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September
9, 2002
Mayor
and Council Members
Chair and Members, City Planning Commission
City of Salinas, Salinas City Hall
200 Lincoln Avenue
Salinas, CA 93901
RE:
The Salinas General Plan Update A Time For Extraordinary
Actions
Dear
Mayor Caballero and Council Members:
LandWatch
has previously provided comprehensive comments on the Draft Environmental
Impact Report prepared on the June 2002 Draft Salinas General Plan.
This letter is to comment on the Draft General Plan itself, and
to outline changes that LandWatch believes would strengthen the
June 2002 Draft.
We
hope that the Council will seriously consider the suggestions we
make in this letter, which we will present to you officially at
your September 16, 2002 public hearing. LandWatch also hopes
that the City Council will take the time necessary to make changes
to the June 2002 Draft General Plan, so that the General Plan as
finally adopted will be a stronger and better document.
The
Draft General Plan that will come before you on September 16th has
many positive features. As outlined below, however, we believe that
the Draft General Plan can beand should besignificantly
strengthened and improved. The General Plan that you adopt this
year will have a profound impact on what happens in the City of
Salinas over the next twenty years. Almost certainly, Salinas will
experience unprecedented growth pressures during this time. The
General Plan you adopt should include measures that will help Salinas
defend itself from these growth pressures.
Strong
General Plan policies on housing, school construction, agricultural
land preservation, infrastructure and city finance can help ensure
that the future growth and development of Salinas will result in
positive, and not negative, impacts on its economy, environment,
and on social equity. Absent the kind of strong General Plan policies
outlined in this letter, it is all too likely that future growth
will result in:
- Higher
housing costs, resulting in housing that is ever less affordable
to persons who live in or work in Salinas.
- Increasingly
overcrowded and substandard schools.
- An
accelerated loss of agricultural land, with dramatically negative
impacts on the local economy.
- More
traffic, more noise, and a decline in the quality of life now
available to Salinas residents.
- Significant
new costs to the city and its residents, with resulting cutbacks
in the level of services currently available.
- All
the negative social impacts that go along with a community that
fails to meet the basic housing and educational needs of the majority
of its residents.
Salinas
is in an unusual and extraordinary position, which is why it needs
to take extraordinary measures in its General Plan. The Silicon
Valley is 30-40 miles away. That means that it is also about 30-40
minutes away, in terms of commute times. The Silicon Valley is one
of the most dynamic centers of business expansion in the entire
world. The market in which Salinas finds itself includes
the Silicon Valley. This means that whatever is offered for sale
in Salinas is offered to a market that includes over a million people
who have an average income almost double the average income of a
Salinas resident.
If
the City of Salinas allows residential developments that are just
like what is offered in the Silicon Valleybut that cost lessthe
people with the most money will buy the houses that Salinas allows
to be built. That is what a market economy is all about.
Some people call it the Golden Rule. Those who have
the gold make the rules.
The
General Plan policies recommended in this letter are an exercise
in realism. The geopolitical reality is that
private developers will attempt to build for the market,
and the market includes the Silicon Valley. In fact, the Silicon
Valley will dominate the market in which Salinas finds itself, and
ever more so as time goes on. The Salinas City Council needs to
do something, in its General Plan, that recognizes the real situation,
and that attempts to protect the interests of its residents. We
think the following policies are worthy of adoption. If the Council
prefers some other approach, we again urge the Council to take
the time necessary to strengthen the General Plan, to avoid all
the negative impacts that are otherwise so clearly predictable.
Here
are the areas where LandWatch thinks changes are needed:
1.
Housing
As
we note above, unless some extraordinary or unusual efforts are
made, the normal housing market will not produce housing
that can be afforded by an average income or below average income
person who resides in or works in Salinas. We are urging the
City to take affirmative action to make certain that
future residential development will result in better housing opportunities
for local residents and workers. We recommend a number of different
strategies, to help achieve that objective. Specific
policies are provided at the end of this letter. In brief, we
recommend policies that will:
- Make
a strong inclusionary requirement part of the General
Plan.
