(Editor’s note: Radley Reep, who for decades has reviewed Fresno County’s General Plan, submitted a letter to the Fresno County Board of Supervisors regarding its new Guidance Document for Community Plans, which is supposed to help update antiquated unincorporated community plans for disadvantaged communities such as Biola, Caruthers, Del Rey, Easton, Lanare, Riverdale and Tranquillity. Excerpts from the letter are presented here.)
This communication is a comment upon the County’s Guidance Document for Community Plans (Guidance Document) dated August 2022.
I have these eight requests:
- The draft Guidance Document explains the relationship between community plans and the General Plan:
“Community plans are part of the General Plan. Since the General Plan is required to be internally consistent, the provisions of a community plan must be consistent with all other provisions of the General Plan.”
This new process to review and update community plans, with the Guidance Document as its cornerstone, is entirely separate from the process now employed by the County to update the General Plan Policy Document. In practice, this means that important policy and environmental discussions pertinent to the update of community plans are separated from public review of the update of the General Plan Policy Document.
The significance of this schism becomes apparent with the realization that public review of the County’s land-use plans for disadvantaged communities will be separate from public review of the County’s Land Use Element and the County’s new draft Environmental Justice Element.
Community plans must align with the General Plan Policy Document. I therefore ask that the review and update of community plans be folded into the current review and update of the General Plan Policy Document.
- The REAP grant application enumerated the main reasons for drafting the Guidance Document. They were 1) to create a more streamlined and cost-effective process for updating community plans, 2) to expedite the update of several community plans and 3) to expand residential capacity and commercial development in unincorporated
The Guidance Document doesn’t address these matters head-on. Instead, the document focuses more on the applicability, content, amendment and adoption of community plans and addresses, as well, General Plan consistency issues and factors supporting the creation of new community plans.
I ask that the Guidance Document be revised to include a discussion of the purposes outlined in the grant application.
- In developing the Guidance Document, it appears the County failed to satisfy some grant requirements. For example, the Guidance Document does not acknowledge that plan updates must include current sustainability standards. In addition, according to the project description in the grant application, all updated community plans must contain strategies to reduce greenhouse gas emissions.
I ask that strategies for environmental sustainability be included in the Guidance Document.
- At the Zoom meeting held Sept. 8 for public discussion of the draft Guidance Document, County staff stated that the Board of Supervisors would simultaneously approve the Update Prioritization Criteria and the scoring results. This is not logical.
Since the authorization of scoring criteria must precede the actual scoring of community plans, I ask that the board review the scoring criteria prior to staff scoring and ranking community plans.
- I also ask that County staff test the workability of the scoring criteria before taking it to the board for approval.
- I heartedly recommend that the County include in the Guidance Document a short study of the Laton Community Plan update, which took place in 2012. It is the only operational community plan update since the General Plan was updated in 2000.
It would be a perfect case study for measuring how well or to what degree plan updates benefit communities. It is my understanding that while the 2012 update added a small amount of acreage to Laton for recreational and commercial uses, it added over 100 acres for future residential development.
The update also brought community plan policies and objectives into alignment with those in the General Plan. Since the update has been in effect for a decade, the County would benefit greatly by studying the extent to which the update enhanced growth and improved the lives of those living in that community.
It would make good sense to study the benefits and detriments that resulted from that update prior to launching into an effort to update other unincorporated community plans.
- As I understand it, County staff does not know of any funding to update more than one community plan. That’s a big problem. As everyone knows, without funds, there can be no updates. Some of these plans are so old—such as the community plans for Lanare, Tranquillity and Shaver Lake, which were last updated in 1982, 1984 and 1986, respectively—that, according to the County, they may no longer be valid.
A statement from the County’s 2000 General Plan Background report reads as follows: “The target date or buildout timeframe for many of these [community] plans has passed or is fast approaching…which raises concerns about whether they are still valid.”
If these antiquated plans are no longer valid, then it follows, logically, that the community plan component of the General Plan is also no longer valid. Therefore, I ask that the County conduct, as part of the development of the Guidance Document, analyses of funding sources and of the validity of existing community plans.
- There are two statements in the draft Guidance Document that I would like staff to review. The statements are these:
“An amendment to a community plan, including updates to existing community plans, may or may not require an amendment to the General Plan, depending on the scope of change.”
“Although the area covered by a regional plan may surround the area covered by a community plan, the community plan area is carved out from the regional plan area. This means that the regional plan does not apply to the community plan area.”
I do not understand how a community plan, which is part and parcel of the General Plan, can be amended without also amending the General Plan, and I don’t understand how regional plan policies are not applicable to a community plan that lies within it.
Surely, all components of a General Plan must align with one another. Therefore, I ask that the County either revise these two statements or provide more in-depth discussions of these matters in the Guidance Document.
Thank you for the opportunity to comment.