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HomeMy WebLinkAbout27 RAPC RECOMMEND'S 02-22-94AGENDA NO. 27 · 2-22-94 DATE: FEBRUARY 22, 1994 TO: FROM' SUBJECT: WILLIAM A. HUSTON, CITY MA/~AGER COMMI/NITY DEVELOPMENT DEPAR%74ENT REGIONAL COMPREHENSIVE PLAN- ORANGE COUNTY REGIONAL ADVISORY PLANNING COUNCIL (RAPC) RECOMMENDATIONS RECOMMENDATION It is recommended that the C~5y Council at their meeting of February 22, 1994 concur with RA~Z's recommendations to SCAG on the Regional Comprehensive Plan by authorizing the City Manager to transmit'a letter (see Attachmen: I) to that affect to the SoUthern California Association of Governments (SCAG). FISCAL IMPACT None BACKGROUND For the past two years, the staff of the Southern California Association of Governments (£CAG) has been working on the development of the Regional Comprehensive Plan (RCP). The Plan, authorized by SCAG's Executive Committee, is proposed to set a broad set of goals for the six county Southern California region (Los Angeles, Imperial, Orange, Riverside, San Bernardino and Ventura) and identify strategies for cities and counties to use in guiding decision-making to meet those goals by shaping the area's growth and character. It is proported to be the first comprehensive overview, of the entire region. While the idea may have merit, there has been much concern and doubt expressed by Orange County cities regarding %he Plan. In June 1~92, the City Council authorized the transmittal of a letter to SCAG with responses to a Notice of Preparation for the RCP. That letter expressed our concern regarding a number of potential issues; the Plan's impact on local control by expanding SCAG review powers over local projects to determine consistency with the RCP; .costs associated with implementaticn of the RCP; timeliness and practicality of developing the RCP; legal status of the RCP, and development of Elements beyond %he mandated Elements. The City of Tustin strongly recommended tha: SCAG not pursue the RCP concept. City Council Report Regional Comprehensive Plan - Orange County (RAPC) Recommendations February 22, 1994 Page 2 Due to input received from SCAG member cities, on January 7, 1994 the SCAG Regional Council (previously Executive Committee) took action to direct SCAG staff to proceed with the RCP development with only the three mandated Elements (Regional Mobility Element, Air Quality Element and Growth Management Element). The remaining 10 components originally proposed by staff would be either incorporated into the mandated Elements or developed as separate Elements under approval by the Regional Council.· Orange County interests spearheaded by RAPC have been reinforced at Regional Council meetings. RAPC and Orange County staff have been closely monitoring the development of the RCP and have continued to keep Orange County cities apprised of concerns and issues. City staff has attended numerous SCAG workshops on the RCP as well as a number of RAPC meetings where RCP positions were developed. DISCUSSION City of Tustin staff has separately reviewed and inputed on all previous RCP draft documents including the Notice o~ Preparation, Discussion of Draft RCP and the Draft RCP. The concerns identified by RAPC (see Attachment II) are shared by city staff. The RCP fails to answer a number of critical questions regarding component mandates, SCAG authority, funding, implementation and ramifications on cities. The scope of the Plan is broad and fails to have regional and subregional agreement. On January 20, 1994 RAPC adopted six recommendations. These recommendations (Attachment III) have been forwarded to all Orange County cities and special agencies for consideration and action. Each Orange County city has been encouraged to perform their own --- analysis on the Plan. The recommendations transmitted by RAPC represent the views of various Orange County cities that have provided input to County staff. Cities have been requested to take action on the recommendations in the form of adoption of a Resolution or a support letter from the Council or City Manager. All Orange County city responses will be combined and forwarded to SCAG by March 1, 1994. It is expected that a combined Orange County response will have a greater impact on the SCAG Regional Council when they have their final vote on the RCP at their April 7, 1994 meeting. City Council Report Regional Comprehensive Plan - Orange County (RAPC) Recommendations February 22, 1994 Page 3 cities who do not wish to support RAPC's recommendations are still encouraged to submit responses to SCAS on the RCP separately. CONCLUSION The RCP as written has the potentia2 to affect local land use control; provide SCAG with new roles and powers; affect local financial resources and create a new level of bureaucracy. The Regional Advisory Planning Council's (RAPC) recommendations reflect the concerns of the City of /ustin and it is recommended that the City Council support RAPC's position by authorizing the City Manager to transmit the attached ~raft letter (see Attachment I) to the Southern California Associa-ion of Governments (SCAG). Assistant Director Community Development Department Ckristine A. Assistant City Manager RW: CAS :'kbc\rapc · rw ATTACHMENT I .. Letter to SCAG Concurring ~vith RAPC's Recommendations DRAFT FebrUary 22, 1994 Mark Pisano, Executive Director Southern California Association of Governments 818 West 7th Street, 12th Floor Los Angeles, California 90017 Dear Mr. Pisano: I am writing to provide the