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  Regular-Community Services   # 32.       
Board of Supervisors   
Meeting Date: 06/04/2013  
Brief Title:    Draft Dunnigan Specific Plan
From: John Bencomo, Director, Planning and Public Works Department
Staff Contact: David Morrison, Assistant Director, Planning and Public Works, x8041
Supervisorial District Impact:

Subject
Direct staff to begin the formal environmental review process of the application for the Dunnigan Specific Plan and prepare the Environmental Impact Report (EIR), once all required materials have been satisfactorily submitted, provided all of the following specific revisions have been incorporated into the Specific Plan. (No general fund impact) (Bencomo/Morrison)
Recommended Action

Direct staff to begin the formal environmental review process of the application for the Dunnigan Specific Plan and prepare the Environmental Impact Report (EIR), once all required materials have been satisfactorily submitted, provided all of the following specific revisions have been incorporated into the Specific Plan:

  • Comprehensive mitigation program for the conversion of all farm land developed to non-agricultural uses at a minimum 1:1 ratio;
     
  • Detailed program that includes a commitment to take effective actions if the jobs/housing balance has not been achieved at the end of any phase;
     
  • Detailed proposal to extend sewer and water lines into the Hardwoods and Old Town neighborhoods, to be included as a part of the Development Agreement;
     
  • Programs to achieve a maximum of 44 vehicle miles of travel (VMT) by plan build-out;
     
  • Affordable housing program consistent with the County Inclusionary Housing Ordinance, or equivalent; and
     
  • Greenhouse gas emission reduction objective for the Specific Plan, along with the necessary actions needed to achieve the objective.
Should staff’s recommendation not be supported, the Board of Supervisors may allow the application to proceed as currently written, augmented with General Plan Amendment application(s) that would allow deviation from one or more of the requirements listed above. As a second alternative, the Board of Supervisors may direct staff to reject the application and not pursue the Dunnigan Specific Plan at this time.
Strategic Plan Goal(s)
Champion job creation and economic opportunities
Collaborate to maximize success
Enhance and sustain the safety net
Preserve and ensure safe and crime free communities
Preserve and support agriculture
Protect open space and the environment
Provide fiscally sound, dynamic and responsive services
Reason for Recommended Action/Background
REASON FOR RECOMMENDED ACTION

The Dunnigan Specific Plan is the largest land use development proposal undertaken by Yolo County since the adoption of the Southport Area Plan in 1982.  If approved, it would transform Dunnigan into Yolo County's fourth largest community and would have significant impacts on County services over the next several decades. 

As directed by the Board of Supervisors, staff has been working diligently with the applicant over the past four years to ensure that the draft Specific Plan is consistent with the County goals as expressed in the 2030 General Plan.  However, there are several key concerns that have yet to be resolved.  These issues address fundamental policies adopted by the Board of Supervisors, but they also have important consequences for how the Specific Plan is developed and eventually implemented, and may affect the economic feasibility of the project for the applicant. 

Staff has not yet started the environmental review process for the draft Specific Plan application, and work has not begun on the Environmental Impact Report (EIR). These tasks are expected to take up to 18 months and are estimated to cost the applicant more than $1 million in staff time and consultant contracts. Before the County and the applicant devote substantial resources to this effort, it is critical for the Board of Supervisors to weigh in on the fundamental General Plan issues that have been identified. Consideration by the Board of Supervisors is necessary so that staff has a clear understanding of how to address potential conflicts with the General Plan, and so that the applicant has a clear understanding of the costs required for future project approval.

BACKGROUND

History


On March 4, 2009, a letter was submitted to the Board of Supervisors by Russ Davis on behalf of Elliott Homes Inc.; J. Timothy Lewis on behalf of TL Investments LP and STL Companies, LLC; and Rob Capps on behalf of Doherty Partners 750 LP.  The letter requested that the Board of Supervisors direct staff to accept an application from the signatories for the Dunnigan Specific Plan.  On May 19, 2009, the Board of Supervisors unanimously took the following actions (Minute Order 09-140):
  • Approved the request by the Dunnigan Landowner Group to accept an application for the Dunnigan Specific Plan for processing, prior to adoption of the 2030 Countywide General Plan;
  • Approved the draft Funding Agreement with the Dunnigan Landowner Group to reimburse the county for staff and consultant costs associated with processing of the Specific Plan application in the amount of $1.311 million, and to establish an initial schedule of 18 months for completion of the Specific Plan; and
  • Directed staff to immediately prepare and distribute a Request for Proposals (RFP) to select a consulting firm to prepare the Environmental Impact Report for the Specific Plan
Over the following two years, there were several changes in the membership of the Dunnigan Landowners Group, changes in the applicant's project manager for the Specific Plan, changes in County staffing and in County consultants.  In addition, the recession and the downturn in the real estate market both deepened during this time.  However, staff and the applicant met regularly and worked out a land use plan, developed the Countywide Climate Action Plan, met with Caltrans to address circulation concerns, created the Specific Plan framework, wrote the Transportation Impact Study guidelines, and began evaluating alternative infrastructure models. 

