The Developers have put up a website to promote their 1930 Ocean St. Ext. proposed 40-unit project. There is a FAQ section on their website, in which they pose both the questions and their answers to many of our concerns.

Below you will find the Ocean Street Extension Neighborhood Association (OSENA) rebuttals to their answers.

FAQ questions are in italics following “Developers”
The indented paragraph following the question is their answer to their question
OSENA’s rebuttal and answers to their question follow after that.


Developers: Won’t traffic increases resulting from the project cause traffic hazards at the intersection of Graham Hill Rd and Ocean St. Extension?

A traffic report for the proposed project was prepared by Hatch Mott MacDonald in accordance with City and State standards. The Graham Hill Rd., Ocean St. and Ocean St. Ext. (OSX) intersection currently operates at an LOS (level of service) of “A” for exiting Ocean St. Ext. and an LOS of “B” for entering Ocean St. Ext. With the addition of the project’s traffic (25 vehicle trips during the PM peak hour), the intersection LOS is not changed.The traffic report studied vehicle accidents at the intersection and within 300’ each direction, over the past 13 years. There were 10 reported accidents. This accident rate is 60% of the statewide average for similar intersections. The project proposes substantial improvements to the intersection. The improvements include extending the left turn lane, reconfiguring of the medians and removal of vegetation to increase and improve sight distance up Graham Hill Rd. A speed calming radar sign will be installed 300 feet up Graham Hill Rd. These upgrades will improve both the operation and the safety of the intersection.


  • Visibility up Graham Hill Road at the left turn exit from Ocean Street Extension is blocked by the curve in the road, a power pole and a natural berm on the curve. No “hedge trimming” or removal of vegetation will create a good enough sightline to make the turn up Graham Hill Road safe. When representatives of the Planning Department and Public Works Department met with local residents on the site, they could not confirm that the line of site had been calculated.
  •  Even if there is only one trip a day, 80-100 resident cars will produce 180 additional trips along a narrow road (two outings a day are more likely, for a total of 320 trips). Then there are guests, service vehicles, deliveries, waste collections, etc. Local residents do not think that changing the median and removal of the protective left turn lane curbing and median which channel downhill traffic away from those waiting to turn left onto Ocean Street Extension, local residents doubt that the proposed reconfigurations will improve the operation and the safety of the intersection, given the the added congestion on an already dangerous intersection.
  • The Developer’s traffic study indicates that there were 10 reported accidents reported at Graham Hill Road/OSE intersection over 13 years. Having followed this project since 2010, our group received reports from local law enforcement agencies indicating there were 31 reported accidents at the intersection in 15 years. The developer’s number, as stated in the EIR and the FAQs, therefore seems radically understated.

Developers: What about the projects impact on the other intersections in the area?

The project will generate a modest increase in traffic (two to four PM peak hour trips along Hwy 1 and two additional PM peak hour trips along Hwy 17). Currently the intersection at Ocean St/Highway 1 southbound off ramp, is operating at an unacceptable level of service. Caltrans is considering the widening of the off ramp and signalization of the intersection. These improvements would raise the LOS to an acceptable level. This project may be asked to contribute financially to these proposed improvements, based on the project’s percent of the increase in the traffic volume. In this case, the increase is 1.3% during PM peak hours.


  • This FAQ speaks to a future situation but basically admits that the current traffic situation is untenable. It also doesn’t take into account how much worse the situation will be while Caltrans is addressing the concern (fixing the off-ramp), which will take a considerable amount of time. There is no money in the City budget to finance this proposed fix.
  • The Highway northbound on-ramp situation is also untenable, with cars backing up Graham Hill Road at peak traffic hours and other cars making left turns onto on ramp, creating a dangerous situation for pedestrians and bicyclists and creating traffic gridlock at rush hours.


Developers: Is there a safety concern for pedestrians and bicyclists on Ocean St. Ext. because of the increase in the number of cars?

While the Traffic Study concluded that the project would have no impact on bicyclist or pedestrian safety, the project does include offsite improvements that will improve safety for bicycles, pedestrians and cars. Ocean St. Ext. will be improved from the intersection to the north side of the entrance to the cemetery. The work will include improving the street to City standards with two vehicular travel lanes, a new sidewalk on the cemetery side, parallel parking spaces and street drainage improvements.


