T.O. General Plan Update: Knowing the Impacts
In a previous article, I described the need for an alternative to the proposed General Plan update, one that is reduced in size and scope. When reviewing the initial three alternative proposals (Alternative 1 served as the starting point for the map ultimately endorsed by the City Council), I characterized them as “three flavors of large” and that the message to the community was: “We must change; It must be this large; Pick your flavor of large.”
In the historically slow growth community of Thousand Oaks, a more prudent approach can be pursued to accommodate change, yet align with what has made our city a great one in which to live, play, work, and raise families.
In this article, I’ll focus on the need to understand the real impacts of the proposed changes to our General Plan. With the City’s environmental review of the General Plan update, now is the time for public discussion. Below is the second in a three-part series, where the articles include:
A Reduced Scope Alternative – A More Prudent and Measured Approach
Sufficient Impact Analysis and Disclosure to the Public [this article]
Voter Approval Requirements of Amendments to the Land Use Element
As I mentioned previously, I’ve provided specific and more technical comments, highlighting what I believe should be reviewed in preparing the Environmental Impact Report; my memo to the City can be found here.
Sufficient Impact Analysis and Disclosure to the Public
To date, the evolving nature of the recommended changes to the General Plan Land Use Element map (“LU Map”) makes it difficult for the public to understand the impacts of the proposed changes, whether cumulatively, in important areas such as noise, water, traffic, and burdens on infrastructure, or specifically, such as in existing neighborhoods.
One reason is that the maps presented to the Planning Commission, City Council, and the public in May 2021 weren’t complete; they didn’t display the full array of proposed land use designations. Residential designations such as Neighborhood Low 1 & 2, having maximum residential densities of 4.5 and 6.0 dwelling units per acre, respectively, [1] weren’t applied on the map reviewed by these city committees at the time; only a draft map with coarser designations such as Neighborhood Low (with a 6 du/ac maximum) was available to the public. [2] The final draft map attached to the Notice of Preparation (“NOP Map”) is a revised version of the one reviewed and endorsed by the City in May 2021; it includes modifications directed by the Council, but also other various residential density changes to existing neighborhoods. The final draft map only became available in December 2021.
The challenge for the public: it’s difficult to provide informed comments to city decision makers if the specific changes being considered keep evolving.
Though final numbers have not yet been presented, using the estimates provided in the May 18, 2021, staff report [1] and accounting for subsequent direction provided by Council (e.g., reducing Mixed-Use Medium to Mixed-Use Low), [3] it is estimated that the additional residential capacity resulting from the NOP Map would be between 12,000-20,000 residential units within the areas identified as “Areas of Change.” As noted in a previous article, these changes alone result in a significant increase in residential buildout projections.
However, additional residential areas outside the “Areas of Change” (labeled as “Areas of Stability”) will also be changed, and no analysis has been presented to date as to these impacts. This “stability” labelling and lack of public review prior to Council endorsement presents the impression that there will be no changes of significance. As noted in the staff report: [4]
“As part of the redistribution of residential units to the areas of change, the areas of stability will be assigned land use designations that reflect the densities on the ground for those established neighborhoods. Subcategories for the Neighborhood Low through Neighborhood Medium categories will be calibrated to reflect the existing density for tracts of land that are occupied by subdivisions and condominiums that have limited to no potential for further development. The purpose behind this concept is to allow unused residential capacity under Measure E to be allocated to the proposed areas of change and preserve the character of existing neighborhoods.”
The description above implies that any changes within the “Areas of Stability” would be to match existing conditions and thereby reduce the maximum residential densities in these neighborhoods, “allow[ing] unused residential capacity under Measure E to be allocated to the proposed areas of change…”
However, a detailed comparison of the NOP Map and the current General Plan LU Map [5] shows otherwise.
The NOP Map affects nearly every property in the City, [6] both in the “Areas of Change” and the “Areas of Stability,” and it’s expected that there are neighborhoods where the maximum density is reduced to make the proposed reallocation possible.
However, many other neighborhoods will unexpectedly have their residential densities increase under the NOP Map; while the intent of the proposed designations in the NOP Map is to “maintain the character of existing residential neighborhoods,” [7] numerous residential neighborhoods will see an increase in maximum allowable residential density, many by 33% (e.g., from Low Density Residential (max 4.5 du/ac) to Neighborhood Low 2 (max 6 du/ac)).
In comparing the NOP Map with the current land use designations, examples of residential neighborhoods that are recommended to have an increase in allowable residential density, include, but are not limited to:
Treasures and others in Dos Vientos
Most of Newbury Park south of Borchard Road
Westlake Hills
Some neighborhoods near Westlake Lake
Central Thousand Oaks bordered by Avenida de las Arboles and Avenida de las Flores
Given the state of analysis to date, key questions arise:
How do the citywide density reallocation numbers work out if, within the “Areas of Stability,” there are many acres adding 1.5 du/ac in residential density?
Do the residents in these neighborhoods know that the densities will increase under the proposed General Plan?
One of the reasons why this is important for those residing in existing neighborhoods is the City’s interpretations of recently approved state law. In correspondence I had with the City’s Planning Department in 2021, the City mentioned that “attorneys and staff from the State Department of Housing and Community Development (HCD) have been unanimous in their view that the intent of the legislation is that the highest density designated on a property is what’s applicable, whether specified in the General Plan or zoning.” [8] [emphasis added]
This interpretation indicates that increasing the General Plan designations of certain existing neighborhoods could create unexpected and undesirable situations. New projects, which currently could be denied as being too dense for an existing neighborhood, could not be denied if the Council approved higher densities for that neighborhood.
The key question here is: why would the Council endorse a plan to increase densities throughout existing neighborhoods?
The effects of changing the General Plan Land Use Map are more widespread than has been indicated to date; they are not limited to the “Areas of Change” but instead are applied throughout the city. A detailed analysis of the citywide impacts of land use designation changes should be conducted as part of the environmental review; it cannot be assumed that the effects of these changes can be limited to analysis only to within certain areas designated “Areas of Change.”
For reference to conduct your own comparisons:
A high resolution map of the one attached to the Notice of Preparation can be found here.
A version of the current General Plan Land Use map (current through April 24, 2018) [5] can be found here.
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[1] Memo to City Council from Kelvin Parker, Community Development Director, “Subject: General Plan Update – Consideration of Draft Preferred Land Use Map (GPA 2019-70760) LOCATION: Citywide,” May 18, 2021, Attachment #8.
[2] Memo to City Council from Kelvin Parker, Attachments #6 and #7.
[3] Minutes of the Thousand Oaks City Council, May 25, 2021.
[4] Memo to City Council from Kelvin Parker, p 13.
[5] Retrieved from the City’s website, updated through April 24, 2018, via approval of Resolution 2018-017
[6] With the exception of most (though not all) lands currently designated “parks, golf courses, open space.”
[7] Memo to City Council from Kelvin Parker, p 3.
[8] Email from Michael Forbes, Deputy Community Development Director, to Mic Farris, “Subject: Re: Thousand Oaks General Plan Advisory Committee - Meeting on April 21st,” April 21, 2021.