On September 27, 2011, the Board of Supervisors approved four agreements to process the Dunnigan Specific Plan, as follows:
  • Agreement with ASCENT in an amount not to exceed $250,000 for professional consulting services to prepare the Environmental Impact Report (EIR) for the Dunnigan Specific Plan project;
  • Agreement with Tschudin Consulting Group in an amount not to exceed $276,700 for professional management consulting services for the Dunnigan Specific Plan project;
  • Agreement with Fehr & Peers in an amount not to exceed $149,500 for professional consulting services related to the transportation analysis for the Dunnigan Specific Plan project; and
  • Agreement with the Dunnigan Landowner Group to reimburse the County for staff and consultant costs associated with processing of the Specific Plan application in the amount of $1.048 million, and to establish an initial schedule of 18 months for completion of the Specific Plan.
In the past two years, staff and the applicant have focused on residential density, infrastructure design, schools, jobs/housing balance, and economic development.  The first draft of the Specific Plan was provided to staff for review in December of 2012, followed over the following months by drafts of 17 technical appendices.  A revised draft of the Specific Plan was submitted in late April.  Documents related to the draft Specific Plan are provided on-line at http://www.yolocounty.org/Index.aspx?page=1827

Staff has not yet accepted the application as “complete” for processing under the California Environmental Quality Act. As of the date of this staff report, several reports have not been submitted by the applicant, including the revised services financing plan, the revised facilities financing plan, fiscal impact analysis, revised drainage infrastructure plan, revised phasing plan, revised biological mitigation plan, revised agricultural mitigation plan, revised transit plan, and tentative subdivision map.

Issues

In reviewing the draft Specific Plan application and associated appendices, staff has noted several instances where the proposal is inconsistent with adopted County policy, as required by the 2030 General Plan. For each issue discussed below, a summary of the approach proposed by the applicant is provided and relevant General Plan policies and actions are cited, followed by a brief analysis of staff's position regarding the issue.

It should be noted that the issues listed below include those topics where there is significant inconsistency with General Plan policy. Should the application move forward for processing, there will continue to be a wide range of details where interpretation will be made by staff regarding compliance with local, state, and federal regulation, as well as to address fiscal and economic impacts. These technical issues will be evaluated through the EIR and negotiation of the Development Agreement, and presented as a part of the overall recommendation to the Planning Commission and Board of Supervisors (if the project moves forward).

1.     Agricultural Mitigation

Application:
Text on Page 8-13 states: "The high cost of acquiring mitigation land may warrant a departure from the strict application of the Agricultural Land Conservation Ordinance to the DSP."

General Plan: 
Policy AG-1.6 states: "Continue to mitigate at a ratio of no less than 1:1 the conversion of farm land and/or the conversion of land designated or zoned for agriculture, to other uses."

Analysis:
Development of the nearly 2,300 acres of existing farmland in the draft Specific Plan would involve mitigation costs of approximately $23 million.  The applicant has verbally indicated that they would like to mitigate at a lesser ratio such as 0.5:1 (one-half acre of mitigation for each acre of farmland to be developed).  They would also be interested in pursuing an agricultural mitigation strategy that would be completed early in the process, rather than being phased in with each new development.  The applicants suggest that approximately 1,150 acres of agricultural mitigation be provided concurrently with Phase 1, in an area of strategic interest to the County, as a way of accelerating the benefits of protecting farm land, as well as furthering other broad County conservation goals. 

