed changes to the City’s Proposed Complete Communities Housing Solutions Regulations
Recommended Motion which addresses the identified Issues of Concern; approved 12 in favor, 1 opposed:
1. Remove RM-1-1, RM-1-2, and RM-1-3 zones from these requirements. 2. Require Neighborhood Enhancement Funds to be spent within community where located, depending on definition of “Community of Concern” and park deficiency. 3. Spend Neighborhood Enhancement Funds on capital improvements only. 4. Allow promenades on main Commercial and Mixed-Use streets only. 5. Require promenades to meet City or Community Plan criteria for park placement if park credit is given. 6. Require public input on design of public amenities. 7. Reduce on-site commercial tenants to a maximum 25%.
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SAVE OUR ACCESS
May 25, 2020
To: Community Planners Committee For the 5/26/20 meeting
Re: COMPLETE COMMUNITIES - HOUSING SOLUTIONS
Introduction: In January 2019, Mayor Faulconer introduced a proposal to add more density and eliminate height limits near transit corridors. This proposal has now evolved into "Complete Communities".
This analysis deals primarily with the component for Housing. Not included in this document are the other three components, for Mobility, Parks and Infrastructure.
Summary of findings: The proposed program is unnecessary, poorly conceived, and is excessive in many ways. It seeks to authorize high density projects in communities, with downtown-style density and no height limits.
The program is unlikely to achieve goals of stimulating more housing. As designed, it would shut-out the public, with no public review of projects. The project should be put on-hold until the health crisis has subsided, and budget shortfalls have been dealt with.
Findings: 1. This housing component is not needed. The City has a large inventory of housing sites now. The draft Housing Element shows "capacity for at least 174,678 housing units". Also, there are many City and State programs in place which facilitate the production of housing, and they are working. These include: Affordable Housing Density Bonus, up to 50% Affordable Housing Expedite Program Removal of parking requirements There are currently in work six California Senate Bills intended to stimulate housing production near transit corridors. More City programs are not needed at this time!
1 Page 27 of 43 2. The program is too broad, covering vast areas of the City. The affected area would be about 2/3 of the entire central portion of San Diego. Also, the Transit Priority Areas (TPA's) which form the basis of the program are drawn incorrectly. (A report was submitted to City staff by David A. Potter, AICP, Planning and Environmental Consultant and former City of San Diego Deputy Planning Director)
3. The program would be harmful to communities. It would override the Community Plans and existing zoning, in essence throwing out many years of work, by hundreds of residents.
4. The public would be shut out. By classifying projects as ministerial, there would be no notices, no hearings, no CEQA review, and no right of appeal. Community Planning Groups would be mostly put out of business. Residents wouldn't know about projects until the bulldozers appeared.
5. The Floor Area Ratios (FAR) proposed are excessive for communities outside downtown. Currently, communities have FAR in most areas of 0.5 to 2.0. The proposed FAR of 4.0 to 8.0 would typically result in buildings of 8 to 24 stories!
6. Coastal communities are included in the plan. The FAR ratios, allowing buildings of 8 to 24 stories, obviously do not respect the 30 ft height limit. Why would City staff and the Mayor include the coastal communities with FAR consistent with 8 to 24 story buildings, unless they plan to eliminate the Prop. D height limit which has been in place since 1972? (see the Addendum)
7. High rise buildings are not affordable. It's well-known that buildings over 3-5 stories have very expensive construction costs. The developer must target high-end rents and selling prices to offset the high costs.
8. Lack of transition areas. TPA areas are circles on a map. They don't correspond to streets, canyons or any other boundaries. They are a poor basis for a program with "no height limits". Residents could find a building of 12-24 stories across the street from their home, or next door!
9. Infrastructure planning is absent, at this time. City staff seems unaware of residents' outcry since the 198o's for Adequate Public Facilities. The staff has not released a plan for providing the parks, libraries, fire stations, and transportation systems needed to serve allowable development. Will there be a phasing program to ensure facilities at the time of need? (concurrency requirement). The City's record has not been good. In taking away parking requirements, they defined a "planned transit stop" as operational by 2050, 30 years in the future!
10. The Environmental Report is seriously flawed. Harmful impacts have not been properly considered or reduced. (Available on request or see the Final EIR: Attorney's letter detailing the deficiencies).
