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X82 STAFF REPORT
PLANNING COMMISSION
FOR
DATE: November 13, 2012
TO: Planning Commission
SUBJECT: PUBLIC HEARING — Eastern Dublin Specific Plan Amendment to
Eliminate the Requirement for Development Agreements and related
Financing Plans and Infrastructure Sequencing Programs (Legislative Act)
Prepared by John Bakker, City Attorney
EXECUTIVE SUMMARY
The Eastern Dublin Specific Plan (EDSP) requires that Applicants for development in the
Specific Plan area enter into a mutually acceptable development agreement with the City. The
EDSP also requires the development agreements to include detailed financing plans and
infrastructure sequencing programs. The City's original purpose for these requirements in the
EDSP was to ensure the adequate provision of infrastructure needed by planned development.
There are now other implementation measures in place that insure the provision of infrastructure
and payment of fees, so these requirements are no longer necessary.
City staff is recommending that the EDSP be amended to eliminate the above requirements
because they are no longer needed and because the City would then have the opportunity to
negotiate for community benefits when developers desire the certainty provided by a voluntary
development agreement.
RECOMMENDATION
Staff recommends that the Planning Commission: 1) Receive Staff presentation; 2) Open the
public hearing; 3) Take testimony from the public; 4) Close the public hearing and deliberate;
and 5) Adopt a Resolution recommending that the City Council
amend the Eastern Dublin Specific Plan to eliminate the requirement for development
agreements and related financing plans and infrastructure sequencing programs.
Submitted By lRevi ed By
City Attorney Assistant Community Development Director
COPIES TO: Applicant
File
ITEM NO.:
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DESCRIPTION
Authority for Development Agreements
Under the common law of California, the approval of a development project does not give the
developer a right to proceed to complete the project. Rather, the local agency can change the
rules and regulations at any point up until the developer has been issued a building permit and
incurred substantial liabilities in good faith reliance on the permit. Even then, the vested right
only gives the developer the right to complete the development described in the building permit.
To provide relief from this rule, the Legislature has developed two means by which a developer
may protect its project from subsequent changes in regulations. The first is a vesting tentative
map, which gives the developer the right to proceed with development in substantial compliance
with the rules and regulations in effect at the time the map application was deemed complete.
(See Gov. Code, § 66498.1(b).) The second is a development agreement between the local
agency and the developer. A development agreement vests the developer's right to proceed
with the approved project and, unless otherwise specified in the agreement, locks in the rules
and regulations applicable to the property. The local agency normally has no obligation to enter
into a development agreement, and therefore it can negotiate for consideration (community
benefits) in exchange for giving the developer vested rights.
Eastern Dublin Specific Plan Requirement for Development Agreements
In contrast to a typical voluntary development agreement, Section 11.3.1 of the Eastern Dublin
Specific Plan requires all Applicants for development in the Specific Plan area to enter into a
"mutually acceptable development agreement" with the City.
As further directed by the EDSP, the City Council adopted a Standard Master Development
Agreement on October 10, 1994 and amended it on November 28, 1995. Over the years, the
Council has unofficially established five years as the time for specific plan required development
agreements. Because the Specific Plan requires a development agreement, the City cannot
bargain for consideration from the developer in exchange for the development agreement. For
this reason, the standard Specific Plan development agreements have not been used by the
City to exact benefits the City cannot otherwise obtain.
Purpose of Eastern Dublin Development Agreements
The Specific Plan identifies the following purposes of the development agreement requirement:
1) augment the City's standard development regulations for specific projects; 2) spell out the
precise financial responsibilities of the developer; 3) ensure the timely provision of adequate
public facilities; 4) streamline the development approval process by coordinating various
discretionary approvals; 5) provide the terms for reimbursement when a developer advances
funding for specific facilities which have community wide area benefits; and 6) provide for
mutuality to the City and the developer regarding entitlements to the developer in return for
commitments for public improvements. (Section 11.3.1.)
At this point in the development of Eastern Dublin, none of these purposes offers a compelling
rationale to maintain the requirement. This is because some level of entitlement has been
approved for virtually all specific plan properties and major infrastructure has been constructed
or planned for construction through these approvals. Additionally, when the Plan was first
adopted, there were not administrative or formal procedures in place to ensure these purposes
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could be accomplished. The development agreement temporarily filled that need and is no
longer necessary.