Staff strongly opposes this proposal, as the protection of agricultural land has been one of the highest land use priorities for Yolo County over the past 50 years.  This request would be weaken that commitment, particularly at a time when the  County is currently studying the feasibility of requiring 2:1 mitigation for farmland.  This would also set a landmark precedent that would be requested by other developers.  As a result, this could cumulatively affect the County's work to permanently conserve farm land, as the amount to be mitigated for the Dunnigan Specific Plan represents nearly one quarter of all farm land expected to be converted during the life of the 2030 General Plan.  The mitigation of farm land at a ratio of at least 1:1 was relied upon in the Environmental Impact Report (EIR) for the 2030 General Plan.  Any change from that standard would have to be separately evaluated in the EIR for the Specific Plan.  Staff remains open to other alternative equivalent approaches to agricultural mitigation, including conservation banking, strategic locations outside the two-mile mitigation limit from Dunnigan, and in-lieu fees for smaller developments.  However, given the strong theme of protecting farm land in the General Plan, any amendment that reduces the 1:1 mitigation ratio would be difficult to reconcile with the existing policy framework.

2. Jobs/Housing Balance

Application:
Text on Page 7-7 states: "The jobs-housing monitoring program does not require any particular jobs-housing relationship at the end of Phase 1 of the DSP."

General Plan:
Policy CC-3.3 states: "Ensure that jobs are created concurrent with housing to the greatest feasible extent. Include requirements to ensure a reasonable ongoing balance between housing and jobs by phase. Strive to match overall wages to home prices. For areas within Specific Plans the amount of land designated for residential and job generating uses shall be evaluated during the Specific Plan process, and land uses must be “re-balanced” within each phase in order to achieve a jobs/housing balance of 1.2 jobs per household. A jobs/housing monitoring program shall be established as part of each Specific Plan for its planning area. The jobs/housing relationship (balance, phasing, and match) for each Specific Plan area shall be monitored by phase. If, at the end of any phase, the required jobs/housing relationships are not achieved, the County shall require immediate and effective actions to be taken by the developer to ensure that the required jobs/housing relationship is achieved as a part of any subsequent phase..."

Analysis:
The applicant is concerned that economic development will be challenging in Dunnigan, particularly in the early phases, until there is a sufficiently large population of consumers and workers that would attract potential businesses.  The problem of creating jobs is made even more difficult given the ongoing weak economy.  A strictly enforced jobs/housing balance standard that is not achieved in Phase 1 or 2 could provide the County with the opportunity to halt further development.  From the applicant's perspective, that uncertainty would make it difficult to attract the financing needed to fund significant infrastructure investment over the life of the Dunnigan Specific Plan. Per unit development costs will be high in the early phases of the Specific Plan, with no guarantee of a return in investment should the County prohibit later phase development.

Staff strongly opposes the language proposed by the applicant, as the jobs/housing balance is a key metric in gauging the ultimate success of the Specific Plan.  It is also the basis for the conclusions in several impact areas in the EIR for the 2030 General Plan.  If economic development does not occur concurrently with residential construction, then Dunnigan residents will likely commute to Woodland, Davis, or Sacramento to work.  This would make it very difficult to achieve the greenhouse gas emission reduction targets for this project, and would result in significant additional traffic and air quality impacts.  Equally important, residential construction generally results in negative revenues for the County, as the cost of services exceed the property tax generated by new housing.  Without the supplemental revenues provided by robust economic development in the early phases (e.g., sales tax, transit occupancy tax, etc.), Dunnigan will likely be a drain on County finances, requiring subsidy that would have to be paid from contingencies or cuts in existing programs and/or service levels.  Finally, one of the goals of the County in establishing the Dunnigan Specific Plan is to create a complete and balanced town with businesses that serve local needs and support community institutions such as civic groups, churches, and recreational programs.  Without jobs in the earliest phases, Dunnigan would simply develop as another commuter suburb and would lack the vitality that is crucial to eventually create a self-sustaining community. 

If the jobs/housing balance at the end of Phase 1 has not been adequately met, the County will be faced with a difficult choice: either halt development and leave Dunnigan as an incomplete town and ongoing fiscal liability, or allow subsequent phases in the hope that growth will lead to economic development and risk making the problems even worse if businesses do not come.  The General Plan allows further growth to continue (if the jobs/housing balance is not met), conditioned upon the acceptance of a plan of more effective measures proposed by the developers to ensure the robust economic growth needed to guarantee a balance by the end of each subsequent phase. 

