Floor Area Ratios

Position paper #07-06 of the El Dorado Hills Citizens Alliance

Summary

El Dorado County General Plan Amendment A06-0002 proposes to increase Floor Area Ratios permitted in Commercial, Industrial, and Research & Development land uses. The Draft EIR for this amendment reports potential for excessively high impacts to El Dorado Hills,  authorizing development which is forecast to take our community to up to 81,501 jobs. The corresponding traffic impact is extreme, the amendment has no provisions to provide corresponding capacity increases in our road system.

This amendment should itself be altered to reduce impacts on El Dorado Hills:

• It provides entitlement of business growth to reach levels which would effectively immobilize traffic in EDH. This is a potentially severe problem for not only our citizens but also for our businesses.
• It virtually assures growth of EDH to a size far beyond any which is compatible with the predominant vision of EDH citizens for our community.

Also, it would be appropriate for the County to consider submitting whatever decision it reaches to El Dorado Hills voters in a referendum. With 1/3 of the total increase in jobs and consequent impacts throughout the County being located in El Dorado Hills, and with El Dorado Hills already committed to host a disproportionate share of County business development, this a compelling issue for El Dorado Hills alone.
 
Discussion

The proposal to increase maximum FARs (Floor Area Ratios) is:

• Increase Commercial maximum FAR from 0.25 to 0.85
• Increase Industrial maximum FAR from from 0.25 to 0.85
• Increase Research and Development maximum FAR from 0.25 to 0.50
• Delete specific limitation of maximum FAR to 0.30 in the El Dorado Hills Business Park

The Draft Environmental Impact Report (DEIR) for this amendment cites higher FAR ratios in other communities in the Sacramento Region. It does not cite FAR standards of small towns in the Sierra, which may be a more appropriate standard of comparison according to the community vision most evident among El Dorado Hills citizens.

One report by the City of Grass Valley cites actual FAR values ranging from 0.11 to 0.24 for retail, commercial, industrial, and R&D land uses. The Town of Truckee uses a maximum FAR standard of 0.2 for all land uses except downtown tourist lodging (0.25) and industrial (0.40).

The DEIR reports 27 impacts in its Executive Summary which are classified as Significant and Unavoidable at buildout. We are particularly concerned about traffic impacts.

• At buildout El Dorado Hills will host up to 81,501 jobs.
• About 1/3 of the new employment county-wide occurs in El Dorado Hills.
• Increased employment will produce a substantially radical increase in traffic congestion.
  County-wide delays can reach 53.03 Vehicle Hours Delay per day per capita instead of the current forecast of 0.63.
• It produces a list of at least 27 impacts classified as Significant and Unavoidable.

An additional concern is the advancing change in character of El Dorado Hills toward that of a truly urban city. From available samples of opinion we believe that about 80% to 90% of all El Dorado Hills citizens want to keep a small town atmosphere.


Recommendations

The County should reconsider the Floor Area Amendment to introduce more moderate FAR limits than those proposed, at least in El Dorado Hills. The General Plan should define locality-specific limits, not a single standard to be applied throughout the County. This is critical to El Dorado Hills, which itself is already the County's largest community and has its most complex assemblage of planning issues. This amendment subjects EDH to a much higher level of environmental impacts than the rest of the County.  We need both planning specialization and environmental analysis specialization specific to the El Dorado Hills Community Region.

The Citizens Alliance agrees strongly with a principle from the General Plan quoted in this DEIR as significant, which is to give attention to community values, visions, and objectives as the basis for planning.  At least two specific points in this DEIR refer to "the community's vision of its long term physical form and development" as the basis for planning. The Citizens Alliance recognizes that vision from within our community as it is shared by an overwhelming majority of our citizens, and it differs substantially from the vision apparent in past planning at the County level. This includes land use choices and policies within the General Plan. The County should formally identify the actual community vision of El Dorado Hills citizens and consider it carefully in all General Plan amendments.

For this particular General Plan amendment an appropriate response would be a finding that environmental impacts of this particular proposal are incompatible with the El Dorado Hills community vision. More significantly, they are potentially and irreversibly damaging to the community at the level proposed, especially in traffic impacts.

We recognize the appropriateness of this amendment in other areas of the County, and we recognize that even in El Dorado Hills it is appropriate consider some degree of change to FAR standards in individual sub-areas within the community. Any such changes should be considered in connection with other planning changes to fully compensate for impacts, especially to traffic conditions.