City of Tustin's comments on Regional Comprehensive Plan (RCP). We have a number of concerns regarding the scope, implementation and funding of the propcsed RCP. On February 22, 1994, the Tustin City Council considered recommendations of the Orange County Regional Advisory Planning Council (RAPC) and supported those recommendations. The Counsil authorized me t© transmit a letter to SCAG supporting RAP-'s recommendations and identifying the following issues: Regarding the scope of the RCP, it is our belief that the Plan should be limited, at this time, to those elements znd components for which there is both a clearly defined mandzne and deadlines in the near future. Currently, only the Grcwnh Management Component/Growth Forecast and the Regional Mobi!ZsY Element fit this category. As currently written, neither nhe Air Quality Element, nor the Housing Element, addresses S2AG mandated roles, and should be removed, along with the other non-mandated elements and components, pending development of a regional consensus on the content and intention of these elements and components. a , SCAG's focus should be limited to RCP components wkzch have adequately defined mandates and near-term deadlines. These include the Growth Management component (SCAS's development of the Regional Growth Forecast), and nhe Regional Mobility Element (long range transportation plan -- for the region). b . The Air Quality component as currently written should not be considered as a "core" component of the RCP, and should instead be addressed in future discussions concerning the RCP's voluntary components. C - The Housing component as currently written should non be considered as a ,,mandated" or "core" component of nhe RCP, and should instead be addressed in funure discussions concerning the RCP's voluntary componenns. Letter to Mark Pisano SCAG Feb~aary 22, 1994 Page 2 . Because of its importance to the region, with both state and federal mandates affecting more than $24 billion in public transportation investment over the next seven years, we urge that the Regional Mobility Element remain as SCAG's highest priority. , Regardless of the ultimate breadth of the final RCP, all assumptions as they relate to the regional forecast should be based on market trends/best estimates of future growth, and not policy projections that are artificially derived and do not reflect local/subregional estimates of such growth. With the exception of the Growth Management component and Regional Mobility Element, all remaining RCP components should be removed from the RCP at this time so that discussions among the subregions regarding their content and intention can occur and regional consensus can be developed on how the RCP should or should not fit into local government decision-making and permit review. Funding sources for continued work on these components should be clearly identified, and SCAG should not in any instance utilize funds earmarked for transportation purposes for these efforts. ThaDf< you for your consideration of our position on these important issues. Sincerely, Wil!=am A. Huston City Manager W~: RW: k~c\pisano, l~r cc: Stan Oftelie - OCTA Bill Hodge - LOCC, OC ATTACHMENT II RAPC Transmittal letter- January 26, 1994 and Summary of Issues RAPC Orange County Regional Advisory and Planning Council ' RECEIVED -- 2 7 199Zl ADMINISTRATION January 26, 1994 William A. Huston, City Manager City of Tustin 300 Centennial Way Tustin, CA 92680 Mr. Huston: SUBYECT: Orange County Regional Advisory and Planning Council Recommendations on SCAG's Draft Regional Comprehensive Plan Attached for your city's consideration please find recommendations from the Regional Advisory and Planning Council (RAPC) regarding Orange County's input into the Southern California Association of Government's (SCA(3) draft Regional Comprehensive Plan (RCP). As you may recall, last year thc County of Orange, Orange County Division, Ix:ague of California Cities, and the Orange County Transportation Authority (OCTA) entered into a Memorandum of Understanding with SCAG to utilize a "bottom up" approach to regional planning by developing Orange County's input to certain components of the RCP. These components included Regional Mobility, the land use and transportation control measures in the Air Quality Management Plan (AQMP), the Regional Housing Needs Assessment HNA), and the supporting demographic projections. SCAG proposed to package these components-with othe/r items of regional interest (such as water quality, finance, human services) into a 13-component Regional Comprehensive Plan in order to take a sweeping and comprehensive look at the region, its problems and possible solutions. However well intended this may be, it has been the subject of cc, ntinu.