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11. Faulty basis. Despite all the statements about a "housing shortage", there is no accepted method for measuring this. The most common claim is that "population has grown at a higher rate than housing." This is simplistic. There are many reasons why "household size" can increase: Young people living at home longer; and seniors choosing to live with their offspring. Why should that be viewed as a negative?
12. Unlikely to get more housing. Economists and housing experts state that San Diego's population growth is largely based on job growth. That rate of growth is not infinite, but rather has been under 1% per year. Referring to the draft Housing Element, and its capacity for over 174,000 housing units, demand can easily be met with existing Community Plans and zoning. If future projects are built with very high FAR and very tall heights of 12 to 24 stories, a community may get one project like this, and then none while the new homes are being "absorbed" by the market. The community won't get more housing, it will get a few out-of-scale projects which will tower over existing homes.
13. High FAR, high prices. Allowing high FAR's of 4.0 to 8.0 predictably leads to large, high-priced housing units. The Uptown community got an example of this. At the Mi Arbolita project (now Park One), 6th and Upas, the community was shocked to get a 14 story building where seven stories were expected. With little restriction on FAR or heights, the developer designed very large units, with one entire floor per unit. The high FAR in the proposed program would work directly opposite to the stated goal of smaller, more affordable units.
14. Regarding "Mobility" the City staff in their response to a letter stated: "Congestion, delay and parking are no longer issues to be evaluated in CEQA documents" (!!) The implications of this statement have not been discussed by Community Planning Groups. What is required by State law, and what could the City do to interpret this intelligently, when writing implementing ordinances? Is the City going beyond what is needed, and creating harmful conditions unnecessarily? Is their goal to ignore traffic and parking entirely?
15. Planning Groups have holdover boards. Many of the Planning Groups did not hold elections in March 2020, because of the lockdown order from the Governor on March 11. They've been directed by the City Council to delay elections until the State of Emergency is lifted by the Governor. In many cases, termed-out board members have agreed to serve for the interim, but they are not obligated to do so.
16. Health crisis limits participation. In the midst of the pandemic, residents are necessarily preoccupied with work and family responsibilities, also trying to stay healthy. Without the ability to attend in-person meetings, public participation is limited. Many residents do not have the technology to participate in electronic meetings. This is a terrible time for the City to attempt rushing-through a program with far-reaching changes. To continue this would be undemocratic and unjust.
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17. Budget. The budget shortfall is currently projected at the daunting figure of $370 million. This will have extensive impacts in all aspects of City operations, from planning budgets to street maintenance. This is no time to carry out a major change in zoning, certain to be expensive in planning and implementing.
Knowledgeable People: What is being said by people knowledgeable in planning issues:
From Dr. Nico Calavita, in written comments to the Planning Commission: The City, then, has engaged in a reckless approach that makes possible higher and higher densities without the necessary infrastructure. With Complete Communities it is not too difficult to imagine a nightmarish future with the streets of the urbanized communities faced with a wall of high and mid rises with cars driving around in search of parking. From a former City Councilmember: Great harm is in the offing as transit and affordable housing arguments are used to overwhelm public infrastructure and environments -- which citizens have created over the years to make their communities more livable. All these changes should, community by community, be put to a vote of the residents. Planning should occur bottom up, not top down.
The last decision for Planning Groups: In the original Terminator movie, the people turn over control of the nation's computer systems to Skynet. It's the last decision under their control.
That's what the City staff wants you to do. If you say yes, and the City Council approves this plan, it is the last decision you will make, for large areas of your community.
a. On future projects which apply for the incentives: Approvals would be ministerial, eliminating all public input. Planning Groups, to a large extent, would be put out of business. You and your neighbors wouldn't find out about a project until the bulldozers showed up. This situation is already happening, and would increase many- fold with this program. b. On projects which don't apply for the incentives: The amended Recreation Element would apply. No specific amount of park land would be required. The communities would be left with a policy that the City would "strive" to meet some standards. Those standards are a "point system" which is easily manipulated by staff. c. On all projects, infrastructure could be provided 10-20 years late or never.
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Action: This analysis details many serious flaw in the Housing component. The other three components have significant deficiencies also.
