The URL can be used to link to this page

Home My WebLink About7/22/2020 Item 4, Cooper Wilbanks, Megan From:Allan Cooper < To:Cohen, Rachel; Corey, Tyler; Advisory Bodies Subject:6th Cycle Housing Element Update Attachments:707_19_20...lettertopc.pdf; 506_15_20...lettertopc.pdf Dear Rachel and Tyler - Would you kindly forward the letter attached below to the Planning Commission? This letter (and a letter I wrote last month to the Planning Commission) pertains to their Wednesday, July 22, 2020 meeting where they will be reviewing, presumably for a final time, the 6th Cycle Housing Element Update. Would you also place this letter in the City's correspondence file as well? Thank you and stay safe! - 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, Rachel Cohen and Tyler Corey Re: Item #4: July 22, 2020 Review of the 6th Cycle Housing Element Update   From: Allan Cooper, Secretary Save Our Downtown Date: July 19, 2020 Honorable Chair Dandekar and Commissioners - On Wednesday, July 22nd you will have your second and ﬁnal review of the 6th Cycle Housing Element Update. Hopefully you have had an opportunity to look over the letter we wrote you on June 15, 2020. This letter placed some emphasis on how we are going to cope with both social distancing and climate change. I am attaching this letter for your convenience. We have formatted our response to these changes in the following manner. We will be addressing proposed strikeouts and additions to the Housing Element Update in the following order: public comments, planning commission comments and legislative changes. At the very end we would like to revisit our concerns about the City's lingering emphasis on promoting ﬂexible density, micro-units in tall buildings and on the elimination of personal transportation and parking. We say “lingering emphasis” because all of these goals and priorities were put in place prior to this pandemic and prior to the realization that there will be more pandemics like this in the near future. To quote Sam Lubell, a proliﬁc author on architecture, a staff writer at Wired and a Contributing Editor at The Architect's Newspaper: “The time to reassess our built world is now, not after the next catastrophe. What if we more effectively employed modular building tools not just to face pandemics or natural disasters, but also to create less costly, more quickly built buildings in general, from pop-up shops to affordable housing? What if we broadened our sense of what a building could be and turned vacant malls into schools, or vacant offices into transitional housing for the homeless? What if we harnessed telecommuting as not just a way to social distance, but a way to help employees achieve work-life balance — spending more time with family, or exercising, or doing any number of things that would make them healthier?” Public Comments 78 individuals responded to questions in the June 8 - June 24, 2020 Housing Element Online Survey. Of comments gleaned from this online survey plus public comments reputedly ﬂowing from the Housing Major City Goal work program, only two “comments” were singled out as worthy enough to be incorporated into this Update. Needless to say, none of the comments emanating from Save Our Downtown’s numerous letters and public testimony were incorporated into this document. Public Comments: Policy 8.9: “Encourage a variety of housing types that accommodate persons with disabilities, and promote aging in place, and include amenities such as visiting space, ﬁrst ﬂoor accessibility, etc.” SOD Comments: What is the context behind this recommendation? Obviously, disabled housing has accessibility requirements covered through the Americans with Disabilities Act (ADA) so mention of this seems redundant. Could the emphasis on housing types that cater to aging in place have to do with a much needed examination of congregate living and this in response to the social distancing requirements caused by future pandemics? If so, then the reasoning behind this should be made more explicit. Public Comments pertaining to new Policy 2.13 (see below): Staff states that this program was recommended in part by input from the community and the work program associated with the Housing Major City Goal. The community and Council identiﬁed that the Downtown and portions of Upper Monterey and Mid-Higuera Special Focus Areas could be appropriate for higher density housing development. New policy 2.13: “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).” SOD Comments: How could the so-called “community” recommend a “ﬂexible density pilot program” when very few residents would be able to grasp the full meaning behind this term? This is strictly “planning jargon” and its advocates are more likely an unrepresentative, more sophisticated segment of the population, probably comprised of out-of-town developers. And by the way, were residents in the Upper Monterey Focus Areas consulted and did they too buy into this idea of ﬂexible density? We think not! Planning Commission Comments PC Comments: Most of the June 10th Planning Commission’s discussion centered on “workforce housing”, which has yet