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HomeMy WebLinkAbout5/8/2024 Item 5b, Minnick Jake Minnick < To:Advisory Bodies Subject:PC Agenda Correspondence - Item 5.b GENP-0175-2024 Attachments:General Plan Conformity Report - GENP-0175-2024.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Good afternoon, Staff, Please see the attached community correspondence regarding the May 8, 2024 Planning Commission Meeting, Item 5.b. Thank you, Jake Minnick 1 VIA ELECTRONIC MAIL May 7, 2024 Planning Commission 990 Palm Street San Luis Obispo, CA 93401 RE: General Plan Conformity Report - GENP-0175-2024 Dear Planning Commission, We are citizens and homeowners in the City of San Luis Obispo, and we are writing to express our concerns regarding Agenda Item #5.b, which recommends the Planning Commission determine that the "Welcome Home Village" project that San Luis Obispo County is proposing on the parking lots at the intersection of Bishop Street and Johnson Avenue in the City of San Luis Obispo conforms to the General Plan for the City. More specifically, the County plans to lease the property to Dignity Moves, who will construct 34 interim housing units and 46 permanent housing units, for future management and operation by another entity, Good Samaritan Shelter. Before getting further into the substance of the matter, we want to start by clarifying that none of us are opposed to helping the homeless. The truth is that we all want to be involved in the process of developing the right solutions. Ordinarily, the City of San Luis Obispo is very proactive about community engagement, and seems to genuinely take pride in hearing, and later addressing, community concerns. However, that doesn't seem to be the case with this project. For example, this item is on the consent agenda, when it is widely known to be controversial. More on this, later. We acknowledge the fact that homelessness is a problem in our community, and while that topic tends to ignite an emotional conversation, our goal with this letter is to present you with straightforward facts and questions that are directly related to your role in the process. The Agenda Report indicates that this project is "consistent with General Plan policies [emphasis added] because it provides an opportunity to develop interim and supportive housing for individuals and families experiencing homelessness or at risk of becoming homeless." However, the Agenda Report only actually cites one single policy in support of that statement. The selected policy is Housing Element Policy 8.1, which states: Encourage housing development that meets a variety of special needs, including large families, single parents, disabled persons, the elderly, students, veterans, the homeless, or those seeking congregate care, group housing, single -room occupancy or co -housing accommodations, utilizing universal design. Community Letter to the Planning Commission Regarding GENP-0175-2024 Given the ambiguous nature of Housing Element Policy 8.1, it is reasonable to conclude that this project, or any other type of housing project, would be consistent. That said, the project is inconsistent with a number of more specific General Plan policies, including, but not limited to, the following: Land Use Element, Conservation and Development of Residential Neighborhoods, Policy 2.1 The City shall preserve, protect, and enhance the City's neighborhoods and strive to preserve and enhance their identity and promote a higher quality of life within each neighborhood. The proposed project will not preserve or enhance the identity of the neighborhoods off of Johnson Avenue, because these neighborhoods predominantly consist of single-family residences on larger lots with adequate setbacks and appropriate scale, as required by the Zoning Code for R-1 and R-2 designations. Land Use Element, Conservation and Development of Residential Neighborhoods, 2.14.E - F Involve residents early in reviewing proposed public and private projects that could have neighborhood impacts, by notifying residents and property owners and holding meetings at convenient times and places within the neighborhoods. Provide appropriate staff support, and train all staff to be sensitive to issues of neighborhood protection and enhancement. The City has taken zero action to involve residents in reviewing the proposed project that is known to be controversial, and widely considered to result in significant impacts to the neighborhoods off of Johnson Avenue. Instead, the County hosted only one community meeting on May 1, 2024. However, to be informed of basic information about the meeting including the location, one was required to "Register" by providing their first and last name and email address on an internet form. At the community meeting, numerous residents raised concerns about the lack of communication regarding the project and lack of opportunities to participate in the process. Furthermore, at the community meeting, project proponents indicated that the Board of Supervisors already had established plans to approve the project at their meeting on May 21, 2024, but never once mentioned that the Planning Commission was scheduled to determine if the project was consistent with the General Plan on May 8, 2024. Two days after the community meeting, and following plentiful local news coverage, the County sent an email only to those who had "registered" for the meeting to provide information about both upcoming meetings. Relative to the Planning Commission, the email emphasized the fact that "the County is able to self -permit the project and the City's Planning Commission has no decision authority regarding the merits of the project." Community Letter to the Planning Commission Regarding GENP-0175-2024 We respectfully disagree with the message this language sends. We very much respect and value the role of the Planning Commission in evaluating consistency with the General Plan, and being tasked with finding that the project "will not harm the general health, safety, and welfare of people living or working in the vicinity." In conclusion, local residents have been given approximately 20 calendar days to attempt to understand the scope of this project and what opportunities, if any, are available for public engagement and participation. Actions that both the City and County have taken relative to this project (seemingly behind closed doors) are directly contributing to widespread distrust of the public process among our community. 