In view of the many serious limitations in the proposed program, community leaders cannot be expected to go along. A reasonable response is this:
1. Reject the Complete Communities program as presented.
2. Recommend that the program be put "on-hold" until the following have been achieved: a. The governor has lifted the State of Emergency. b. Community Planning Groups have held the 2020 elections, and the new boards have been seated. c. November general elections have been held. d. The City budget has stabilized, and funds are not being used for Complete Communities planning and implementation while parks, libraries and code enforcement are being cut. e. To resume no earlier than January 2021.
Tom Mullaney Save Our Access [email protected] 619-889-5626
Complete Communities analysis, Save Our Access.pdf
5 Page 31 of 43 ADDENDUM: HIGH-RISES ON THE COAST MAP of LA JOLLA, showing proposed Floor Area Ratios (FAR) of 4.0 and 8.0.
If a building covered 1/3 of a lot, then a FAR of 4.0 (orange) would result in a building height of 12 stories. For example, a 5000 sf lot would be allowed 20,000 sf of building space. With 1667 sf per floor, the building height would be 12 stories. A FAR of 8.0 (green) would allow double the above. A 5000 sf lot would allow 40,000 sf, with 24 stories. Why would the Planning Dept and Mayor want to allow 12 to 24 story buildings in the coastal communities, which are subject to the 30 ft Coastal Height Limit? Apparently they have a plan to eliminate the height limit, adopted in 1972 by a Citizens Initiative.
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Dear Commissioners,
I am Professor Emeritus in the Graduate Program in City Planning at SDSU where I have taught classes in Housing, Site Planning and Analysis and History of Urban Planning. I was also adjunct professor at UCSD where I taught classes in Land Use Planning and Housing. I am a nationally and internationally recognized expert on Inclusionary Housing and Commercial Linkage Fees.
In the past ten years or so I have become interested in Land Value Capture (LVR), a process through which some of the increases in land value resulting from public actions – such as Community Plan Updates or upzonings – are recaptured for public benefit, especially for additional Inclusionary Housing requirements. This approach was spelled out in my coauthored 2010 book : “Inclusionary Housing in International Perspective: Affordable Housing, Social Housing and Land Value Recapture.” I am attaching a publication prepared for the Metropolitan Transportation Commission of the San Francisco Bay Area: Public Benefit Zoning, that provides the theory and examples of LVR.
I am impressed with the City of San Diego Planning Department’s proposal Complete Communities: Housing Solutions and Mobility Choices. It is laudable for the city to propose a program that would allow for developers to opt
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for FAR density increases and other incentives provided by Complete Communities, in exchange for more affordable housing and linear open space. But the proposal has an overriding flaw: the benefits to the city are not worth the costs to the communities involved. .
I apologize for the length of this letter, but the Complete Communities proposal is massive in its scale and possible impacts, and the application of LVR is quite complex. Here are some of the salient points of the letter:
• Large density increases have been granted already, as part of Community Plan updates, making LVR difficult to implement • Proposing downtown type densities of FARs of 8 uniformily across large swaths of the urban communities goes against well established land-use planning principles that taylor land use intensities to local conditions • FARs are justified on the basis of good transit availability. However, the possibilities of a good reional mass transit system are limited • Uniform application of an FAR of 8 plus a great variety of additional incentives and wavers would make the impact on the existing urban environment very damaging • The proposal would opt the city out of a previously approved state program that attaches density bonus awards with deeper affordability requirements
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• The proposal would hasten processes of gentrification and eviction • The proposal wold eliminate current and successful FAR acquisition and FAR incentives programs downtown • The proposed benefits are small because: 1) There is little density to give away and, 2) The blunt approach that treats all properties the same, regardless of their location and base density, is very ineffective in capturing land values.
Please see “What to do” (beginning page 8) for a more detailed explanation of the alternative LVR mechanisms, and other suggestions for change ______
The problem. During the past few years the city has updated several community plans, granting huge density increases – for free. In a March 2013 “Viewpoint” in Planning, the magazine of the American Planning Association titled “Getting Our Fair Share,” I concluded the article with: “So, land-use planners, don’t upzone or change your plans willy-nilly. Recapture some of the increases in land value for the building of the public city.” At the local level, I have published Op-Eds & Commentaries in the San Diego Union and Voice of San Diego (one of them with Betsy Morris, former CEO of the San Diego Housing Commission ).But today, because of the city’s history of changing its plans willy-nilly, LVR has become problematic.