-~i controversy since the release of SCAG's Notice of Preparation for the corresponding ~IR in April,_.1992. Working through the established Countywide committee structure of the Executive Steering Corem/tree (F. SC) and RAPC, Orange County's position has steadfastly been that SCAG staff should focus on the mandatory plans first; other components could subsequently be pursued so long as nbn-transportation moneyi were identified and there was regional consensus on how such components should be developed. Orange County interests have repeatedly stated, both in writing and at Regional Council meetings, that there are inherent dangers in developing a Regional -Comprehensive Plan. of such broad scope, without first having regional and subregional agreement on how the RCP should or should not fit into local government decision-malting. ? January 26, 1994 Page Two Based upon input from ESC (which includes City Managers from around the County), city and county staff, special agencies (such as Sanitation Districts, OCTA and the Transportation Corridor Agencies) and the private, sector, the attached recommendations were adopted by RAPC at theix meeting of January 20, 1994. They have been sent to SCAG's Regional Council members as RAPC's recommendations to the interested parties within Orange County. In accordance with our Work Program with SCAG, we are forwarding them to you for consideration and action by you and/or your City Council. It would be appreciated if you could review the attached recommendations, and, if you concur with RAPC's approach to the RCP, take action on them during the next few weeks and transmit such action to Bill Hodge at the League of Cities. Although we are confident that these recommendations collectively reflect Orange County's sentiment on the RCP, please note that RAPC's recommendations are only advisory. You may choose to submit separate correspondence to SCAG. In such instances, it would be appreciated if copies of your correspondence to SCAG are also sent to Bill Hodge at the League of Cities. In that the SCAG Regional Council is scheduled to vote on the RCP at their April 7, 1994 meeting, we ask that you have comments/action transmitted to the League of Cities for packaging and delivery to SCAG by March 1, 1994. Thank you for your attention to this matter. In addition to RAPC's recommendations, this transmittal includes some bad,ground information on the RCP which was developed to assist you in your review of this lengthy document. If you have any questions, please contact Bill Hodge, League of Cities at 97243077; Tony Carstens, County of Orange at 834-5111, or Cindy Krebs, OCTA at 560-6282. Sincerely, Tom Day,Chairman Regional Advisory and Planning Council .Mayor of Anaheim CH:mm SCAG's Regional Comprehensive Plan Summary Of Orange County Issues and Recommendations Regional Advisory and Planning Council Meeting of January 20, 1994 Dlscus~iQn: Should the Regional Compreh'ensive Plan (RCP) Include 15 chaptem and 13 components as currently proposed by SCAG staff, or should it be more limited In scope? A. Issue has been at the heart of the RCP debate among Orange County interests since RCP Notice of Preparation was issued in April, 1992 B. SCAG Regional Council discussed the issue during 1992, and in January, 1993 resolved that RCP focus would be on mobility, growth management, housing, air quality, water quality and hazardous waste, with other components "... either being incorporated as relevant into the above required elements or incorporated as separate elements as approprfate and justified and approved by the Executive Committee' (Regional Counc~'l). Ce To date, Orange County interests are largely in agreement that cdticaJ questions remain unanswered or the RCP is unclear regarding component mandates, SCAG a~, funding, Implementation and ranlific, ation8 on jurisdictions and special agencies. Examples include: 1) The "Bottom-up' nature of RCP development: SCA(3 is promoting the RCP aa being developed in a 'Bottom-up' fashion, but most subregions have participated in the development of Ieee than half of the Plan's components (See Attachment A). 2) Profx~ed delegation of implementation responsibilities to subregions Is not applicable to Orange Coun~ A major selling point of the RCP regarda a decen, tralizing of SCAG's Intergovernmental Review to subregions. As proposed in the RCP, submg[onaJ agencies could, be involved in the "certification" of local general ~ar~ The process envisions subregional enUties (~ere is no such entity in Orange County) certifying local generaJ plans as being consi~ with the RCP (See Attachment B). 3) Concerns continue regarding assignment of new roles to SCAG: SCAG, in the RCP, contends that no new roles/mandates for SCAG are created, but many in Orange County disagree. Wrftten comments received contend that SCAG, in several Instances (Water Quality,. Integrated Waste Management, Air Quality/Land Use, Open Space), developing new roles for itself. Many RCP recommendations have no discussion on who would be responsible for implementation, funding, timing, etc. (See Attachment C). 4) SCAG review of plans/projects against RCP are widely perceived as duplicative and bureaucratic. "If the project is found to have a negative impact on the attainment of regional goals, policies or objectives, than SCAG staff will recommend either revision of the project or development of sufficient mitigation to offset the negative impact." (RCP p. 15-12) "SCAG will review local general plan amendments and updates, ~ provide guidance on how best to adopt regional goals, standards, and procedures to local conditions. If a modification to a general plan is ~ (emphasis added) SCAG will offer to provide assi~ in formulating the modification." (RCP p. 15-13) 5) TI~ Draft RCP does not discuss how implementation will be funded, o[ how much it will cosL SCAG staff has emphasized the Importance of the finance component, however, this ssction is not Included in the current draft of the RCP. Only the Regional Mobility Element contains a discussion of required finandal resoumes. 