Wednesday night, January 31, 2023, the City of Oceanside, Toll Brothers, NCTD and their Environmental Impact Report consultant received a significant amount of input on the proposed Oceanside Transit Center Development. A letter developed by our neighborhood is attached. The impacts raised included:
-Additional noise pollution from increased traffic, including diesel vehicles.
-Additional air pollution relocated from a commercial area (GHG & PM).
-New trash in residential areas relocated from the current transit center.
-Increased traffic and parking in residential areas from buses and private vehicles.
-Additional storm water pollution that leads to the ocean.
-Additional unhoused population and accompanying challenges.
-Bicycle access, usability and safety need to be integrated into the site and it is not currently included.
-The project needs to be better integrated into the community and it needs to have an outward facing welcoming arrival.
-The speed at which this project has arrived at this stage with very little input was a concern to many.
Many of the newly impacted residents may be lower income and a more vulnerable population than the existing placement thereby creating an issue of public justice and dumping negative impacts on those part of a more vulnerable community. Most heard for the first time that the units would be rental and there would be no home ownership opportunities. The area impacted by the new pollution and challenges of the proposed bus stalls and station is the area with the most residential occupancy.
It was expressed by the Toll Brothers and NCTD representatives that the project has been designed with NCTD and Rider needs in mind. This indicated that little if any existing needs, concerns and input had been received from the existing population in the surrounding community. No community input was gathered prior to plan development and submission and NCTD acted like a private party not having workshops to gather stakeholder input in plan development.
January 30, 2023
Mr. Rob Dmohowski, AICP, Principal Planner
City of Oceanside 300 N. Coast Hwy Oceanside, CA 92054
Sent via email to rdmohowski@oceansideca.org
Mr. Dmohowski,
The attached are comments related to the EIR Scope for the Oceanside Transit Center Mixed Use Project (OTC) AKA GPAA22-00002 proposed by North County Transit and Toll Brothers Apartments. Please also include these comments in other reviews and comments related to this project. These may include Planning Commission review, Council review, Coastal Commission review, Federal reviews, and applications (for consideration of the project or grants).
Overall this project has many good attributes, but one aspect of the development is of concern to many of our fellow neighbors South of the Transit Center and directly adjacent to the newly proposed relocation of the bus stalls. NCTD and Toll Brothers are jointly proposing to relocate the bus stalls (For NCTD, Greyhound, Bus Bridge buses and Special Event buses) and the transit center approximately 1,000 feet south and in a fashion that will be adjacent to our homes. Our neighborhood consists of ground-level residential, and this location is problematic due to the following issues:
1. Additional pollution – additional noise pollution from increased traffic, including diesel vehicles
2. Additional pollution – additional residential air pollution relocated from a commercial area
3. Additional pollution – new trash in residential area relocated from current transit center
4. Additional pollution – increased traffic and parking in residential areas from busses and private vehicles
5. Additional pollution – additional stormwater pollution that leads to the ocean
6. Additional unhoused population and accompanying challenges
7. Reduced property values due to some of the above-noted issues
This new and unexpected change moves air pollution, trash, increased noise, and greater vehicle traffic nearer ground-level homes. In addition, it relocates the unhoused population who use the bus stalls and staging areas for sleeping, assembling, drug use, other illicit activities, and other incompatible uses near ground-level homes in its new suggested placement. We do know the Bosie Decision impacts how the unhoused population is addressed and this concerns us even more since government entities (and others) have very little control over these issues. We do know even the best intentions of government agencies have unintended and unconsidered impacts. For example, our neighbors have been advised from senior NCTD Leadership, that NCTD realized, after the most recent relocation and construction of the New Coaster Platform, that they should have included shore power to reduce the idling/pollution of the Coaster, which now must idle if it’s in the station for 1 hour or less. We believe that with a thorough review of all areas indicated in the EIR project description and additional input provided by this group and others, a better project with mitigated impacts can be constructed for the benefit of old and new oceanside residents, businesses, and visitors. One additional item, of many we have seen missing, is how will the number of bus bridge buses that will provide support to Amtrak, Coaster, and Metrolink customers be accommodated when tracks are down or under construction. Currently, four or more buses are supporting Amtrak due to the San Clemente track construction, and there does not seem to be sufficient capacity in the proposed plan for these considerations. Further, it does not appear that the height of the residential building is sufficient to allow bus bridge buses or special event buses (like double-decker buses providing transport to Oceanside Harbor Days) to pass under the proposed structure to exit out Michigan to Coast Highway. This would leave Missouri as the only alternative street, further impacting the residential area.