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To attempt LVR at this point huge additional densities would have to be granted – and this is the course that the Mayor and the Planning Department have chosen. FARs of 8 are being proposed for the urban core of the city, with the largest area surrounding El Cajon Boulevard and University Avenue. FARs of 8 are downtown type densities (see attached slides). FARs downtown vary, depending on location and other characteristics. But for the Urban Core, FARs of 8 are applied uniformly, with side streets being treated the same as University Avenue and El Cajon Boulevard, for example. In a relentless, single- minded drive to build more housing, the City of San Diego is proposing to discard the most basic planning principles by taking neighborhood characteristics into consideration in determining land uses and densities . The public facilities problem. We already know that, in the urbanized communities of the city there is a huge deficit in public facilities and infrastructure and that DIFs cannot pay for existing facility deficits and will not pay for all the needs created by new development. For example, the implementation section of the Midway-Pacific Highway Community Plan states that: “Public improvements described in this community plan vary widely in their range and scope. Some can be constructed incrementally as scheduled street maintenance or private development occurs, and others will require significant capital funding from city, state, regional, and federal agencies. Grants and other sources of funding should be pursued wherever
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possible.” For the past few decades the city has attempted to find ways to finance the backlog of needed public facilities, to no avail. It is very doubtful that "significant capital funding from city, state, regional, and federal agencies” will materialize; especially after COVID-19. The result will be a worsening of an already, long-term, bad situation. Complete Communities, by substantially increasing densities, would make an already bad situation disastrous.
Transit. As mentioned above, one reason why I oppose FARs of 8 outside of downtown is because of the inadequacy of the existing infrastructure that intense new growth will make only worse. These densities are being proposed in “transit priority” areas. The principle is good. But where is the transit? Our transit system is limited in scale and service. What is the likelihood that the region will develop a system that would make drivers choose mass transit? I believe that, even before the huge economic dislocations of COVID-19, it would be unlikely that San Diegans would agree to tax themselves to build a first class transit system. And in a post COVID-19 economic reality, funding from the Federal government or the State is very unlikely. Additionally, with COVID-19 the desirability and feasibility of transit has taken a hit. Complete Communities is based on future good transit. That is very unlikely to happen. FARs of 8 are appropriate downtown exactly because of its excellent mass transit system.
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Parking. Last year, City Council eliminated parking requirements in Transit Priority/Complete Communities areas. No parking provisions while planning for tens of thousands of new units is a disaster in the making. Barry J. Schultz, a former San Diego planning commissioner, in a San Diego Union Tribune Op-ed opposing the elimination of parking requirements, noted that “While some neighborhoods have access to public transportation, it does not efficiently get people where they need to go and a car is necessary to take care of most daily needs (shopping, medical appointments, etc.). He proposed a “more strategic and phased approach” to the lowering of parking requirements, but to no avail.
The city, then, has engaged in a reckless approach that makes possible higher and higher densities without the necessary infrastructure. With Complete Communities it is not too difficult to imagine a nightmarish future with the streets of the urbanized communities faced with a wall of high and mid rises with cars driving around in search of parking.
Incentives/Ministerial Approval. In addition to the proposed FARs of 8, a great variety of additional proposed incentives and waivers would make the impact on the adjoining single-family neighborhoods even worse, with no recourse. Developments that opt for the Complete Communities program will need ministerial approval only (except for developments in Environmentally Sensitive Lands). Regardless of size? This is a significant time cost
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saving for the developers, at the expense of the communities involved.
And for what?
Proposed Benefits are small. The most important economic issue with LVR is to make sure that the costs to the developer of the public benefits to be provided for higher densities are not so high that the projects are rendered infeasible. On the other hand, the benefits should not be lower than what is economically feasible. The key is finding the so-called sweet spot.
The Planning Department has been working with Keyser Marston Associates to find out what is economically feasible. Good. But the problem is not only that significant densities have been given away already, but that with existing base densities being so different – some lots might have an FAR of .5 and another 4 – the potential FAR increases can vary greatly. The property that gets an increase of 7.5 FAR has an increase in land value much greater than the property that gets an increase of 4. But since Complete Communities treats all properties the same, the benefits to be required are based on the properties that get the least density increase. To ask for more would make developing those properties infeasible. Again, the benefits are minimal because: 1) In most communities densities have already been given away and; 2) All properties are treated the same, regardless of base densities.