6) The RCP EIR, which contains project alternatives and mitigation measures, has not been received by Orange County jurisdictions or agendes. Orange County interests are at a disadvantage because a full analysis of the RCP is currently nonexistenL' ATTACHMENT III RAPC Recommendations to be forwarded to SCAG Recommendations: 1) SCAG's focus should be limited to RCP components which have adequately defined mandates and near-term deadlines. These Include the Growth Management component (SCAG's development of the Regional Growth. Forecast), and the Regional Mobility Elemer (long range transportation plan for the region). 2) The Air Quality component ~..g&lJ33LEt~ ~ should not be considered as a "core" component of the RCP, and should Instead be addressed in fdture discussions concerning the RCP's voluntary components. DiscussiOn'. The Air Quality component offers no discussion on air qu.ality issues for which SCAG has a statutory responsibility. SCAG's formal role in the air quality process (as iterated in a SCAG/SCAQMD Memo~dum of Understanding) is covered pdmadly in the Regional Mobility ElemenL Orange County's efforts related to air quality have been to develop efficient and workable Transportation Control Measures (TCM) for inclusion to the 1994 Air Quality Management Plan (AQMP) via the SCAG/SCAQMD agreement, and the RCP Air Quality component would not suffice as such input to the 1994 AQMP. 3) The Housing component as ~ written should not be considered as a "mandated" or "corn" component of the RCP, and should Instead be addressed in future discussions concerning the RCP's voluntary components. Discusskm: Orange County, in its work program wi~ SCAG, agreed to participate tn the Regional Housing Needs Assessment (RHNA) allocation of housing units to Orange County jurisdictions. In 1993, the RHNA was suspended due to lack of funding at the state level, thus Orange County's attention to this component has been limited. Verbal comments on the. current Housing component indicate that it is difficult to understand, is prepared under no statutory requiremenL and generally paints an unnecessarily disparaging picture of the region's housing s~tuation. '4) The Regional Mobility Element, should remain as-SCAG's highest Discussion: The long-range transportation p;an Is required by federal and state law. In SCAG's own words, it Is the basis for more than $24 billion in federaJ, state and local investment in transpor~tlon within the region over the next seven years. Without the tnulsportatlon plan, funding could be stopped until the plan is complete and meets all requirements. OCTA has taken the lead on responding to the Regior~ Mobility Element Am(x~ the concerns: a) Assumptions that go into SCAG's tmnslx)rtstion modeling data have not been shared. What pricing, demand management and transit enhancement assumptions would double and triple transit usage, as shown? b) Based upon Orange County poll results, a regional consensus needs to be built before market incentives and pricing mechanisms are included as a'key strategy. Voters doubt that pricing activities will reduce congestion and air pollution. c) Proposals to reduce energy consumption and tax exempt alternative fuels will reduce gas tax revenues, undermining the financing base. This is not reconciled. d) SCAG proposes to extend the planning hodzon from 2010 to 2015. This is too far in the future. Decisions such as whether to pursue urban rail in orange County have not been made and several county sales taxes sunset around 2010, Extension can c(xne at the next plan update in three years. 5) Regardless of the ultimate breadth of the final RCP, all assumptions as they relate to the regional forecast should be based on market trends/best estimates of future growth, and not policy projections that are artificially derived and do not reflect local/subregional estimstes of such growth. Discussio~ SCAG's continued resuscitation of the jobs/ho~ing bal~ issue is disturbing in light of:. a) · its prevtous agreement with Orange County to utilize projections developed by Orange County jurisdictions; b) SCAG's own admission that data partially supports that ~ng balance will occUr naturally over time without regional policy Intervention (RCP p. 3-13); _ d) previous analyses have greatly overestima~ed the impact of jobs/h~ng balance on air quality emissions reductions; and there Is CUrrent~ no discussion underway that would Include a jobs/housing balance or urban form TCM in the 1994 AQMP. With the exception of the Growth Management component nnd ReglonaJ Mobility Element, all remaining RCP compormnta should be removed from the RCP at this time so that discussions among the submgions regarding their content and Intention can occur and regional consensus can be developed on how the RCP should or should not fit into local government declsion-maldng and permit review. Funding sources for continued work on those components should be clearly Identified, and SCAG should not In any Instance utilize funds earmarked for transportation purposes for these efforts. Discussion. The sentiment among Orange County interests regarding potential p~escdptiVe nature of the remaining RCP components is somewhat mixed, with repeated concerns regarding how such components could impose additional burdens on jurisdictions/agencies and create new roles for SCAG that are not mandated or neces~uT. This recommendation recognizes that many ideas in the remainder of the RCP merit further research and discussion, and proposes that as long as new, non-transportation funding sources are identified, dialogue among the sul:~egi~s to further develop these components should continue.