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HomeMy WebLinkAboutPlanning Commission 2012-06-12 #3e�/�� Community Development Department ..../ '7j MEMORANDUM DATE: June 12, 2012 TO: Planning Commission FROM: Paul A. Jensen, Community Development Director; 415.485.54"" Paul.lensena),cityofsanrafael.org SUBJECT: Status Report on Plan Bay Area Sustainable Communities Strategy (SCS) and Regional Housing Need Allocation (RHNA) SUMMARY: On May 7, 2011, the Community Development Department staff provided the City Council with a status report on the "Plan Bay Area" Sustainable Communities Strategy (SCS) and the Regional Housing Need Allocation (RHNA). The SCS and RHNA are very separate regional planning processes but have been linked by Senate Bill 375 (SB 375). Signed by Governor Schwarzenegger in 2008, SB 375 establishes the requirement for a regional -level strategy to achieve reductions in greenhouse gas (GHG) emissions. Over the past year, there has been a substantial amount of press coverage on the Plan Bay Area SCS, which is a joint effort of the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC). There has been criticism about the jobs and housing projections that have been developed as part of this process as well as the concern over the potential loss of local planning control. Further, the numerous scenarios of projections and linkage of SCS with RHNA have created confusion. A copy of the May 7, 2012 City Council staff report on SCS/RHNA is attached. This staff report provides some background and clarity on SCA and RHNA, their linkage, as well as a status on the progress and next steps for the Plan Bay Area SCS. This status report will be presented to the Planning Commission. RECOMMENDATION: Accept Report SCS-RHNA.PCmemo 6 12 12 CITYOF�J" Agenda Item No: 6 b. Meeting Date: May 7, 2011" Z SAN RAFAEL CITY COUNCIL AGENDA REPORT Department: CopiMnity Deve o m_ent Department :J Prepared by: Paul A. Jensen,, Director City Manager Approval, SUBJECT: Status Report on Plan Bay Area Sustainable Communities Strategy (SCS) and Regional Housing Need Allocation (RHNA); City File No. P09-019. RECOMMENDATION: Accept Report. BACKGROUND: Overview Over the past year, there has been a substantial amount of local and Bay Area media coverage on the joint effort of the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC) to develop the "Plan Bay Area." The Plan Bay Area is being developed as the Bay Area's "Sustainable Communities Strategy" (SCS). As a requirement of Senate Bill 375 (SB375), the development of an SCS is intended to serve as a planning tool to facilitate regional reductions in greenhouse gas emissions (GHG) to targeted levels by 2020 and 2040. During this process, ABAG/MTC has published several scenarios of year 2040 jobs and housing growth projections for each Bay Area county and the local municipalities. The jobs and housing projections have been criticized and questioned by some local jurisdictions as being unrealistic and unsustainable. This criticism has been coupled with concern that the Plan Bay Area SCS promotes the loss of local planning control. Linked into the SCS process is the State -mandated Regional Housing Need Allocation (RHNA), which over the past 30 years, has been a staple base to planning for housing goals in local General Plan Housing Elements. The linkage of RHNA to the Plan Bay Area SCS has complicated matters in that there have been numerous scenarios of growth projection numbers published, some related to SCS and some related to RHNA. This staff report is intended to provide some background and clarity on SCS and RHNA, their linkage, as well as a status on the progress and next steps for Plan Bay Area SCS and RHNA. Sustainable Communities Strategy (SCS) Response to Senate Bill 32 (SB32) and Senate Bill 375 (SB375) Assembly Bill 32 (AB 32), the California Global Warming Solutions Act of 2006, established state legislation requiring a statewide reduction in greenhouse gas (GHG) emissions to 1990 levels by 2020. The reduction of GHG emissions is to be achieved in numerous ways. In 2008, Governor Schwarzenegger signed Senate Bill 375 (SB 375), which established a direct linkage of regional FOR CITY CLERK ONLY File No.: -9 `3 j Council Meeting:/ /:< Disposition: SAN RAFAEL CITY COUNCIL AGENDA REPORT / Pa2e: 2 transportation plans (RTP) with the statewide goals to reduce GHG emissions. The RTP sets the long- term transportation needs (transportation improvements) for a region and the funding to implement these needs. SB 375 requires that metropolitan transportation organizations (such as the Bay Area's MTC) develop a Sustainable Communities Strategy (SCS), which is to serve as a new element of the RTP. The goal of the SCS is to reach a GHG reduction target for each region. The target for the Bay Area is a seven percent (7%) GHG reduction per capita by 2020 and a 15% reduction per capita by 2040. The primary contributor to GHG impacts is emissions from fossil -fueled vehicles. Therefore, the greatest effort to reach this target is to develop ways to reduce the amount of vehicle miles traveled, such as planning for more housing and jobs that can be concentrated in the urban/developed areas and around or near transit. Elements of SCS The SCS is to add three new elements to the RTP: a) a land use component demonstrating how the region could house the entire population by 2040; b) a discussion of resource and farmland areas to be protected; and c) a demonstration on how the development pattern and the transportation network can work together to reduce GHG emissions. The SCS is also structured to ultimately synchronize the separate, State -mandated Regional Housing Need Allocation (RHNA) process with the RTP process. The SCS process is intended to plan for concentrated growth in the urban core of the Bay Area, but there is no mandate that this planned growth be built. However, as discussed below, the RHNA process mandates that the housing allocation that is distributed to each local municipality be addressed in their respective Housing Elements. Right now, Housing Elements are on a seven-year review and update cycle. The SCS coordination with RHNA and this linkage with the RTP would reduce the Housing Element review and update cycle to once every 8.8 years for local municipalities that demonstrate compliance with the ultimately -adopted SCS. Bay Area SCS- "Plan Bay Area" For the Bay Area, the SCS involves a partnership of all of the local municipalities with four regional agencies: a) MTC; b) the Association of Bay Area Governments (ABAG); c) the Bay Area Air Quality Management District (BAAQMD); and d) the Bay Conservation and Development Commission (BCDC). Both MTC and ABAG are leading the coordination effort to complete the SCS by 2013. The goal of the Plan Bay Area SCS is to focus future growth in and around a sustainable transportation system by concentrating this growth in the inner, urban areas of the Bay Area, thus reducing the need to continue to reach out to the outer areas to accommodate housing growth. By focusing growth in the inner -urban areas, there would be less reliance on vehicle travel, which would reduce GHG emissions. Priority Development Areas (PDA) and Priority Conservation Areas The key SCS tool to achieving concentrated growth has been the establishment of "Priority Development Areas" (PDA) and "Growth Opportunity Areas" (GOA). A PDA is a geographic area that is close to, along, or within transit nodes and connections that can be earmarked for concentrated growth, particularly housing growth. Unlike a PDA, a GOA is a geographic area that has the potential for concentrated growth, but may not currently