The new Mid-City Rapid Bus on El Cajon Boulevard presents a golden opportunity to invite transit oriented development (TOD) into the heart of San Diego. One way to issue this invitation is through a corridor plan between Park Boulevard and College Avenue. The purpose of the corridor plan would be to orchestrate public and private investment in a way that creates greater value than could be accomplished by individual development projects under the current development review process.
Efforts to revitalize the El Cajon Boulevard corridor are not new. The envisioned corridor plan passes through three former redevelopment areas: North Park, City Heights, and Crossroads (College Area). With the dissolution of the redevelopment agencies, revitalization efforts must rely on both traditional and emerging planning tools applied in more creative ways.
As envisioned, the El Cajon Boulevard Corridor Plan would be fully compatible with the San Diego City of Villages General Plan, Draft North Park Community Plan and Mid-City Community Plan. No radical departure from the current allowable height or density would be anticipated. The plan would be crafted to accommodate and support the goals of the two existing business improvement districts.
The Corridor Plan would also serve as a regulatory document, creating a streamlined pathway to development approvals not currently possible under the City’s current land development code (Mid-City Planned District). A key goal of the plan would be to reduce permit processing times and bring certainty to the development review process.
The following are some recommended components of the Corridor Plan as envisioned.
Complete Streets Throughout
The central focus of the Plan would be the public right-of-way with major emphasis on accommodating all users of the street, enhancing the public realm, creating value for the community, and inducing the type of development desired. From building façade to building façade, El Cajon Boulevard would be transformed into one of the most complete streets in the region.
Following extensive public outreach to ascertain community values and preferences, sidewalks would be widened and redesigned with attractive materials, landscaping, lighting and benches. Opportunities for lane narrowing, mid-block crossings, dedicated bicycle lanes, cycle tracks and sharrows would be identified and implemented. Dedicated transit lanes would be added. Where desired, main street treatments such as diagonal parking or convertible plazas and sidewalk pavers could be introduced at one or more locations within the corridor.
To demonstrate the City’s commitment to Mid-City revitalization, right-of-way improvements should be installed as soon as possible. If thoughtfully implemented, the visible transformation of the public realm will become a major catalyst for TOD development not to mention a smart investment for the City.
A Transit System as Originally Envisioned
The new Mid-City Rapid Bus line is an indispensable component of the Corridor Plan’s street-centric vision. While scaled back from the original concept, the transit line still has the potential to initiate a virtuous cycle in attracting TOD development. Residents moving into the corridor will provide additional support for the line eventually demanding a full functioning BRT. In anticipation, the Corridor Plan would contain a mid-term goal to upgrade the rapid bus to a BRT as originally envisioned with pre-paid fares, multiple door boarding and dedicated bus lanes. A long term goal would be for the construction of a BRT (or rail) subway system beneath El Cajon Boulevard connecting Mid-City with Downtown and other locations.
Upgraded Infrastructure to Support Projected Development
Needed upgrades to water, sewer, stormwater and other utilities would be identified in the Corridor Plan and installed in concert with the street improvements. To compensate for the loss of traditional tax increment financing, the infrastructure funding plan would explore other financing tools such as Community Financing Districts (CFDs) and new financing mechanisms such as Enhanced Infrastructure Financing Districts (EIFDs). Tax increment financing may still play a role if available, but the Plan need not depend on it. From 2002 to 2015, the City of Seattle undertook a highly successful revitalization effort powered by strategic infrastructure upgrades and private investments. No tax increment financing was used.
An important objective of the Corridor Plan would be to identify the full set of mitigations for all future development anticipated within the plan area. Developers would know exactly what they will pay in infrastructure impact fees and no further mitigations or exactions would be required at the time a project is reviewed. The developer contribution would be supplemented by general infrastructure funds, state and federal grants and other available funding sources. SANDAG Smart Growth Incentive Grants could be used to pay for the some of the planning costs.
As new development takes place, the City can expect to realize significant increases in sales tax and property tax revenue. While it may be a challenge to actually prime the planning area with infrastructure—the ability to sell bonds, compete for federal and state grants and attract private investment would only be enhanced by a visionary plan designed to facilitate the transformation of El Cajon Boulevard corridor.
A Context-Oriented By-Right Development Code
A form-based code, hybrid code, or other context-oriented code would be used to implement the development standards. The code would determine the allowable building types, placement of buildings, maximum number of stories and permitted uses. The regulations would be simple, easy to use and would give the Planning Director authority to resolve design issues and approve minor deviations minsterially. Mixed-use would be encouraged but excess commercial areas may be pruned back where appropriate. No density limit or Floor Area Ratio (FAR) would be imposed as the allowable building types and story limits would constrain the density to a predictable range.
A major advantage of a form-based code, if kept simple and implemented in accordance with the Plan’s intent, is that it adds certainty to the development process without compromising design integrity. Development that meets the code is approved by-right avoiding the need for conditional use permits, site development permits and other discretionary approvals that trigger environmental review.
A Reasonable Affordable Housing Requirement
California State housing law requires all cities in the state to provide a fair share of housing opportunities affordable to persons and families of low and moderate income. The fair share is determined by a process initiated by the State Office of Housing and Community Development (HCD) resulting in what is referred to as the Regional Housing Needs Assessment (RHNA). The process culminates with each city and county being assigned a number of low and moderate housing units for which adequate sites and zoning must be documented in the City’s Housing Element. With the passage of SB 375 and the emphasis on promoting infill development within transit priority areas, the identification of suitable sites to fulfill the City’s RHNA requirement has become increasingly challenging. Further, the actual production of affordable housing on the identified sites nearly always falls short of the potential.