Advantages and Disadvantages of the Development Agreement Requirements
The specific plan development agreement requirement has advantages and disadvantages.
The advantages of the specific plan development agreement requirement are that 1) the
agreements satisfy the Specific Plan requirement for "financing plans" and "infrastructure
sequencing programs"; 2) the agreements secure project conditions that cannot be satisfied at
final map; and 3) the agreements can clarify Conditions of Approval. The disadvantages of the
specific plan development agreement requirement are that: 1) the City, since it effectively gives
away five years of vested rights, cannot bargain for community benefits in exchange for
providing vested rights; and 2) the requirement, by adding another required City approval,
increases the developers' costs to process their projects.
The advantages are not significant. The requirements for a "financing plan" and an
"infrastructure sequencing program" are facilitated by the development agreement, but in light of
the City's comprehensive impact fee program and extensive body of development standards
and Ordinances, these requirements are no longer necessary. Further, development
agreements would not be needed to clarify conditions if the conditions are clearly written.
Finally, project conditions that cannot be satisfied at final map can be secured by a separate
agreement prior to final map approval.
On the other hand, the disadvantages of the requirement are significant. First, most developers
in Eastern Dublin apply for vesting tentative maps and are thereby able to obtain vested rights.
These rights may be adequate for many developers. For developers who desire development
agreements, eliminating the requirement will give the City the ability to bargain for consideration
in exchange for providing vested rights to the developer. There are no restrictions on what the
City can ask for or receive, other than what the developer will agree to provide. Any future
development agreements for properties in Eastern Dublin would be freely negotiated. Second,
over the years many developers, particularly those that are ready to immediately proceed with
development, have expressed displeasure about the need to enter into a development
agreement. These developers have expressed concern both about the costs and time
associated with drafting, negotiating, and processing the development. Thus, eliminating the
requirement will have an economic development benefit in that it will reduce the expense of and
expedite the processing of development in Eastern Dublin.
The proposed amendments are shown in Attachment 1 with additional text shown with an
underline and deleted text shown with a stFikethMu h. The amended text is included in the
Planning Commission Resolution as Exhibit A to Attachment 2.
CONSISTENCY WITH GENERAL PLAN, APPLICABLE SPECIFIC PLANS
The development agreement requirement and its related financing plan and infrastructure
sequencing program is unique to the Eastern Dublin Specific Plan There is no comparable
provision in the General Plan, nor is there any General Plan direction that the EDSP include
these requirements. As amended by the Project, the EDSP would remain internally consistent
because other existing City processes insure adequate infrastructure will support development,
including impact fees, PD-Planned Development zoning and other application reviews that apply
adopted development standards and ordinances.
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NOTICING REQUIREMENTS/PUBLIC OUTREACH
In accordance with State law a Public Notice was published in the Valley Times and posted at
several locations throughout the City. A notice of this hearing was mailed to those requesting
such notice ten days before the hearing and the Staff Report and attachments were made
available for public review prior to the public hearing in accordance with Government Code
Sections 65090 and 65091. A notice of this Public Hearing was also sent to active developers
within the Specific Plan area.
ENVIRONMENTAL REVIEW:
The California Environmental Quality Act (CEQA), together with the State Guidelines and City
Environmental Regulations require that certain projects be reviewed for environmental impacts
and when applicable, environmental documents be prepared. Staff recommends that the
Project be found exempt under the general rule in CEQA Guidelines section 15061(b)(3) that
CEQA does not apply where it can be seen with certainty that there is no possibility for a
significant effect on the environment. There is no such possibility for the Project since all
applicable development standards and ordinances, including payment of impact fees, would
continue to apply to development projects to ensure they are supported by needed infrastructure
and public utilities.
ATTACHMENT: 1) Proposed Eastern Dublin Specific Plan Amendments
shown in stFukethreugh and underline.
2) Resolution recommending that the City Council amend
the Eastern Dublin Specific Plan to eliminate the
requirement for development agreements and related
financing plans and infrastructure sequencing
programs, with the City Council Resolution attached as
Exhibit A.
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GENERAL INFORMATION:
APPLICANT: City
LOCATION: All properties in the Eastern Dublin Specific Plan area
ASSESSORS PARCEL
NUMBER: Various
GENERAL PLAN
LAND USE DESIGNATION: Various
SPECIFIC PLAN
LAND USE DESIGNATION: Various
1858785.6
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