Preliminary Comments on Draft Marina General Plan

Here are preliminary comments of LandWatch Monterey County on the City of Marina General Plan dated March 2000, and denominated as a "Final Draft" General Plan. LandWatch has previously submitted comments on the Draft Environmental Impact Report prepared on this General Plan document.

Detailed comments on the General Plan text follow these more general observations:

• LandWatch believes that the March 2000 draft is a good beginning, but that it should definitely not be the "Final Draft." We think that the General Plan can and should be strengthened, and that the Planning Commission and the Council should take the time necessary to produce an excellent General Plan, not simply one that is technically adequate in terms of the minimum standards required under state law. We also think that some major policy decisions are implicit in the current version (these general observations are intended to highlight these), and that the Commission and Council need to take time to ponder the choices, and to hear extensively from the public and local businesses, before making the final decision on what direction the city should go.
  
  
• We hope that the Planning Commission and the Council will at least take enough time to allow the voters to decide whether or not they want to incorporate a "growth boundary" concept into the General Plan policies governing the future development of the city. If the voters adopt the Marina Urban Growth Boundary initiative in November, the policies contained in the current draft document would need to be reconsidered and revised. We don't think that work on the General Plan should be stopped, between now and the November election, but we do think that the Planning Commission and Council should not take final action until after the people have made their decision on the initiative measure. Taking additional time will not only indicate respect for the voters of the city, but will also give the Commission and Council an opportunity significantly to improve the final plan.
  
  
• In our comments on the Draft Environmental Impact Report, we noted that one of the most important negative impacts identified by the EIR was the permanent and unmitigated loss of visual beauty and scenic views that would be the inevitable outcome of the proposed Armstrong Ranch development. A picture really is worth ten thousand words, and we urge the city not to commit itself to the destruction of its scenic beauty without first reviewing what the visual impacts of the proposed Armstrong Ranch development would actually be. We believe that there is an actual legal requirement to apply available technology to see what the effects of the proposal would be, before deciding to do something that the EIR clearly identifies as a major negative impact. However, even if undertaking such a visual model is not a legal requirement, the city really ought to do this to make sure it gets the best plan possible. LandWatch hopes that the Commission and the Council won't sell Marina short. By using computer modeling technology, the city can make sure that its land use plan will result in future development that is visually beautiful&emdash;and not visually destructive. Please take the time really to know what is being proposed, before making a commitment to policies that may be sending the city in the wrong direction.
  
  
• At the start of the General Plan process, the City Council made a commitment to undertake a financial and fiscal analysis, to accompany the preparation of the General Plan and EIR. The results of the financial and fiscal analysis done by the City needs to be released to the public and to the Planning Commission, and should be used by the Commission and the Council as one basis for their decisions, as they evaluate what policies should best be included in the General Plan. Land use policies don't only have environmental consequences. Most importantly, they have social and economic consequences. LandWatch urges the Planning Commission and the City Council to consider the proposed General Plan from an economic and social perspective&emdash;and this consideration should be based on a rigorous financial analysis, to which the City Council committed at the start of the process.
  
  
• With respect to the likely social and economic consequences of the current draft of the General Plan, it appears to LandWatch that a likely outcome of the proposed plan would be to divide the city of Marina into two (unequal) parts. The current city would of course remain, but the Armstrong Ranch would represent a new and separate area, not well integrated into the current city. Centering the Armstrong Ranch development on a country club (please note that the current plan proposes a community center directly tied to the golf course clubhouse) will tend to establish an exclusive and separate community of higher-income persons. The Armstrong Ranch will be "new" and top quality. What happens to the rest of Marina? It seems simply to be "left behind."
  