have the optimum conditions for immediate access to transit or adequate infrastructure to accommodate growth. ABAG has established a process by which a local municipality can designate a PDA. This designation commits the local municipality to receiving a higher percentage of projected growth for the PDA, but it also comes with incentives. The incentives for a PDA include, among others: a) the potential for reduced requirements for and/or an exemption from CEQA review for future development in these areas; and b) grants and funding opportunities for planning, transportation and infrastructure. The Plan Bay Area SCS is accompanied by the One Bay Area Grant process. This grant process will make $600 million in funds available for land use planning and transportation improvements. The current policy for this grant process is that 50% of this grant money is to be allocated to the PDAs, with the other 50% allocated to all other geographic areas outside the PDAs. The Marin Transportation Authority of Marin (TAM) has provided a lead role in coordinating information on SCS as it administers the RTP for Marin County. At present, the RTP for Marin includes an allocation of grant funds for the designated and planned PDAs. Approximately 250 PDAs and GOAs have been designated in the nine Bay Area counties. At present, in Marin County there are two designated PDAs in San Rafael (Downtown and Civic Center) and one GOA (San Quentin area; PDA application filed but ultimately withdrawn by the County). A planned PDA is proposed covering several, unincorporated areas along the US 101 corridor (Marin City, Strawberry, SAN RAFAEL CITY COUNCIL AGENDA REPORT / Paae: 3 Greenbrae/Larkspur, Marinwood; see attached map of Marin areas). San Rafael has received MTC grant funding for the development of two SMART station area plans (the Downtown and Civic Center PDAs), which are in -process. Another important key tool in the SCS is the Priority Conservation Areas (PCAs). A PCA is a geographic area that is designated for conservation/protection because of its significant resource value to the region. Marin County has the highest amount of designated PCAs for the region, mostly concentrated in West Marin. A map of the Marin PDAs and PCAs is attached (see Attachment 1). Preparation and Public Review Process for Plan Bay Area SCS MTC/ABAG started the Plan Bay Area SCS process in 2009. This process has been structured to involve the following steps and phases (we are currently at steps 3 and 4), which has included and will continue to include public outreach: 1. Development of an Initial Vision Scenario (IVS), March 2011. The IVS started the SCS process by presenting draft jobs/housing projections based on existing, unconstrained conditions. City staff submitted comments on the IVS in 2011. (See report Attachment 5) 2. Alternative Scenarios and Results, November 2011. Five Alternative Scenarios were developed. This phase included a broad assessment of the scenarios to determine how each scenario performs against the SCS targets (e.g., the 7% reduction in GHG emissions by 2020). City staff commented on the alternative scenarios earlier this year. (See Attachment 4) 3. Draft Preferred Jobs -Housing Connection Scenario, March -April 2012. A Draft SCS Preferred Scenario was developed based on the results of and comments on the Alternative Scenarios. This scenario will be used as the base or project description for completing the SCS/RTP. This scenario represents the latest jobs/housing projections. On April 17, 2012, the City staff submitted written comments on this scenario (See Attachment 2). A discussion of this latest scenario projections and how they compare with the region and Marin County is provided below. 4. Release of Preliminary Draft RHNA Methodology, May 2012. As discussed below (RHNA section of report), the methodology that is used to distribute the RHNA to the local jurisdictions is being revised to coordinate with the ultimate housing growth projections considered in the SCS Draft Preferred Scenario (#3 above). The RHNA methodology will be finalized in July and will be folded into the SCS Draft Preferred Scenario and accompanying EIR to be prepared for the SCS/RTP. 5. Release of Draft SCS/RTP and Draft EIR, late 2012. ABAG will observe a 60 -day public review period and will hold public hearings, which will provide the City an opportunity to comment on the Preferred Scenario and Draft EIR. 6. Adoption of SCS/RTP and Final EIR, spring -2013. Following ABAG's adoption of the SCS/RTP, local municipalities will be given approximately 1 '/-year (late 2014) to adopt an updated Housing Element to address the 2014-2022 RHNA cycle. The Marin SCS Ad -Hoc Committee has been formed to track and monitor the SCS process for Marin County. The SCS Ad -Hoc Committee is comprised of elected officials (Councilmember Barbara Heller representing San Rafael) and public agency staff that meet quarterly to discuss information as it is distributed or made available by ABAG. The SCS Ad -Hoc Committee is coordinated by Transportation Authority of Marin (TAM) to promote collective review and comments from all communities/cities in Marin. Latest Projections (Step 3) — Draft Preferred "Jobs -Housing Connection" Scenario In March 2012, ABAG/MTC released the Draft Preferred Jobs -Connection Scenario. As is the case with the previous projection scenarios that were prepared, the methodology that was used by ABAG to develop the jobs/housing projections is complicated and difficult to understand. However, simply explained, the projections consider trends (both past and projected) that are specific to: a) regional SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 4 growth patterns; b) employment (by sector/job type); c) population changes (by age, demographics and immigration); and d) housing (production and choices in housing). The Draft Preferred Scenario responds to a compilation of comments on the last Alternative Scenarios submitted by many of the Bay Area communities (step 2 listed above). Consequently, this latest scenario presents an adjustment in the 2040 projections by considering/incorporating the following factors: 1. "Recession recovery." To address recession recovery, it is projected that 350,000 new jobs will filling current, vacant office space. For San Rafael, this factor is critical as there is a current 20% office vacancy. It is projected that this recovery would occur between now and 2020. 2. An increased trend in home-based businesses and employees working from home. 3. Local government input for housing unit forecast (local plan capacity; designated PDAs). 4. Absorption of current housing vacancies (6.4%) to 4% in 2040. 