Draft MTP/SCS Comments Received - sacog

This study by the Urban Land Institute estimated that over half of the residential demand between
2010 and 2020 will be for attached units; and by 2035, about 60% of demand will be for attached
units. The MTP/SCS predicts a lower share of attached units.
This result of this overemphasis on single-family large-lot development is significantly more
developed acreage than necessary to meet demand, and the less-compact land use form results in
greater vehicle trip lengths and greenhouse gas emissions. Table 3.11 of the MTP/SCS shows
that 45 percent of additional developed acres between 2008 and 2035 are in Developing
Communities – where much of the single-family large-lot development would occur.
The fundamental cause of this problem is the MTP/SCS assumption that 42 percent of forecasted
housing demand and 18 percent of employment demand will be in Developing Communities. 3
Not surprisingly, the largest increase in housing units by community type between 2008 and 2035
is in Developing Communities, where the share of housing units increases from three percent in
2008 to 13 percent in 2035.
To remedy this problem, we recommend that SACOG work with individual jurisdictions to refine
the demand analysis and land use distribution to reduce the 2035 forecasted housing unit
allocation for Developing Communities by at least 50% (to a total of not more than 75,000 units)
and reallocate the remainder to Center and Corridor Communities.
In addition, we encourage SACOG to develop a guidebook that provides clear examples of the
key characteristics of the various development types in the MTP/SCS. The Guidebook could be
developed similar to the Title 24 guidebook that was published shortly after the Title 24 standards
were adopted in 1978.
Finally, SACOG’s 2020 and 2035 GHG reduction targets are difficult to consider at the Plan or
Project level because there is currently no method/model that could evaluate plan or project
performance at meeting the targets. We encourage SACOG to work with ARB, local air districts,
educational institutions, and others to develop technical tools (similar to CalEEMod) that would
provide the ability to evaluate individual projects and their contribution to regional targets.
CEQA Streamlining Determination Process:
SB 375 gives the local jurisdiction the discretion for making the determination for what level of
CEQA exemptions a project is qualified for within the SCS, but, while it is suggested, there is no
mandate for a public notice, hearing or review process for this determination (PRC 21155.1). In
most cases, the usual required CEQA process would ensue after the determination, but of course;
the determination affects what will be reviewable in that process. Further, after that
determination, the ability to challenge findings is made more difficult, being raised to the
"substantial evidence" standard. And with no precedence, it remains unclear if it is possible to
challenge the determination itself. And, in the event that a project is dubbed to be a "sustainable
communities" project, qualifying for a full CEQA exemption, then there will be no ensuing
process.
Page 3-36 of the plan states, “To determine a project’s consistency with the SCS, a jurisdiction
must find it consistent with the general land use, density, intensity, and any applicable land use
3 SACOG, p. 3-15.
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