Housing Element

CPA has advocated for transparent community planning since its founding in 1960. CPA has followed the HEU process. Since early 2001, CPA has expressed concern to various county officials about the absence of transparency or community engagement, starting with the proposed disproportionate allocation of housing units being recommended by staff to SBCAG. While we greatly appreciate the efforts of local reporters to raise awareness about the flaws and consequences of the County’s failure to Citizens Planning Association would like to point out a couple of facts that are missing.

While the state of California issues the overall number of units and approved the methodology, it is local government officials, including all five County supervisors and mayors from each City, who ultimately vote on the regional distribution. Remarkably, SBCAG and all members, except Mayor Clark from Carpinteria, voted to support the lopsided allocation of 73% of the units to the South Coast.

In our July 2021 letter to SBCAG, we pointed out:“It is difficult to fathom where those high cost units, likely in the Coastal zone, whether on the Gaviota Coast, in Eastern Goleta Valley or in Montecito, might be placed other than with a complete disregard for the Community Plan and the Agriculture Conversion policies.” Alas, that has proven to be the case.

CPA has also expressed repeated concerns, by letter and in person at our monthly zoom meetings where elected and appointed officials were invited to explain the HEU process. We urged them at these sessions to be more transparent and not formulate these plans seemingly behind closed doors.

CPA and the public are baffled that the County staff spent over a year with consultants and property owners deciding which parcels to recommend for extremely high density increases, with no input from the public along the way and then wait until mid-November to release the map of proposed rezones. How and when was the decision made and approved to rely on rezones alone? Why choose to prepare a Programmatic EIR for these potentially huge projects? Such decisions are usually vetted in public?

Staff holding private meetings with developers and property owners about decisions that impact the entire community is the antithesis of the purpose of CEQA and thoughtful land use planning. Such closed door decision making flies in the face of the tradition of transparency that characterized decades of the County Long Range planning projects. CPA raised this concern at a Board of Supervisors meeting in early December, and requested all records of private meetings and communications about the Housing Element between County officials and developers/property owners. We have received some troubling public records in response, that have only heightened our concerns. Further, the BOS met TWICE in Closed Session in December regarding the Housing Element, only posting “significant exposure to civil litigation” as the explanation- even though the source of that threat was not identified. It is our understanding that the “Builder’s remedy” threat is actually the result of legislation- not litigation.

To propose complete evisceration of years of community planning and protection of agriculture on the South Coast has predicably resulted in an outcry from the impacted communities. Now the public is being told that not meeting the February deadline means the State will give developers ‘by right’ ability to develop anywhere without environmental review. Surely, the Planning Director and the Board of Supervisors had to be aware of the timeline and the consequences of not meeting that timeline.

Community plans and ag protection policies in the unincorporated Eastern Goleta Valley and Carpinteria/Toro Canyon areas were achieved through careful and lengthy community plan processes, including Coastal Commission review. These two communities will be most impacted by the suggested rezones. Why is there no consideration for the number of ADUs, second units and commercial property rezones included? Why is there NO consideration of upzoning or mixed use zoning in the unincorporated areas of Montecito or Summerland?

These and other questions must be addressed publicly by the BOS as soon as possible. CPA has requested a public hearing at the BOS to get answers to our many questions and to understand why the deadline will not be met. CPA also requests that a record of all private meetings regarding specific rezones be provided.

CPA has included links below to the three letters we sent to request transparency during the Housing Element update process.

Marell Brooks
President, Citizens Planning Association

====== Related Letters ======

  1. On September 8, 2022 CPA submitted a comment letter to County Planning during the scoping phase of the HEU.
    https://www.citizensplanning.org/county-housing-element-update
  1. On May 13, 2022 Letter to BOS and CEO Miyasato re: lack of transparency and community engagement in the Housing Element Process:
    https://www.citizensplanning.org/cpa-promotes-transparency-and-community-involvement
  1. On July 9, 2021 CPA sent a letter to SBCAG, in advance of their final vote on allocation of housing units.  We raised several concerns about the process and staff recommendations for disproportionate allocation of the state mandates.
    https://www.citizensplanning.org/cpa-asks-sbcag-to-justify-high-south-coast-housing-numbers-in-face-of-high-fire-zoning/