3.26.2008

HHC to Planning

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The Healthy Humboldt Coalition
P.O. Box 1301,
Eureka CA 95502
707.822.1166
www.healthyhumboldt.org
mail@healthyhumboldt.org

May 10, 2007

Planning Commission
Community Development Department
3015 H Street
Eureka, CA 95503

Re:Chapter Group 4 PoliciesEconomic Development

Dear Commissioners and Staff,

We are writing to provide comments and specific recommendations regarding the recently releaseddraft policies for the Economic Development Element for the General Plan Update. While we aregenerally supportive of the direction established by the staff’s document, we do have some specificconcerns which we believe must be addressed to ensure the document’s consistency with otherelements and with the General Plan’s Guiding Principles, and to ensure the adequacy of theforthcoming EIR.The document lists draft policies for Alternative B, with occasional alternate policies for AlternativesA and C. There are a number of policies which are listed for Alternatives B and C which areexcluded for Alternative A. We understand that the purpose of this is to assure that eachalternative brings with it its own suite of policies. However, most of the omissions for Alternative Aappear to be arbitrary, and are inconsistent with the Guiding Principles for that alternative.The Staff’s document reads:“Plan Alternative A includes many of the components of Alternative B, but as anenvironmentally superior alternative, some wording and policy choices are presented thatare less robust toward economic development initiatives, particularly those that might behigh impact or growth inducing, such as road, rail, and airport expansions. Alternative Adoes not accommodate big box in the unincorporated area.”Staff’s presumption that a ‘robust’ economic development policy is somehow at odds with an‘environmentally superior’ General Plan is misleading and completely unsupported by any facts ordata. More to the point, this assertion is completely contradictory to the narrative in the staff’s owndocument.The policy document identifies nine base industry clusters, none of which are in any way at oddswith the focused-growth approach of Alternative A. In truth many, if not all, of these industrieswould likely benefit from the increased protections for resource lands, scenic beauty and quality oflife presented in Alternative A, making it quite likely the best and most robust alternative foreconomic development. Our comments in this letter are primarily an attempt to remedy thatinconsistency, so as to ensure that the policies ascribed to each alternative are consistent with thatalternative’s goals.There are numerous policy choices which are omitted from A for no apparent reason. Some ofthese omissions create the false impression that something in the nature of Alternative A wouldsomehow be at odds with the desire to create a strong and stable economy. We have providedour own recommendations below and in the attached table.
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org The version of policy ED-G1 which is listed for Alternatives B and C reads:ED-G1. Stable Economy. To enhance and maintain a diverse, stable, and growing localeconomy with an emphasis on base and emerging industries, innovation,entrepreneurship, and global competition.The version listed for Alternative A reads:ED-G1. Stable Economy. To maintain a diverse, stable local economy with an emphasison strengthening existing local industries.Again, this gives the false and unsupported impression that Alternative A would not fostereconomic growth, and would not support emerging industries, innovation, entrepreneurship orglobal competition. The reasoning for this is not given. We ask that staff reference the recent“Targets of Opportunity” report, which clearly shows the high premium placed on open space,environment, and quality of life by those business which are thriving locally. An accurate goal forAlternative A should include all of the goals listed in ED-G1, plus the reference to “strengtheningexisting local industries.”It is equally inconsistent to include Alternative C in policy goal ED-G1. As a ‘free-market’ approachto our future, the County should not be making any judgements about what kind of economicgrowth it will be supporting, and should allow the County’s economic fortunes to rise or fall uponthe whims of the market. There should be no presumption that a less-controlled market will be agood thing for us in Humboldt County.Goal ED-G4 is also improperly omitted from Alternative A, and equally improperly listed forAlternative C. If government is to ‘get out of the way’ of industry, then it should be making nopresumption as to the type of workers that will be needed by industry in the future, nor should ithave any obligation to provide for those industries.ED-G5 falsely assumes that clarity and specificity regarding land use is somehow at odds withtimely and efficient processing of permits. If anything, such clarity should make permittingsmoother. On the other hand, the lack of specificity in Alternative C should be assumed to be arecipe for permitting gridlock when it comes to implementation. G5 should apply to A, and not C.Alternative A should also be assumed to have the most efficient and best planned infrastructure fortransportation and wastewater, where C will be unplanned and inefficient. Thus, G6 should alsoapply to A and not C.We have provided these corrections in the attached table, shown in markup.Sincerely,Mark LovelaceHealthy Humboldt Coalition
