Reasons Why Plan Bay Area 2040 is Seriously Flawed for Marin County.
|Planners and Politicians never learn. Plans based on false data assumptions will NEVER work.|
1. Proposed changes to the projected household and jobs projections.
a. The proposed preferred scenario reduces the growth in Priority Development Areas (PDAs) from 80% to 75% for households and from 70% to 50% for jobs. The reduction of job growth in PDAs does not coincide with the intent of SB 375 and PBA to reduce Greenhouse Gas Emissions (GHG) by focusing housing and jobs near transportation corridors and/or transit. We suggest that ABAG and MTC consider maintaining the level of job growth in PDAs to between 65 - 70%.
b. For the first time, PBA is using the UrbanSim model for projecting household and job growth which does not factor in the projected growth in our General Plans. During our public workshop in May 2016 and in several of our comments from local governments in Marin, the projected job growth of the alternative scenarios was too high given our demographics and constraints. Unfortunately, the proposed preferred scenario did not reduce the job growth enough (NOTE TO MARIN CITIES/TOWNS: This does not apply to some of the smaller cities/towns). Please re-consider the job growth projections based on what is our General Plans.
2. Some of the Proposed PBA 2040 Assumptions are not realistic. Our comments are below on each assumption.
a) Current urban growth boundaries are kept in place. Comment: Support.
b) Inclusionary zoning to all cities with PDAs, meaning that these jurisdictions are assumed to allow below market-rate or subsidized multi-family housing developments. Comment: Not all jurisdictions with PDAs have adopted inclusionary zoning and may not support. ABAG and MTC should review what percentage of jurisdictions have adopted inclusionary zoning and modify the assumption accordingly.
c) All for-profit housing developments are assumed to make at least 10 percent of the units available to low-income residents, in perpetuity (via deed restrictions). Comment: Not all jurisdictions require all developments to include units for low-income residents and some require more than 10% affordable as part of their inclusionary zoning ordinance. ABAG and MTC should survey the local jurisdictions and modify the assumption accordingly.
d) In some cases, PDAs were assigned higher densities in the future than are currently allowed. Comment: Not all jurisdictions agreed with the higher densities in PDAs requested by ABAG/MTC. This assumption should be changed to only include those local jurisdictions that agreed with higher densities in their PDAs since they were self-nominated.
e) The cost of building in PDAs and/or Transit Priority Areas (TPAs) is assumed to be reduced by the easing of residential parking minimums and streamlining environmental clearance. Comment: This assumption should be changed to reflect only those jurisdictions that have already passed ordinances to ‘reduce the residential parking minimums and streamlined the environmental clearances’ in PDAs. Since local jurisdictions did not propose TPAs nor may not even know where the TPA’s are located in their jurisdiction, TPA’s should be removed from this assumption. Before TPAs are included, ABAG/MTC should identify and ensure that the Council/Board of Supervisors (elected body) support the specific locations of the TPAs.
f) Subsidies are assumed to stimulate housing and commercial developments within PDAs. Comment: This assumptions is unrealistic. ABAG/MTC should not include this assumption unless the subsidies are going to be provided by ABAG/MTC. Most local governments do not have access to ‘subsidies’ for private housing and commercial developers; and struggle to help not for profit housing developers. In addition, most local governments do not have the financial strength to provide all of the services anticipated (e.g. police, fire, parks, recreations, street maintenance, etc..) with the anticipated household and job growth articulated in PBA; so, local governments are not where these subsidies should be coming from.