Staff believes that there is room to negotiate a middle ground between the two extremes of inflexible enforcement and no control.  A reasonable jobs/housing target must be established and met by the end of Phase 1.  Economic forecasting is highly variable, especially over the long term, and policies that depend on future business conditions should include the ability for government to adjust and adapt.  Discussions between the applicant and staff may provide the opportunity to structure a framework of thresholds and criteria which provides sufficient assurances for investors while retaining sufficient control for the County to ensure that overall plan objectives are being met.

3.     Infrastructure

Application:
Text on Page 2 of Appendix E states: "Through the course of development in Phases 1-4, adequately sized water and wastewater backbone conveyance facilities (e.g., water transmission mains, sewer gravity lines, or sewer force mains, if necessary) will be stubbed out from Phase 1 to the borders of the Hardwoods and Old Town Districts."

General Plan:
Policy CC-2.2: Ensure that the appropriate base level of rural services and infrastructure for existing development in each community is required in connection with new development.

Policy CC-3.10 states: "In addition to Table LU-11, achieve the following within the Dunnigan Specific Plan growth boundary:" Table LU-11 lists Community Planning Guidelines for the three primary Specific Plan Areas. For Dunnigan, the "Minimum sustainability standards for infrastructure" include: (a) Municipal water system serving entire town; and (b) Tertiary sewer system serving entire town.

Analysis:
The Specific Plan application includes studies which assume both sewer and water capacity for all existing neighborhoods in Dunnigan, including the Hardwoods, Old Town, and Road 8. Trunk lines would be appropriately sized to handle the flow from these areas, water demand includes usage from all existing homes and businesses, and the sewer treatment plant has been sized to accommodate existing development.

The area around Road 8 would be served by sewer and water infrastructure in Phases 3 and 4, as the community grows from north to south. However, both Old Town and the Hardwoods are included in Phase X, which is not assumed to develop beyond what is currently allowed under existing zoning.  In public meetings, the applicant has stated that sewer and water infrastructure would be extended only as far north as Road 5, which is the southern boundary of the Hardwoods, and as far east as the Southern Pacific Railroad, which is the western boundary of Old Town. The application assumes that connecting these neighborhoods to future infrastructure would occur through a separate action and not as a part of the Specific Plan. 

The extension of sewer and water lines into these neighborhoods is an expensive proposition.  A preliminary estimate prepared by staff of the financing plans submitted as a part of the Specific Plan application indicates that sewer/water lines in the Hardwoods and Old Town neighborhoods account for approximately 22 percent of the total proposed infrastructure network of pipes.  Build-out of the sewer and water lines, including trenching and earthwork, is estimated by the applicant to cost approximately $73 million at full build-out.  (This is for installation of the pipes only and does not include the proportional cost of the water and wastewater treatment plants.)  At 22 percent, the cost to extend lines into Phase X could be nearly $16 million.  For comparison, the total infrastructure and public facilities cost is estimated by the applicant to total nearly $550 million for the Dunnigan Specific Plan.

Under existing policy, extending infrastructure to the Hardwoods and Old Town neighborhoods would occur as part of the overhead cost to the applicant.  The partnership does not control any lands within these areas and the Specific Plan does not proposed to redevelop them, so there would be no profit for the applicant to recoup the cost of providing infrastructure services, (although the cost could be reimbursed back to the developer through future connection fees.)  This would be considered a "net gain" to the community and would be implemented as a part of the negotiations regarding the Development Agreement.

Staff opposes the approach proposed by the applicant. The extension of services into the existing Dunnigan community was a key consideration in approving the Specific Plan concept as a part of the 2030 General Plan.  A central theme of the debate regarding Dunnigan during the General Plan hearings was that growth could only occur to the extent that it benefited the community and improved the quality of life for its residents.  Providing sewer and water to residents who currently are impacted by groundwater with high nitrate levels was an important part of the decision.  Not providing these services as a part of the Specific Plan could result in two separate communities and would run counter to the intent of integrating both existing and new neighborhoods into one community.

However, staff also acknowledges the significant costs involved in extending these services, and requests direction to explore collaborative ways to achieve this goal. These could involve one or more of the following: direct subsidy by the applicant; long-term bonds (issued and backed by the County) that could reduce costs to individual homeowners for connecting to services; development impact fees on new residents to help offset costs to existing residents; infrastructure bank loans or grants from the State to assist disadvantaged communities; and allowing further subdivision in the Hardwoods as a financial incentive for sewer/water connections. The timing of when infrastructure is extended would also be a part of this discussion, as improvements required in Phase 2 or 3 would allow more new units over which the additional costs could be spread.

