Subject: PLANNING COMMISSION RECOMMENDATIONS FOR GPU5

September 24, 2007

Dave Potter, Chair
Monterey County Board of Supervisors
168 Alisal
Salinas, CA 93901           

Dear Chair Potter and Members of the Board of Supervisors:

We have reviewed the Planning Commission's recommendations for GPU 5, and completed a comparison of major provisions with those of GPU 4 and the Community General Plan Initiative.  A copy of this comparison is attached.

Our comments are made within the context of this comparison and the proposed Greenhouse Gas Reduction Plan which was added to comply with new state requirements to address global warming.

We note the following significant differences between GPU 4 and GPU 5:

• Nine (9) Rural Centers are reduced to six (6) and seven (7) Community Areas are reduced to five (5), for a total reduction of 1,790 units.
• They are replaced with four (4) Affordable Housing Overlay (AHO) districts with a potential of 2,810 units, an increase of over 1,000 units;  a specific AHO Program to encourage production of a variety of affordable and workforce housing has been added.
• Estimated units that could be built under GPU 4 is 21,520; under GPU 5 it is 19,461 (excludes units that could be built in areas outside Community Areas and Rural Centers).
• Requirements for subdivisions outside of planned areas of development are strengthened.
• Proposed General Plan amendments would be reviewed only once per year and addressed as a package.
• GPU 5 commits the County to tracking the number of housing units approved and actually built each year.
• A mandatory pass-fail evaluation system is proposed for subdivisions outside planned areas of development

We support the following recommendations:

• The reduction in the number of Community Areas and Rural centers.
• The Affordable Housing Overlay concept and the specific criteria proposed by the Planning Commission for projects to qualify for the Program.
• In general, inclusion of the densities included on the 1982 Area Plan maps.
• Use of those densities as a requirement for subdivisions outside Community Areas, particularly those on agricultural land; i.e., no subdivisions smaller than one unit per 40 acres.
• Consideration of one package of General Plan amendments per year.
• The provision that Land Use Advisory Committees shall have an opportunity to recommend changes to Area Plans.

We also recommend following:

1.  The number of housing units allowed in GPU 5 should be further reduced to a level that is more consistent with AMBAG's population forecasts for the region, which recognized major infrastructure constraints to new housing development. The estimated number of housing units that could be built under GPU 5 is currently only 2,000 less than under GPU 4.  It would still allow almost 9,000 more units than proposed in the CGPI.

2.  Affordable and workforce level housing units should be the County's priority and should constitute a larger percentage of the total number of units allowed over the next 20 years.  Simply relying on a 20% inclusionary requirement with 80% market rate has not produced the types of housing that our workers need.  Adding four market-rate homes
for every one that is affordable simply places additional burdens on our infrastructure and does not serve the resident population.  We urge the County to take a leadership role in working with cities, the development community and non-profit organizations to focus on meeting the county’s share of affordable housing.

3.  The Affordable Housing Overlay Districts at Mid-Carmel Valley and near Monterey should be deleted because there is no water.  These Districts should also be identified in Community Areas and Rural Centers where infrastructure is planned and community services are available instead of just encouraged prior to needed infrastructure studies.  They should also be identified adjacent to cities or in immediate proximity to areas where services are available.

4.  Consider adoption of in-lieu fees for all "mega-mansions" built, recognizing that these add to the demand for public services, increase auto traffic and create more service-level jobs, without affordable housing to support them.  The fees could be used to acquire property which could then be placed in land trusts to be maintained in perpetuity for affordable housing.  This could be a means of providing needed affordable units in areas where land costs are high.

5.  Preservation of the permanent affordability requirement for inclusionary housing units and non-negotiable terms of affordability for workforce housing.

6.  Mapped land use densities for areas severely constrained by lack of infrastructure, such as in North Monterey County, should be revised to reduce the number of units allowed per acre.

7.  Adoption of a LOS D standard for areas already at LOS D and Community Areas. Adoption of a LOS C standard for areas at C or above.

8.  Additional criteria for identification of a long-term water supply. At a minimum, water supply projects should be under construction and consistent with the project description in their environmental documents.

9.  Cultivation on slopes over 25% should be prohibited in order to protect wildlife corridors and habitats and oak woodlands, and to prevent water quality degradation through runoff and erosion.

Thank you for your consideration.

Sincerely,

MaryEllen Dick, President                              Janet Brennan , President
LWV of the Salinas Valley                             LWV of the Monterey Peninsula