5. An aging population. It is projected that by 2040, the population of 65 years and older in the Bay Area will increase by 131%. For Marin County, this factor is critical as it has a higher than average percentage of older residents. The 2040 projections for this scenario were reduced from the previous alternatives, presenting a Bay Area job/housing growth of 1,120,000 jobs and 700,000 households (equating to 660,000 housing units). Jobs-Housinq Connection Scenario for Bay Area Region 2010 US Census 2040 Growth 2010-2040' Jobs 3,385,000 4,505,000 1,120,000 Population 7,152,000 9,299,000 2,147,000 Housing Units 2,786,000 2,446,000 660,000 The Bay Area jobs and housing growth projections were distributed to the nine Bay Area counties, as presented in the table below. Overall, Marin County's household and employment is projected to grow more slowly and far less than all other counties in the 2010-2040 period (e.g., 7% housing unit growth projection for Marin County, as compared to a 24% housing growth projection for the Bay Area). Jobs -Housing Connection Scenario by Bay Area County County Housing Units;' Emplo ment (Jobs) 2010 2040 addition % Increase 2010 2040 %lncrease addition Alameda 582,540 153,990 26% 694,450 252,450 36% Contra Costa 400,260 85,285 21% 344,920 122,920 36% Marin 111,240 85150 7% 110,730 19;290 17% Napa 54,760 5,650 10% 70,650 19,560 28% San Francisco 376,940 80,640 21% 568,720 175,060 31% San Mateo 271,050 58,250 21% 435,200 112,730 33% Santa Clara 631,930 201,210 32% 926,260 296,600 32% Solano 152,690 29,700 19% 132,350 50,970 39% Sonoma 204,580 37,140 18% 192,010 70,350 37% Region 2,785,990 660,010 24% 3,345,300 1,119,920 33% As presented in the table below, the countywide jobs and housing growth projections were distributed to the Marin communities. Please note that in this latest scenario, San Rafael represents 34.6% of the 2040 housing growth projection and 32% of the 2040 job growth projection for Marin County. The higher percentage projected for San Rafael is attributed to it: a) being the urban center for Marin County; and b) containing two designated PDAs. While the 2040 housing growth projection for San Rafael (12%) is SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 5 higher than the Marin average (7%), the 2040 job growth projection is slightly lower than the projected average for the county (17%). Jobs -Housing Connection Scenario for Marin Count -Municipality Housing Units Emplo ment Jobs 201.0 2040 addition %Increase. 2010 2040 (addition % Increase Belvedere 1,050 20 2% 430 70 16% Corte Madera 4,030 210 5% 7,940 440 6% Fairfax 3,590 310 9% 1,490 370 25% Larkspur 6,380 140 2% 7,190 750 10% Mill Valley 6,530 570 9% 5,980 1,160 19% Novato 21,160 890 4% 20,890 3,390 16% Ross 880 80 9% 510 110 22% San Anselmo 5,540 460 8% 3,740 870 23% San Rafael 24,010 2,820 12%° 373626 6,190 16% Sausalito 4,540 380 8% 6,220 1,510 24% Tiburon 4,030 330 8% 2,340 540 23% Marin uninc. 29,500 1,940 7% 16,380 3,890 24% Marin Total 111,240 8,150 7% 110,730 19,290 17% ABAG has noted that every four years, the jobs and housing forecasts will be updated as part of the regular review of funding for transportation projects. City staff has been active in tracking and participating in the Plan Bay Area SCS process. A summary of the City staff comments on the projections covered in this scenario is provided in the Analysis section of this report, below. Regional Housing Need Allocation (RHNA) State Mandate The Regional Housing Need Allocation (RHNA) is the housing need allocation that is set and determined for each region by the State of California Department of Housing and Community Development (HCD). The allocation represents a target number for planning and accommodating new housing units for a broad range of affordability levels. For the Bay Area, ABAG is provided this RHNA and it is the job of ABAG, in coordination with the nine Bay Area counties and respective cities/towns, to distribute this allocation to each community. Each county and local municipality must take the share of the allocation and incorporate it into their respective Housing Elements. The Housing Element must demonstrate how the local allocation can be met or achieved through zoning for housing and supportive General Plan implementation measures. While RHNA does not require municipalities to build housing to meet this allocation, the Housing Element must demonstrate, to the satisfaction of HCD staff, that the local municipality zoning and property inventory can accommodate the allocation. Further, approved and proposed housing development projects are counted toward meeting the RHNA. Once incorporated into the local Housing Element and adopted by the local municipality, the Housing Element must be certified by HCD. Once certified by HCD, the local RHNA obligation has been met. RHNA, which has been administered since 1981, is implemented in seven-year cycles. Therefore, the local Housing Elements are required to be reviewed and updated commensurate to this cycle. San Rafael Housing Element In 2011, the City Council adopted an update of the San Rafael General Plan 2020 Housing Element to cover the RHNA cycle for 2007-2014 RHNA. Subsequent to this action the Housing Element was certified by HCD. The adopted Housing Element incorporates a RHNA of 1,403 units for the 2007-2014 cycle, which demonstrates that: San Rafael's current zoning provisions allow for housing in a number of the non-residential zoning districts, as well as higher densities in our residential zoning districts. Suitable opportunity sites have been identified (vacant and underdeveloped sites) for housing. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 6 c. San Rafael has approved a number of housing development projects that are credited toward RHNA (e.g., Village at Loch Lomond Marina, 1203 Lincoln Avenue). A total of 219 approved/built units have been credited. The data supporting the above is presented in the Housing Element Background Report, which is available in Appendix B of the San Rafael General Plan 2020. Please note that the Housing Element that is available on the City's website has not yet been updated to reflect this adopted Housing Element. RHNA for 2014-2022 Cycle In March 2012, HCD released the Bay Area RHNA for the next 2014-2022 cycle. For the Bay Area, the allocation is 187,990 housing units for an 8.8 -year projected period. ABAG, in coordination with a committee of representatives from local planners and elected officials (ABAG Housing Methodology Committee), has developed an updated methodology for distribution of the RHNA to the nine counties and municipalities. The methodology committee developed a multi -step formula to ensure a fair distribution of the household growth to the nine counties and municipalities. Simply described, the updated methodology for the local distribution of the RHNA considers the following factors: ➢ The SCS is now considered in determining the distribution of this allocation (discussed above). The growth assumptions are based on the Draft Preferred Jobs -Housing Connection Scenario. ➢ Sphere of influence is considered. For the unincorporated areas that are within the sphere of influence of an incorporated city/town, a portion of the County's allocation for this area is distributed to the appropriate jurisdiction. ➢ A "sustainability split" is applied, meaning that 70% of the growth is distributed to the Priority Development Areas (PDAs). "Caps" and "floors" are applied. For PDAs, the RHNA numbers are capped to have no more than 110% of the projected household growth. For all other areas, at least 40% of the projected household growth must be planned. ➢ Fair Share is applied. Three fair share factors are considered in adjusting the allocation for non - PDA areas. These fair share factors consider past RHNA performance, transit availability and projected jobs growth. In March 2012, the first draft 2014-2022 RHNA for Marin County was made available disclosing a countywide allocation of 3,392 housing units (about 2% of the Bay Area total) of which 898 units were allocated to San Rafael. However, on April 26, the latest draft RHNA was released reducing the countywide allocation to 2,436 units. Of this total, the latest draft 2014-2022 RHNA for San Rafael is 940 housing units, which is a 33% reduction from the last, 2007-2014 RHNA cycle that is reflected in our adopted Housing Element. The following table provides a breakdown of the latest draft Marin County RHNA 2014-2022 by municipality, which also provides a comparison with the 2007-2014 RHNA cycle: Municipality RHNA 2007-2014 RHNA 2014-2022 (Draft) Change Percent of Change Belvedere 17 16 1 -6% Corte Madera 244 72 172 -71% Fairfax 108 63 45 -42% Larkspur 382 131 251 -66% Mill Valley 292 128 164 -56% Novato 1,241 412 829 -66% Ross 27 18 9 -33% San Anselmo 113 106 7 -7% San Rafael 1,403 940 (4 63 -33%' Sausalito 165 83 82 -50% Tiburon 117 78 39 -33% Marin Co. uninc.) 