  
• One reason to support a growth boundary strategy for the Marina General Plan is to make sure that new economic investment will go into the existing city first&emdash;and not be siphoned off into an easily-developed area of open space land. Only a certain amount of growth and investment will come to Marina in the next twenty years. The proposed General Plan directs the bulk of this growth to the Armstrong Ranch. The likely effect will be a "disinvestment" within the current city. The new commercial areas on Armstrong Ranch will siphon business away from current business locations, and private development funds will not go to improve the infrastructure of the existing city, but will be directed to the Armstrong Ranch. This is not the priority that best serves the existing City of Marina and its existing residents.
  
  
• Significant traffic between Salinas and the Monterey Peninsula currently goes through the City of Marina, using Del Monte Avenue and Reservation Road as the connection between Highway One and Blanco Road. The proposed General Plan would redirect this traffic onto a major new arterial that will essentially "bypass" the existing city, and most specifically bypass its existing business areas. Reservation Road and Del Monte Avenue are, for better or worse, the places where commercial development has concentrated in Marina. If the Blanco Road extension to Imjin Road, to Twelfth Street, to the freeway is actually constructed, what will be the economic effect on the current stores along Reservation Road and Del Monte?
  
  
• While the plan proposes "beautifying" Reservation Road, making it an attractive shopping location, where would the funds come from to undertake such work? Unless there is new commercial and other development taking place on Reservation Road, there won't be a source of funds for the proposed improvements. Yet, the draft General Plan probably undercuts the possibility of new investment along Reservation Road and Del Monte by proposing to take traffic from these areas and to convey it&emdash;at a very significant public cost&emdash;to a new commercial area adjacent to Highway One at Twelfth Street. This part of the plan makes it likely that current businesses will be "left behind," with all the new investment going into the new areas. This is a kind of "flip side" to the proposals to direct new residential development to the Armstrong Ranch. It represents the same vision&emdash;develop new areas on the periphery, instead of revitalizing and redeveloping the existing center of the city. Should that really be the priority of the new General Plan?
  
  
• Marina does not, currently, have a fully functional "entryway" onto Highway One. The Reservation Road interchange is remote from current activity centers. The Del Monte Avenue connection to Highway One functions only for traffic going to or coming from the Monterey Peninsula&emdash;and not for traffic going to or coming from the North. The Twelfth Street connection, even if upgraded, is also remote from the current activity centers of the city. The General Plan should consider how (or if) it would be possible to establish a more functional entryway for the city onto the Highway, and particularly in the Del Monte Avenue area.
  
  
• The General Plan should address more directly how to maximize the connections between the existing city and the lands on the former Fort Ord, so that future growth and development on the Fort Ord lands will be integrated into the existing city center. Strategies that accomplish this might be integrated with the proposed extension of Del Monte Avenue and a possible intersection improvement there.
  
  
• At the time the General Plan drafting process was initiated, both the Planning Commission and the City Council talked about making sure that future development would be "cost effective," and that new development should at least "pay for itself." This is important because the tax revenues produced by new residential and other development often do not offset the cost of the increased services that the development requires. Thus, new development may actually decrease the services available to existing residents, and thus negatively impact their quality of life. The current version of the draft General Plan does not contain policies that will insure that future residential and other development is cost effective. If the city is serious about this goal, a much stronger policy statement should be adopted as part of the plan, and this policy statement should include a requirement for a positive fiscal analysis as a condition of development.
  
  
• Similarly, at the time the General Plan drafting process was initiated, both the Planning Commission and the City Council talked about "phasing" new residential development, and linking such new development to the prior or concurrent development of jobs within the city. Again, the current version of the draft General Plan does not contain policies that will achieve this objective. If the city is serious about "phasing" new residential growth, and linking it to job growth within the city, a much stronger policy statement should be made part of the General Plan before its final adoption.
  