It should be noted that the new placement is unlike the majority of multi-story residential and commercial uses with the bus stalls’ current placement. Some of our neighbors have also reviewed the typical wind patterns on the SDG&E website for this new location, and it looks like the typical onshore breeze will not dissipate but instead concentrate the Sprinter, Coaster and now the bus particulate matter (PM), and other greenhouse gasses (GHG) on an already impacted residential population. Many of the newly impacted residents, in our estimation (looking at the residential density and age of the housing stock), may be a lower income and more vulnerable population (Children, elderly, and others) than the existing bus stall placement, and this could disproportionately impact them. The San Diego Air Pollution Control District (APCD) has differing standards for mostly residential areas when considering acceptable air pollution levels due to longer-term pollution exposure for residential uses. This should also be considered with regard to the proposed relocation of the bus stalls to an almost completely residential area versus the current mixed-use location. The EIR for this project should evaluate the impacts of the bus stall relocation and all potential alternatives and mitigation. NCTD staff have advised us they want the bus stalls nearer the Coaster and Sprinter for ease of the users; however, other alignments would be less impactful to the existing and future residential populations in the newly suggested alignment.
Several of our residents did a significant amount of research prior to purchasing our homes, and one even talked to Oceanside City Staff, NCTD Staff, and SANDAG Staff. In each conversation, they were advised that there were no plans to move the bus stalls to the southerly position, which was specifically asked. It also appears that the proposed relocation could not be undertaken under the City Zoning and Land Use Maps. If NCTD is looking for an alignment that may best serve direct access to transit, might we suggest an East-West alignment for bus queuing on Michigan to Coast Highway? This would allow for the most direct access to the transit options, and massing the buildings on either side would create a sound/impact barrier to those residential and other uses to the north and south. This option would place buses on a solely commercial street with no direct access to the southern residential neighborhoods. Another consideration is leaving the bus stalls where they are and placing the hotel near the southern location.
To date, we have not seen any project alternatives in the proposed development materials. These alternatives are missing for the project and specific project elements, including the proposed relocation of the bus stalls, street alignments, project density, and building placement (partial list). We feel all alternatives need to be considered, so all approving authorities can best review, consider and determine how best to construct the project with minimal environmental and community impacts.
Several of our residents are employed in law enforcement, government, healthcare, private business owners, homeless support professionals, and lawyers (to name a few professions). We do understand the need for additional housing and how the State and Courts have removed many of the provisions of local control. The highest and best use of the site can address issues related to local control and the dictated State and Court conditions at the same time. The plan presented does not need to be constructed as designed. Although this may provide the highest value to NCTD and Toll Brothers, “Highest And Best Use”, should also consider those who were here under prior and existing conditions/regulations (to the extent legally feasible) and minimize (mitigate) the impacts to those who have already called this area home. The plan indicates a seven-year timeline for construction. It is unclear how this long and delayed process will impact coastal access, pollution, traffic, and other potential negative impacts. The plan should clearly outline current, interim, and final construction timeline impacts and mitigation.
As Oceanside residents and business owners, we believe that with the consideration of our comments related to the proposed bus stall placement and the corresponding impacts of the project overall, this project can be constructed in a way that allows for our continued quiet enjoyment of the homes south of the proposed project site and does not constitute a property taking. Thank you for the consideration of our input.