773 389 384 -50% Marin Co. Total 4,882 2,436 (2,446) -50% Please note that these numbers will likely change before they are finalized in early summer. As discussed above, the draft 2014-2022 RHNA methodology will be made available for public review in SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 7 May. A summary of City staff comments on the draft RHNA is provided in the Analysis section of this report, below. I_IkiVIA'b96� San Rafael Projections for Draft Preferred "Jobs -Housing Connection" Scenario As we have reported, City staff has closely monitored the Plan Bay Area SCS process, which has included continual City participation in the efforts of the Marin SCS Ad -Hoc Committee. On behalf of the SCS Ad -Hoc Committee, TAM submitted a letter to ABAG outlining comments on the latest scenario of projections (see report Attachment 3). For the most part, City staff has mirrored the TAM comments in recent and past communications to ABAG. On April 17, 2011, City staff submitted a letter to ABAG listing specific comments on the latest Draft Preferred Scenario. As noted above, a copy of this letter is attached (Attachment 2). A summary of the scenario comments is as follows: Jobs projection growth is inflated. The 2040 jobs projection (growth of 6,190 jobs) in this scenario has been reduced by 50% from the projections presented in the earlier Alternative Scenarios. The jobs projection has been adjusted to account for recession recovery and some increase in home-based jobs. However, this lower jobs growth projection is still inflated and would still equate to several million square feet in new commercial building area. This building area equivalent is more than the amount of commercial development planned in the San Rafael General Plan 2020 (approx. 400,000 sf). In our comments to ABAG, we note that this development equivalent would require major transportation and utility service infrastructure that exceeds current and planned capacity. Housing projection growth coincides with RHNA. The 2040 housing projection (growth of 2,820 housing units) in this scenario is in the same projection range presented in the earlier SCS Alternative Scenarios. This SCS growth projection forecast to 2040 essentially spans three RHNA cycles (8.8 years each). At the time of our comments, the first draft 2014-2022 RHNA of 898 housing units for San Rafael was available representing 30% of the 2040 projection, which we noted as coinciding with this scenario. The latest RHNA of 940 units represents 33% of the 2040 projection. Staff has reviewed the 2040 housing growth projection of 2,820 units with growth projections covered in the currently -adopted San Rafael General Plan 2020 Housing Element. The Housing Element includes the results of a citywide residential capacity analysis, which analyzed potential sites and areas as opportunities for housing. The analysis demonstrates opportunities for a potential capacity of approximately 2,500-3,000 units. 3. Peer review of projections methodology is warranted. The inflated growth projection numbers have been cause to question the methodology that was used to develop the projections. As a result, several Bay Area municipalities have recommended that ABAG commission a peer review of the projections methodology. In our comments to ABAG on this scenario, we supported this recommendation. 4. Credit for implementing GHG emission reduction measures. As discussed above, the Plan Bay Area SCS targets a 15% reduction in Bay Area GHG emissions by 2040. It is estimated that the implementation of this latest scenario would reduce GHG emissions by about 9%, meaning that the 15% target goal would not be reached through concentrated growth alone. To supplement the shortfall, ABAG/MTC recommends that other non -land use measures will need to be implemented to reach this target. Such measures would include, among others, telecommuting, vanpooling, and safe routes to schools/pedestrian networking. As San Rafael has adopted a Climate Change Action Plan and accompanying GHG Emissions Reduction Strategy that include aggressive and tangible measures to effectively reduce GHG emissions, our comments to ABAG request that credit be given to our commitment in this effort. Comments on Latest Draft 2014-2022 RHNA While the draft 2014-2022 RHNA is subject to change, the latest 940 housing unit allocation for San Rafael is supportable for our next Housing Element update. RHNA is structured to 'start over' at each SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 8 cycle. Therefore, as our currently certified Housing Element has demonstrated that we have planned for 1,403 units, review and update of the next Housing Element may be uncomplicated unless the draft 2014- 2022 allocation (940 units) dramatically changes. As the current economic recession has lingered, there have been few approved housing projects that have been built to occupancy. So, currently approved projects that are not permitted and built by January 1, 2014 will be credited toward meeting the RHNA in the next Housing Element update. Staff does not recommend any further action on RHNA at this time. Staff will continue to monitor RHNA and report back as information becomes available through the SCS/RTP process. ABAG Membership As the City Council is aware, the Town of Corte Madera recently voted to withdraw its membership from ABAG. This action was initiated in response to the SCS process and the questionable projections for local growth. In response, there has been some interest in forming an alternate, local -based "Council of Governments" (COG) to serve as an alternate to ABAG (similar to efforts by San Mateo and Napa counties). In considering this issue, staff offers the following comments: Opting -out of ABAG and forming a Marin -based COG will not eliminate (and will not likely reduce) the RHNA for Marin County and its cities/towns. The COG would be responsible for taking the countywide allocation provided directly from HCD and distributing it to the Marin cities/towns and unincorporated areas. Opting -out of ABAG a Marin -based COG will shift the responsibility of addressing the AB32 and SB375 obligations directly to the Marin -based COG. Forming a Marin -based COG would require staffing, which has fiscal implications for each community in Marin. With the ABAG membership dues comes the staffing to administer RHNA and SCS. San Rafael has had a long-standing membership with ABAG and has been successful in receiving grant funding for projects. While the City has not always agreed with ABAG's regional planning efforts, particularly its long-term projections for jobs and housing, there is value in the ABAG membership. ABAG provides, among others: a) a conduit to other cities/counties in the region; b) training that is tailored for Bay Area government needs and issued; and c) a source of funding and grants for local governments and non-profit groups. OPTIONS: The City Council has the following options to consider on this matter: 1. Accept Report; or 2. Direct staff to return with responses to questions ACTION REQUIRED: No action is required of the City Council at this time. ATTACHMENTS Attachment 1: Map of Marin County identifying PDAs and PCAs Attachment 2: Letter to ABAG from City of San Rafael addressing SCS Draft Preferred Scenario; April 17, 2012 Attachment 3: Letter to ABAG