  • Once a bicycle leaves Ocean St extension, the ride to the levee bikeway is dangerous, given the speed that cars are traveling down Graham Hill Road and the sharp curve they need to take at the bottom of the hill. It is unlikely that anything will improve this problem. A sidewalk along the cemetery is out of character with the rest of the street, which has no sidewalks.
  • There is increased danger to pedestrians and bicyclists on the narrow road. This is especially true at the intersection of Graham Hill Rd/OSX where utility boxes prevent the existing sidewalk and bike lane along Graham Hill Rd. from continuing further and disconnect the sidewalk and the bike lane from the dirt lane fronting the cemetery.
  • The increased traffic would undoubtedly complicate crossing Ocean St. at Jewell St.


Developers: Will this project cause a blockage of traffic for the emergency access for Paradise Park and Ocean Street Extension residence?

The use of Ocean Street Ext. as an alternative emergency route by residents of Paradise Park and Ocean Street Ext. will not be affected by the proposed development. In fact, with the improvements to the intersection and the widening improvements to Ocean Street Extension, emergency access through this section will be improved.


  • FAQ assumes there will be no blockage from traffic at the entrance/exit to the housing development.
  • Ocean Street Extension serves as the emergency exit for all 391 residences in Paradise Park when Highway 9 or their existing drive is closed due to natural disaster. In the winter of 2017, for two separate events, Ocean Street Extension was the only access available for these residences, many of which were experience flash flooding from the San Lorenzo River.
  • Because of the locked gate at Paradise Park, Ocean Street Extension is at all times the only exit for the 49 homes that are not part of Paradise Park, and passage can already be hampered during funerals or due to the narrow width of the road.
  • By allowing intensive urban development at the entrance to Ocean Street Extension, effectively doubling the number of residential units, the City is significantly impacting the ability of these residents to evacuate in the event of an emergency.
  • The use of tandem parking in the proposed development will result in more street parking, which will impede efficient ingress and egress for emergency vehicles; tandem parking will also endanger residents attempting to evacuate.


Developers: Will the project cause parking problems along Ocean Street Extension?

The project is providing 92 onsite parking spaces. This is 13 more spaces than the City code requires. In addition, the widening of Ocean Street Ext will provide 8 additional street parking spaces for the public.


  • The widening of Ocean St extension will reduce the net total of parking spaces along the cemetery on Ocean St extension.
  • Currently there is room for more than 8 cars, and many more than 8 cars park there when there is a service/burial at the cemetery.
  • There is no mention of adding a bike lane in this FAQ.
  • During events such as funerals, the number of parking spaces needed increases exponentially. If residents are using street parking, there will be no parking for others along the cemetery line.


Developers: Why is the project requesting a variance to the parking regulations?

The project proposes tandem parking in the semi subterranean garages. The City Code allows tandem parking in single-family residences and townhouses but requires a variance for tandem parking in condominiums and apartments. This project proposes tandem parking for the private spaces only and the pair of tandem spaces would be assigned to the same unit. So, someone living in a particular apartment could park behind another person living in the same apartment.


  • This will create congestion at the points of entry to the garage, as one car has to back out before the other car can leave. It could also result in residents parking on the street to avoid having to move cars.
  • This situation could also pose a danger to residents needing to evacuate quickly.


Developers: [Is it a problem that] this project is not located close to urban services and therefore will require a car to get around?

Many urban services such as schools, shopping, entertainment and parks are located less than 2 miles from the project site. Bicycle parking is being provided within the project for each unit as well as additional bicycle parking for guests. Ocean St. has bike lanes and sidewalks on both sides of the street. The project is less than 1/2 mile from the San Lorenzo Riverwalk, multi-use levee trail and bridge. This provides easy and quick access to many services in downtown Santa Cruz and other areas of the City. The project proposes the installation of a sidewalk on the west side of Ocean Street Ext. from the cemetery entrance to the existing sidewalks on Ocean Street. And while the bus service that existed on Ocean St. just south of the project was eliminated due to budget cuts, there is a bus stop on Ocean St. that is less than 1/2 mile from the project site and connects to the downtown Metro Station.