  
• When the lands of the former Fort Ord are transferred to the City of Marina, the City will possess a resource of incredible value&emdash;something other cities can only dream about. The city will actually own some of the most desirable real estate in the world, with spectacular views of Monterey Bay. The city's new General Plan should establish a program that will maximize the value of this land to the city, and to its current residents. In particular, the city should be able to work with the University of California at Santa Cruz, owner of the MBEST Center, to put together package development proposals that will directly link new job creating development at MBEST with housing developments on city-owned lands. Such housing developments should be constructed specifically to meet the housing needs of the new employees who will fill the new jobs, and the affordability of the housing created should be permanently protected. The General Plan could, and we believe should, establish such a program for the city's lands on the former Fort Ord.
  
  
• The current version of the draft General Plan suggests that the existing Lone Star sand plant should be converted to a visitor serving development, which would typically include a hotel, restaurant, and associated commercial shops. LandWatch believes that future coastal development for visitor-serving uses should be concentrated in the areas off Reservation Road that are already committed to that type of use, and that the remainder of the coastline should be protected in its natural state.
  
  
• As a conclusion to these general observations, LandWatch Monterey County believes that the current version of the draft General Plan needs to be strengthened and modified, to achieve all of the following objectives:
  
  • To protect the scenic beauty of the city, instead of undermining it.
    
    
  • To make sure that future growth and development will build and improve the existing city&emdash;not weaken it, both economically and socially, by directing new investment and new business to areas on the periphery.
    
    
  • To insure that future development will be cost effective, and that Marina will not permit residential developers to build lots of bedrooms for commuters to jobs in other areas, whether within Monterey County or in the Silicon Valley, but that residential development will be firmly tied to job growth inside Marina itself.

In addition to these general observations, LandWatch has the following specific comments on the March 2000 draft of the proposed General Plan:

1. On page 1-1, the current text says that the General Plan is a statement of what the "residents" of Marina believe to be in the best interest of their community. If the Commission and the Council want to include this statement in the General Plan, then the city should not adopt the General Plan until after the residents of Marina have had an opportunity to vote on the Marina Urban Growth Boundary initiative, at the election to be held this November. That election will determine what the residents of Marina (as opposed to their elected and appointed officials) think is in the best interest of their community with respect to the question of whether or not a "growth boundary" concept should be incorporated into the Marina General Plan.
   
   
2. On page 1-2, in the final sentence of section 1.4, reference is made to the City's "Urban Service Boundary," with a citation to Figure 1.1. In fact, Figure 1.1 does not include any designation of the "Urban Service Boundary" mentioned in the text.
   
   
3. On page 1-2, section 1.6, the text says that the General Plan "incorporates by reference the City's Local Coastal Program's land use plan and the resource protection policies contained therein." The General Plan is legally required to be internally consistent. The text should therefore state that if there is any apparent inconsistency between the Local Coastal Program and the General Plan, the Local Coastal Program will prevail. Otherwise, the new General Plan is vulnerable to legal challenge.
   
   
4. On page 1-2, section 1.7, the text refers to the "state's" housing element. State law requires the housing element, but it is in fact "Marina's," not the "state's." The text should probably say, "state required."
   
   
5. On page 1-2, in section 1.13, the definition of "should" is very convoluted and difficult to understand. The text should probably say that the word "should" "represents the intent of the City unless other factors make it infeasible actually to accomplish the intent stated…"
   
   
6. On page 1-4, section 1.13 (2), the definitions of "units per gross acre" and "units per net acre" are quite difficult to understand, and should be redrafted.
   
   
7. On pages 1-4 and 1-5, section 1.16 and Figure 1.2, the text and map are interrelated, but the text uses numbers and the map uses letters, and the lists are not in the same order. This makes it harder to follow the policy statements. The text and figure should be made consistent.
   
   
8. On page 1-6, section 1.17, the text references "17 specific goals." These are then listed in section 1.18, but they are not listed numerically, but by letter of the alphabet. The goals should be numbered, to be consistent with what the text says.
   
   
9. On page 2-2, policy 2.4 (4), LandWatch urges the city to get comments from the Monterey Salinas Transit District, to make more specific its commitment to transit oriented development. Unless the commitment of the city to such development is more specific, it will be difficult to ensure that future development actually achieves the stated goal.
   