to be deﬁned, and on the lack of middle income housing a.k.a., the “missing middle”, which has also yet to be deﬁned. SOD Comment: Staff has loosely deﬁned the “missing middle” to be housing types that include “duplexes, triplexes, quadplexes and cottages”. However, the City has recently determined that the 300-500 sq. ft. micro-units located within a proposed 1144 Chorro Street residential tower qualiﬁed as “moderate income housing”. Because duplexes, triplexes, quadplexes and cottages are more family-friendly, more ecologically sustainable and more pandemic-proof than mid-rise residential towers, every effort should be made to further deﬁne this category of housing. PC Comments: Staff stated that Policy 7.9 has been added as recommended by the Planning Commission on January 10th to address public health and housing. This policy now appears in the update as follows: “Encourage neighborhood design elements that improve overall health of residents such as providing safe and convenient opportunities to access food outlets and active places for recreational exercise.” SOD Comments: Pursuant to Goal 7’s original policy statement, Commissioner Shoresman proposed the following additions (and this is my word-for-word transcription): ”Neighborhood quality is especially needed during pandemics.” She stated that this goal “should make reference to walkability, to health and to climate change. The City should encourage residential design that improves our health through the creation of community gardens, though avoiding “food deserts”, through ensuring that housing is free of auto exhaust and that there are opportunities for recreational exercise." As you may note, staff has strategically expunged all references to pandemics or climate change which were included in this motion. Moreover, Commissioner Shoresman includied in her motion reference to “residential design that improves our health” while staff merely refers to “neighborhood design elements”. The important difference here is that “residential design” is where the proverbial “rubber hits the road” when it comes to responding to both climate change and the proliferation of zoonotic diseases. PC Comments: Commissioners Michael Hopkins and Robert Jorgensen correctly pointed out that the Nexus Study only saw ﬁt to increase our proportion of inclusionary housing by 2%. At this rate, we will never reach our low income housing targets. However there was no future discussion of this and this concern did not show up in the PC’s ﬁnal motion. SOD Comments: We had previously pointed out to the Commission that the proportion of inclusionary housing units could be increased to 20% of affordable housing set-asides like Santa Monica, CA or even 35% like Davis, CA without affecting project feasibility. Michael Codron insisted however that increasing the percent of inclusionary housing above 5% would jeopardize project feasibility. We still believe that it is within the PC’s purview to question such a small increase in the required percent of affordable housing if other comparable cities can address this need more effectively. Legislative Changes Staff Comments: Staff states that Policies and programs within Goal 11 (see below) are covered by the other Goals of the Housing Element, the Housing Major City Goal, the Conservation and Open Space Element, the Land Use Element, and the Safety Element. Goal 11: “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.” SOD Comments: However this phraseology is nowhere to be found in the Housing Element, the Conservation and Open Space Element, the Land Use Element or the Safety Element. We belatedly discovered that the reason for its strikeout should instead be that this Goal is stated in Policy 5.1: "Encourage mixed-use residential/commercial projects in all commercial zones, especially those close to activity centers.” Also see Program 6.13: “Consider General Plan amendments to rezone commercial, manufacturing or public facility zoned areas for higher- density, inﬁll or mixed-use housing where compatible with surrounding development”. Staff Comments: Staff struck out Policy 6.23 which reads: “Assist in the production of affordable housing by identifying vacant or underutilized City-owned property suitable for housing, and dedicate public property, where feasible and appropriate for such purposes, as development projects are proposed.” SOD Comments: Staff stated that they had completed an inventory of City-owned property and found that no City-owned properties are suitable for housing. What about the Nipomo Street Parking Garage? What about the eleven existing City-owned surface parking lots (lots 2-18). These may or may not be earmarked for parking structure locations. Staff Comments: Under Policy 9.2 which reads: “Residential units site, subdivision layouts, and neighborhood designs amenities should be coordinated to support make residential sustainable design work” staff chose to strike out all of the previously listed “innovative sustainable design strategies”. The reasoning for this is that staff concluded that examples of innovative sustainable designs are extensive in new