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Home My WebLink About6/10/2020 Item 3, Cooper Wilbanks, Megan From:Allan Cooper < To:Cohen, Rachel; Advisory Bodies Subject:Item No. 3: 6th Cycle Housing Element Update Attachments:906_06_20...lettertopc.pdf Dear Rachel - I am submitting the letter attached below to the Planning Commission. This letter pertains to their June 10, 2020 review of the Housing Element Update. Would you also ensure that this letter is also entered into the City's correspondence file? By the way, your online survey pertaining to this Update is still under construction. Considering this short turn around time, we hope that you will have it up and running first thing Monday morning. Thanks and I hope you're keeping safe and well! - Allan 1 Save Our Downtown ______________________________________________________________________________ Seeking to protect and promote the historical character, design, livability and economic success of downtown San Luis Obispo. To: San Luis Obispo Planning Commission and Rachel Cohen Re: June 10, 2020 Meeting Item Number 3: 6th Cycle Housing Element Update Proposed Policies and Programs  From: Allan Cooper, Secretary Save Our Downtown Date: June 6, 2020 On Wednesday, June 10, 2020 you will be reviewing a 6th Cycle Housing Element Update on Proposed Policies and Programs. According to staff, you have only two opportunities to do this. So it is important that you address these changes at your earliest opportunity.  First, we would like to address, staff’s explanation for removing certain policies and programs: Staff determined that the following policies and programs no longer ﬁt the current needs and issues of the community or no longer comply with new state regulations: Goal 11, policies 3.3, 6.6, 8.3, 9.3, 11.1 and 11.2 and programs 3.8, 6.2 and 11.3 be removed. We have investigated the three policies listed below and highlighted in bold type above and none of them appear to be in conﬂict with new State regulations. If this is correct, then we are also puzzled why the policies listed below “no longer ﬁt the City’s current needs”. These policies address our jobs-housing imbalance, public safety considerations when determining the location of new housing developments, the sustainability of our neighborhoods and the retention of our historically designated housing stock. Permit us to reiterate these policies which have been deleted from the Housing Element Update followed by our comments. 11.1 Where property is equally suited for commercial or residential uses, give preference to residential use. Changes in land use designation from residential to non-residential should be discouraged. Comment: This was an excellent policy in that excessive growth of commercial uses relative to to the growth of our housing stock only exacerbates our jobs-housing imbalance. 11.2 Prevent new housing development on sites that should be preserved as dedicated open space or parks, on sites subject to natural hazards such as unmitigable geological or ﬂood risks, or wild ﬁre dangers, and on sites subject to unacceptable levels of man-made hazards or nuisances, including severe soil contamination, airport noise or hazards, traffic noise or hazards, odors or incompatible neighboring uses. Comment: So are we now to believe that it is in the City’s best interest to place future housing and their occupants in harms way? 9.3 Preserve the physical neighborhood qualities in the Downtown Planning Area that contribute to sustainability. Some ways to do this include: A) Maintain the overall scale, density and architectural character of older neighborhoods surrounding the Downtown Core. B) Encourage the maintenance and rehabilitation of historically designated housing stock. Comment: Eliminating these policies suggests that we are constrained to devalue our older neighborhoods and reduce our historically designated housing stock in order to address our future housing needs. This is not an “either-or” proposition. We can do both! Additions: There are a number of additions made to the Housing Element with which we agree. Pertaining to inclusionary housing: Added: Correct (i.e., increase) proportion of inclusionary affordable units required as a part of new development. Comment: However, we are disappointed that the Nexus Study only saw ﬁt to increase this proportion by 2%. At this rate, we will never reach our inclusionary housing targets. Added: Address the “missing middle” housing types including duplexes, triplexes, quadplexes, cottages. Comment: Incentivizing the addition of duplexes, triplexes, quadplexes and cottages to our current housing stock will address three major challenges ahead: 1) increasing our housing stock while insuring neighborhood compatibility; 2) providing badly needed workforce, “family- friendly” housing” and 3) maintaining social-distancing in a world beset with pandemics. Pertaining to jobs-housing imbalance: Added: Encourage or require new housing developments giving ﬁrst preference to individuals who are employed in businesses that are located in geographic areas that are customarily