   
10. On figure 2.1 (Community Land Supply), the map legend for "Very High Susceptibility for Liquefaction" has its diagonal lines running a different way from the actual designation on the map. The figure should be made consistent.
    
    
11. Figure 2.2 is the proposed Land Use Plan. LandWatch has the following specific comments:
    
    • We urge the city to remove the "Visitor-Serving" designation from the land on both sides of Blanco Road, near the airport. These areas are isolated from other commercial and visitor-serving locations, so developments there will not lead to beneficial economic synergy. Furthermore, these parcels are immediately adjacent to prime agricultural areas and their development would have a negative impact on agriculture.
    
    • As indicated earlier, we believe that the "Visitor-Serving" designation should be removed from the Lone Star sand plant site.
    
    • LandWatch does not believe that the city should make any General Plan designations for those portions of the Armstrong Ranch that are outside the existing city limits&emdash;except to indicate this area as "possible urban expansion."
    
    • Were the city to permit development of the Armstrong Ranch, we think another pattern of development would be far preferable. The proposed configuration will produce unsightly, freeway-oriented retail, office, and commercial development at the Del Monte (North) intersection with Highway One. It also uses most of the developable land for relatively low-density development in both the "Village Homes" and "Fairway Homes" designations. As noted earlier, we also believe that it is inappropriate to attempt to integrate the community center with a country club. LandWatch thinks a preferable development pattern would be to tie future development as much as possible to the existing city, instead of proposing what is essentially a "new" community out in the middle of the current open space. We also believe that the city should not perpetuate current residential-business conflicts, and should eliminate the proposed "light industrial" areas along Del Monte Boulevard.
    
    
12. On page 2-7, section 2.7 (2) the city's "Urban Services Boundary" is mentioned. Earlier in the Plan, this is called the "Urban Service Boundary," and is not mapped. The Plan should be made clear and consistent.
    
    
13. On page 2-7, section 2.9, the text claims that 53% of the land in the "Planning Area" is designated for open space uses. Most of the "Planning Area" is outside the City limits, either as currently existing or as proposed. How much land is devoted to open space uses within the city limits, both in terms of acres and percent?
    
    
14. On page 2-9, Table 2.3, the park standards are outlined. The land area required for a "Sub-neighborhood" park seems extremely small. .2 acres, or approximately 8500 square feet, are supposed to serve approximately 1200 people.
    
    
15. On page 2-12, section 2.26, the text says that county general plan policies call for "urban development of a major portion of the Armstrong Ranch property." In fact, this is not true.
    
    
16. On pages 2-13 and 2-14, section 2.31, the text says that 61 acres of vacant land and 66 acres of land in already-developed areas can be used for housing, but says that only 200 units could be developed on these 127 acres. That is an average density of only 1.6 units per acre. If developed at 10 units per acre (a relatively moderate urban density) the 127 acres within the existing city could provide 1270 units. In addition, the draft General Plan significantly underestimates the development potential of the existing city by not considering the amount of housing that could be developed by employing a second unit and mixed use development strategy.
    
    
17. On page 2-15, section 2.32 (9), the text contains what is probably intended to be a "policy" that would guide future development. Because the statement is not clear about what is a "fair share of infrastructure and public-service costs," it is almost valueless as a way to ensure that future development conforms to any specific standard. This is an example of a general problem with the draft General Plan. The text contains both descriptive material and "policy" statements, intermixed. To make the General Plan effective as a document that insures that specific development requirements are met, the "policy" statements should be clearly separated from the descriptive material. The policy statements, which should be definite and precise, should stand alone.
    
