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Status Report On The Update Of Plan Bay Area 2040

Plan Bay Area, a joint project of the Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG), is the Bay Area’s Sustainable Communities Strategy (SCS) mandated by Senate Bill 375. This state required, nine-county, Bay Area regional blueprint plans for transportation, housing and land use until 2040. It seeks to reduce greenhouse gas emissions by concentrating high-density housing and mixed-use commercial development near transit hubs.

The Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG) recently released the first quadrennial update of Plan Bay Area (Plan Bay Area 2040 Draft Plan) and a Draft Environmental Impact Report. The Draft Plan is a limited and focused update of the initial Plan Bay Area approved by MTC and ABAG in 2013.

The Update’s regional forecast estimates a population growth of 2.3 million more people living in the Bay Area between 2010 and 2040. Over the same time frame, Marin County (the Cities and the Unincorporated Areas) is projected to grow by 9,700 more households. To put this in perspective, 9,700 households is just slightly below the current number of households in Mill Valley (6100 households) and Sausalito (4100 households) combined.

On May 23rd, Brian Crawford, Director of the Marin County Community Development Agency, gave a brief verbal status report on the Plan Bay Area 2040 Draft Plan and its process.

Here is a link to Mr. Crawford's presentation:


Director Brian Crawford presented the Draft Plan Bay Area 2040 Update’s household and job growth projections for Unincorporated Marin County in comparison to previous growth projections.

Here is the initial 2013 Plan Bay Area’s growth forecast for the unincorporated areas of Marin County between 2010 and 2040:

Original Plan Bay Area 2013 Growth Forecast for Unincorporated Marin County between 2010 and 2040 (** The Priority Development Area is not included.)

The Draft Plan Bay Area 2040 Preferred Scenario is a more recent forecast for Unincorporated Marin's household and employment growth by the year 2040. The Draft Preferred Scenario for Unincorporated Marin was first presented in August 2016 and is shown below:

Draft Preferred Scenario Growth Forecast for Unincorporated Marin County between 2010 and 2040 (August 2016) (** The Priority Development Area is not included.)

In October 2016, the Marin County Board of Supervisors sent in a letter asking for revisions to the growth projections of the Draft Preferred Scenario. In March 2017, an updated Preferred Scenario for Unincorporated Marin came out with the Draft Plan Bay Area 2040 and is shown below:

Draft Plan Bay Area 2040 with updated Preferred Scenario Growth Forecast for Unincorporated Marin County between 2010 and 2040 (March 2017) (** The Priority Development Area is not included.)

Per the above tables, the Draft Plan Bay Area 2040 Update Scenario Forecast of Unincorporated Marin Household Growth has dropped from 3150 households (August 2016 Scenario) to 2200 households (March 2017 Scenario). The Draft Plan Bay Area 2040 Update Scenario Forecast of Unincorporated Marin Job Growth has dropped incrementally from 3850 (August 2016 Scenario) to 3800 (March 2017 Scenario).

Although the March 2017 growth projections are lower than the August 2016 projections, the updated projections still exceed Marin County's historic growth patterns. They also exceed the original 2013 Plan Bay Area growth forecast, which was unrealistically high.

Attached is a letter, dated October 1, 2016, from Sustainable TamAlmonte to the Marin County Board of Supervisors regarding the August 2016 Draft Preferred Scenario Growth Forecast for Unincorporated Marin. The letter demonstrates why the growth projections were unrealistic and too high.


Supporters for Plan Bay Area believe the plan achieves its main goals to reduce per capita CO2 emissions from cars and light-duty trucks and provide adequate housing for the region’s projected population growth. They further believe that it is reasonable for Marin County to accommodate 1% of the Plan’s projected growth for the Bay Area.


Critics of the Draft Plan Bay Area 2040 Update state that the update has most of the same problems that the original 2013 Plan Bay Area had, which include:

1. The cost effectiveness of Plan Bay Area is abysmal, with costs of implementing Plan Bay Area far surpassing any benefits achieved:

Numerous comment letters on the 2013 Plan Bay Area and its Environmental Impact Report demonstrated, with expert evidence, that the land use, development and transit provisions of Plan Bay Area, if implemented, would reduce green house gas emissions by less than 1%, yet would cost 100s of billions of dollars and would cause multiple significant unavoidable adverse environmental impacts, resulting in increased risk of environmental harm and jeopardy of public health and safety. The Draft Plan Bay Area 2040 Update is very similar to the original 2013 Plan Bay Area and follows a similar format for reducing greenhouse gas emissions. Therefore, it has similar problems with cost effectiveness.

