Amador County Board of Supervisors
Amador County Planning Commission
Amador County Staff
Dear Supervisors, Planning Commissioners, and County Staff:
We thought it might be useful to put forward a short note as to the major points that should be foremost in your deliberations on the future progress of the General Plan update.
We thank all of you for the time and effort that it has taken to get to this point. We also thank you for committing the effort that will be needed for success in this process.
ACRG feels strongly that any General Plan that is finally adopted needs to reflect the collective wisdom of the elected officials with input from the Planning Commission and interested stakeholders. The role of the consultant is to prepare the documentation to implement that collective vision.
A General Plan should be general in nature with the majority of the heavy lifting being done in implementing ordinances prepared at a later date. Many in this process would like the General Plan to enact their vision and mandate their personal preferences for implementation. The result of this approach is in fact to create unfunded mandates that are so completely embedded within the structure of the General Plan that they can not be changed.
One such unfunded mandate, for example, would result from the suggestion that the General Plan should "ensure" the creation of an integrated system of trails. Whether or not trails would be nice is separate and distinct from the question of what a system such as this would cost and how the funds would be raised.
The General Plan could encourage the creation of a trails system and leave it at that. This would allow the enactment of an ordinance later describing how trails are to be set aside in future projects and describing other details of the program. This would also allow the program to be amended later to account for future opportunities.
Some programs need to be spelled out more specifically in terms of CEQA mitigations. It needs to be determined if, in fact, the program is appropriate to mitigate impacts of future development. It is critical to the future financial health of the community that programs that are "wish list" items rather than environmental mitigations be left to future ordinances. It is absolutely critical that the Board of Supervisors know which is which. It is also critical that the consultant be informed that "wish list" programs are not to be included as mitigation measures in the EIR unless absolutely necessary.
To the extent that the community believes the existing General Plan is adequate and functional it is important that a mechanism be created to allow for consideration of the existing plan as one of the alternatives in the update process. Major changes in policies or loss of opportunities need to be justified.
ACRG has given written input as to the major policy directions. We would like those suggestions to get serious consideration. We have included another copy for your convenience.
We believe the most important decision to be made is for both the Board of Supervisors and Planning Commission to determine how much time can be devoted to this process in the coming year. How many meetings might it take for the Planning Commission to review the important policies? Should the Board of Supervisors take on that task?
We do not believe that the process to date has resulted in documents that can be used as the basis for making many of these difficult decisions. We feel the Planning Commission needs to assert its statutory role of recommending a General Plan. We also feel that this effort needs to be monitored closely by the Board members so that decisions that can be made are dealt with as soon as possible and not wait until every possible issue has been heard.
One approach might be to ask for input on the various subjects in writing. This might be an opportunity to not only see the range of possible decisions, but a little more background as to what various groups or individuals think the results of a particular decision might include. To date there has been little comment on the volumes of information presented to the GPAC and not a single vote of the GPAC to guide your use of that material. We think there is a significant portion of that material that needs further review. We are not comfortable with the premise that this pile of documents that few have reviewed should be the only administrative record that would form the basis for your General Plan.
Two major inputs into the final product are not yet available. These are the UPLAN report and the guidelines being developed for AB32 compliance. Because both traffic and AB32 considerations are so critical to the direction of the General Plan, perhaps decisions on the final direction of the General Plan needs to wait for these vital inputs.
To close, we urge both the Planning Commission and Board of Supervisors to look at the decisions that need to be made and make those decisions you feel comfortable making. Should you not feel there is enough information try to be specific as to what you wish to know to make a decision. If this is not possible, we urge you to decide whether the Planning Commission or Board of Supervisors directly will take additional steps to clarify the issues.
It is time to define a decision making process. The time is over for a process which gets everyone in a big room, puts big paper on the wall, and writes down every possible suggestion on every imaginable subject. That is not decision making—that is brainstorming. That part is done.
You must decide the direction for the future, and decide the role that the General Plan will play in attaining that vision. We believe the role is a narrow one and that you should not allow Amador County to be dragged into a process that consumes the limited financial resources of the County.
Amador Citizens for Responsible Government
Art Marinaccio
General Plan Consultant
Vince DeStigter
President