included in the City’s annual jobs-housing balance analysis. Comment: This is the only approach that will insure that we can 1) work toward balancing jobs and housing; 2) work toward reducing long commutes into SLO from surrounding bedroom communities and 3) work toward insuring that we are truly creating “work force” housing. However, pertaining to maintaining or even enhancing citizen and advisory body input, we have concerns with the following addition to the Housing Element Update: Added: “Consider amending the Zoning Regulations to streamline the permitting process for mixed-used projects in commercial zones.” Comment: There are many ways to incentivize housing, including reducing development fees and reducing delays in processing building permits. But fast-tracking project approvals should not include eliminating or truncating public and advisory body oversight. Pertaining to ﬂexible densities, we disagree with the following changes made to the Housing Element Update: Added: “Downtown and portions of Upper Monterey and Mid-Higuera Special Focus Areas could be appropriate for higher density housing development. Might allow ﬂexible density beyond what is allowed in these areas to support the production of smaller units (150-600 square feet in size).”“Evaluate a ﬂexible density pilot program and initiate an update of the Zoning Regulations and Community Design Guidelines to incorporate ﬂexible density development options in Downtown and portions of Upper Monterey and Mid-Higuera Special Focus Areas to support the production of smaller residential units (150 to 600 square feet).” Comment: Generally, ﬂexible density housing will be comprised of micro-units in multi-story, dormitory-style buildings. They will be reliant on elevators and narrow corridors for access. It should be clear to many of us that in a world of reoccurring pandemics, high-density, high-rise, dormitory-style housing may no longer be a viable option. Moreover, should these projects obtain the ﬁnancing that they need to be built, they will ultimately become a burden to our community. Why? Because, as a result of social distancing requirements, these projects will likely remain either under-utilized or vacant. More deletions: Your staff report never mentioned the rationale behind these additional policy and program deletions: Pertaining to neighborhood quality, we disagree with the following deletions made to the Housing Element Update: Eliminated: “Encourage neighborhood stability and owner occupancy, and improve neighborhood appearance, function and sense of community.” Comment: Eliminating this policy contradicts the City’s commitment to home ownership which contributes to neighborhood stability. Eliminated: “New residential development shall be of a character, size, density and quality that respects the neighborhood character.” Comment: As was stated previously, eliminating this policy suggests that we are constrained to devalue our neighborhoods in order to address our future housing needs. This is not an “either- or” proposition. We can do both! Eliminated: “Continue to develop and implement neighborhood parking strategies, including parking districts, to address the lack of on- and off-street parking in residential areas.” Comment: It is very concerning that the City, by way of eliminating this policy, is no longer interested in addressing neighborhood parking strategies. Are we to assume that in September 2020 when this Housing Element Update is approved and in effect that we will no longer have car parking issues in our neighborhoods? Pertaining to climate change, we disagree with the following deletions made to the Housing Element Update: Eliminated: “Minimize thermal island effects through reduction of heat-absorbing pavement and increased tree shading.” Comment: This policy should be retained if we, as a City, are to address climate change. In fact this policy should be expanded to address heat-absorbing walls and roofs. Eliminated: “Treat public streets as landscaped parkways, using continuous plantings at least six feet wide and where feasible, median planters to enhance, deﬁne, and to buffer residential neighborhoods of all densities from the effects of vehicle traffic.” Comment: Landscaped buffers are an important means to 1) achieve traffic calming; 2) provide landscaped medians that serve as places of refuge for pedestrians; and relative to climate change 3) sequester carbon, clean the air and provide shade for pedestrians while reducing the heat load on neighboring buildings. Eliminated: “Design subdivisions to maximize solar access for each dwelling and site. Comment: Though this policy has almost never been implemented, homes re-oriented toward the sun without any additional solar features can save up to 40% on home heating according to the City of San Jose, California. Eliminated: “Design sites so residents have usable outdoor space with access to both sun and shade.” Comment: Not only does this policy assure that our new housing stock is “family friendly” but it also insures more green space in the city and safe social distancing during pandemics.