The South Morro Hills Community Plan IS SIMPLY NRF(north River farms) ON STEROIDS!

Oceanside Housing Element (HE) Revision for 2021-2029

The City of Oceanside prepares a HE every 5 years and must demonstrate how Oceanside will meet its housing requirements including supply and affordability for all economic and special needs segments of the community. The HE must be consistent with other General Plan elements including the Draft South Morro Hills Community Plan (SMHCP), the Energy and Climate Action Elements and any environmental/conservation elements etc.

· No more housing is needed in the So Morro Hills (SMH) agricultural area in order to achieve the required number of housing units and no more is desired by the public. Over 80% of residents rejected increased development in that area in order to meet the goal of preserving agriculture. The City should instead focus on building in transit opportunity corridors. Sprawl is to be avoided.

· The HE states “as (new general plan) elements are updated, the city will evaluate the HE to ensure consistency.” The SMHCP already is in conflict with this draft HE- that conflict should be addressed now. The upzoning (increasing density above what is currently allowed) in the SMHCP leads to increased housing that is not consistent with this draft HE and will lead to loss of agricultural land even though this is what is supposed to be preserved. The SMHCP supports increased housing in SMH. SMH is not in a transit-focused, resource-rich corridor. SMH is not included in the Appendix of potential development sites.

· The SMHCP is not consistent with HE and should not be designed in a way that requires changing this HE once it is adopted. That would not be a transparent process and likely would require a resubmittal to the State and further public review placing the City in jeopardy of non-compliance with State Law for an approved HE. And it’s just wrong. Changing the HE ‘after the fact’ would make it inconsistent with the Smart & Sustainable Corridors Specific Plan, the ECAP, Sub Area Plan/environmental policies etc.

· Allowing further development in So Morro Hills has high potential to disincentivize building on transit rich corridors as the ag land is potentially cheaper to develop through lot splits and upzoning.

· Sites with constraints were excluded from the HE. For example: The HE requires water hook-up priority for development to meet the housing goals. This would be impossible in SMH as there is not adequate infrastructure in place. The estimated costs would be prohibitive and the general populous should not be expected to pay to remove this obvious constraint. Further development in the agricultural area is constrained for these goals as well: to be pedestrian friendly, ADA compliant, and to preserve agriculture and open space. Recommendation: Do not place affordable housing units (except farmworker housing) in SMH due to a lack of services/resources and infrastructure capacity. The HE should both incentivize housing/especially affordable housing development where it is consistent with the rest of the GP, and disincentivize it where it is not consistent i.e. SMH.

· The HE recognizes the Agritourism plan as a method to preserve agriculture. Further development could endanger that plan with lawsuits/claims of nuisance, noise, odors etc. from farming operations. A Right to Farm Ordinance would not necessarily protect farming.

· SMH is the last remaining agricultural area in San Diego County with soils and microclimate not found anywhere else in CA.

Gold/Orange Locations represent where houses would be built.

Save Oceanside Farmland- So Morro Hills Community Plan (SMHCP)

Can We Save Our Farmland – So. Morro Hills Community Plan

The city of Oceanside is in the process of updating its General Plan, and preparing a community plan for the South Morro Hills agricultural area- the South Morro Hills Community Plan (SMHCP). While it says its primary goal is to preserve agricultural land, it allows thousands of housing units. That is not farmland preservation, it is more sprawl development that we all pay for. We pay for it with more traffic congestion, air pollution, and higher costs for public infrastructure of roads, and water and sewers.

Where is it?

These 3,400 acres of land zoned for agriculture are in the far northeastern portion of Oceanside- north of the San Luis Rey River. It is noted for the outline of the hills referred to as the sleeping Indian. Hills that once were home to Luisenos and remain part of the heritage of generations who have walked on, hunted, fished and farmed this land.

What is allowed today?

The current agricultural zoning limits subdividing of the land as a way to retain the land use for farming. Lots are required to be at least 2 and ½ acres – what is considered rural estate homes. While this zoning has been in place for decades, few properties have been developed that way. Most remain as actual farms- from small special purpose crops to large farms of hundreds of acres. Because it was planned for farming, none of the infrastructure that supports development is in place. There are mostly two lane unimproved dirt roads. Wells provide most of the water. Septic systems are used as there is no municipal sewer system, except along North River Rd.

If we do nothing- won’t there just be a “checkerboard’ of these small estate properties?

There is little demand for that type of housing, which is why few of the parcels have developed that way. Without public infrastructure there are huge challenges to access water. The county and city have very strict guidelines on new septic systems, and the topography of rolling hills limits where septic systems can even be considered. Expanding water and sewer lines is cost prohibitive for individual parcels- which is part of the justification for pushing for clustered housing.

Isn’t farming dying already ?

San Diego county still has over 250k acres of farmland and it remains an important sector of the regional, and local Oceanside economy. Farming faces increasing challenges from cheaper imported crops, the high cost of water, and challenges of finding farmworkers. Numerous actions are in place to help address this- from water pricing, marketing of local produced food and supporting high value crops like cannabis.