from Marin TAM addressing SCS Draft Preferred Scenario; April 27, 2012 Attachment 4: Letter to ABAG from City of San Rafael addressing SCS Alternative Scenarios; January 26, 2012 Attachmont 5: Letter to ABAG from. City of San Rafael addressing SCS Initial Vision Scenario; May 5, 2011 SCS-RHNA.CCrpt 5-7-12 - Wo - � iJlm . - Wo _dONCITY OF - MAYOR GARY O PHILLIPS CUUNCIL6 UnriR D:LNION C ONNOLLY _ C0UNC11.MFMBrR BARBARA HELLER - - -: _. COUNCILNIENIBER MARC LENIN? - -`"_'-- COUXC71»�IFNIflER ANUREP�CCYl1OAN i\':CCLg1.00Ii311 CONIMUNITY DEVELOPMENT Dr-PARTMEN r PHONE: 415-485-3085 FAX: 415-485-3184 April 17, 2012 Ezra Rapport Executive Director Association of Bay Area Governments P.O. Box 2050 Oakland, CA 94604-2050 SUBJECT: Bay Area Sustainable Communities Strategy (SCS); Review and Comments on Draft Preferred "Jobs -Housing Connection Scenario' (City File No. P09-019) Dear Mr. Rapport: Thank you for the opportunity to comment on the Draft Preferred "Jobs -Housing Connection Scenario" (Draft Preferred Scenario) prepared for the One Bay Area Plan process. Our last correspondence to you on the SCS and One Bay Area Plan (January 26, 2012) focused our comments on the "Alternative Scenarios." In that letter, we expressed serious concerns about the jobs projections and .reported that San Rafael does not have the adequate transportation infrastructure to support the collective housing and job projection numbers. Even though San Rafael has chosen to designate two Priority Development Areas (PDA), we commented that the projection numbers appeared to be impractical and inequitable. Lastly, we questioned the methodology that was used to develop the projections, particularly in consideration of built -out community conditions and the current 20% vacancy in our office space inventory. We have reviewed the latest Draft Preferred Scenario and have found that further adjustments have been made to the 2040 jobs and housing projections from those presented in the Alternative Scenarios. While we acknowledge that some changes have been made in the projections, we respectfully submit the following comments on the Draft Preferred Scenario: Jobs projections have been reduced but are still unrealistic. The projections for jobs through 2040 have been substantially reduced from the projections presented in the Alternative Scenarios. We acknowledge that this scenario takes into account: a) "recession recovery," meaning that a percentage of jobs lost resulting from the current economic recession will be recreated to fill the current, experienced office vacancy; and b) some level of growth over time in home-based businesses. While these factors help to better understand the method for these projections, we continue to have concerns and reservations that a projection of 6,190 new jobs by 2040 is realistic by comparison to the job growth experienced in San Rafael between 1995 and 2010. Even assuming recession recovery and an increase in home-based businesses, the adjusted projection would still equate to several million square feet in new commercial building area, which 1400 FIFTH AN'ENLIE • PO BOX 151560 • SAN RAFAEL, CA 94915-1560 WW W.CI TYOFSANRAFAH-ORO Attachment 2 MR. EZRA RAPPORT, ABAG Ann17, 2012 PACE; 2 is far more than that planned by our current, San Rafael General Plan 2020. This additional commercial building area would require major transportation and utility service infrastructure that exceeds current and planned capacity. Housing Proiections have been adjusted and re -distributed. For the Draft Preferred Scenario, the housing projections for Marin County have been adjusted for most cities/towns. The housing projections for San Rafael are about the same as the lower - range projections presented in the Alternative Scenarios (projection of 2,820 housing units). This projection corresponds with the recently released draft Regional Housing Need Allocation (RHNA) for San Rafael, which is 898 units for the RHNA next cycle (2014-2022). This RHNA allocation represents 30% of the SCS projection for 2040. As is the case with the jobs projections, we question the ability to provide adequate transportation and utility service for this 2040 projection. Peer review of projections methodology Is needed. The City of San Rafael is represented by the Transportation Authority of Marin (TAM). By separate letter, the TAM Board of Director's submitted comments to ABAG. The City of San Rafael fully supports the TAM recommendation to ABAG that a peer review of the projections methodology be performed by the Bay Area Council Economic Institute. The peer review of the projections methodology should consider the individual conditions and characteristics of each county in the Bay Area region to determine if the projections are justified and supportable. For example, for Marin County, the jobs and housing projections are lower than other counties, which we assume is attributed to several factors including: a) the high amount of protected lands and designated Priority Conservation Areas in this county; b) the limited amount of regional -serving mass transit; and c) the high projections for an aging population. These and other factors need to be considered in assessing and confirming the projections methodology. 4. GHG emissions reduction target -goals and alternative Policies. As was the case with the Alternative Scenarios, the Draft Preferred Scenario would not meet the minimum goal of reducing GHG emissions for the Bay Area by 15%. It is estimated that the implementation of the Draft Preferred Scenario would reduce GHG emissions by approximately 9%, meaning that in order to reach the 15% target, other non -land use policies will have to be implemented. Policy incentives have been published with this scenario indicate that implementation of measures such as vanpool incentives, telecommuting, safe routes to schools/pedestrian networking will augment the reduction in GHG emissions in order to meet the 15% target goal. Regarding the GHG emission target goal, please note that the City of San Rafael has adopted a Climate Change Action Plan (CCAP- 2009) and a Greenhouse Gas Emission Reduction Strategy (2011), which both address our local commitment to implementing similar policies and measures to reduce GHG emissions for 2020 and 2035. These measures include, among others: improving the pedestrian/bicycle infrastructure (NTPP); promoting transient -oriented development (TODs); and supporting transit services as well as the SMART station planning, which would increase the performance and safety of public transit, bicycle and pedestrian facilities_ In addition, the City has committed to participate in the local Marin Energy Authority (MEA) alternative to conventional PG &E service. MEA offers renewable energy with service options at several levels, light green and dark green. San Rafael has committed to receive the Attachment 2 MR, F.ZRA RAPPORT, ABAG APR€L 1 7, 2012 PAGe.3 MEA light green service option with a later, more aggressive commitment for the dark green service option by 2020. Lastly, the CCAP implementation program includes other measures that would reduce GHG emissions including the adoption of a Zero Waste Plan, developing a Residential Food Waste Composting Program, and measures for promoting electrical vehicle purchase and use. With the implementation of these measures, our GHG Emissions Reduction Strategy estimates that our annual emissions can be reduced by as much as 56,858 MTCO2e by 2020 and 78,382 MTCO2e by 2035. This local effort should be provided credit to further support reductions in the jobs - housing connection projections for our community. We appreciate the opportunity