developments being reviewed by the City. SOD Comments: We beg to disagree. The following examples are design strategies that are not evident in residential developments recently approved by our City: A)Design subdivisions to maximize solar access for each dwelling and site. Recent subdivisions are neither orienting their housing units or their streets in order to optimize on passive solar heating and cooling. B) Design sites so residents have usable outdoor space with access to both sun and shade. Neither 1144 Chorro or 545 Marsh have capitalized on usable outdoor space. E) Encourage cluster development with dwellings grouped around signiﬁcantly-sized, shared open space in return for City approval of smaller individual lots. Very few cluster developments have been proposed in recent years. F) 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. More often than not ,existing trees have been removed in preparations for the construction of new housing (see San Luis Ranch). These are usually mature, healthy trees that are being replaced by much smaller ones. Staff Comments: Staff chose to strike out the following passage under the old Policy 9.3: “Maintain the overall scale, density and architectural character of older neighborhoods surrounding the Downtown Core. Staff states that the Historic Preservation Ordinance (HPO) preserves and protects historic structures and districts. SOD Comments: But the HPO does not protect “older neighborhoods surrounding the Downtown Core”. Note 545 Marsh Street as a noteworthy example. Over-Riding Priorities Michelle A. Williams, dean of the faculty at the Harvard T.H. Chan School of Public Health and the Angelopoulos professor in public health and international development has stated the following: “The global outbreak of COVID-19 is in no way an anomaly. Today, infectious diseases are emerging and reemerging more quickly than ever before. Between 1980 and 2013, the number of annual epidemics has gone from fewer than 1,000 to over 3,000. Infectious diseases such as Zika, MERS-CoV, SARS, cholera, tuberculosis, HIV/AIDS, inﬂuenza, and Ebola kill millions every year, and their outbreaks have decimated economies and triggered aftershocks and panic around the world.” How do we as urban planners respond to this? Joel Kotkin, a fellow at Chapman University, the executive director of the Urban Reform Institute stated that future cities beset with reemerging infectious diseases will result in the following: “Answers may include allowing more growth in the periphery, which would require substantial changes in land use and zoning regulations; encouraging remote work where possible; and developing personal, eventually autonomous transport systems instead of forcing people into crowded subways.” Increasing residential density in our urban centers in order to reduce long commutes from the outer suburbs (presumably in carbon intensive vehicles) is now a fool’s errand. Why? Because even though in 2017 the percent of the U.S. labor force working from home was 5.2%, a May 26, 2020 CNBC|SurveyMonkey Workforce Survey reported the following: 52% of full- time workers work from home and 39% of part-time workers work from home. Read more at: https://www.cnbc.com/2020/05/26/who-is-happiest-working-from-home-heres-what-latest- jobs-data-says.html Reducing personalized transportation is equally foolhardy because using ride-sharing or taxis is now seen as risky for three quarters (75%) of Americans. As for micro-units: For the past ﬁve-plus years, micro-units have been an intriguing subplot in the grand saga of commercial real estate. As demand for housing has boomed, especially in rent-burdened cities like New York and San Francisco, developers gambled that tenants would tolerate tiny units — some as small as 220 SF — for the chance to access cool neighborhoods at affordable rents. Now, though, some real estate experts wonder whether the coronavirus will kill, or at least cripple, the concept. We will give you three examples of this newly found-skepticism surrounding micro-units: Last month, FM Capital Principal Aaron Kurlansky said during a Bisnow South Florida webinar: "Prior to COVID, there was a big surge in the urban areas, urban core, everyone wanting to live in micro-units, and now it looks like everyone wants to move to the suburbs, buy homes, get out of apartments. Social distancing is the antithesis of the tight-knit living style that micro-units and their cousin, co-living, promote. With bars and restaurants shuttered and remote work gaining more acceptance, renters may see fewer reasons to remain in city centers, where most micro-unit properties are.” Read more at: https://www.bisnow.com/south-ﬂorida/news/multifamily/will-pandemic-kill-off- micro-units-105074?utm_source=CopyShare&utm_medium=Browser Girish Gehani with Trilogy Real Estate Partners believes there will be a move away from micro-units. Read more at: https://www.fetchpackage.com/multifamily-amenities-in-the-post-covid-19- world-top-11-takeaways/ Integra Investments principal Victor Ballestas said: "We always had a little heartburn over the micro-unit model and then [we] started hearing