-
In Future Growth Areas, increase the amount of medium and higher
density housing, relative to low-density housing, to make sure
that new houses will be more affordable to local residents and
workers.
- Provide
a mechanism to ensure that new housing is offered to local residents
and workers first.
- Ensure
that medium and high-density housing is well designed, and meets
community needs, to avoid a duplication of the kind of poorly
designed high density housing currently found in
East Salinas.
- Require
commercial and office developments to become mixed use,
to maximize housing opportunities.
- Encourage
the reuse and private redevelopment
of underutilized lands within the existing city, to increase
the amount of affordable rental housing.
Inclusionary
Housing As you will see from the specific recommendations
at the end of this letter, we believe that the City should establish
a 40% inclusionary requirement for any new housing built on lands
that are not now inside the city. We recommend this figure, rather
than the 50% or 60% figure that would certainly be justified by
the demographics of the city, because CHISPA, the Countys
most successful nonprofit developer of affordable housing, has
stated that the 40% inclusionary requirement is achievable (with
10% set aside for very low income persons, 15% for low income
persons, and 15% set aside for moderate income persons).
We think the Council should trust CHISPA, and set the inclusionary
figure at 40%.
If
the Council doesnt want to impose a 40% requirement, we
urge it to impose the highest percentage (up to 40%) that it decides
is appropriate. We note that the County of Monterey has recently
decided on a 20% inclusionary figure. Salinas deserves great commendation
for its strong history of requiring inclusionary housing. However,
the current 12% inclusionary percentage should be increased, in
view of the housing crisis confronting the community.
It
is particularly important that the City increase the inclusionary
requirement at this time, before lands are annexed. The value
of land outside the city limits is much less than the value of
the same land once it is added to the city. The increase in value
is truly dramatic. Agricultural land may sell for something like
$20,000 per acre. The value of the same land, when zoned for urban
development, can be $200,000 per acre. A significant inclusionary
requirement, in fact, is the way that the residents of the city
can benefit from the increased land value that is caused by the
residents accepting responsibility for the land annexed.
Whatever
inclusionary percentage is ultimately determined to be appropriate
(even if it is only the current 12%), we urge the Council to include
that inclusionary percentage, as a minimum, in the General Plan.
Placing policies in the General Plan helps ensure that they will
not be waived in the future.
Increase
The Amount of High and Medium Density Housing The
June 2002 Draft General Plan says that most of the new housing
will be built at low density residential standards. That means,
as a practical matter, that most of the new housing called for
in the Draft General Plan will not be affordable to the average
income person who lives in or works in Salinas. The following
Charts outline the general situation:
| Density
Type Specified In General Plan |
Acres
Allocated in General Plan |
Percentage
of Total Acres Allocated |
Housing
Type Affordable By |
Percentage
of Population of Salinas in Income Category |
 |
| Residential
Low Density |
1042
|
61%
of Total Acreage |
Above
Median Income |
21%
of Population is Above Median Income |
 |
| Residential
Medium Density |
515
|
30%
of Total Acreage |
Median
Income (Median Income For Salinas is $43,720) |
22%
of Population is Median Income (Actually Less. This is a generous
estimate) |
 |
| Residential
High Density |
160
|
9%
of Total Acreage |
Below
Median Income |
57%
of Population is Below Median Income |
 |
LandWatch
urges the Council to rearrange the amounts of land
set aside for the different density ranges, to allocate more
land for densities that will result in housing that median and
below median income persons can afford. The current plan allocates
only 9% of the acreage for housing that 57% of the population
of Salinas can afford. It allocates 61% of the acreage for housing
that only 21% of the population can afford. Looking at it from
the perspective of the number of housing units, instead of the
number of acres, the disproportion, while less, is still extreme.
The Draft General Plan projects only 17% of the housing units
to be built will be affordable by 57% of the current population.
In
addition, LandWatch urges the Council to establish minimum
densities for all of its residential land use designations,
to make sure that developers dont under develop
lands that are being counted upon to provide housing for lower
income persons.