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org Table 11-1. Plan Alternatives Comparison Chart PlanAlternativeGoalsStaff Remarks Vote:R,D,M B CED-G1. Stable Economy. To enhance and maintaina diverse, stable, and growing local economy with anemphasis on base and emerging industries, innovation,entrepreneurship, and global competition.See alternativewording belowAED-G1. Stable Economy. To enhance and maintain a diverse, stable, and growing local economy with anemphasis on base and emerging industries, innovation,entrepreneurship, global competition maintain adiverse, stable local economy with an emphasis on and strengthening existing local industries.Plan A alternativewording CED-G1. Que Sera Sera. Whatever happens happens,and we will live with it. A B CED-G2. Broadband Internet. To establish a reliablebroadband internet infrastructure that distributes achoice of economically accessible broadband servicesinto our most rural communities, and is not vulnerableto disruption. Integrate broadband service capabilityinto new buildings and developments. Providebroadband access in remote or rural communities.A BED-G3. Quality of Life. To attract and retain youngtalent by developing vibrant town centers thatincorporate a mix of employment, housing, and retailuses as well as access to child care, transportation, andcultural and natural amenities. A B C ED-G4. Skilled and Ready Workforce. To foster alocal workforce that is prepared to succeed in theindustries growing in Humboldt County, which valuesearly education, vocational training, and lifelonglearning. A B C ED-G5. Streamlining. To implement permitting andlicensing processes that are more responsive to theneeds and timelines of the marketplace, particularly formicroenterprises and home-based businesses. A B C ED-G6. Transportation Networks. To havetransportation facilities that allow freight mobility alongthe interstate highway system and provide connectivitybetween residential neighborhoods and employmentcenters.
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org Table 11-1. Plan Alternatives Comparison Chart A BED-G7. Public Water and Wastewater. To haveand maintain adequate public water and wastewaterfacilities to accommodate workforce housing andprovide opportunities for businesses to grow.A BED-G.8 Natural Resource Assets. To protectproductive agricultural, mineral resource, timber, andcoastal dependent lands.A BED-G9. Brownfields. To clean up and reusebrownfield sites.A BED-G10.Cooperation and Collaboration. To buildand maintain partnerships with cities, neighboringcounties, and the private sector that build and enhancecommon assets and resolve common obstacles.A BED-G11. Economic Development AssistancePrograms. To administer and support financial andtechnical assistance programs that support workers,businesses, and service providers.A BED- G12. Informed Public. To educate Countyresidents of economic trends, emerging markets,innovations and opportunities for entrepreneurshipthat benefit the region’s economic prosperity. C ED-G12. Public kept in the Dark. The public shallhave neither a role nor a voice in our economy. PlanAlternativeDevelopment PoliciesStaff Remarks Vote:R,D,M A BED-P1. Prime Employment Land Protection.Identify and protect prime employment lands fromconversion and encroachment of conflicting uses.B CED-P2. Airport Expansion. Support expansion ofthe airport to include service to major airport hubs andexpanded flight schedules.A BED-P3. Broadband Internet. Promote the provisionof broadband infrastructure in all communities.A BED-P4. Workforce Housing. Promote thedevelopment of workforce housing and mixed-usehousing around multi-modal transportation options.A BED-P5. Child Care. Promote the provision of childcare facilities within business, commercial andindustrial centers and housing developments.
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org Table 11-1. Plan Alternatives Comparison Chart A BED-P6. Revitalization. Promote the revitalization ofunderutilized lands in communities in transition due tothe decline of resource-based industries.A BED-P7. Brownfields. Consider land use designationsfor brownfields to encourage cleanup and reuse.A BED-P8. Commercial and Industrial SitesDatabase. Maintain a commercial and industrial sitesdatabase and continue to improve accessibility toonline information on commercial and industrialproperty.AED-P9. Commercial Retail. Large format “big box”commercial uses shall not be located in theunincorporated area to avoid sprawl.Plan A alternativewordingBED-P9. Commercial Retail. Include standards fordiscretionary review of large format “big box”commercial uses to reduce their land use impact.Plan B alternativewordingCED-P9. Commercial Retail. Include standards fordiscretionary review of large format “big box”commercial uses.Plan C alternativewordingBED-P10. Industrial Parks. Where appropriate,promote development of well planned and designedindustrial parks catering to existing local, as well asoutside opportunities. Encourage masterenvironmental assessments for industrial parks in orderto streamline the subsequent development process.From FrameworkPlan AED-P10. Industrial Parks. Where appropriate,promote development of well planned and designedmultiple-use centers which include industrial,commercial, and residential development within acohesive, walkable area. PlanAlternativeInvestment PoliciesStaff Remarks Vote:R,D,M A BED-P11. Financial Resources. Acquire anddistribute financial resources for workforce training,economic research, infrastructure, and businessdevelopment.B CED-P12. Freight Mobility. Pursue financial andtechnical solutions to provide reliable interstate truckaccess on both U.S. 101 and State Highway 299.