2. Plan Bay Area isn’t needed to meet SB 375’s greenhouse gas reduction requirement to lower per capita auto and light truck greenhouse gases by 15 percent:

The only provisions of Plan Bay Area that significantly lower greenhouse gases are from the California Air Resources Board green house gas plan and MTC climate initiatives, which could exist without the regional plan.

According to the initial 2013 Plan Bay Area Environmental Impact Report, in 2010, residents of the Bay Area produced 48.8 trillion tons of carbon-dioxide-equivalent greenhouse gases. The California Air Resources Board (CARB) greenhouse gas plan, mainly because of the Pavley standards, would reduce this by 11 percent to 43.4 trillion tons by 2040. The Metropolitan Transportation Commission’s climate initiatives, which would promote electric cars, carpooling, and similar programs, would reduce emissions another 3 percent to 41.8 trillion tons. All of the other land-use and transportation programs, including transit initiatives, in Plan Bay Area (with great fiscal and environmental cost) would reduce emissions by less than 1 percent, to 41.3 trillion tons (equivalent to a rounding error).

Moreover, new construction, which Plan Bay Area mandates, is one of the biggest contributors to greenhouse gases. The adverse climate change impacts of the plan related to the construction process are unsustainable, at a time when we need a smaller environmental footprint, a reduction in the use of building materials, electricity, and fuel. It takes up to 80 years for an urban village mixed-use building at maximum greenness to overcome climate change impacts from its own construction.

3. Plan Bay Area makes housing and transportation less affordable:

Rather than reducing the combined housing and transportation costs for low and lower middle income households, implementation of the Draft Plan Bay Area 2040 would increase these costs from 67% to 69% of low and lower-middle incomes.

4. Plan Bay Area displaces many lower income households:

The document entitled; “Results of Plan Bay Area 2040 Target Assessment”, provided by MTC and ABAG, states that the Draft Update’s target was to “not increase the share of low and moderate-income renter households that are at risk of displacement.” However, it further states that the plan does not meet this target and instead “moves in the opposite direction. The share of lower-income households at risk of displacement is expected to increase by 5 percentage points.”

5. Plan Bay Area does nothing to stop the hollowing out of the middle class:

The Draft Plan Bay Area 2040 forecast predicts; "The 'hollowing out' of the middle is projected to continue over the next 25 years. Household growth will be strongest in the highest income category, reflecting expected strength of growth in high wage sectors combined with non-wage income (interest, dividends, capital gains, transfers). Household growth will also be high in the lowest wage category, reflecting occupational shifts, wage stagnation, and retirement of seniors without pension assets."

6. The Draft Plan Bay Area 2040 forecast of Jobs, Population, and Housing for Marin County is unrealistic:

** Please read the attached letter from Sustainable TamAlmonte to the Marin County Board of Supervisors to understand why the Draft Plan Bay Area 2040 household and job projections for Unincorporated Marin are unrealistic and too high.

7. Implementation of Plan Bay Area would cause multiple significant unavoidable adverse environmental impacts, resulting in increased risk of severe environmental harm and serious jeopardy of public health and safety:

The impacts would be unavoidable either because mitigations will not reduce the impacts to less-than-significant or else because the regional agencies cannot require local jurisdictions to impose the mitigation measures. Moreover, the mitigations are unfunded.

8. Plan Bay Area promotes unfunded mandates:

Plan Bay Area does not identify or address how communities will fund the expansion of public infrastructure and services necessary to accommodate the plan’s projected growth. There is no funding in place to address the significant adverse impacts that the plan will create. The local jurisdictions and tax payers are expected to pick up the tab, when they don’t even have enough available funds to properly provide for the existing demands.

9. Plan Bay Area reduces local control (with a carrot & stick approach):

Plan Bay Area is the Bay Area's Sustainable Communities Strategy (SCS) as mandated by Senate Bill 375. SB 375 does not supersede local laws and local governments are explicitly not required to update their general plans in accordance with the law's centerpiece, the Sustainable Communities Strategy (SCS). However, SB 375 uses incentives (E.g. transportation funding, etc.) and penalties (E.g. court sanctions, accelerated Housing Element update cycles, etc.) to entice local jurisdictions to follow the law.