3 Land Use Element, Public and Cultural Facilities, Policy 5.1.5 The City shall promote the location of the following uses in a social -services area in the general vicinity of South Higuera Street near Prado Road (Figure 5): County Social and Homeless Services; California Employment Development and Rehabilitation; Federal Social Security Administration. This area should have sufficient space to accommodate regional offices of State and Federal agencies. The proposed location for the County Homeless Services project is not in "the general vicinity of South Higuera Street near Prado Road." in fact, the project is approximately 4 miles away from that general vicinity. In a small town like San Luis Obispo, the "general vicinity" could be reasonably considered as 0.5 - 1 miles. 4. Land Use Element, Public and Cultural Facilities Policy 5.1.7 Dwellings may be provided only as caretaker quarters, as shelters (with discretionary review), or as part of a specially approved mixed -use development. The appropriate residential density would be set considering the maximum residential density allowed in any neighboring land use district. Section 5 of the Land Use Element acknowledges that the City of San Luis Obispo is the "County seat," and contains "several types of facilities to support government... services." As a result, this section of the General Plan was developed to "describe the preferred locations for various types of [government] facilities." Policy 5.1.7 is one of twelve policies in this section that indicates that dwellings and governmental functions are not necessarily compatible land uses. As a result, the policy requires the density of government projects within these areas to be considerate of the maximum residential density allowed in neighboring zones. The proposed project involves a density of 80+ individuals on 1.46 acres (which translates to approximately 55 dwelling units per acre), whereas the neighborhoods off of Johnson Avenue are predominately zoned R-1 and R-2 where the maximum allowable density is 7 - 12 dwelling units per acre. Community Letter to the Planning Commission Regarding GENP-0175-2024 4 5. Circulation Element, Neighborhood Parking Management Policy 14.1.2 The City shall facilitate strategies to protect neighborhoods from spill -over parking from adjacent high intensity uses. The proposed project is located on two existing parking lots at the intersection of Bishop Street and Johnson Avenue, which collectively contain over 100 parking spaces for the County Health Agency facilities. Elimination of these parking lots will result in "spill -over parking" into the adjacent neighborhoods, further exacerbated by the fact that the project will require additional staff for management and operation of the "Welcome Home Village." In addition, the proposed plan appears to erroneously assume the tenants will not have their own vehicles. How will these additional parking needs be met? 6. Circulation Element, Scenic Roadways Policy 15.1.2.A-C and Conservation and Open Space Element, Views Policy 9.2.1.A and D The City will preserve and improve views of important scenic resources from streets and roads. Development along scenic roadways should not block views or detract from the quality of views. Projects, including signs, in the viewshed of a scenic roadway should be considered as "sensitive" and require architectural review [emphasis added]. Development projects should not wall off scenic roadways and block views. As part of the City's environmental review process, blocking of views along scenic roadways should be considered a significant environmental impact. Figure 3 - Scenic Roadways of the Circulation Element of the General Plan indicates that Johnson Avenue between Smith Street and Fixlini Street has "High Scenic Value," and designates that area as a "Scenic Visa." When will this project be presented to the Architectural Review Commission? This matter is not on the agenda for the meeting on May 6, 2024. Will this item be on the agenda for the meeting on May 20, 2024? How is there sufficient time to address the Commission's feedback on the project before it is slated to be rubber-stamped by the Board of Supervisors on May 21, 2024? 7. Housing Element, Housing Conservation Policy 3.6 Preserve the fabric, amenities, yards (i.e. setbacks), and overall character and quality of life of established neighborhoods. The proposed project will not preserve the character and quality of the neighborhoods off of Johnson Avenue, because these neighborhoods predominantly consist of single-family residences on larger lots with adequate setbacks and appropriate scale, as required by the Zoning Code for R-1 and R-2 designations. Community Letter to the Planning Commission Regarding GENP-0175-2024 8. Housing Element, Neighborhood Quality Policy 7.1 Within established neighborhoods, new residential development shall be of a character, size, density, and quality that respects the neighborhood character and maintains the quality of life for existing and future residents. The proposed project is not of a size, density, or quality that respects the neighborhood character and maintains the quality of life for existing and future residents. The proposed project involves a density of 80+ individuals on 1.46 acres (which translates to approximately 55 dwelling units per acre), whereas the neighborhoods off of Johnson Avenue are predominately zoned R-1 and and R-2 where the maximum allowable density is 7 - 12 dwelling units per acre. 9. Housing Element, Neighborhood Quality Policy 7.2 Higher density housing should maintain high quality standards for unit design, privacy, security, on -site amenities, and public and private open space. Such standards should be flexible enough to allow