Give
Local Residents and Workers The First Opportunity
For Housing The policies we advocate, contained at the
end of this letter, would require the City to set up an administrative
mechanism to ensure that residents of and workers in Salinas get
a maximum opportunity to participate in the review of proposed
new housing developments, and that local residents and workers
will get the first opportunity to rent or purchase
all new housing constructed. This is an extraordinary policy recommendationbut
Salinas is in an extraordinary situation. Genuine affirmative
action on behalf of local workers and residents is needed.
Otherwise, they will simply be outbid by people who
have higher incomes, earned elsewhere.
Insure
Good Housing Design The kind of high density
housing that has been built in the past leads to significant social
and community problems. The policies we recommend would make sure
that high and medium density housing built in the future will
provide residents with the type of community facilities and amenities
that will make these higher density developments attractive and
livable.
LandWatch
also recommends policies to make more certain that parks and libraries
are made available, as needed, as new growth occurs. Our specific
suggestions strengthen the policies of the June 2002 Draft
Require
Mixed Use Developments To Maximize Housing Opportunities
The policies we recommend go beyond allowing
developers to utilize mixed use techniques to increase
housing opportunities. They require such development, as a general
principle. Again, this may seem like an extraordinary policy.
Its a policy that could have extraordinary and very positive
results.
2.
Schools
State
law makes it very difficult (almost impossible) for the City to
turn down a development that it knows will overcrowd local schools.
In fact, the City is directly prohibited from denying a development
on that ground. You can turn down a development because it will
overload the sewer system, or the storm drainage system, but you
cant deny a project because it will overload the school
system.
Given
that current state law, the policies we recommend would give the
City the maximum leverage possible, to make sure that new developments
dont overwhelm the local school districts.
3.
Agricultural Land Preservation
LandWatch
believes that the City of Salinas should modify its Land Use Map,
and that it should significantly reduce the amount of land it
proposes to annex and develop over the next twenty years.
That
said, the policies we recommend would not result in any such change.
Our recommended policies on agricultural land preservation are
intended simply to make sure that the lands that the Draft General
Plan says are agricultural will actually remain agricultural,
over the twenty-year life of the General Plan.
Protecting
commercially viable agricultural land for agricultural use is
an economic issue, not an environmental issue. The policies we
recommend are truly modest, but that is not to say
that they would be ineffective. They would make a real difference.
We urge the Council to provide the maximum protection possible
for the lands that the Draft General Plan indicates should remain
in agricultural use.
4.
Traffic, Noise, and Water
The
Draft Environmental Impact Report indicates that Salinas will
experience increased traffic congestion, noise, and diminished
water resources if various planned infrastructure improvements
are not in fact built as forecast.
We
recommend policies to insure that if infrastructure starts falling
behind, new growth will be suspended, until the necessary infrastructure
is in fact made available. The current Draft General Plan doesnt
have this kind of circuit breaker policy. It needs
such a policy, to protect the citys quality of life, and
to tailor future growth to the infrastructures and services needed
to support it.
5.
City Finance
We
recommend policies to help make sure that the Citys finances
are not undermined, as new development occurs. Bigger
is not (automatically) better. The opposite may be
the case. The most common result in fast-growing California cities
is for new development to benefit the developers, and to lead
to a genuine economic crisis for the local community, with increased
debt, and a diminished level of services. We hope the City will
strengthen the policies in its Draft General Plan, to address
this very real life concern.
6.
Other Issues
The
LandWatch / Creekbridge Design Principles We believe
that these principles should be incorporated into the final General
Plan. They are in addition to, and not a substitute for, the other
policies we recommend.
No
Roads In Carr Lake We strongly urge the City Council
to remove the new roadways shown on the Land Use Map, cutting
through the center of Carr Lake. We believe these roadways are
inconsistent with other provisions of the Draft General Plan,
and are ill advised.