Moreover, under the Regional Housing Needs Allocation (RHNA) state law, a local government is still required to amend its Housing Element (and amend its General Plan if necessary to be internally consistent) and rezone its land in order to accommodate the quantity of housing it is assigned under the RHNA. And SB 375 requires that the RHNA be consistent with the Sustainable Communities Strategy (SCS) - AKA Plan Bay Area. In that sense, local governments will still be called upon to implement major aspects of Plan Bay Area (the Bay Area's SCS) via RHNA, whether or not they want to.

10. Plan Bay Area does not respect environmental constraints and limits to growth:

The total projected build-out, allowed by Marin County’s and Marin Cities’ general plans, exceeds the capacity of Marin’s infrastructure, public services and utilities, and environment. This is demonstrated by the findings of the 2007 Countywide Plan’s EIR, which concludes that "land uses and development consistent with the 2007 Countywide Plan would result in 42 significant unavoidable adverse environmental impacts”. Therefore, it is important for Marin County and Cities to recognize that there is an ultimate limit to growth and work together to reduce the total projected build-out of city and county general plans to a level that is sustainable. Plan Bay Area should respect this sustainable growth limit but, unfortunately, it does not.

11. Plan Bay Area furthers CEQA exemptions and streamlining:

Plan Bay Area furthers along California Environmental Quality Act (CEQA) streamlining and exemptions that are allowed by Senate Bill 375.

SB 375 adjusted the California Environmental Quality Act (CEQA) to allow streamlining or exemptions of Environment Impact Reports (EIRs) for:


Below are comments that the Marin County Supervisors made about the Draft Plan Bay Area 2040 update at their May 23rd meeting.

Supervisor Katie Rice: “I wish to say thanks to Supervisors Connolly and Rodoni serving on the MTC and ABAG Boards with regards to really speaking up forcefully for the local voice and for the recognition that across the Bay Area you have unique communities. Local control and local driving of what happens in our communities is critically important. At the same time we recognize we are part of a larger region. We have commuters crossing jurisdictional lines. We have pollution crossing jurisdictional lines. And we have housing needs across jurisdictional lines. So I actually think that Plan Bay Area 2040 is an improvement over the prior Plan Bay Area and I appreciate your work on the Boards you serve.”

Supervisor Dennis Rodoni: “Thank you Supervisor Rice. Although, I really can’t take a lot of credit. But I can comment that much of the criticism we are hearing is around displacement and loss of middle-income wage earners. Quite honestly I am kind of perplexed by that argument from the same people who don’t want to build housing because that is the net result of not having adequate housing. So, I think that Plan Bay Area’s projection of 2200 households is quite reasonable for Marin County. You can’t have no new housing and be concerned about displacement of workers.”

Supervisor Damon Connolly: “I wanted to commend the community as well. We had a public forum this past weekend in Mill Valley. Very well attended. ABAG and MTC were there. Many of the arguments that we’ve heard here today have been on both sides of the issue. What was evident today and throughout the process is that it is important for the local community to directly engage on this issue. And as was mentioned earlier, there is a more formal public comment period going on now. It will be crucial that local needs and perspectives are met in the context of ‘What do we need to do here locally to keep Marin’s unique character and meet our housing needs?’ I am confident that the process has improved in terms of where we were with Plan Bay Area and where we are now. Let’s stay on it but things are moving forward.”

Supervisor Judy Arnold: “Everyday 60,000 cars come into Marin for people going to work because many can’t afford to live here. We are looking at converting existing housing to affordable housing. Supervisor Connolly has worked with landlords encouraging them to accept Section 8 and that’s been successful. At some point in time we are going to run out of space. Just sitting here thinking about how we might deal with that… We might try tying in the reduction of greenhouse gases to the number of housing. If we could get down to zero greenhouse gases, this might be another route to take. We do need to encourage our workers who live here to take the trains, buses, carpools because this is a problem and it has to be dealt with as a regional issue.”

Supervisor Kate Sears: Supervisor Sears did not make any comments on the plan.

Before closing their discussion, the Supervisors unanimously approved Director Brian Crawford's informational status report on the Draft Plan Bay Area 2040.

Here is the remaining schedule for the adoption process of the Draft Plan Bay Area 2040 (an update of the original Plan Bay Area adopted in 2013):