innovative design solutions in special circumstances, e.g. in developing mixed -use developments or in housing in the Downtown Core. There are no attachments available to review for GENP-0175-2024 on the Online Permit Portal. When staff was directly asked for the "application or materials that were provided to the City of San Luis Obispo for the purposes of preparing the General Plan Conformity Determination," they indicated that "no application or materials [were] submitted by the County." Rather, staff stated that their review was based entirely on "collaboration with County staff during discussions of various jurisdictional questions regarding the grant application and project." If no materials were provided, and the Agenda Report does not summarize the collaborative conversations amongst the government agencies, how can the Planning Commission possibly or reasonably confirm that the project will maintain "high quality standards for unit design, privacy, security, on -site amenities, and public and private open space?" Aside from the single nebulous policy that Staff selected to reference, the Agenda Report indicates that a few "Programs" within the Housing Element "further support homeless services and transitional housing opportunities." However, each element of the General Plan, including the Housing Element, begins by defining the distinguishing characteristics between a "Policy" and a "Program." Policies are defined as "specific statements that will guide decision -making. Policies serve as the directives to ... decision makers and others who will initiate or review new development projects." For all policies in the General Plan, "'shall' means the policy is mandatory; "should" or "will" indicate the policy should be followed unless there are compelling or contradictory reasons to do otherwise." • Programs are "actions that help achieve goals." Community Letter to the Planning Commission Regarding GENP-0175-2024 Since the Planning Commission is tasked with determining that the "Welcome Home Village" project the County is proposing in the City conforms to the General Plan for the City, consistency with all General Plan Policies should be the basis for the decision. In making the determination that the "Welcome Home Village" project the County is proposing in the City conforms to the General Plan for the City, the Planning Commission must also find that "use of the subject property will not harm the general health, safety, and welfare of people living or working in the vicinity." The Agenda Report does not provide a rationale for how the Planning Commission could make this required finding. The rationale in "Resolution No. PC-XXXX-24" simply states that the finding is substantiated "because the proposed use of the land is consistent with the General Plan." This circular logic should not be considered as a sufficient explanation. Any land use can, conceivably, be consistent with the General Plan, and still have a negative impact on people living or working in the vicinity. Time and time again, the Planning Commission holds hearings for proposed projects that are technically consistent with the General Plan, but generate substantial controversy due to the potential impacts. The Planning Commission is responsible for preparing a general plan, and making recommendations to the City Council for development that are consistent with that plan and considerate of community input. Making sound recommendations requires taking the time and steps necessary to understand and balance competing interests. So, even though it is certainly possible to approve any imaginable land use in any potential location, the Planning Commission was established for the express purpose of providing an additional level of discretion to matters that are defined by the municipal code as not necessarily straightforward, non -controversial, or widely agreeable. In conclusion, we strongly urge the Planning Commission to either: a. Do not find the proposed use of land consistent with the General Plan based on the overall lack, and gross inadequacy, of the available information, and testimony submitted by the public; or at the very least, Continue the item to a future date, and direct staff to: i. Collect an adequate amount of information about the project; ii. Conduct a comprehensive analysis of consistency with all General Plan Policies such that a defensible decision can be made; and iii. Create additional opportunities for public engagement so that the project can be shaped in such a way that it is considerate of all interests. We recognize that the City has chosen to prioritize efforts to address the ongoing issue of homelessness, and we wholeheartedly support the City in their endeavors accordingly. However, we simply want to ensure that actions taken are done so in a way that is thoughtful, sustainable, and considerate of everyone that is affected. Community Letter to the Planning Commission Regarding GENP-0175-2024 Print Name Address Signature QX DeAW Say, w s O W, o, C - 20(,rD TOhKSD(A Aye �O CA `T 3 vn�+ttlf.L P6i�IZr �---- �' N' Community Letter to the Planning Commission Regarding GENP-0176-2024 Print Name Address Signature �911 lie G-nkc 1-121 44-AUec\ �1 i fit. (All/low 2 r; �s 1 l Community Letter to the Planning Commission Regarding GENP-0175-2024 Thank you in advance for your service to our community, and consideration of our requests. Sincerely, All those undersigned. Print Name Address Signature -Lace nd cTaxe 'i'�'1 r67< j �2 s 5 doe St. iI A+M A i `ion Heh�y �L�4vL c� l 'ZI`3 i 7l ierr� we ! �1 fir— a n S S Almm 2-0 7 5 wr;�- rZ-� cv,I . Z Community Letter to the Planning Commission Regarding GENP-0175-2024 Thank you in advance for your service to our community, and consideration of our requests. Sincerely, All those undersigned. Print Name Address Signature H/FND y 5N1r-rIj 1365 8lsHOP 3T. 4J S ii 64�11c— Community Letter to the Planning Commission Regarding GENP-0175-2024 Thank you in advance for your service to our community, and consideration of our requests. Sincerely, All those undersigned. 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