Fred Weis – February 14, 2023 – Judith Mayer’s General Plan Growth Management comments

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    From Fred Weis February 14, 2023
    Re: My comments on the Comments of Commissioner Judith Mayer
    on Draft General Plan update & amendments: Land Use & Growth Management elements
    This is NOT a summary. This is NOT a compilation.
    These are some notes on items that Judith has brought up that attracted my attention.
    I have copied just a sentence or two for each item – generally she has written more, which must
    be read for her full comment on the subject.
    Page 1 – Page 78 in the packet
    General: Vision: The Commission has not yet addressed the Plan’s over-arching Vision
    statement.
    Element order: Let’s discuss the Land Use element before the Growth Management element.
    Explicitly address drivers of land use change: The draft plan should address the different
    drivers of land use change in terms of the types of change involved.
    Page 2 – Page 79 in the packet
    Maps: Not all of the maps that the text mentions appear to be included in the Draft element
    in locations that are easy to find and read.
    Very important:
    Infill opportunity areas and streamlined / ministerial review: Before adopting such a policy, the
    Planning Commission should discuss and figure out exactly what those streamlined review
    and ministerial pathways should involve, possibly together with the City Council, but
    definitely BEFORE we recommend such a policy TO the Council! We haven’t addressed or
    resolved this in the Gateway, let alone in any or all of the City’s other “infill opportunity” areas!

    Page 3 – Page 80 in the packet
    Residential Zoning: : Recent state rules may increase the actual allowable dwelling densities ….
    The Land Use element should explicitly address these new possibilities and their implications.
    Very important:
    Density designations: … in terms of both dwelling units (which state housing guideline use)
    and bedrooms (which more closely represent actual population). A development of “single
    room occupancy” or efficiency apartments will impose different demands for services than a
    similar number of 3-bedroom “dwelling units.”
    Planned Developments: The Planning Commission should consider separating policies for the
    Planned Development areas for which an actual Planned Development Permit has been issued,
    from those for which no actual Planned Development permit has ever been approved. Staff
    had told the Planning Commission there are very few of these locations, yet two have come
    up within a couple of months.
    Agriculture and Natural Resource Lands (Policy LU-6): … consider regulating agricultural
    industries and processing with extensive or largescale structures separately from agricultural
    production that looks like, and imposes infrastructure demands more like “farming.”
    Page 4 – Page 81 in the packet
    Industrial Land Uses & Public Facility Land Uses: (Typo Policy LU-4: 150 years rather than 50
    years?) – [Page 51 in the packet]
    Little Lakes (Draft policy LU-5): It may be time to rethink that, considering the need to
    remediate toxic site contamination, and the serious risks to any permanent structure posed by
    sea level rise, rising groundwater, earthquakes, and tsunami.
    Presumably the LCP [Local Coastal Plan] element will also address this
    More specific – Growth Management element draft:
    However, the Growth Management element can go further in protecting the City’s greenbelt
    and “bluebelt,” maintaining viewsheds, etc. It can strengthen the City’s ability to do so in the
    face of potential development pressure on and from the County.

    Page 5 – Page 82 in the packet
    Very important:
    County referrals to City: … Our General Plan should also strongly encourage the Community
    Development Department to refer those proposals to the Arcata Planning Commission for
    review and comment. (Nothing prevents this now.) This could provide valuable public review
    and comment opportunities by Arcatans within our own public process.
    Land-use designations within the Planning Area: … Growth Control element should also
    recommend that the County divide its ag land designations between those uses that would
    permit large-scale structures, and those that would not permit large-scale structures,
    disruptive lighting or noise, extensive groundwater draw-down, etc.
    Very important:
    Annexation for conservation: …
    New Draft Policy GM-3c adds that the City may annex undeveloped land even beyond
    Arcata’s Urban Services Boundary if the City owns that land for resource / habitat
    management or to fulfill the City’s greenbelt policies.
    However, I believe that the General Plan should go further, and should extend this language
    to reinforce the City’s ability to annex land that the City does not own (or does not yet own),
    for conservation purposes.
    A General Plan policy broadening opportunity for such conservation annexation would
    indicate to LAFCo and to state authorities that Arcata considers annexation an important
    conservation tool, rather than just as a means to expand urban development.