June 23, 2022
California Air Resources Board
1001 I Street
Sacramento, CA 95814
Reference: Draft 2022 Scoping Plan
Update
Subject:
Rancho Mission Viejo Comments
Dear Board Members:
Rancho Mission Viejo, LLC
(“RMV”) appreciates the opportunity to provide the
following comments in relation to the Board’s draft 2022
Scoping Plan Update dated May 10, 2022 (the “Plan
Update”).
By way of introduction,
RMV and its affiliates are the owners of those lands comprising the
historic Rancho Mission Viejo in the unincorporated portion of
southern Orange County.
Encompassing nearly 23,000 acres, Rancho Mission Viejo (or,
the “Ranch”) is the subject of a comprehensive land use
and conservation program originally approved in 2004 and commonly
known as the “Ranch Plan.” Notably, the Ranch Plan is predicated upon
achieving a holistic balance between necessary housing and
commercial growth in California and the need to preserve
California’s open space areas and heritage. To that end, the Ranch
Plan provides for the permanent protection of approximately 17,000
acres of open space, while simultaneously creating the opportunity
for development of up to 14,000 new homes to meet the housing needs
of current and future Californians.
We appreciate the
Board’s continuing efforts to advance the quality of life for
existing and future residents of California. However, RMV is concerned
that the approach laid out in the Plan Update for achieving the
Board’s goals in reducing greenhouse gas (GHG) emissions and
achieving carbon net neutrality is inconsistent with the
State’s need for additional housing. As identified in the Plan
Update, the State is currently in the midst of a housing crisis
– with a reported need for an additional 2.5 million housing
units over the next 8 years.
Plan Update at Appendix E (page 26). The Plan Update identifies
a series of goals (vis-à-vis DHCD Prohousing Designation
Program) that may be used to accelerate housing in California, but
goes on to assume (or, more directly, prescribe) that higher
density infill development located within one-half mile of
high-frequency public transit facilities is the best way to create
additional housing that is in line with the Board’s
objectives. RMV
appreciates the value of infill development as an important element
in addressing California’s housing deficit. However, we respectfully
submit that the Plan Update’s characterization of ‑ and
prescription for ‑ high-density infill development as the
singular pathway for addressing California’s housing shortage
is misguided. More
directly, RMV believes that infill development should be viewed as
one of the many strategies and programs which are available for
addressing the concurrent objectives of (i) addressing the
State’s need for additional housing and (ii) improving
air quality. And, one
of the most important ‑ and immediately available ‑
stratagems for achieving these concurrent goals is through the
promotion and
development of entitled
projects that have already considered (nee embraced) the need for
accomplishing the State’s housing and air quality
objectives.
The solution is simply
stated: Development
of entitled residential projects should be viewed as complementary
to infill development – not as competitive or
alternative. As
opposed to dismissing greenfield development in favor of infill
development, the Board should look for ways to encourage the
development of entitled projects – particularly when the
project demonstrates the incorporation of sustainability measures
and encourages / provides modes of transportation that are in line
with the Board’s objectives.
In the case of the Ranch
Plan, RMV and its affiliates spent countless hours ‑ and
dollars ‑ designing a project that is both sensitive and
responsive to the State’s need for additional housing and the
goal of reducing air quality externalities. In addition to providing
significant open space (as described above), the Ranch Plan seeks
to improve the quality of life for existing and future residents
through a variety of facilities and programs – including, but
not limited to, development of a circulation network for
neighborhood electric vehicles (NEVs) and the provision / promotion
of ride share and other programs intended to reduce vehicle miles
traveled (VMT). RMV
has developed approximately 4,000 homes to date within the Ranch
Plan project area, and residents have responded positively (by both
attitude and usage) to the alternative transportation options
afforded by the Ranch Plan and its developers.
In
short: RMV believes that the
Board – through the Plan Update – should seek to
protect and advance entitled development programs as a critical
element of the Board’s sustainability efforts. To that end, the Board
should adopt measures that encourage the development of
previously-approved projects – like the Ranch Plan –
that strike an appropriate balance between the need for housing and
environmental sustainability.
As the Board evaluates
potential adoption of the Plan Update, RMV believes that the
following items are important for the Board to consider in the
context of the Ranch Plan:
·
The
Ranch Plan is the subject of several agreements with federal and
state agencies and the environmental community. The rights and obligations
of the parties under said agreements are premised, in large part,
upon the development of approved roadways and infrastructure which
are necessary to serve the project and its residents. If said infrastructure is
not developed (due to loss of State funding, etc.) and
access to / development of the Ranch Plan community is compromised,
the potential exists for breach of the referenced agreements and,
by extension, loss of the open space identified for permanent
protection.
·
The
Ranch Plan – as a planned community with existing
entitlements -- has been incorporated into the Southern California
Association of Government’s regional database as part of the
approved Regional Housing Needs Assessment (RHNA) and the 2020
Regional Transportation Plan and Sustainable Communities Strategy
(RTP/SCS). As such,
from a regional perspective, the Ranch Plan could be construed as
an “infill project” – as development of the
project has already been accounted for / assumed for the study
area.
The
foregoing list of concerns is not exhaustive, and RMV would
appreciate the opportunity to perform additional analysis of the
proposed Plan Update and to provide additional comments. To that end, RMV
respectfully requests that the Board extend the comment period for
the Plan Update for an additional thirty (30) days in order to
allow supplemental analysis and commentary.
Thank
you, in advance, for your courtesy in considering the foregoing
comments and requests.
Should you have any questions, please contact the
undersigned at your earliest convenience.
Sincerely,
Michael Balsamo
SVP, Government Relations
Rancho Mission Viejo, LLC