No
Eastern Bypass We urge the Council to remove
the so-called Eastern Bypass, not only because of
its conflict with the Airport (which is not an inconsiderable
problem), but because it would have growth-inducing and traffic
generating effects that would injure, not assist, with traffic
problems in the City. The City should use land use planning techniques
to reduce the need for this kind of new roadway.
Thank
you for taking our comments into consideration. As noted above,
our specific policy recommendations are outlined on the following
pages.

| cc: |
City Manager
City of Salinas Planning Staff
Salinas Planning Commission
Salinas Library Commission
Salinas School Districts
Monterey County Board of Supervisors
CHISPA
Latino Issues Forum
Líderes Comunitarios de Salinas
Citizens For Responsible Growth
CSUMB Watershed Institute
Housing Advocates
Interested Persons
LandWatch Website (www.landwatch.org) |
Specific
Policy Recommendations
LandWatch
Monterey County urges the Salinas City Council to include the following
policies in the final version of the Salinas General Plan. Each
numbered policy contains the specific language we recommend:
| Housing
|
| 1. |
A
Policy Commitment To Affordable Housing The lack
of adequate affordable housing within the community is causing
extremely serious economic, public safety, social, and environmental
problems. These problems constitute a community crisis, and
absent the policies established within this General Plan, new
commercial and residential developments within the community
will make these problems worse. It is critically important for
the public health, safety, and welfare that all new developments
within the community help provide additional housing opportunities
for persons who live and work in the community, and particularly
for those persons with very low, low, or moderate incomes. |
| 2. |
Affordable
Housing Defined Affordable housing
for persons and families with very low incomes
shall be defined as housing that is capable of purchase or
rental by persons or families with incomes at or below 50%
of the median income in this community, with the understanding
that a person or family with a very low income should not
be required to use more than 30% of that income to meet housing
needs.
Affordable
housing for persons and families with low incomes
shall be defined as housing that is capable of purchase or
rental by persons or families with incomes from 50% to 80%
of the median income in this community, with the understanding
that a person or family with a low income should not be required
to use more than 30% of that income to meet housing needs.
Affordable
housing for persons and families with moderate
incomes shall be defined as housing that is capable of purchase
or rental by persons or families with incomes from 80% to
120% of the median income in this community, with the understanding
that a person or family with a moderate income should not
be required to use more than 30% of that income to meet housing
needs.
In
all cases, when housing is constructed within the community
as affordable housing, such housing will be capable
of purchase or rental by persons of very low, low, or moderate
incomes, and will be permanently protected for sale or rental
to persons and families with very low, low, or moderate incomes,
through deed restrictions or other equivalent and effective
methods.
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| 3. |
An
Inclusionary Requirement For New Residential Developments
When lands are annexed to the City for the construction
of residential housing, an affordable housing requirement shall
be imposed as a condition of project approval: 10% of the housing
units constructed shall be capable of purchase or rental by
persons or families with very low incomes; 15% of the housing
units constructed shall be capable of purchase or rental by
persons or families with low incomes; and 15% of the housing
units constructed shall be capable of purchase or rental by
persons or families with moderate incomes. All such housing
shall truly be inclusionary, and shall be constructed
within each individual development. No offsite transfer of such
inclusionary units shall be permitted. All inclusionary affordable
housing shall be built either prior to or concurrently with
the market-rate housing built within the residential subdivision
or residential housing development, and all such inclusionary
housing shall be permanently protected for sale or rental to
persons and families with very low, low, or moderate incomes,
through deed restrictions or other equivalent and effective
methods. |
| 4. |
New
Jobs And New Housing Go Together When newly constructed
professional office, industrial, or commercial facilities create
50 or more new jobs, the employers utilizing these new facilities
shall be required to help provide, directly or indirectly, new,
permanently affordable living quarters, to help meet the housing
demand generated by the new jobs. |
| 5.
|
Establish
Minimum Density Requirements The Land Use Classification
System established within the General Plan shall provide for
minimum as well as maximum densities within each of the Residential
Land Use Designations. The minimum density for the Residential
Low Density Land Use Designation shall be 6.5 DU/Net Acre. The
minimum density for the Residential Medium Density Land Use
Designation shall be 11.75 DU/Net Acre. The minimum density
for the Residential High Density Land Use Designation shall
be 16.75 DU/Net Acre. |
| 6. |
More
Land For Medium and Higher Density Development
Of all those lands designated for residential development
within the community:
- No
more than 40% shall be designated for low-density residential
development.
