CPA Asks SBCAG to Justify High South Coast Housing Numbers in Face of High Fire Zoning

July 9, 2021

To: Santa Barbara County Association of Governments (SBCAG)

RE: July 15, 2021 Regional Housing Needs Allocation [RHNA] Public Hearing and Adoption

Dear Chair Sierra and Honorable SBCAG Board of Directors:

Citizens Planning Association (CPA) understands and is sympathetic to the goals of RHNA/Housing Element to increase the supply of housing in proximity to jobs. However, we are alarmed at the numbers allocated to the South Coast, as well as the disproportionate allocation among South Coast jurisdictions.

For examples, the increase in jobs in the City of Goleta did not increase proportionately the proposed RHNA allocation there, but it disproportionately impacts the unincorporated Eastern Goleta Valley and other unincorporated South Coast areas where jobs have NOT increased. In addition, policies dedicated to preservation of agricultural land in the unincorporated area are a longstanding goal of LAFCO, as well as most General and community plans, and these policies would appear to be threatened by the allocations.

Also: what appears to be an increasing demand for housing for UCSB students and staff must be a priority of the University itself, through local jurisdictions’ insistence on adherence to UC’s Long Range Development Plan.

CPA has commented on or been involved in the development of community plans and related policies within the County of Santa Barbara for decades. We are concerned that longstanding plans and policies, whether on the Gaviota Coast, Toro Canyon, Montecito or Eastern Goleta Valley (EGV), could be radically undone in a manner that does not truly result in housing that will be affordable and accessible to the people who need it.

In April of this year, CPA invited County P&D Deputy Director Dan Klemann and City of SB Principal Planner Dan Gullett to speak to our members and others interested regarding the proposed RHNA numbers. Despite the many committee meetings cited in your staff report, most members of the public were largely unaware of the numbers being recommended. It does not appear that any meetings, even virtual meetings, were held within the communities being targeted with the disproportionately high numbers. Many members, including those of us who are more engaged than the average person on planning issues, were surprised to learn of the disproportionately high and almost unfathomable numbers proposed for the South Coast.

Mr. Gullett represented that the high number of units allocated to the City of Santa Barbara would likely be achieved via new building standards, ADUs, and incentives for affordable housing.

Comments by Mr. Klemann raised concerns in response to questions about where the 4142 units allocated to the unincorporated South Coast might be placed. Mr. Klemann indicated that County staff, in preparing the housing element, was likely to recommend using urban agriculture in the EGV to achieve much of the number.

He added that conversations were already underway with property owners in the Patterson Ag Block (an area of prime soils) who wished to convert their Ag operations to housing. He added that Urban Ag in the unincorporated Carpinteria area would likely remain Ag because the landowners there are making sufficient profits from cannabis sales and are investing in “new greenhouses”. Mr. Klemann also mentioned plans to increase the number of units on some of the housing opportunity sites identified in the EGV plan adopted in 2015 [MTD and Tatum].

CPA is very concerned that major planning decisions or desires seem to have influenced the allocation of RHNA numbers based on private meetings with developers/land-owners focused on their profit margin, without benefit of public scrutiny and transparency. The RHNA and Housing Element processes must not be used as a pretext, or shield for developers wishing to circumvent existing policies, or for staff to avoid the need to engage the community on Community Plan issues.

The draft allocation calls for almost 2,500 units of moderate/above moderate housing in the unincorporated south coast alone. It is difficult to fathom where those high cost units—likely in the Coastal zone, whether the Gaviota Coast, EGV, or Montecito— might be placed other than with a complete disregard for the Community Plan and Ag conversion policies. Despite these concerns, SB County Planning leadership submitted its own letter to the SBCAG Board in December, enthusiastically supporting the allocations, with no mention of potential implications for long range planning

We ask that you take these concerns and implications into consideration going forward. If there are to be no more SBCAG hearings on this issue, then we assume the venue for discussions would be at the individual jurisdiction level. We urge the elected representatives in those jurisdictions most heavily impacted to take these concerns seriously and to direct staff to begin to engage the communities likely to be most impacted by these numbers.

Marell Brooks


Citizens Planning Association

916 Anacapa Street

Santa Barbara, CA 93101

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