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
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_dONCITY OF
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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.}.
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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