to review and comment on the Draft Preferred Scenario. We will continue to monitor the SCS process and look forward to reviewing future documents when it is completed and published and available for public review. Sincerely, Paul A. Jensen,(AICP Community Development Director cc: Mayor and City Council Planning Commission City Manager City Attorney Public Works Director Economic Development Director Transportation Authority of Marin scs.ABAG Itr 4-16-2012 Attachment 2 www.tam.ca.gov April 26, 2012 750 Lindaro Street Draft Preferred "Jobs -Housing_ Connection Scenario` Suite 200 San Rafael Mr. Ezra Rapport California 94901 Executive Director Corte Madera Association of Bay Area Governments Phone: 415/226-0815 101 Eighth Street Fax: 415/226-0816 Oakland, CA 94607-4700 www.tam.ca.gov Subject: Comments Regarding the Sustainable;Communities Strategy Belvedere Draft Preferred "Jobs -Housing_ Connection Scenario` Sandra Donnell Dear Director Rapport: Corte Madera Diane Furst This letter transmits the Transportation Authority "of Marin (TAM) Board's Fairfax comments regarding the region's Sustainable Communities Strategy (SCS) .john Reed Draft Preferred "Jobs -Housing Connection Scenario." Larkspur We recognize the Association ofBay Area Government (ABAG) staff for Dan Hillmer working with TAM and Marin'County 's local jurisdictions to adjust housing and Mill valley employment forecasts to more accurately reflect -,local character and general Stephanie Moulton -Peters plan capacity. We trust that-:.ABAG wlll continue working closely with jurisdictions that have additional` concerns regarding the projections. Novato Eric Lucan We appreciate ABAG's recognition of Marin County's Priority Conservation Areas and agricultural land in the Plan Bay Area SCS. We cannot overstate the Ross R. Scot Hunter importanceof these areas to the region. = San Anselmo Since ifs ,release, on _ March 9, TAM staff has presented the "Jobs -Housing Ford Greene Connection 'Scenario" _to the TAM Executive Committee, Board, the SCS Ad eP Hoc Committee, and , the Marin County Planning Directors. In general, we San Rafael received feedback that the current Marin housing and employment projections Gary Phillips are more appropriate than previously presented in the Initial Vision Scenario or Sausalito Alternative Scenarios. However, some jurisdictions continue to have concerns Mike Kelly and Will provide their comments directly to ABAG. Tiburon It is our understanding that ABAG has requested a peer -review of its housing Alice Fredericks and employment projections by the Bay Area Council's Economic Institute. We County of Marin look forward to hearing the results of that review. Susan L. Adams Katie Rice The intent of this letter is to provide county -wide comments on the Jobs- Kathrin Sears Housing Connection Scenario, based on discussions among our Board Steve Kinsey members and SCS Ad Hoc Committee. We have continuing concerns about the )udy Arnold overall SCS that were stated in previous comment letters. Rather than restate Making the Most of Marin County Transportation Dollars Attachment 3 Letter to Director Ezra Rapport, ABAG April 26, 2012 Page 2 of 2 each point here, we refer you to our letters of June 13, 2011 and January 31, 2012. Employment The Jobs -Housing Connection Scenario forecasts employment growth at 17% by 2040, or about one-half percent per year. Although this appears to be consistent with historical growth of 16% from 1980-2010, Marin County lacks the type of developable land associated with traditional business growth, and has limited availability of water resources. It is unlikely that Marin can match the robust job growth of the 1980s. Therefore, we advise against -using the last 30 years as a basis for projecting future growth. The SCS should accurately account for the reduction in greenhouse gas production and vehicle miles travelled associated with home-based employment":_and telecommuting, along the transportation corridors. We ask ABAG and the Metropolitan -Transportation Commission (MTC) to identify and adopt a method to account for these employment locations. Housing Senior housing is a crucial and urgent issue for Marin C&Wy._The Bay Area's senior population is expected to increase by 131% by 2040. Marin County is expected to have a higher than average proportion of seniors. We are very ,concerned that the State does not recognize most types of senior and other group housing as _`u.pits" that may be' --counted toward meeting a jurisdiction's Regional Household Needs Assessment (RHNA) If we_ build units according to existing rules, we risk "crowding out" our senior population by not providing the right type of housing for those who wish to remain in their communities, but not in their single-family home. ABAG is in a unique position to educate and advocate with: --,the state Department of Housing and Community Development to recognize common types of senior and other group housing for RHNA purposes and thereby meet the population n'eeds>projected by the SCS forecasts. Finally, we want to again emphasize that Marlin's unique place and role as a recreational, environmental and agricultural resource in the -Bay Area should be a primary consideration in long-term regional planning„scenarios: We look forward to working with ABAG, MTC, and the public to lead the Bay Area into compliance with the SB 375p _Jag for greenhouse gas emissions reduction. Sincerely, Alice Fredericks TAM Board Chair Transportation Authority of Marin cc: Steve Heminger, Metropolitan Transportation Commission Marin County SCS Ad Hoc Committee TAM Commissioners Making the Most of Marin County Transportation Dollars Attachment 3 CITY OF MAYOR GARY O PHILLIPS CCOUNIILIFSIBB LiA ON RBAR-AN\OLE.}. � COUN('EI NF4l8FR B•\h641 4 HI Ll C-R COUNCHAILAMM MAP.0 LL\'INE C:OUN('11.AI[1IBFR ANEIRE.\' CU]'1!GA�: hWCULLOUGH UNITY DEVELOPMENT DEPARTMENT PHONE: 415455-3085 FAX: 415485-3184 January 26, 2012 Ezra Rapport Executive Director Association of Bay Area Governments P.O. Box 2050 Oakland, CA 94604-2050 SUBJECT: Bay Area Sustainable Communities Strategy (SCS); Review and Comments on Alternative Scenarios Report & Results (City File No. P09-019) Dear Mr. Rapport: For the past two years, the City of San Rafael has been tracking the Bay Area Sustainable Communities Strategy (SCS) process. Last year, when your office published the Initial Vision Scenario (IVS) outlining possible growth projections for the Bay Area in 2035, the City of San Rafael provided you feedback. In our letter to you dated May 5, 2010, we endorsed the value of regional planning for the goal of addressing climate change and reducing greenhouse gas (GHG) emissions. San Rafael has been in the forefront to address these planning issues through, among others the: a) adoption of a Climate Change Action Plan (CLAP); b) incorporation of a Sustainability Element in our San Rafael General Plan 2020; and c) adoption of a GHG Emissions Reduction Strategy. Further, these efforts have been reinforced by designating two Priority Development Areas (PDAs) within our city, which are located around two, future SMART rail stations. However, in our comments to you on the IVS, we responded that we strongly opposed the growth projections as they represented an inequity in the growth distribution of both housing and jobs in Marin, and a disproportion of the allocation of growth to San Rafael. Further, based on the IVS projections, San Rafael is expected to produce about one-half of Marin's housing growth in the next 25 years. This projected growth rate is three - times the rate that has been experienced over the past decade. In our letter, we requested that the