    
18. On page 2-15, section 2.34, the text says that a total of approximately 3,580 units of housing are "permitted" on the Armstrong Ranch. This language is different from that used elsewhere. For instance, section 2.36 says that the General Plan "allows for" a certain number of units on Fort Ord lands. The difference in wording would be presumed to have a legal significance, and it appears that the owner of the Armstrong Ranch is being given a stronger guarantee of developability than the owners of other lands. If this is intended, it seems unfair. If it is not intended, then the language in the Plan will create confusion. Uniform language should be employed throughout the document.
    
    
19. On page 2-18, Table 2.5, a chart of Floor Area Ratios is displayed. To understand the policy choices available to the city, a comparison with the standards used in various other jurisdictions would be helpful.
    
    
20. On page 2-19, section 2.47 (1), the General Plan allows convenience stores at the intersection of Reservation Road and existing Blanco Road, and at the intersection of Imjin Road and Abrams Drive. These locations are totally auto-dependent, and business development there would not increase the synergy that comes from co-location of businesses. These designations should be eliminated.
    
    
21. On page 2-20, section 2.51, the designation of a visitor-serving area at Blanco Road should be deleted, for the reasons earlier specified.
    
    
22. On page 2-23, section 2.63, the inclusion of the "descriptive" material indicating that development of the MBEST Center will be "limited" to certain uses will probably be read as a policy restriction in the General Plan, putting the MBEST Center at a competitive disadvantage, since the limitations will not be ones imposed by the University, but by the City, through their General Plan. See also page 4-33. This is another example of why descriptive and policy statements should be clearly separated.
    
    
23. On page 2-23, section 2.64, unless the wording "or as amended" is added to the citation to the MBEST Plan, that plan will be "frozen" by the Marina General Plan and will not be able to be amended without an amendment to the General Plan.
    
    
24. On page 2-23, section 2.66, the General Plan text discusses the retail and office and industrial uses proposed for the Armstrong Ranch. An earlier comment noted that this designation proposes a typical "freeway off ramp" future for this property. Directing this type of development there, as opposed to directing it to lands on or adjacent to Reservation Road and around the Airport, will also detract from the City's ability to attract development to the existing city, where it would be particularly desirable.
    
    
25. On page 2-24, section 2.72 (3), the definition of "warehousing" will allow all industrially designated lands to be used for mini-storage units, as a permitted use. This will probably result in Marina becoming an increasing mini-storage center for surrounding communities, and will significantly underutilize lands that could provide for actual industrial developments.
    
    
26. On page 2-26, section 2.77, the General Plan says that the industrially designated lands on Armstrong Ranch can be used for miniature golf courses and similar outdoor recreational uses. This seems to be another example of under valuing the development potential of lands that should be reserved for "better" uses that would provide more economic potential to the City of Marina.
    
    
27. On page 2-27, section 2.87, the projected K-12 enrollment figures seem quite low. It would be helpful to know how these figures were calculated.
    
    
28. On page 2-31, section 2.101, the policy statement that the police force "should be" sufficiently staffed as the population grows has no effectiveness as a statement of policy, and will not prevent a dilution of current levels of service as new growth occurs. In fact, the experience of many other jurisdictions is that local services, like police services, do decline as new residential growth proceeds, because such growth does not produce enough new revenues to maintain or improve service levels. If the City were serious about maintaining service levels as new growth occurs, then it should establish quantitative service standards as part of the General Plan, and say that these service levels "shall" be achieved. The General Plan should provide that no new development will be permitted that will cause these standards to be violated. In fact, if new development were subjected to a required and adequate financial analysis, and such standards were made part of the General Plan, the City could ensure that new growth would be "cost effective." However, the developers wouldn't like it, because they would then have to pay for the costs that their developments bring, instead of expecting existing residents to subsidize the new growth.
    
    
29. On page 3-1, section 3.3, the text talks about the General Plan "Transportation and Infrastructure Element." The actual title of this element appears to be "Community Infrastructure." The City has chosen to construct a General Plan that does not directly conform to the state law requirements for certain designated "elements." It is certainly possible to do this legally, but the language used should be internally consistent.
    
