County Housing Element Update

TO: Jessica Steele/Staff

RE: County Housing Element Update

Scoping Comments

Dear Staff: CPA has written several letters to County Planning and BOS over the past year urging public information and outreach by County Planning, as the plan to site over 5000 units in the unincorporated County, over 4000 in South County alone, was underway with what we perceive as little to no public engagement. Individuals familiar with the HEU process in the past shared with us that the County would not be preparing the HEU in the usual way but would instead pursue a “programmatic EIR” [PEIR] for the entire County. The Notice of Preparation [NOP] of the PEIR was posted in the News-Press in late July. None of us who were on the mailing list for the HEU were notified. When we went to the website, none of the documents were there.

After CPA pointed out that the Notice of Preparation document had NOT been posted, P&D agreed to re-post the document and delay the scoping meeting, which several of our members attended.

These are our comments:


  1. CPA would like to reiterate our concern with the overall process and form of the HEU update. The public, including CPA, has not been provided with the actual PROJECT that will be studied. We read a statement: 5,664 units of housing will be built (according to SBCAG based on State RHNA) This massive amount of development would have tremendous impact upon the unincorporated area, with disproportionate impact on the South Coast which is expected to absorb 73%.or 4,142 units of housing. Yet we are not told the specifics about how staff intends to site those units.
  1. The absence of site-specific information, which, we have been told, staff possesses and a consultant has been working on, renders this process an exercise akin to finding one’s way in the dark. CPA members have heard about a “site map”, yet staff indicated during the scoping meeting that it would not be released until AFTER the deadline for scoping comments. That does not make sense.
  1. Pg 1 of the Scoping document includes a statement that

“This environmental scoping document provides a preliminary review of the potential environmental impacts associated with the proposed HEU””

However, that makes no sense and is not accurate because the scoping document does NOT contain a program description of the proposed HEU. It contains generalized statements about potential impacts to the various categories typically studied in an EIR. The scoping document makes repeated references to the “EIR”; however staff seem to already to have made up their minds and embarked on a PEIR.

For the above reasons, we believe a Programmatic EIR ( PEIR) is NOT the appropriate environmental document upon which an adequate study can be based. The public is entitled to see the siting map and to comment specifically on what should be studied at the various sites. It appears clear that the County long ago made a decision to pick the properties to be rezoned to meet the staggering number, supporting the disproportionate allocations during the SBCAG/RHNA process, and then solicited input from developers and property owners, all outside of the view of the public. This seems contrary to the CEQA Guideline Section 15151 cited on Pg 6 of the scoping document, ““…[a]n EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences”. . However, that is not possible if a determination has been made in advance to prepare only a programmatic EIR, and not do site specific review.