Alternative Scenarios consider a more even distribution of housing throughout Marin County, with focus of future growth around the SMART light rail corridor. We have had an opportunity to review and study the latest Alternative Scenarios report and results published in December 2011. In brief, while the San Rafael housing projections presented in these latest scenarios are aggressive, we are encouraged that in all scenarios, they have been reduced from the IVS projections (even by upwards of 50%). However, the jobs projections have doubled from those presented in the IVS; these projections are not only unrealistic but unsustainable for San Rafael. Our more detailed comments on the Alternative Scenarios and study results are provided as follows: 1400 Fwn AVENUE • PO Bot 151560 • SAN RAFAEL, CA 94915-1560 e�v\c.clnorsAxR�4tusL.oRG Attachment 4 MR. DRA KAnou, A13AG J. �'UARY 26, 2012 PAGE; 2 Comments on Alternative Scenarios Projections ➢ 2010 base year adjustments. In your report, it is noted that for three of the Alternative Scenarios, the 2010 base year estimate of jobs and housing were adjusted using the most current 2010 US Census data. Use of this data was critical in reflecting the current depressed economic conditions. A 20% office vacancy rate has been experienced in San Rafael over the past several years, which means fewer jobs. However, it is unclear how the job recovery is factored into the long-term job projections. This detail in the projections methodology needs to be clearly described. Y Little distinction in Alternative Scenarios. Interestingly, there is not much difference in the growth projections among the Constrained Core Concentration (#4), Focused Growth (#3) and Outward Growth (#5) alternative scenarios. In reviewing the description for each scenario, one would expect that the projections for San Rafael would be much lower for the Constrained Core Concentration scenario, as this scenario focuses more growth in the inner urban areas as compared to the other two scenarios. Under all three scenarios, San Rafael is in the outer urban area. Elements of the Core Concentration Scenario (#2, unconstrained) are concerning and questionable. Specifically, the latest public draft description of this scenario includes a section entitled "game changers." This draft defines game changers as "places where capacity exists for a high level of growth and is envisioned to occur given supportive policies and resources." This draft lists Southeastern San Rafael as a "game changer." We understand that the geographic area of Southeastern San Rafael is identified as the industrial area located south of Downtown San Rafael (essentially the Woodland Avenue/Francisco Boulevard West area). This geographic area is fully developed and cannot support additional growth because of numerous constraints including limited traffic capacity. Most importantly, this area of San Rafael provides most of Marin County's needed trades services (auto repair, home improvement services and supplies, etc.), which are critical to retain for the county as a whole. Without these services, Marin residents are forced to go elsewhere (outside of Marin County) to get these service needs met, which is not sustainable. Our San Rafael General Plan 2020 has very clear policies that promote the preservation and protection of the industrial uses because of their critical service to the Marin County. For these reasons, the City of San Rafael would strongly oppose any substantial growth or planned land use changes for this area. i Jobs are not clearly defined and are grossly inflated. In reviewing the supportive materials describing the scenarios, there is no indication if, how or what percent of new jobs include self-employed persons that work from home, or even an expectation of job growth for existing, established businesses (which, under current economic conditions many have downsized). In communications with your staff, we were informed that ABAG defines jobs to include both full- and part-time employment of wage and salary workers, plus self-employed persons. We were also informed that jobs are projected by place -of -work, not place -of -residence. So, if one were to conservatively look at the jobs projections solely being accommodated by new development, a conversion of jobs to building area needs to be logically considered. If a job equates to an average of 275 square feet of building area, the job projections for San Rafael could equate to upwards of 3.7 million square feet of additional commercial building area. This amount of commercial building area development in a fully -developed community is unrealistic. Attachment 4 %I R_ FTRa RAPPORT. ABAG IWUARY 2G, 2012 Nc,F. 3 Even if we were to account for a reasonable percentage of work -from -home jobs and infill of jobs with now -vacant office/retail space the job projections are far more than those planned by our San Rafael General Plan 2020. In summary, we find the jobs projections to be grossly inflated and are much greater than the job growth experienced between 1995 and 2010. Y Increase in Marin iob proiections is puzzling. It Is unclear why the job projections increased in Marin under all three scenarios as compared to the IVS projections (upwards of 50% for San Rafael), while the job projections for these alternatives decreased by 19% for the Bay Area region. In fact, many of the job -center counties and cities that can sustainably support more jobs have decreased by upwards of 30%. Further, San Rafael is shown to have the highest projections for job growth as compared to the rest of Marin. San Rafael presently provides the bulk of employment for Marin County and the future job growth should be more evenly distributed throughout the county. d Comparison of Marin housing projections to region. Under all Alternative Scenarios, the housing growth for Marin County is projected to be a 10% increase by 2040. By comparison, a 34% housing growth is projected for the Bay Area region (all counties combined) by 2040. The total projected households for Marin is a reasonable proportion of the growth being planned for the Bay Area. This proportion is reinforced by the fact that Marin County is home to national and state parks and recreation areas, as well as a substantial network of preserved agricultural lands. Housing proiections reduced and re -distributed. For three alternative scenarios, the housing projections for San Rafael have been significantly reduced (down by a range of 20-50%) from those presented in the IVS (except for Civic Center PDA). It is acknowledged that the housing growth projections for these alternatives are more evenly distributed throughout the Marin County. Thank you for responding to our IVS comments regarding the re -distribution. Y Projections for San Rafael PDAs. The projections for the two, San Rafael PDA's still represent an inequity of growth distribution both in jobs and housing. San Rafael made a conscious decision when designating these PDA's that they would be areas that are suitable for higher densities/intensities because of access to SMART rail service. We understand that if the City were to consider withdrawing/dropping the PDA designations, it would not significantly change either the housing or the jobs projections for San Rafael or Marin County. However, the jobs and housing projections for the PDA's should be further reduced and redistributed so that there is a more equitable and even distribution of this projected growth along the SMART rail corridor throughout Marin County. While the alternative scenarios show substantial reductions in the housing projections from the IVS projections, this