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Housing: 1) The 10% at 60% of AMI requirement is the same as the city-wide Inclusionary Housing (IH) Ordinance. 2) The 10% at 120% AMI is the additional requirement resulting from Complete Communities which, I believe, is not much of a cost to the developer. The proposed policy does provide a significant public benefit, however, in that developers cannot pay an in-lieu fee, but have to build units, on-or off-site (near the development).
What is disappointing is that the IH requirements are based on the “pre-density” level. It would seem that if a developer builds on a site with a base density that would allow 10 dwelling units, only two affordable units would be required, even if the development would include 100 units. If correct, this provision would actually reduce the current citywide IH requirements.
Infrastructure amenity. The proposed payment into a Neighborhood Enhancement Fund ($9 sq. ft. of lot size) seems to be too low to generate significant funding. A 10,000 sq. ft. lot would pay $90,000. Compare this fee to the downtown “FAR and Bonus Payment Program” that basically “sells” additional FARs to developers, with the revenues to be used for the acquisition of public parks and enhanced public rights-of-ways downtown (the first slide of the STRATA project downtown shows that the developer acquired 0.69 FARs for the project). The payment to the city is $19 per sq. ft. of FAR, not lot area.
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Other Issues
Downtown. Given that under Complete Communities there are no FAR limits downtown, it seems that this program eliminates the current FAR acquisition and FAR incentives programs. That would be a huge loss, certainly not justifiable by the benefits provided.
Gentrification and evictions. The protections are for non- market affordable housing. As Senator Scott Wiener pointed out in an interview with the San Diego Union Tribune Editorial Board, about 90% of affordable housing units are market rate units – the housing many low- income families pay 50% or more of their incomes for and are evicted from when more money can be made from new development of the land on which the units are located. Thus Complete Communities will accelerate the gentrification process and evictions in many neighborhoods, which was one of the major concerns about SB 50. Weiner made some changes to the bill to lessen the impact. Complete Communities does not have those protections.
What to do?
Refining LVR. For the city to get much more, the benefits should be tailored to the proposed FAR increase over the existing base density. With this alternative approach - based on tiers - the inclusionary housing and fee requirements would vary on the basis of
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the density increases that different properties would receive (see pages 19-26 of attached Public Benefit Zoning, especially Table A-2). For large properties, the developer and the city should negotiate the public benefits, based on an economic Residual Land Value Analysis that would establish the land value increases resulting from the upzoning (see pages 27-29 of Public Benefit Zoning). In the absence of such approaches, this proposal should be scrapped. The benefits to the city compared to the land use, parking, public facilities and transportation impacts on the neighborhoods - especially in light of the fact that a good transit system is not likely to be built – are not enough.
CASA/AB 2372. AB 2372 (also known as the California's Sustainable and Affordable Housing Act CASA), passed in 2018, contains provisions that tie density bonuses to affordable housing provisions. Complete Communities is being proposed as the implementing mechanism for AB 2372. The major difference is that CASA requires 20% of the units at 50% AMI. Also, while Complete Communities includes parcels zoned for 5 dwelling units or more, CASA requires parcels to be zoned for 20 units or more and limits heights. By increasing affordability and lessening impacts on urbanized communities greater benefits can accrue to the public.
Public Participation. Citywide changes of this type are just as significant in terms of their impact as the City of Villages program and the General Plan updates of the
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past. Those plans engaged in very extensive public participation processes. Unfortunately, for members of the public who wanted to learn more than a generalized description of Complete Communities, the only available document was the very unfriendly proposed ordinance. The report to the Planning Commission, however, presents Complete Communities in a way that will make possible public (non-specialist) involvement. But how much time does the public have now? This process is being pushed through at astounding speed.To ensure that Complete Communities achieves its intended goals without causing serious negative impacts on the communities it affects, the City of San Diego should slow down the process and expand opportunities for public participation.
The Planning Commission should form a subcommittee of its members charged with analyzing Complete Communities, including giving consideration to a more refined LVR approach and a CASA alternative, and making recommendations to the full commission.
Nico Calavita, Professor Emeritus Graduate Program in City Planning SDSU
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