through the grapevine also that people that are moving into micro-units are, you know, moving out after the year. It's pretty much like 100% turnover rate, which obviously impacts performance signiﬁcantly.” Read more at: https://www.bisnow.com/south-ﬂorida/news/multifamily/will-pandemic-kill-off- micro-units-105074?utm_source=CopyShare&utm_medium=Browser 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, Michael Codron and SLO City Council Re: June 10, 2020 Planning Commission Meeting; Review of the 6th Cycle Housing Element Update From: Allan Cooper, Secretary Save Our Downtown Date: June 15, 2020 Honorable Commissioners - When staff presented their draft version of SLO’s Housing Element Update to the Planning Commission on June 10, 2020 there was a conspicuous and surprising omission. No mention was made of this pandemic’s and future pandemic's new social distancing requirements. Social distancing will have a profound impact on housing density, housing layout and on neighborhood density in general. Commissioner Mike Wulkin correctly expressed concern with the deletions made to Goal 7 “Neighborhood Quality”. The deleted passages read as follows: “… encourage neighborhood stability and owner occupancy, and improve neighborhood appearance, function and sense of community.” Mr. Wulkin was particularly concerned with the deletion of neighborhood stability and owner occupancy. Subsequently Commissioner Michelle Shoresman proposed revisions to Goal 7’s policy statement. These revisions were accepted by all of her fellow commissioners. Following Goal 7’s original policy statement, Commissioner Shoresman proposed the following additions: ”Neighborhood quality is especially needed during pandemics.” She stated that this goal “should make reference to walkability, to health and to climate change. The City should encourage residential design that improves our health through the creation of community gardens, though avoiding “food deserts”, through ensuring that housing is free of auto exhaust and that there are opportunities for recreational exercise." Why should this Housing Element Update, as Commissioner Shoresman suggested, address pandemics and health? Atlantic Magazine has an excellent article titled "How Pandemics Will Change The Face of Retail" (click on: https://www.theatlantic.com/ideas/archive/2020/04/how- pandemic-will-change-face-retail/610738/). But this article goes further to discuss how this pandemic and future pandemics will reshape housing and cities as well. While the YIMBY’s and State Senator Scott Wiener are pushing for higher density housing, we should be reminded of the fact that high-density, dormitory-style housing (like 1144 Chorro) may never again be safe or even habitable because of the likelihood that we will almost certainly be beset with multiple pandemics in the future. Should you wish to dispute this future scenario then I would like to refer you to two more articles: “Though the COVID-19 pandemic is still unfolding, it offers a warning of what lies in store as zoonotic diseases proliferate at greater rates due to climate change. Empty streets and upended lives could become more frequent occurrences as disease outbreaks, both life- threatening and relatively benign, swarm the globe.” (click on: https://blogs.ei.columbia.edu/2020/02/24/coronavirus-climate-induced-pandemics/ "Over the past few decades, the number of emerging infectious diseases that spread to people — especially coronaviruses and other respiratory illnesses believed to have come from bats and birds — has skyrocketed. A new emerging disease surfaces ﬁve times a year. One study estimates that more than 3,200 strains of coronaviruses already exist among bats, awaiting an opportunity to jump to people.” (click on: https://www.propublica.org/article/climate-infectious-diseases) Commissioner Mike Wulkin also expressed concerns with the following additional deletions: 7.1 Prohibition on building in parks. Staff stated that this is covered in the Open Space Element. 8.3 Encouraging manufactured housing. Staff stated that higher density developments are more efficient from a sustainable point of view and that developers are not interested in doing mobile home parks. 9.3 Scale, density of older neighborhoods. Staff stated that this is covered in the Historic Element. 11.2 Preventing new housing on hazardous sites. Staff stated that this is covered in the Safety Element. The reason I’m raising these additional points made by Commissioner Wulkin is that many of these deletions pertain to the preservation of parks, maintaining existing neighborhood (i.e., lower) density and avoiding placing housing in areas susceptible to wildﬁres and ﬂoods. All of these considerations have direct bearing on how we are going to cope with both social distancing and climate change. Staff’s assurances that these policies are covered elsewhere is patently untrue. This wording is neither found in the Open Space Element, the Historic Element or the Safety Element. I challenge you to ﬁnd the passages that are supposedly duplicating these policies. Thank you for your time and consideration. - Allan