Oceanside also has developed plans to support “Agritourism” as a way for farmers to supplement their income with farm related activities like farm stands, tasting rooms, and even boutique hotels and farm-to-table restaurants. Preserving the agricultural character of the area is essential for these activities to thrive. The farmers in Morro hills support this concept. Find the Agritourism Strategic plan here.

What is allowed in the South Morro Hills Specific Plan (SMHCP)?

The SMHCP will :

Allow thousands of housing units to be developed in “clusters”

It allows one landowner to transfer their development rights to another. This zoning system is called Transfer of Development Rights (TDR). The “sender” landowner can send the rights to development units they in theory could have built on their land to another landowner, the “receiver”. The receiver can then use these development rights to convert up to 25% of their land to dense housing clusters. The “sender” is paid for these development rights and guarantees they will keep their land in farming. The “receiver” pays for these rights and guarantees that they will only develop 25% of their land and keep the rest in farming. But that remaining 25% of the land can then include hundreds of housing units. The current 2 and ½ acre lots in theory allows 815 housing units. The clustered housing allows over 2,000. Plus each of those units is allowed an “accessory dwelling unit” (ADU, and another junior ADU that could add thousands more.

Add exorbitant costs for public infrastructure

Water and sewer line extensions alone are estimated to cost over $ 73m. Expanding the roads, will cost millions more. Will the increased traffic justify another bridge over the San Luis Rey River? Will it lead to completion of the hard-fought effort to stop the Melrose “gap” and loss of more farmland and impacts to Guajome Regional park? The SMHCP assumes the farmers in Morro Hills will vote to tax themselves to cover the initial construction costs. Even those who oppose this will end up paying their share. Once sewer lines are extended than most will be obligated to connect, whether they want to or not. But everyone will pay for the ongoing operation and maintenance of this expanded system in fees for these services for generations. Sprawl development costs $ in service for every $ dollar it creates in revenue (link to JP Theberge article re cost of sprawl) We all pay for that.

Jeopardize the farmland that remains

There are inevitable conflicts between housing and farming. It is just like the people who buy a house next to an airport and then complain about the planes. These neighborhood complaints over time make it harder and harder for farmers to continue to farm. Plus adding thousands of cluster homes will change the character of the area- making it less viable for Agritourism further jeopardizing ways for farmers to continue farming.

Compromise the regional conservation plan

Oceanside is one of 7 cities in coastal north county that is part of a regional conservation plan- the Multiple Habitat Conservation Plan (MHCP). That regional plan, and the Oceanside part of that plan, rely on landscape level wildlife movement corridors, and the protection of natural wetlands. These plans assumed that these agricultural lands would remain in agriculture, but if they were to be converted substantial mitigation will be required. But how can we even begin to mitigate for such a loss?

How does this relate to the already approved North River Farms project?

North river Farms was the first project that proposed to convert this farmland to housing. It included taking 176 acres of the farmland in Morro Hills for 585 housing units. The Oceanside City council approved this project in 2019. Preserve Calavera legally challenged the project approval and that litigation is still on-going. Because the City had approved the project, they removed it from the SMHCP planning area. The result is that this single project could add another 585 homes to what is now being proposed for the rest of Morro hills.

Can we Fix the Morro Hills Plan ?

We think a compromise is possible that actually preserves most of the farmland, allows limited low impact development, and reduces the public infrastructure costs for everyone.

This would include:

Revise the transfer of development rights (TDR) program to increase sending parcel size to 5 acres, and allow receiving parcels to be where growth is wanted- along major transportation corridors instead of on farmland

Reduced development would reduce infrastructure costs- that need to be more equitably allocated with development paying its fair share

Strengthen the Agritourism Plan and give farmers a way to increase their income that supports farming.

Adopt strong “Right to Farm” and nuisance ordinances that reflect the community’s values to preserve agriculture.

Require comprehensive analysis of wildlife movement corridors, wetlands and native plants and wildlife before any zoning changes that will convert ag land to more housing.

Analyze the alternatives to increased sprawl vehicle trips to prevent traffic congestion, compromising safe evacuations, and adding to air pollution and even more GHG.

What can You do ?

1. Email city council and staff and tell them you want them to ‘fix” the SMHCP- and really preserve farmland, Send to council@oceansideca.org.

2. Attend community meetings to get more details and join our effort- and spread the word to your friends and neighbors

3. Watch for our action alerts and key hearings where you can make your voices heard!

Additional Resources

For a one page summary see this document.
Survey: https://onwardoceanside.com/s/SMH-Survey-Report_final.pdf
Read Draft SMHC PLAN: https://www.dropbox.com/s/m7w28vwmfphgpxe/SMH_Preferred%20Plan_Draft_Revised%20042121_web.pdf?dl=0
Read Draft Sustainable Corridors Plan: https://onwardoceanside.com/smart-sustainable-corridors-plan
Sierra Club Action Alert, April 2021
References on sprawl:
Fiscal Cost of Sprawl. How Sprawl Contributes to. Local Governments’ Budget Woes. A REPORT BY THE. RESEARCH AND POLICY CENTER. William Coyne.20 pages
https://vault.sierraclub.org/sprawl/report00/sprawl.pdf
Oceanside Agritourism Strategic Plan
TDR Fact Sheet