- 40%
or more shall be designated for medium-density development;
and
- 20%
or more shall be designated for high-density residential
development.
The
Land Use Map included within the General Plan shall reflect
these designations.
|
| 7.
|
Ensure A Range of Housing Types New residential developments
shall include a mix of low-density, medium density, and high-density
units. |
| 8. |
Mixed
Use Developments To Increase Housing Opportunities
New commercial and professional office developments within
the City shall incorporate residential housing opportunities
on site. Existing commercial and professional office developments
shall be encouraged to redevelop and reconfigure uses to incorporate
new residential housing opportunities. Notwithstanding this
general rule, the City may make a finding that it would be inappropriate
to require on site residential housing in a proposed new commercial
or professional office development, and in that case shall require
equivalent residential housing to be constructed at an offsite
location. |
| 9. |
Design
Housing To Meet Community Needs Every new residential
development constructed at either Medium or High Density shall
incorporate all of the following design features:
- ß
On site recreational facilities, appropriately sized to
serve the needs of the residents of the development.
- ß
On site childcare facilities, or the provision within the
development of one or more units specifically designed to
accommodate family day care, including necessary outdoor
space, and appropriately sized to serve the needs of the
residents of the development.
- ß
Indoor space, including simple kitchen and restroom facilities,
to accommodate educational, social service, and similar
programs, and appropriately sized to serve the needs of
the residents of the development.
|
| 10. |
First
Right To Rent or Purchase The City shall establish,
maintain, and administer a list of persons who live in or
who work in the community, and who are interested in renting
or purchasing new housing to be constructed in the community.
The government shall give written notice to everyone on this
list whenever a new housing development of five or more units
is proposed, and is set for public hearing.
When
residential housing developments are approved within the City,
or within any area proposed to be annexed to the City, it
shall be a condition of approval that the new residential
units constructed shall first be offered for rental or sale
to individuals who currently live in or work in the community,
and who have indicated their interest in renting or purchasing
new housing constructed in the community by having their names
placed upon the list maintained by the City.
|
| 11. |
Parkland
To Be Provided Developments within Future Growth
Areas shall be conditioned to provide all the land and improvements
required to achieve the parkland standard of three acres of
developed public parkland per 1,000 residents, and to construct
and provide the facilities necessary to meet existing and future
park acreage needs, as referenced in Table COS-5. All new parks
constructed within the City shall meet, at a minimum, the park
standards established in Table COS-2. |
| 12. |
Libraries
To Be Provided New developments shall be conditioned
to provide the funding necessary for the City to achieve the
recommended standard of 0.5 square feet of library space per
capita. |
| Schools
|
| 13. |
Notice
To School Districts When Developments Proposed When
any person submits an application to the City for the development
of fifty or more residential units on property either in the
City, or proposed for annexation into the City, a full copy
of that application will promptly be furnished to each school
district in which such property is located. Each affected school
district will be formally invited to submit a report to the
City, documenting any impacts that the school district believes
might be caused by approval of the application. Upon request,
City staff will consult with and assist each affected school
district in submitting such a report. A full copy of the report
submitted by a school district, pursuant to this policy, will
be furnished to the Planning Commission and the City Council,
at the time that the Planning Commission and the City Council
considers the project application. |
| 14. |
School
District Consultation Prior to Project Approval Prior
to the approval of any application for the development of fifty
or more residential units, the City shall consult with each
school district in which the property proposed to be developed
is located. If a school district submits a report documenting
that the proposed development, if approved, could have negative
impacts upon existing school facilities, and requests that some
or all of the property proposed for development be reserved