A corridor plan for El Cajon Boulevard could provide a way to address both the problem of adequate site identification to meet RHNA requirements and the actual production of affordable housing. As envisioned, the plan would require at least 10% of the new units constructed in each project to be deed restricted for affordable housing. The affordable units would be required to be integrated into the project and no in lieu fee option would be available through the plan regulations directly.
At the same time, the Corridor Plan would be exempted from the City’s Inclusionary Affordable Housing Regulations which require a higher percentage of affordable housing or the payment of in-lieu fees. To ensure compliance with recent court decisions regarding inclusionary ordinances, the existing development code would remain in place as a parallel code. Developers would have the option of building to the existing development code rather than the form-based code. Under this option, the City’s Affordable Housing Regulations would apply making available the in-lieu fee option. But the developer would also forgo the unrestricted density provided by the form-based code and may need to secure discretionary permits subject to CEQA review.
A requirement to provide the affordable units on site would have several benefits. First, it would ensure that the affordable units are built in the neighborhood undergoing gentrification. Building the units on site would be a direct mitigation for local increases in the cost of housing caused by the development. Second, the process of building the affordable units would be more efficient than with in-lieu fees. The units would be built sooner (concurrent with the development) most likely at a lower per square foot cost than a 100% affordable housing project built in the same community. Provisions in the code would reduce interior finishing standards for the affordable units. Finally, the City could document the production of affordable housing units on underutilized sites within the corridor providing more reliable projections for future Housing Element updates.
One possible barrier is that financial institutions may be reluctant to finance mixed-income projects. But the unrestricted density should ease these concerns. The Corridor Plan itself will be a key to getting the financial industry to adjust their development financing models.
On-site affordable housing has proven to be viable in other California cities. The Beach and Edinger Corridors Plan in Huntington Beach, CA, for example, has a form-based code with a 10% onsite affordable housing requirement. Not only are developers including the affordable housing in their projects, the production of new multi-family residential development has progressed more rapidly than anticipated. Recently, in response to concerns of area residents, the Huntington Beach City Council directed staff to study possible amendments to the plan including lowering the overall density. While a density roll-back would not be the hoped for outcome within the El Cajon Boulevard corridor, the experience of Huntington Beach clearly demonstrates that a 10% on-site affordable housing requirement need not be an impediment to the production of new multi-family development.
CEQA and the Presumption of Less Than Significant Transportation Impact Based on Location (PLTSIL)
The Corridor Plan as envisioned would be designed to incorporate all anticipated mitigations needed to protect the physical environment and adequately address public health, safety and general welfare issues. The Plan could be approved under a Program EIR or, if adopted as a Specific Plan, potentially determined to be exempt from environmental review under the streamlining provisions of SB 743.
The exemption approach is supported by a major shift in how transportation is perceived to impact the environment. Within fully urbanized transit priority areas traffic congestion is still the number one CEQA issue. But following the adoption of SB 743, OPR is now defining traffic congestion as a “social” impact—rather than a “physical” impact to the environment. Further, OPR is recommending the replacement of Level of Service (LOS) traffic analysis with Vehicle Miles Travelled (VMT) analysis.
With LOS out of the way, the next logical step may be a “presumption of less than significant transportation impacts based on location” (PLTSIL). PLTSIL was briefly considered by OPR as a replacement for LOS analysis under the new CEQA guidelines. The underlying assumption (rooted in SB 375) is that when it comes to Greenhouse Gas (GHG) reduction, no single component of a project is as important as location. If a project is already located in a transit priority area, further mitigations to reduce GHG are relatively superfluous. The PLTSIL argument acknowledges CEQA’s ineffectiveness as a means of promoting infill development in transit priority areas. CEQA’s best contribution would be to identify a “project alternative” for relocating the project. But moving a project to a more sustainable location is rarely considered a feasible option. The only effective way to encourage infill development in the transit priority areas is through real planning coupled with meaningful incentives.
VMT analysis is certainly the preferred metric to evaluate transportation impacts at the plan level. Once the mitigations are identified however, further VMT mitigations should not be applied at the project level. Doing so would add time and uncertainty to the permit review process—a disincentive to infill development. According to the PLTSIL argument, the value added in terms of reducing GHG emissions would be minimal compared to the greater GHG reduction achievable by encouraging new development to locate within transit priority areas.
Prioritizing the Greater Public Interest
For many planners, no other public policy has quite captured our aspirations to promote sustainable and livable communities than has SB 375. While controversy over global warming and debate over its causes persists, the California legislature has acknowledged that global warming is a fact. Steps to reduce GHG emissions must be implemented now. Right or wrong, the scenarios for a warming planet as depicted by scientists are almost too dismal to contemplate. Even if global warming were ultimately to be discredited, the planned promotion of compact development is clearly in the greater public interest.
The El Cajon Boulevard Corridor Plan would be designed to promote compact TOD development in one of the most promising transit corridors in the City. Inviting new TOD development into the El Cajon Boulevard corridor represents the next logical step in regional efforts to reshape the density footprint of the City and lower overall carbon emissions.
We already know what to do. Downtown is the poster child for infill development and a proven planning and regulatory model for other high quality transit priority areas within the City of San Diego. What we need now is another bold move to invite transit oriented development into the heart of Mid-City. A corridor plan along El Cajon Boulevard would be a very smart way to do that.
Greg Konar is a principal planner for Atkins North America. He is also the chair of the San Diego Complete Streets Task Force and the immediate Past Section Director for APA San Diego. The views expressed in this article are the author’s alone and have not been reviewed or endorsed by APA San Diego.