  • The walk between the project site and Ocean St is a very dangerous walk or bikeway. There is a sidewalk, but bicycles are not supposed to go on the sidewalk. Furthermore, the curve at the bottom of Graham Hill means that cars often stray into the bike lane on the right side/cemetery side of the street. Whether on foot or by bicycle, it is necessary to cross the street at the onramp to Highway 1, where cars are turning both left and right onto the on-ramp and where there is no traffic light to permit pedestrian crossing. It is a dangerous place to walk or ride a bike, before arriving at the bikeway on the levee. There is no question but that it will require using a car for all necessities.
  • There are no grocery stores, laundry services, entertainment, or schools easily accessible within two miles of the project. All services require using Ocean St for access. At 8 am traffic coming from Felton means that one has to wait at the egress of Ocean St extension for up to 15 minutes to join the traffic on the way to Ocean St. With increased density at the entrance to Ocean St extension, cars will back up a considerable distance along OSX. In the summer, traveling time can take up to 45 minutes to get from the top of Ocean St (near the highway 17 entrance) to Soquel Avenue, where most of the nearest services are located. Traveling to the project site from Ocean St likewise takes 45 minutes on Sunday evenings and at peak after-work rush hour and holidays.
  • The closest park is Grant Park, which can be accessed only by crossing Ocean St at the highway entrance (not particularly safe for pedestrians and children), and which is also known as a moderate crime area.


Developers: Why not just build the project with the existing General Plan and Zoning?

The proposed 40 unit project meets the City’s objectives of providing housing on underutilized sites which can provide a housing opportunity for individuals and families of all income levels. While building nine single family residential units would be in keeping with the current designation of the property, the price of those houses based on today’s market would exclude the vast majority of people looking to live in Santa Cruz. This property is also very well located in terms of freeway access, and biking or walking to many services and venues that are less than 2 miles from the property. The City wants to encourage higher densities for properties such as this. The proposed density is in keeping with the density of other housing projects on Ocean St. within the City of Santa Cruz.


  • A distinction ought to be made between Ocean St proper (high-density housing) and Ocean St extension. In between there is a relatively high-speed roadway, a highway off-ramp and a highway on-ramp, and an underpass that is also a site for unsavory activity. The density of housing once one is less than a ¼ mile from Ocean St changes completely. High-density housing is out of character with the rest of the neighborhood, which is agricultural land and single-family dwellings.
  • The project site is not well located for biking, walking, services, as noted above.
  • The development, if converted to condominiums, will also be inaccessible cost-wise for the majority of residents.


Developers: Why 40 units?

While 44 units could be built on the site with the proposed general plan and zoning change, 40 units preserves the mature oak trees and provides open space area that exceeds the City’s requirements. A 40 unit project would allow for four handicap accessible units to be built, offsite intersection and street improvements and still make the project economically feasible.


Forty units is four times the number of units for which this property is zoned. The current zoning would allow for 9 single-family homes.


Developers: How is this project compatible with the neighborhood?

The property is located in a mixed use area with the predominate adjacent use being the cemetery. Within the City limits south of the project site are multifamily developments similar to the proposed project. Along Graham Hill Rd are single family dwelling. Within the County area north of the project, on Ocean Street Extension, are agricultural uses and single family homes. The proposed development is most closely aligned with the area within the City limits to the south along Ocean St. which has similar type and density of development. Those developments also have the same urban services as the project site, (i.e., municipal water, City sewers, etc.). The area to the north, within the County, along Ocean Street Extension is a well established neighborhood but is apart from the proposed site. This is a rural area which does not have the same urban services and therefore are not allowed the same densities. It is also separated from the project site by the cemetery and the topography and oak grove just north of the site. The project consists of 10 buildings spread out on the site (similar to 10 single family units), providing a good transition between the City development and the County development. The Tanner Heights neighborhood to the east of the project site, off of Graham Hill Rd., is also a well established neighborhood. This neighborhood is separated from the project site by significant elevation and a eucalyptus grove.


There is no reason to consider the project as aligned with one side of the neighborhood while being grossly misaligned with its adjacent neighborhood. The alignment in question above is to a neighborhood separated by a major roadway. All contiguous areas to the site are not aligned with the density of the site.


Developers: Will the project be affordable to low income individuals?

Rental projects are considered affordable housing and are not required to participate in the affordable housing program. Rents for these units will be affordable to moderate income households. This typically includes police, health care workers, teachers, retirees, tech workers, students, etc. If the units are sold (condominiums), then 15%, or 6 units, will be sold to people that qualify under the City’s Affordable Housing Program.


This FAQ answer basically admits that the housing will not be affordable housing by saying that ipso facto rentals are “considered” affordable housing and are in any case exempt from the requirement to provide low-income housing, while the rents are advertised as affordable to “moderate” income households. What is considered “moderate income”? What will the rent be?


Developers: Why is the project requesting a variance from the required 20 foot setback from a 30% slope?