as a school site, the City Council shall take action to amend
the City General Plan to designate an appropriate and adequate
portion of the property as a school site, pursuant to the authority
provided by Government Code Section 65998. |
| 15. |
Recognition
of School Overcrowding If, pursuant to Government
Code Section 65971, the governing body of a school district
which operates an elementary or high school has notified the
City Council that conditions of overcrowding exist in one or
more attendance areas within the district, and that these conditions
of overcrowding will impair the normal functioning of educational
programs, and if the City Council has concurred in the findings
submitted by the district, then the City Council, basing its
authority on Government Code Sections 65996(a)(2) and 65997(a)(7),
and Government Code Section 65972, shall not approve an ordinance
rezoning property to a residential use, grant a discretionary
permit for residential use, or approve a tentative subdivision
map for residential purposes within such areas, unless the City
Council makes a finding that there are specific overriding fiscal,
economic, social, or environmental factors which justify the
approval of a residential development. |
| Agricultural
Land Preservation |
| 16. |
Protection
of Lands Designated Agriculture Land
designated as Agriculture on the Land Use and Circulation
Policy Map (Figure LU-3) shall be protected and preserved for
agricultural use. |
| 17. |
No
Utilities on Agricultural Lands The City shall not
extend sewer or water services into or across any lands designated
as Agriculture on the Land Use and Circulation Policy
Map (Figure LU-3). |
| 18. |
Agricultural
Land Protection Boundary An Agricultural Land Protection
Boundary is hereby established. All of the areas located within
the Agricultural Land Protection Boundary may be developed,
consistent with the provisions of this General Plan. The following
lands designated on the Land Use and Circulation Policy Map
(Figure LU-3) are hereby determined to be within the Agricultural
Land Protection Boundary, and are therefore potentially developable
according to this policy: Residential, Retail, Arterial Frontage,
Office, Business Park, Mixed Use, General Commercial/Light Industrial,
General Industrial, Parks, Public/Semipublic, and Open Space.
All areas designated for Agriculture on Figure LU-3 are hereby
determined to be outside the Agricultural Land Protection Boundary.
Until December 31, 2025, no new development other than public
parks and open space uses (including agricultural uses) shall
be permitted outside the Agricultural Land Protection Boundary.
For the purpose of this policy, open space uses are those uses
defined in Government Code Section 65560, as that section of
law exists on September 1, 2002. |
| Traffic,
Noise, and Water |
| 19. |
Adequate
Infrastructure The City shall regularly monitor
the adequacy of the Citys infrastructure to support
new development, as new development proceeds under the provisions
of this General Plan.
Before
approving any new residential or other development, the City
Council shall require that adequate water and wastewater facilities,
roads, parks, libraries, public safety services, and all necessary
infrastructure improvements will be provided prior to or concurrent
with actual construction of the new development.
Impact
fees shall be imposed, or other arrangements shall be made
as a condition of any project approval, to insure that required
infrastructure, public facilities, and public services will
be provided in accordance with this policy and the other requirements
of the General Plan, and consistent with the Environmental
Impact Report prepared in connection with the adoption of
this General Plan.
Residential
and other developments not located within Future Growth Areas
shall be conditioned to provide the funding necessary to carry
out infrastructure repairs and to make the improvements needed
to eliminate the deficiencies in the Citys current facilities,
as identified in Table COS-3.
|
| City
Finance |
|
Cost-Benefit
Analysis A cost-benefit analysis or fiscal impact
report shall be prepared prior to the consideration or approval
of new residential subdivision project of six or more housing
units, to determine the impacts that additional residential
units will have on existing Salinas neighborhoods and on the
community as a whole. The cost-benefit analysis or fiscal impact
report shall include an examination of the fiscal and service
impacts of the proposed project on roads, water, sewer, storm
water runoff, fire, police, schools, libraries and other community
facilities. Such cost benefit analysis or fiscal impact report
shall identify any impact fees necessary to offset the public
costs that would be caused by the proposed project. |
|
|
posted
09/10/02
|