| E-Mail Forum | |
RETURN |
|
| A General Plan for a Worse Richmond - I Can't Support It January 6, 2012 |
|
|
When we embarked on the creation of a new General Plan several years ago, I looked on it as an opportunity to create a future Richmond that would be a better Richmond. As the process proceeded, there were great hopes and lots of hype. For example, we bragged that Richmond would have the first general plan health element in California – maybe in the whole United States. In a breakthrough concept that could improve the health of people in urban environments statewide, The California Endowment has provided a $255,000 grant to include Public Health in a new General Plan for the City of Richmond, California—the first plan in the State to include this element. The project will be led by MIG, Inc., the land use planning firm for the City of Richmond's General Plan Update, in consultation with Contra Costa Health Services. Well, my hopes were dashed back in October 2011 when I read for the first time in the proposed resolution accompanying the Planning Commission’s review that the new General Plan was not going to result in a better future; it was going to result in a degraded future. In fact, Planning Commission Resolution 11-19, adopted October 20, 2011, includes the following: Whereas, even after implementation of all available mitigation measures identified in the Draft EIR for the proposed General Plan, impacts relative to air quality, climate change, cultural resources, noise, public utilities, transportation and circulation, and visual services [resources] would remain at a level of significant and unavoidable… In order to adopt the new General Plan, the City Council would have to adopt what are known in CEQA jargon as “overriding considerations.” In other words, we acknowledge significant impacts but conclude they are unavoidable. However, the “project,” in this case the general plan, has advantages that outweigh the negatives. It was the projection of unavoidable impacts and the need for overriding considerations that was a significant basis for the City Council’s rejection of the proposed casino at Point Molate. This is a great disappointment and totally unacceptable to me. Just in the category of climate change, we all know that California law (AB 32) requires a reduction of greenhouse gas emissions to 1990 levels by 2020. Yet, Exhibit A1 to the EIR states: 3.3-1: Implementation of the proposed General Plan could provide new sources of regional air emissions that would conflict with or obstruct implementation of the Clean Air Plan. How could that be? I envision a future where Richmond will do its part to meet the goals of AB32, and the General Plan should provide the roadmap. Take a look at what the EPA says about urban infill and increased density, which is what the new General Plan is all about:
In some cases, the EIR conclusions were just plain wrong. For example, under Cultural Resources, Exhibit A1 stated: Nonetheless, because existing and proposed City policies do not explicitly prohibit demolition or inappropriate alteration of historic-period buildings or structures, it is possible that development activities resulting from implementation of the proposed General Plan could cause a substantial adverse change in the significance of a historical resource. Impacts on historical resources are, therefore, considered potentially significant. As discussed above, Historic Resource Policy HR1.A indicates that the City intends to protect and encourage the preservation and adaptive reuse of significant historical resources in the City. Nonetheless, in some instances, such as those related to public health or safety reasons, it may be infeasible to protect a historic structure and the City could still approve the demolition of a historic structure. While Mitigation Measure 3.5-1 requires conformance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties, there are no mitigation measures available to ensure that the City does not approve the demolition of a historic building or structure; therefore, this impact is significant and unavoidable. In fact, the City Council amended RMC Chapter 6.06, Historic Structures Code, in 2010 to prohibit the demolition of historic resources without a discretionary review process that includes implementation of mitigations and consideration of alternatives. Much of the basis for predicting potentially adverse impacts is the growth projected by the General Plan, but there is overwhelming evidence that such growth in an already urbanized area such as Richmond has multiple benefits, and that increased density, properly planned and implemented, improves the environment instead of degrading it. Just take a look at the EPA Website on Smart Growth. Smart growth developments can minimize air and water pollution, facilitate brownfields cleanup and reuse, and preserve open space. One principle of smart growth is to take advantage of compact building design. Building great dense places with good design is not just an abstract theory - it is a practical approach to growth that is being used in diverse places across the country. There is an increasing recognition nationwide that density is integral component to the creation of neighborhoods that offer convenience, value and a high quality of life. You know I have a deep seated suspicion of and bias against EIR consultants, and this one doesn’t seem to be any better than other miserable consultants Richmond has used in the past. Because the City could not come to grips with a General Plan that actually improves the future, other organizations stepped up, most notably the REDI (Richmond Equitable Development Initiative) Coalition that includes ACCE, APEN/LOP, CBE, CCISCO, Faith Works/Richmond Vision and Urban Habitat. They proposed amendments to the Draft General Plan that addressed some of the concerns about a plan that envisioned a worse Richmond. The Planning Commission considered and adopted some of the proposals in Resolution 11-20. The hidebound Richmond Chamber of Commerce, which is controlled by heavy industry and does not want to see quality of life improvements in Richmond, has launched an assault on the provisions in Resolution 11-20. As a reluctant member of the Chamber of Commerce, I received the email below yesterday.