4.     Vehicle Miles of Travel (VMT)

Application:

Text on Page 4-32 states: "The most effective VMT reduction strategies for achieving the General Plan target of 44 will likely depend on specific circumstances associated with future conditions such as fuel costs and other factors that are outside of the County’s regulatory control and would be difficult to predict at this time."

Text on Page 4-33 states: "As noted above, the DSP forecast of 53 VMT generated per household is largely the result of strategies that are reflected in the project’s physical design and represented by the land use and circulation plans of the DSP."

General Plan:
Policy CI-3.20 states: "The Dunnigan Specific Plan shall incorporate a maximum of 44 vehicle miles of travel (VMT) generated per household per weekday through implementation of all feasible actions including but not limited to specifications contained in Policies CC-3.3 through CC-3.6. As part of the specific plan implementation, the VMT performance shall be monitored at each phase...  Achievement of the VMT threshold shall be measured based on the build-out of the plan area phases using a travel demand forecasting model that is sensitive to built environment variables including but not limited to the 4Ds (density, diversity, design, and destination)."

Analysis:
The applicant indicates that they have included all reasonably feasible measures as a part of the draft Specific Plan to reduce VMT, but are unable to reduce the forecast at build-out below the current projection of 53 vehicle miles of travel. However, the applicant has yet to provide a description of the types of programs considered and rejected (such as more aggressive transit), as well as their associated costs, so that staff could independently verify the feasibility of attaining a lower VMT.

It should be noted that the VMT goal set by the County is very aggressive.  It represents nearly a 50 percent reduction of VMT over existing conditions.  For comparison, the Cordova Hills Specific Plan recently adopted by Sacramento County, which has a similar number of units and area to Dunnigan, included a goal of reducing VMT by 25 percent from the projected base case scenario.  

Fehr and Peers, the County's transportation consultant for the Dunnigan Specific Plan, has indicated that there are standard assumptions built into the framework of the VMT computer model that make it difficult for the plan to achieve the 44 goal.  In addition, the VMT model does not take into account the rising popularity of electric and hybrid vehicles, future prices of oil or natural gas, or the increase in telecommuting and Internet shopping.  Any or all of these future variables could increase or reduce the forecasted VMT for Dunnigan.

Staff strongly opposes the proposal to reduce the VMT threshold.  As indicated in Appendix C of the Climate Action Plan, future greenhouse gas emission projections and reductions are entirely based on the expectation that Dunnigan will achieve a VMT standard of 44.   The VMT standard was the basis for several conclusions reached in the EIR for the 2030 General Plan.  It was also a key factor in the acceptance of the Dunnigan component of the 2030 General Plan by both the Sacramento Area Council of Governments (SACOG) and the California Attorney General's office. 

With additional measures, such as increased subsidies for more extensive public transportation (working with the Yolo County Transit District), work force housing (where incentives for housing are provided to employees of local businesses), ride sharing and ride mathing programs, and/or car and bike sharing programs, it may be possible for the Dunnigan Specific Plan to further reduce the 53 VMT currently projected.  Staff believes that additional discussions and considerations of factual data are warranted to explore options for refining the model to make it more accurately reflect the Specific Plan, as well as to incorporate enhanced efforts to reduce the VMT rate. 

5.     Affordable Housing

Application:

Text on Page 7-10 states: "Rather than mandating the sale of a certain percentage of units within the Plan Area to households within the income levels specified in Table 7-3, the DSP has established a range of housing density, and has allocated sufficient units in the RM and RH zones to provide for market-rate housing that is affordable to low and very-low income households."

Text on Page 7-10 also states: "...Historically, some cities and counties required homebuilders to set aside units within otherwise market-rate developments at below-market prices (for rent and for sale). These prescriptive measures have come under scrutiny, with courts restricting the use of such requirements in cases involving both rental and for-sale housing. For these reasons, the Inclusionary Housing Ordinance does not apply to the DSP. Instead, the DSP provides its own Affordable Housing Strategy, which requires the production of low-income and very-low income housing, and relies on presumptions and incentives in the Housing Element to provide housing for a range of household income levels."

General Plan:
Policy HO-5.1 states: "Plan communities to avoid the concentration of affordable housing projects, while ensuring that affordable housing has access to needed services and amenities."

Action HO-A4 states: "Apply resale controls and rent and income restrictions to ensure that affordable housing provided through incentives and as a condition of development approval remains affordable over time."