The eastern edge of the property, below Graham Hill Rd has areas with 30% and greater slopes. This slope was created as a result of the installation and improvements along Graham Hill Rd. Rick Moe and Craig Rowell (the Developers) had the slope analyzed by Haro, Kasunich and Assoc. to assess the stability of the slope. They concluded that building level building pads with a cut and fill retaining wall would improve the overall stability of the slope. Therefore, the slope variance would achieve the objectives of the City Code regarding slope stability.


Will the slopes be of a less steep grade? What in the proposed project site will ensure greater stability in the slopes? (the “cut and fill” retaining walls?) If the slope was created to create greater stability for Graham Hill Road, who is to say that change will not erode the stability of the roadway? How will runoff be addressed, given the change to the slope that is being proposed? From an engineering perspective, the project would be safer if the design avoided the steep hills. The municipal code codifies this basic engineering principle with its ordinance requiring structures to be set back from 30% slopes.



Developers: Will drainage problems along the gully to the northwest be made worst by the project?

No. The drainage gully to the north is on the neighboring parcel. The proposed project’s drainage will not be directed to this gully.


The developer’s plan uses 10 and 25-year storm probability figures for the design of the detention and retention areas. This is problematic in general (with the onset of global warming), and specifically for the site, where there are known downstream flooding issues. At a minimum, the 50-year storm figures should be used, since when detention and retention volumes fill up during a storm, any additional rainfall will “sheet flow” (an overland downslope movement of water taking the form of a thin, continuous film over soil or rock surfaces) from the site into the downstream system. That downstream system adjacent to the proposed project is a combination of informal (i.e. unlined) swales and culverts.


Developers: How will the project affect drainage along Ocean Street Extension to the northwest?

The project drainage plan is designed so that post development runoff does not exceed pre-development runoff. The drainage calculations exceed City requirements by using 25 year storm volumes rather than the required 10 year storm volumes. The majority of the onsite driveways will be pervious asphalt which allow much of the precipitation to be absorbed by the ground below. The onsite storm water is filtered, retained and detained in bio swales before being released at metered rates into the existing drainage channel along Ocean St. Ext. to the north of the site. Storm water from the new Ocean St. Ext. road improvements is also filtered, retained and detained in bio swales before being released at metered rates. The project and street improvements should cause no increase in storm water runoff to the north.


If the plan is to channel additional runoff to the north of OSX, and northward currently experiences winter flooding, how can the FAQ say this will not increase runoff in the northward direction? Pre-development runoff at a 10 or 25-year storm level is already at flood levels.


Developers: Even though the drought has ended there is still a concern about water usage. Won’t this project add to the water concerns?

The 40 units being proposed will create a minuscule impact on the City’s overall water demand (2.0 MGY). The project will include water conservation fixtures, drought resistant landscaping and drip irrigation as required by the City. In addition, the developer is required to pay a system development charge as part of the new service connection fees required for new water service.


The analysis in the DEIR is contrary to the principles for analyzing cumulative impacts. Water supply is a perennial problem in the City and County. The dire status of water supply means that ever-greater care and attention is needed to analyze the direct and cumulative impacts of this project. The purpose of the cumulative impact analysis is to look at those impacts in conjunction with other developments to determine whether the impacts are cumulatively significant. “Cumulative impacts can result from individually minor but collectively significant projects taking place over time.” CEQA Guideline 15355. The City cannot escape this analysis by simply saying the project’s contribution is miniscule.


Developers: How will this project affect the groundwater basin?

The City does not identify properties located in a groundwater recharge area. However, according to the County’s maps there is a portion of the property identified as being inground water recharge basin. According to the County’s Geologist, Joe Hanna, this designation is based on underlying Santa Margarita geologic formations that support regional aquifers (Draft EIR, pg. 4.6-14). The City’s policies require that new impervious surface area, for development within a groundwater recharge basin, not exceed 55%. The proposed development proposes new impervious surface area of 42%. In addition, a geologist study, conducted by Haro Kasunich and Associates, confirmed that no regional groundwater basins were encountered in the soil drilling studies they conducted.


Pervious asphalt is problematic in that it requires reliable maintenance in order to retain its effectiveness. Once the voids are filled, the paving no longer functions as a semipervious surface. Although the maintenance section calls for the “vacuuming” of the surface, the timing of the vacuuming is a known problem since the need varies depending upon conditions. For example, if a series of storms deposit sediment in the voids but the vacuuming is not scheduled for several months, subsequent storms will sheet flow on the paving as though it were impervious paving.