What's the concern? Richmond cannot afford to adopt public policy that stops or discourages new businesses and other enterprises from locating in Richmond, or encourages existing businesses to leave. Most importantly, the lack of transparency for passage of the proposed amendments undermines a multi-year public review process for the General Plan. They duplicate existing complex and highly technical air regulation programs and regulation that already exist at the Federal, State and Regional levels. Local planning and zoning ordinances should not be used to overlap and conflict with such schemes, especially where the City lacks the essential technical expertise and resources. These measures will cause existing and potential new businesses in Richmond to defer or void any new investment and development, at a time when jobs and tax revenues from smart growth are sorely needed. These proposed amendments are adverse to Businesses in Richmond. What can you do? First, please carefully review the proposed changes outlined in the resolution linked below. Second, call and ask City Council members to support a General Plan that does not include the Planning Commission's proposed amendments. Finally, send the same request and any other comments to Mr. Richard Mitchell, Richmond Building and Planning Director, at email address Richard Mitchell@ci.richmond.ca.us. Please email a copy to the Richmond Chamber of Commerce for incorporation into the business coalition comments. PLANNING COMMISSION RESOLUTION NO. 11-20 For additional information please contact me by email or call (510) 234-3512. Improving environmental quality is not bad for business. See CCAP’s new report, Growing Wealthier: Smart Growth, Climate Change and Prosperity: In CCAP’s new report, Growing Wealthier: Smart Growth, Climate Change and Prosperity, authors Chuck Kooshian and Steve Winkelman present evidence on how application of smart growth principles can improve the bottom line for businesses, households and governments by increasing property values, cutting fuel and infrastructure costs, creating jobs, enhancing public health and strengthening communities
Excerpts from Exhibit 1A follow: STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to CEQA Section 21081(b) and the CEQA Guidelines Section 15093, the City of Richmond has balanced the benefits of the proposed General Plan against the following unavoidable adverse impacts associated with the proposed General Plan and has adopted all feasible mitigation measures. The City of Richmond has also examined alternatives to the proposed project, and has determined that adoption and implementation of the proposed General Plan is the most desirable, feasible, and appropriate action. The other alternatives are rejected as infeasible based on consideration of the relevant factors discussed in Chapter 5 of the Draft EIR. SIGNFICANT UNAVOIDABLE IMPACTS 3.3-1: Implementation of the proposed General Plan could provide new sources of regional air emissions that would conflict with or obstruct implementation of the Clean Air Plan. 3.3-2: Implementation of the proposed General Plan would result in operational emissions that could contribute substantially to an existing or projected air quality violation. 3.5-1: Development activities associated with the proposed General Plan could cause a substantial adverse change in the significance of a historical resource as defined in section 15064.5 of the CEQA Guidelines. 3.6-1: Implementation of the proposed General Plan would result in the generation of GHGs that may have a significant impact on the environment. 3.10-1: Construction activities associated with the future land use changes under the proposed General Plan could generate noise levels that exceed the noise standards established by the City of Richmond Municipal Code and would expose sensitive receptors to substantial temporary or periodic increases in ambient noise levels. 3.10-2: Construction of future new land uses under the proposed General Plan could generate or expose persons or structures to excessive groundborne vibration. 3.10-3: Implementation of the proposed General Plan could expose sensitive receptors to noise levels in excess of the noise standards established by the City of Richmond. 3.10-5: Operation of new land uses under the proposed General Plan would generate increased local traffic volumes that would cause a substantial permanent increase in ambient noise levels in the project vicinity. 3.13-3: Implementation of the proposed General Plan would require the construction or expansion of wastewater treatment facilities or conveyance systems that could cause significant environmental effects. 