Action HO-A17 states: "Through development agreements, acquisition and conversion, and City assistance, ensure that 10 percent of all lower income affordable units are affordable to extremely low income households."

Action HO-A58 states: "Disperse affordable housing units throughout each residential development, where required, and require design standards that ensure that affordable units are visually indistinguishable from surrounding market rate units."

Action HO-A84 states: "Maintain and update the County Inclusionary Housing Ordinance, as appropriate, to account for changes in the law and in housing prices."

Analysis:
The applicant has stated that complying with the County's existing Inclusionary Housing Ordinance would be cost prohibitive.  The applicant has also stated, without legal justification, that the Inclusionary Housing Ordinance “does not apply to the DSP.”  As an alternative, they propose to designate sites in the Medium and High Density Residential Zones to provide 10 percent of all units for low-income households and 10 percent for very low-income households.  Any excess units on sites designated for very low-income units would reduce the need for low-income units.  With regards to housing diversity, the applicant proposes to provide incentives for the construction of secondary units ("granny flats") in the Residential Estate and Low Density Residential zones.  Deed restrictions would not be placed on affordable units. 

Yolo County's Inclusionary Housing Ordinance currently requires that 10 percent of new single family homes be set aside for low-income households and 10 percent for moderate-income households. These two categories are targeted because they are the types of housing that the County has historically had challenges in providing.  Affordable units are required to be integrated throughout Low Density Residential neighborhoods, typically in the form of duplexes on corner lots and/or smaller units and lots mixed in with the larger homes.  Multiple-family units are required to set aside 25 percent for very-low income households and 10 percent for low-income families.  All affordable homes are required to have deed restrictions that last a minimum of 20 years. These requirements have been successfully implemented within subdivisions approved and constructed in Esparto and Knights Landing over the past fifteen years.

Yolo County is one of a dozen or so counties (not cities) in California with a mandatory inclusionary housing provisions.  We were also one of the earliest proponents of affordable housing, dating back more than 20 years.  Of the more than 100 cities and counties that have inclusionary housing in the state, only 25 percent of jurisdictions have inclusionary housing rates of at least 20 percent. 

Inclusionary housing has been a topic of much debate in recent years, as the significant decrease in housing prices during the ongoing economic downturn has created a large inventory of affordable homes (although home prices in some areas such as Esparto are beginning to increase again).  Inclusionary housing programs were primarily designed to address skyrocketing prices for new homes, and/or high mortgage interest rates.  Current difficulties for families in purchasing homes today are more likely the result of insufficient down payment, low credit score, and lack of job security.  Inclusionary housing programs are not structured to address these concerns.  Consequently, several cities have recently begun revising their programs to reduce the percentage of affordable housing required and provide greater flexibility in how those goals are met.

Staff is willing to discuss with the applicant alternative affordable housing programs that are equivalent to current County requirements. Reducing the percentage of affordable housing required for multiple-family units from 35 percent to 20 percent, and providing credit for secondary units are both ideas worth exploring. However, staff strongly opposes the concentration of affordable housing in only the Medium and High Density Residential zones and also strongly supports the requirement that affordable housing be enforced through deed restrictions.

6.     Climate Change:

Application:

Text on Page 9-5 states: "In order to comply with the CAP, the DSP incorporates applicable strategies and measures as requirements of development. Table 9-1 identifies the measure and the implementing tool that will be used to verify compliance with each of the applicable measures."

General Plan:
Policy CC-3.5 states: "In addition to Table LU-11, achieve the following within the Dunnigan Specific Plan growth boundary:...  J. Establish a total greenhouse gas emissions objective for all new development in Dunnigan, along with the specific, enforceable actions necessary to achieve the objective."

Action CO-A118 states: "Pursuant to and based on the CAP, the following thresholds shall be used for determining the significance of GHG emissions and climate change impacts associated with future projects:...

2) Impacts associated with GHG emissions from projects that are consistent with the General Plan, fall within the assumptions of the General Plan EIR, consistent with the CAP, and not exempt from CEQA are determined to be less than significant or mitigated to a less-than-significant level, and further CEQA analysis for this area of impact is generally not required.
 
To be determined consistent with the CAP, a project must demonstrate that it is included in the growth projections upon which the CAP modeling is based, and that it incorporates applicable strategies and measures from the CAP as binding and enforceable components of the project.
 