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org Table 11-1. Plan Alternatives Comparison Chart B CED-P13. Broadband Internet. Support thedevelopment and management of a redundant fiberoptic line that connects to the fiber backbone runningalong the U.S. 5 corridor. Support the expansion anddelivery of broadband Internet in the rural or remotecommunities in the county through all appropriatetechnologies.See alternativewording belowAED-P13. Broadband Internet. Support the expansionand delivery of broadband Internet in the rural orremote communities in the county through allappropriate technologies.Plan A alternativewordingA BED-P14. Workforce Housing. Encourage productionof housing at a price commensurate with income levels,and a transportation system to provide efficientconnectivity between housing and places ofemployment to maintain satisfactory commute traveltimes and distances.A BED-P15. Public Infrastructure. Pursue anddistribute funding and technical assistance to upgradeand enhance the water and wastewater facilities ofcommunities.A BED-P16. Brownfields. Pursue and distribute fundingand technical assistance to assess, clean up, and reusebrownfields.PlanAlternativePartnership PoliciesStaff Remarks Vote:R,D,M A BED-P17. Job Growth. Collaborate with economicdevelopment entities in the region to promote jobgrowth, technical innovations, and entrepreneurship inbase and emerging industries.A BED-P18. Workforce. Work with the education andprivate sectors to promote education, vocationaltraining, professional development, and lifelonglearning.A BED-P19. Cities and Counties. Collaborate withcities and neighboring counties to identify andimplement regional economic initiatives that benefitbase and emerging industries.A BED-P20. Child Care. Foster private/publicpartnerships with child care service and informationproviders.
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org Table 11-1. Plan Alternatives Comparison Chart PlanAlternativeImplementation MeasuresStaff Remarks Vote:R,D,M A BED-IM1. Ordinances. Update ordinances related toeconomic development for consistency with the uses ofbase and emerging industries.A BED-IM2. Commercial and Industrial SitesDatabase Mapping. Update the Commercial andIndustrial Sites Database on a two-year cycle andprovide online maps of vacant industrial andcommercial properties using the County’s GeographicInformation System.A BED-IM3. Broadband Deployment. Revisesubdivision regulations to provide infrastructure forbroadband internet.A BED-IM4. Programs. Support technical and financialassistance programs, including delivering capital,technical expertise, and training to businesses startingup and expanding.B CED-IM5. Streamlining. Provide regular review andimprovement of ordinances and permit processes toincrease efficiency and reduce permit processing timesfor strategic targets such as, but not limited to,microenterprises, home based-businesses, andworkforce housing.A BED-IM6. Child Care. Investigate and supportfinancing tools that leverage public and private fundingto increase the establishment, rehabilitation, expansion,and viability of child care facilities.A BED-IM7. Informed Public. Conduct and publiceconomic research relating to emerging markets,innovations, and opportunities in which the region mayhave competitive advantages.PlanAlternativeExisting Framework PlanStaff Remarks Vote:R,D,M D 1. Promote economic development by coordination ofefforts with both local economic developmentorganizations and members of the private sector.Replaced by P16,P17. P18 and P19
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The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition The Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt CoalitionThe Healthy Humboldt Coalition P.O. Box 1301, Eureka CA 95502 707.822.1166www.healthyhumboldt.org mail@healthyhumboldt.org Table 11-1. Plan Alternatives Comparison Chart D 2. Encourage a diverse range of commercial andindustrial development consistent with communitygoals and the level of services provided in each of thecities and communities.Replaced by G1, P1and P9D 3. Continue to provide for, through General Planamendments and zoning revisions as needed, anadequate supply of commercial and industrial land tomaximize opportunities for development.Replaced by P1, P7,P9, IM1, and IM2D 4. Prevent the loss of designated industrial lands toother uses requiring permanent facilities.Replaced by P1D 5. Ensure that industrial or commercial developmentwhich requires provision for public water, sewagedisposal, roads and other needed utilities and services isplaced in a suitable urbanized area.Replaced by P14D 6. Allow Resource Dependent Industrial uses outsideof urban areas when such uses are:• dependent upon close proximity to resourceproduction lands, and• not dependent on urban services.D 7. Where appropriate, promote development of wellplanned and designed industrial parks catering toexisting local, as well as outside opportunities.Encourage master environmental assessments forindustrial parks in order to streamline the subsequentdevelopment process.Included as P10D 8. Locate commercial development in appropriatecommunity centers that will assist and supplementexisting commercial activity.Replaced by P9D 9. Discourage strip commercial development, whereappropriate.D 10. Encourage the economic opportunities forproduction facilities that efficiently utilize all productsand by-products of forestry, fishery, or agriculturaluses.D 11. Maximize local energy opportunities from therenewable resources found in the County.D 12. Encourage innovative methods for pollutionreduction and waste product disposal and utilization.