3.13-1: The proposed General Plan may result in traffic congestion that exceeds the previous City of Richmond traffic LOS standard of LOS D, as well as CCTA and WCCTAC LOS and MTOS standards. 3.13-3: Implementation of the proposed General Plan would produce higher demand for transit service, potentially exceeding the capacity of transit service providers. 3.13-6: The proposed General Plan would increase congestion and reduce travel speeds on various roadways throughout the City, including some that are on primary emergency response routes (i.e. freeways and arterials). 3.15-1: Development activities associated with the proposed General Plan could have a substantial adverse effect on a scenic vista or substantially degrade the existing visual character or quality of the site and its surroundings. 3.15-2: The development of the proposed General Plan could create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. Implementation of the proposed General Plan would also contribute to the following significant cumulative impacts related to air quality, cultural resources, climate change, noise, public utilities, transportation and circulation, and visual resources. Air Quality The emissions associated with vehicle miles traveled are higher than the rate of increase in population within the City; this impact on cumulative conditions would be considered significant. Implementation of the proposed General Plan could result in a cumulatively considerable net increase of criteria pollutants (ozone, carbon monoxide, nitrogen dioxide, and inhalable particulates) for which the region is in nonattainment under an applicable federal or state ambient air quality standard. Cultural Resources The project’s incremental contribution to the cumulative loss of cultural resources would be potentially cumulatively considerable, and thus potentially significant. The proposed General Plan has the potential to adversely affect significant paleontological resources that are non-renewable members of finite classes. Consequently, the project’s incremental contribution to these cumulative effects would itself be potentially cumulatively considerable, and therefore potentially significant. Development in the City and the region could result in the destruction of historic resources. This would be a significant cumulative impact; the proposed General Plan’s contribution to this impact would be considerable, and therefore significant. Climate Change Implementation of the proposed General Plan would result in the generation of GHGs that may have a significant impact on the environment. Noise The construction of future development allowed under the proposed General Plan could occur concurrently and adjacent to similar development/construction within 1,000 feet of City limits; therefore, cumulative impacts would be significant. Vibration from construction of future new land uses within the City and immediately surrounding areas could potentially combine with construction vibration of the proposed project to result in a potentially significant cumulative impact. Rail operations could expose sensitive receptors under the cumulative condition to noise levels above established standards and some of the exposure to rail noise would be attributable to the proposed General Plan. This impact would be significant. The contribution of the proposed project to future roadway noise levels would be considered cumulatively considerable with respect to the projected exceedance of identified thresholds of significance. Public Utilities The growth associated with the proposed General Plan would be the major contributor to future flows to the wastewater treatment facilities, resulting in the need for expansion, which would be a significant cumulative impact. Solid waste generation from approved and foreseeable cumulative projects in the area would exacerbate regional landfill capacity issues in the future. The proposed General Plan’s contribution would be cumulatively considerable and this impact would be significant. Transportation and Circulation The proposed General Plan would contribute to increased congestion and reduced travel speeds on various roadways throughout the City, including some that are on primary emergency response routes Visual Resources
|
|
|
RETURN |
On January 17, the city of Richmond City Council will consider amendments to the General Plan update proposed by Planning Commission (see Resolution linked below). The proposed amendments, provided by Oakland-based Communities for a Better Environment (CBE), were passed by Planning Commission on November 3, 2011 with no public notice, review or comment. The proposed amendments, if adopted, are very harmful to economic development and jobs. 