Over the past year, as I have considered the county’s Housing Element proposed rezones, I have wondered how they would be able to manage these changes without either bearing massive mitigation expenses or reducing the size or density of their projects.
For example, consider the Glen Annie Golf Club proposed housing project. The proposal to rezone the Glen Annie golf course would add up to 1,000 units (about 8% of Goleta’s total current housing stock):
- The proximity of the new housing to the Dos Pueblos High School would make the Alameda intersection and routes to school into a dangerous commute, especially in the mornings and afternoons.
- It would make an already heavily congested 101 highway northbound offramp extremely unsafe, by exacerbating the traffic already backed up along the highway.
- It would further congest the Hollister-Storke intersection, which is already the most congested Goleta intersection.
- It would seem to require that Cathedral Oaks become a multi-lane road, more like Hollister, if that is even feasible.
If, like me, you wondered how the county would overcome these challenges, waiting for some answers, the other shoe has been dropped. As the Planning Commission was considering the rezones, county staff added something not previously studied. They proposed to remove “level of service” standards, which are part of the Circulation Element of the county’s General Plan, but specifically just for the housing rezone sites.
Here’s what that means. When a new project is proposed, the county evaluates traffic impacts in two ways. For the state, as part of CEQA, cities and counties must evaluate the “vehicle miles traveled,” which considers the consequence of a new project on emissions. Cities and counties may also have an additional standard in their general plans, which is to evaluate the local impacts of new developments on traffic safety and congestion; that is the level of service (LOS).
What the county staff is proposing is to add a new exemption to the level of service requirements for specified housing sites: “However, a project shall not be required to fully offset its impacts if doing so would render the project infeasible or require a reduction in density. If roadway and intersection improvements required to meet LOS standards and fully offset its impacts are infeasible [such as because they were too expensive], the project shall be required to implement roadway and intersection improvements to address LOS acceptable to the Public Works Department.”
In short, the county proposes to approve projects without reducing the project density when the cost for the mitigation for traffic impacts would make the project economically infeasible, according to the project developers. Instead of the objective standard for the level of mitigation that must be accomplished, the county proposes a substitute: Public Works staff, with the concurrence of the developers, would determine those improvements that seem acceptable.
Where a project is so dangerously large for the location that mitigation would make their project unable to pencil out, county planning will not reduce the size of the project to fit the location. Instead, the Public Works department would negotiate an outcome that the developer says is acceptable. Costs of mitigation deemed too high by the developer and Public Works would be forgone — and Public Works could just accept that the adverse traffic impacts are acceptable, seemingly not subject to review.
In the proposed change, there is no requirement that the developer must fully and completely document the financial hardships and project infeasibility resulting from adequate mitigation. What a developer chooses to disclose is basically their choice. If a developer insisted that the mitigation meant their project wouldn’t pencil out — but was unwilling to provide the project’s principal financial documents (presumably because of confidentiality) — the county would be unlikely to demand the documents or to halt a project, knowing they would face litigation and pushback from the state.
Such a process leaves unanswered many safety concern questions: How will all those added vehicles endanger Dos Pueblos high school students on e-bikes, for example? Or what happens when traffic is backed up on the freeway exit making an unsafe situation even more dangerous — who anticipates stopped cars on the freeway? Cathedral Oaks was not built for this extra volume of cars — what happens to Cathedral Oaks traffic generally, one of only three east-west roads traversing the Goleta Valley?
Note that the issue is not whether we support housing. I support housing that will benefit the community. However, we want to be sure that the benefits derived from the added housing are greater than the costs to the community in converting the agricultural areas and open spaces. So, is it really necessary for the Glen Annie project to include multi-million-dollar homes with a view of the ocean? Does that really help our shortage of workforce housing? We don’t have that many CEOs struggling to find houses in the area. In fact, if you look at who has moved into the most expensive neighborhoods, you’ll see they recruit from out of the area. Expensive homes frequently require out-of-town buyers. Does it really make sense for the county to say that no project should be adjusted or reduced in response to the conditions on the ground?
The other thing I support is housing based on smart planning. At this stage, the county has done no analysis of the traffic impacts of the new projects that will emerge as a result the proposed rezoning. What they do know is that they do not want any conditions to potentially hinder the new developments, even if a community is made less safe and the traffic is heavily congested.
This staff proposal to amend the county General Plan needs to be dropped. I would hope that the Board of Supervisors act as if these proposed projects were going to be built where they live, and the traffic and safety impacts would affect them and their families. Staff did not.
One set of neighborhoods in the county should not be bearing a disproportionate share of the burdens, particularly when that burden is excessive and unreasonable. How does one justify to the neighborhoods affected that we waived the General Plan protections that have always been in place because they were getting in the way? The state is not mandating this change. The Board of Supervisors needs to drop this proposal.
Stuart Kasdin is a councilmember for the City of Goleta.