adjustment is offset by the unrealistic jobs projections. San Rafael does not have the adequate transportation infrastructure to support the collective housing and job projection numbers. Even though San Rafael has chosen to designate two PDA's, the projection numbers are clearly impractical and inequitable. Attachment 4 MR. I.ZRA RAPPORT, ABAG JANUARY 2G, 2012 PAOL 4 Comments on Study Results for Alternative Scenarios In reviewing the study results, it is interesting to find that some of the SCS goal targets would not be reached by any of the Alternative Scenarios. Specifically, the target goals of reducing vehicle miles traveled (per person), CO2 emissions from cars/light trucks, and GHG emissions by 2035 would not be reached. In this study, it is stated that since certain target goals would not be reached, the SCS process will need to look at other measures to meet these targets. Other measures could be more dramatic and/or significant, including additional adjustments to the local growth projections for housing and jobs. This conclusion is concerning as the Preferred Alternative could result in further increases or changes in the growth projections from those presented in the Alternative Scenarios. Before there is a determination to go in this direction, consideration should be given to other measures that may off -set the target goals. For example, the study reports that the target goals of achieving 100% of protection of open space and agriculture would be reached. When you are reviewing other measures to meet all of the target goals, it is important to remember and critical to consider that Marin County has and will continue to significantly contribute to the region's protection of open space and agriculture. Credit should be given to Marin County's regional contribution in reaching these targets. We appreciate the opportunity to review and comment on the Alternative Scenarios and the study results. We will continue to monitor the SCS process and look forward to reviewing the Draft Preferred Scenario when it is completed and published and available for public review. Sincerely, rl.Q-1 Paul A. Jensen, AICP Community Development Director cc: Mayor and City Council Planning Commission City Manager City Attorney Public Works Director Economic Development Director Transportation Authority of Marin SCS.ABAG Itr 1-20-2012 Attachment 4 CITY OF MAYOR ALBERT J. BORO J VICE MAYOR GREG BROCKBANK COUNCILMEMBER DAMON CONNOLLY COUNCILINIEMBER BARBARA HELLER COUNCILMEMBER MARC LEVINE' COMMUNITY DEVELOPMENT DEPARTMENT PHONE: 415-485-3090 FAX: 415-485-3184 Ezra Rapport Executive Director, Association of Bay Area Governments P.O. Box 2050 Oakland, CA 94604-2050 May 5, 2011 Dear Ezra: This letter is in response to your request for feedback on the recently -released Initial Vision Scenario (NS). The IVS outlines a possible growth scenario for the Bay Area in 2035, and is the first step in a series of draft alternatives that will inform an eventual Sustainable Communities Strategy (SCS) to implement SB 375 and address the important issues of climate change in our region. San Rafael endorses the value of regional planning with the intent to affect climate change by reducing greenhouse gas emissions. San Rafael is a leader in the Bay Area in adoption and implementation of strategies to address climate change. The City acknowledges the need to effectively coordinate jobs, housing and transportation investments that maintain a dynamic and growing regional economy that benefits everyone in the Bay Area. San Rafael also recognizes the coming demographic changes to the region (particularly household formation trends and an aging population) and how that will impact housing needs and the demand for housing types other than traditional low density, detached single family development. The IVS is appropriately based on assumptions that the Bay Area's growth will be contained within the region, and within existing urbanized areas, specifically within Priority Development Areas (PDAs). However, in Marin County, just one city, San Rafael, applied for PDA designations at its future SMART stations. The result was that this first SCS scenario represents an inequity of growth distribution both in housing and jobs in Marin County, and a disproportionate allocation of growth to San Rafael, which is assigned half of the County's projected household growth for the next twenty-five years. The projected household growth rate in the IVS for San Rafael is double that experienced during the housing boom of the early 2000's. This growth simply not be accommodated within the City's infrastructure capacity or created by manufactured real estate demand. To that end, the Mayor and City Council of San Rafael asks that an Alternate Scenario be included in the next round of SCS work that would include a distribution of housing based on two factors: • Half of the future housing growth in Marin would be based on an even distribution of housing among jurisdictions based on their current proportion of countywide housing, and • Half of the future housing growth would be located along the SMART rail corridor, which would result in an additional increment of housing growth equally distributed among the five planned SMART stations. This alternate distribution would be supportive of Marin's pattern of thriving and unique communities, and the creation of successful transit -oriented neighborhoods around each of the new SMART rail stations. 1400 F1FTu AVENUE • PO Box 151560 • SAN RAFAEL, CA 94915-1560 GVW W.CITYMANRAFAEL.ORG Attachment 5 San Rafael is supportive of focusing an appropriate and equitable level of future development within our two PDA designations, but an over -concentration of the County's growth within these two locations may make it necessary for San Rafael to withdraw the PDA designations. In addition, the City Council wishes to transmit the following more general comments regarding the SCS process and outcomes: ■ Marin's role in providing recreational space for the Bay Area should be taken into consideration in the allocation of transportation funds to encourage the use of transit to regional recreational amenities. ■ Since the basis for the proposed density increases is the reduction of greenhouse gas emissions from passenger vehicles, Marin should be given credit for what will certainly be a significantly higher proportion of electric vehicle ownership, powered by Marin Clean Energy. The desired increase in density in already developed areas is dependent upon significant increases in the funding of transit and alternative modes of transportation if quality of life is to be maintained. ■ Housing Element law should be amended to give deference to compliance with the adopted SCS in HCD's evaluation of housing elements. ■ State HCD needs to be more flexible in its administrative policies related to the counting of housing units towards local needs, particularly housing for seniors and mixed use redevelopment of underutilized sites. ■ ABAG, MTC, BCDC and BAAQMD need to coordinate their policies to support the implementation of the SCS, and not create impediments. CEQA exemptions are needed for development consistent with the adopted SCS. We appreciate the efforts that you and your staff are making in this unprecedented process, and the challenges of balancing such diverse interests. We will continue to monitor the refined SCS scenarios, and encourage ABAG to provide a more equitable distribution of growth in Marin. Sincerely, Robert M. Brown Community Development Director cc: Mayor and City Council Planning Commission City Manager City Attorney Transportation Authority of Marin Attachment 5