  1. All of the topics identified in the Scoping Document are of tremendous concern to CPA. We are particularly concerned about the following:
    • Agriculture– potential for conversion of agricultural lands; certain community plans, including the EGV plan, contain specific processes and thresholds to be met before conversion of ag lands is undertaken, including a determination of community benefit [as with any rezone]. Please study the different impacts Ag conversion would have upon the different community plan areas. We also suggest LAFCO participation as their primary job is to support the preservation of Ag land in our County.
    • Air quality/GHG Emission: Please study the impacts of increasingly placing dense housing next to freeways. If claims are made that GHG will be lessened by adding over 4000 to the South Coast, please cite specifics about how that projection is made. Do not lose sight of environmental justice issues as this process continues.
    • Biological Resources: Please be specific about the location of potential impacts to ESH in all forms, and all community plan areas [and NON-community plan areas]
    • Energy: Please identify the sources of fulfilling the increased energy demands that would result from adding these units to the various geographic areas.
    • Hydrology: Similar to above, please cite the sources of groundwater supply that would be utilized.
    • Land Use: Please review policy consistency in each specific region of the county to be impacted, and explain how to reconcile the project with other elements (e.g. open space, agriculture, etc)
    • Public Services: Please discuss the source of funding for the increased public services demand that would result from the project, including schools, libraries, parks, fire and police protection. In particular, when subsidized/affordable housing is built, and does not produce property taxes or school/special district fees, how will those gaps in funding be filled.
    • Transportation: increased traffic, bicycle/pedestrian/vehicle conflicts, and congested roads are already a feature in much of the south coast. What strategies would be implemented to mitigate the inevitable impacts of adding more housing/people to these areas? PG 10 of the scoping document contains a statement that “new housing on the south coast offers the potential to partially address long distance commuting from Ventura and north county with some possible benefits to VMT reduction”. (As a Lompoc area resident, I continue to see hundreds of cars carrying commuters down Hwy 1 as there are still few good paying jobs in the Lompoc Valley). Please provide the source of such data and how that would be quantified. CPA questions staff’s assertion that the people who now carpool from Ventura or North County would be the ones able to move into these housing units. This conclusion or rationalization goes against the experience of the city of Santa Barbara‘s AUD program which added multiple units only to find the cost of both rental and purchase housing escalated. What steps will be taken to limit the astronomical purchase or rental prices so these current commuters will be able to afford these new housing units?
    • Utilities and Water Supply: There are several aquifers in the North County especially that are in over draft now. The Governor’s office recently made the statement that we will lose 10% of our current water sources before 2035 due to climate change. In regards to utilities, as I type this letter, the State is under warning of rolling blackouts during this prolonged heat wave. All these climate change factors must be considered.
    • Wildfire: The scoping document states “The proposed HEU could introduce housing in vulnerable areas such as the WUI and increase housing densities in some places that could create new vulnerable populations. The proposed HEU would increase residential uses that may require defensible space and other fire resiliency techniques

Given the history of devastating wildfires in the County, please explain a decision to add structures and people to these areas that already experience evacuation challenges. Where and what criteria would staff use to make such a decision?

  • Hazards and hazardous materials: SB County residents have been very vocal in their concern about drilling and oil transportation, especially in the No. County. Most new housing should be in-fill or in commercial zoning where transportation of fuel and other dangerous materials will not jeopardize the safety of our residents. (Example being considered right now of trucking from Sentinel through unincorporated neighborhoods north of the city of Lompoc)
  • Cumulative impacts: An EIR for the entire County should highlight cumulative negative impacts. Jumping to a PEIR will not allow a closer public analysis of community impacts, removing public input when projects are brought forward by developers. This puts the public at a disadvantage in the planning process which undermines decades of policies based on strong public participation.
  • Aesthetics and Visual Resources: Each of the local community plans contain listings and policies regarding visual resources highly valued by the individual community’s residents. These policies must be considered in environmental review.

Alternatives: Alternatives must be studied and must include discussion/consideration of possibly balancing the allocation of 73% of the units assigned to the unincorporated area to the South Coast, with more equitable redistribution of at least a portion of that within the entire unincorporated county. The County should also look at what strategies other jurisdictions throughout the State are developing in face of these state mandates which seem to disregard the fact that market forces will prevent the creation of adequate affordable housing in coastal communities up and down the State.

Other Issues:

Short term rentals and “homestays” and second or third homes take up a significant amount of housing stock already. Please describe programs and tools by which the County can better enforce the existing STR ordinance, and consider amending the ordinance to further restrict these vacation homes, especially before new housing units are allocated.

During the last public session, it was mentioned that during the past 8 years under the existing HE, many approved housing project sites were never built. We urge staff to look at what was built in that time period and what was not built. (An example from the City of Lompoc: they still have approx. 800 approved units that have not been built to include the Burton Ranch development of over 400 units.) Most developers don’t want to build what could be affordable housing as it is not in their best financial interest. How will the County change this scenario?

Thank you for the opportunity to comment on the scope of the EIR. CPA appreciates the work of staff in this process but we urge staff to follow a process that strongly considers public input. Lastly, we read the notice in the Santa Maria Times on September 7th asking for public comment on the scope of an EIR, not a PEIR. Nowhere in this notice is a PEIR mentioned. This almost seems disingenuous. We suggest no PEIR be considered until after the project map is published, shared with the public, and discussed in public hearings.

Respectfully submitted,

Marell Brooks, President, Citizens Planning Association