Analysis:
The applicant believes that compliance with a portion of the Climate Action Plan sufficiently addresses the impact of the Dunnigan Specific Plan on greenhouse gas emissions.  The application focuses on green building standards, energy efficiency, and requirements for solar power on new development.   The applicant rejects any consideration of establishing (or joining an existing) Community Choice Aggregation to provide greener energy to the Specific Plan area. 

Projected GHG emissions in energy, transportation, solid waste, and wastewater treatment sectors are attributable to population growth, as described in the projection methodology discussion of each sector. It is worth noting that a sizable portion of the incremental increase in greenhouse gas emissions projections from 2008 and 2030 is attributed in the Climate Action Plan to development in the Dunnigan Specific Plan.  Dunnigan also represents a significant portion of the County’s greenhouse gas emission reduction potential.

Staff agrees with the applicant that full integration of the actions specified in the Climate Action Plan would substantially address the CEQA analysis of the project with respect to any environmental impacts related to climate change. However, staff believes the Dunnigan Specific Plan should be amended to include a GHG reduction target or goal, consistent with the CAP. The computer modeling upon which the Climate Action Plan was based included numerous assumptions regarding the rate at which Dunnigan would develop. If Dunnigan builds out at a faster rate than anticipated, or without the required jobs/housing balance, the impacts on greenhouse gas emissions would be affected. In addition, Dunnigan plays a significant role in the success of the County in meeting its climate change goals.

Establishing a greenhouse gas emission objective for the Specific Plan provides an important metric for use in measuring incremental progress on a large, multi-phased, complex project that will take decades to build. The greenhouse gas objective is as important as other standards such as VMT, jobs/housing balance, and affordable housing in setting benchmarks that future decision makers, staff, and the public can use in determining the future success of Dunnigan.

Developing the objective does not necessarily have to be provided as a part of the Specific Plan application.  Staff would support having the objective developed by the EIR consultant (who also prepared the Climate Action Plan), subject to modification of the consultant contract and agreement by the applicant.

7. Total Number of Homes

Application:
Text on Page 3-1 states: "The Land Use/Zoning Plan and the accompanying Land Use Summary Table 3.1 allocates 8,623 dwelling units within the Plan Area, which includes the housing units that existed prior to the Specific Plan approval. In addition, the Specific Plan has anticipated the potential for 607 additional “secondary” units, which would allow the construction of up to 9,230 total dwelling units."

General Plan:
Policy CC-3.11 states: "The following development capacities shall guide development of the Dunnigan Specific Plan (these numbers are illustrative):... Potential range 2,777 to 10,518 or more units [typical 7269]; General Plan established minimum 5,000 units and maximum 7,500 units by policy."

Analysis:
Staff agrees with this proposal. We believe that the intent of the Board of Supervisors in adopting this policy was to limit the number of new single-family detached homes, exclusive of mixed use units, second units ("granny flats"), existing homes, and/or new units allowed within the existing developed areas of Dunnigan. With this interpretation, the proposed number of homes is consistent with the 7,500 unit limit, meets all necessary density requirements for individual zones as well as the overall community (8 units per acre), and the total proposed number of 9,230 units lies within the accepted maximum range of 10,518 new homes. Staff recommends no further action regarding this issue.
Other Agency Involvement
Staff has worked extensively with the applicant over the past four years on the application.  Presentations on the contents of the draft Specific Plan have been made to the Planning Commission and the Dunnigan Citizens Advisory Committee. 

Staff has also coordinate with SACOG concerning the consistency of the Dunnigan Specific Plan with the Regional Blueprint.  Under the Blueprint, Dunnigan was assumed to begin development after 2035, which is the timeline of the current Metropolitan Transportation Plan (MTP).  Should the Specific Plan eventually be approved by the Board of Supervisors, staff would work with SACOG to integrate Dunnigan into the next update of the MTP.

Fiscal Impact
No Fiscal Impact
Fiscal Impact (Expenditure)
Total cost of recommended action:    $  
Amount budgeted for expenditure:    $  
Additional expenditure authority needed:    $  
On-going commitment (annual cost):    $  
Source of Funds for this Expenditure
$0
Explanation (Expenditure and/or Revenue)
Further explanation as needed:

Attachments
Att. A. Specific Plan
Att. B. Land Use Map

Form Review
Form Started By: dmorrison Started On: 03/27/2012 04:31 PM
Final Approval Date: 05/28/2013

    

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