    
30. On pages 3-3 and 3-6, section 3.9, the General Plan establishes a policy that allows parking on four-lane arterials "until such time that use of the full capacity of the road is required." This builds in future business problems, as businesses will come to rely on street parking that may then be taken away, with no compensating off-street parking being available. As a short-term strategy, this may "work." As a long-term strategy, it will ensure business disruption and traffic congestion problems. If on street parking will not be available in the long run, then adequate off street parking should be made available from the start.
    
    
31. On page 3-16, section 3.47, the text discusses the use of recycled water on the proposed golf courses. The General Plan could and should specify that the golf courses will use recycled water.
    
    
32. On page 4-6, section 4.16, the retention of existing windrows is discussed. The General Plan should map and designate those windrows that the city wishes to preserve, so that developers know, in advance, what the city thinks is significant and worthy of protection. The policy currently proposed, which calls for a "case by case" analysis, will not be effective.
    
    
33. On page 4-8, section 4.24 (4) the text says, "should." It should say, "shall."
    
    
34. On page 4-14, section 4.33 (4), the Highway 1/Del Monte Boulevard connection is discussed. As indicated in earlier comments, the General Plan should seek to establish a plan for this intersection as part of this General Plan update, because establishing an appropriate connection between Del Monte Avenue and Highway One is of critical importance to the future of the city.
    
    
35. On page 4-14, section 4.35, the General Plan indicates that it is planning for a six-lane highway between Blanco Road and Twelfth Street. This is a mammoth facility, larger than the current Highway One. If the City commits itself to a facility of this size, it is saying that it wants to facilitate a major new highway between Salinas and the Monterey Peninsula, most of the traffic on which would pass Marina by. LandWatch urges the city to reconsider this provision.
    
    
36. On page 4-28, section 4.76 (2) the General Plan includes "phasing" provisions. The proposed language is not clear, certain, or effective. Housing development "should" be conditioned upon…commercial development…that "can" generate tax revenue adequate to pay…, etc. This is not specific, enforceable language, and if the city is serious about wanting new development to be phased, and to pay its own way, this section of the General Plan needs to be significantly reworked.
    
    
37. On page 4-28, section 4.77, the policies contained in this section are also not clear, certain or enforceable, and this whole section needs to be significantly reworked.
    
    
38. On page 4-31, section 4.88, the text calls for combining a community park and other community facilities with a clubhouse for the proposed country club. In addition, the General Plan proposes to locate an elementary school adjacent to the country club and clubhouse. These uses are incompatible. It is not appropriate to put community facilities in space shared with a golf course country club.
    
    
39. On page 4-39, policy 4.117, it is good practice to have consultants working to ensure that city policies are being followed to be "employed and hired by" the city (at the applicant's expense, of course) and not merely "approved by" the city.
    
    
40. On page 4-39, policy 4.118, the tree replacement policy should be at a ratio much greater than 1:1. When mature trees are removed, the replacements may or may not survive, and smaller trees will not truly "replace" the tree removed. That is why a 3:1 or greater ratio should be required.
    
    
41. On page 5-2, section 5.7, the plan calls for the preparation of a "growth management ordinance." The General Plan should incorporate the policies that it intends be incorporated in the Growth Management ordinance, since the General Plan is the "foundation" for the city's land use policy, and the ordinance should simply implement those policies specified in the General Plan.
    
    
42. On page 5-4, section 5.9 (2), the text indicates that an inclusionary housing ordinance should be prepared. As in the case of the proposed "growth management" ordinance, the General Plan itself should include the desired policies, and the ordinance should simply implement them. LandWatch suggests a stronger set of policies than outlined in the current version of the draft General Plan. The inclusionary requirement should be applicable to developments of 5 or more units, and at least 15% of the units (25% would be better) should be reserved for persons with average or below average incomes. The inclusionary policies should be more specific than simply requiring the units to be sold as "below market rate" units, and the affordability of the units needs to be protected on a permanent basis.