Methods and Results for the 65/35

Land Preservation Standard Inventory

June 2000

Overview: In 1990, the voters of Contra Costa County approved Measure C (often referred to as Measure C (1990) to distinguish it from an earlier measure of the same name), the 65/35 Contra Costa County Land Preservation Plan. Measure C (1990) requires, among other things, that not less than 65% of the land in the County is preserved for parks, open space, agriculture, wetlands, and other non-urban uses. Staff conducted a land use inventory in 1990 as a part of the General Plan process to assess the County’s status relative to the 65/35 standard. That analysis measured the developed or urban area of the County at 25.4% of the County and the undeveloped or non-urban portion at 74.6%. An updated land inventory is needed now to support the review process for proposed changes to the Urban Limit Line and to inform land use decisions on pending projects.

Community Development staff conducted a detailed 65/35 land use inventory over the winter and spring of 2000. The inventory was based on two primary sources: 1) current General Plan information from the city and County General Plans; 2) up-to-date information on actual public park lands, dedicated open space lands, and on other public and semi-public lands. Information from these sources was mapped over the County’s parcel base and entered in the Department’s new computer mapping/Geographic Information System (GIS) software. Staff used these computerized mapping tools to perform electronic area measurements on the completed map data, replacing the past practice of performing measurements by hand. Staff also chose the computer approach because the GIS software provides an adaptable repository for the mapping work, enabling the Department to begin to build a digital version of the county-wide General Plan map (as well as GIS data on public lands and facilities) while performing the 65/35 inventory.

The results of the year 2000 65/35 inventory process may be summarized as follows (Table 1 presents the results of this inventory in more detail):

69.6% of the County has a non-urban use and is planned for a non-urban use

30.4% of the County has an urban use or is planned for an urban use

This report outlines the process by which the above figures were developed. It is organized according to the following main subject areas: 1) background on key requirements of the 65/35 ordinance; 2) the general approach chosen to complete the inventory; 3) steps in the inventory process; 4) discussion of results; and 5) an overview of alternative inventory approaches which were considered.

1) Background On Key Requirements Of The 65/35 Ordinance

Provided below are two excerpts from the text of the Measure C (1990) ordinance which outline the

Table 1: Summary Results of 65/35 Land Preservation Standard Inventory

for June 2000

Area of the County[1]: 481,430 acres

Area outside the Urban Limit Line (ULL)[2] 265,240 acres 55.1% of County

Total area of non-urban uses inside the ULL: 69,870 acres 14.5 % of County

Total area of non-urban uses in County: 335,110 acres 69.6% of County

Total area of urban uses in County: 146,320 acres 30.4% of County

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Breakdown of non-urban uses inside the ULL:

Category of non-urban use	Acres	Percentage of County Area
Park & Recreation areas inside the ULL	11,890	2.5%
Dedicated/restricted open space inside the ULL	12,820	2.7%
General Plan Open Space inside the ULL	7,420	1.5%
Water inside the ULL	990	0.2%
Agricultural Land inside the ULL	22,310	4.6%
Canals & flood control channels inside the ULL	1,760	0.37%
Airports inside the ULL(excluding areas under conservation easement)	830	0.17%
Major Sanitary District Properties inside the ULL	440	0.09%
Cemeteries inside the ULL	160	0.033%
School & college facilities inside the ULL	3,110	0.65%
Public watershed lands inside the ULL	1000	0.21%
Landfill inside the ULL (includes Keller areas not under conservation easement & Acme)	1,940	0.40%
Off-Island Bonus Area inside ULL, not including 320 acres approved for urban in Cypress Lakes	1,940	0.40%
Delta Recreation inside the ULL	2,470	0.51%
Industrial buffer inside the ULL	790	0.16%
Total non-urban inside the ULL	69,870	14.5%

Breakdown of Public/Semi-Public uses inside the ULL which were categorized as urban:

Freeways & Highways inside the ULL	4,660	0.97%
Railroad inside the ULL	1,510	0.31%
BART inside the ULL	300	0.062%
Other urban-type public/semi-public facilities inside the ULL (government offices, community centers, hospitals, public corporation yards, etc.)	3,290	0.68%
Total urban Public/Semi-Public inside ULL	9,760	2.0%

65/35 requirement and describe the basic guidelines for measuring compliance with standard.

From Section 4 of the ordinance:

B. 65/35 Land Preservation Plan

The policies contained in this chapter shall be reflected in the New General Plan, as ultimately adopted by the Board of Supervisors in accordance with the California Environmental Quality Act and State Planning Law.

1. 65/35 Land Preservation Standard

Urban development in the County shall be limited to no more than 35% of the land in the County. At least 65% of all land in the County shall be preserved for agriculture, open space, wetlands, parks and other non-urban uses.

2. Changes to the 65/35 Land Preservation Plan

No change shall be made in the New General Plan after its adoption that would result in greater than 35% of the land in the County being permitted for urban development. This limitation shall not prevent any increase in agriculture, open space, parks, wetlands or other non-urban uses to greater than 65% of the land in the County.

Also from Section 4 of the ordinance:

F. Definitions

1. As used in this chapter, the phrase "land within the County" shall mean all of the acreage within the boundaries of Contra Costa County except the water area of the County west of Stake Point.

2. As used in this chapter, the term “non-urban uses” shall mean rural residential and agricultural structures allowed by applicable zoning and facilities for public purposes, whether privately or publicly funded or operated, which are necessary or desirable for the public health, safety or welfare or by state or federal law.

2) General Approach Chosen to Complete the Inventory

As is clear from reading the above excerpts, the 65/35 ordinance provides a standard to be met, it does not specify the precise methodology by which this measurement should occur. Staff considered a range of alternative approaches for completing the analysis and evaluated them based on a several of factors, including accuracy, repeatability, consistency with the ordinance requirements, amount of work required, and ability to relate the measurement to an enforcement mechanism (see section 5 for a detailed discussion of the alternatives considered).

The approach chosen was to rely on city and County General Plans for information on the extent and location of urban and non-urban uses, but to augment this plan information with up-to-date, parcel-specific information on public parks, dedicated open space, and other public and semi-public uses. General Plan designations from city General Plans were converted to the closest equivalent designations from the County General Plan, and this converted information from the city plans was used to map non-urban uses in all incorporated areas over a parcel base. The County General Plan was used to map non-urban uses in the unincorporated areas over the same parcel base. Detailed information on current, actual locations of parks, open space, and other public lands—often missing from General Plan maps which tend to omit some fine details and are updated over a relatively long time scale—was used to fill in information gaps and override General Plan data. It should be noted that this approach classifies areas planned for development as urban even if that development has yet to take place.

Some reasons staff selected the above-described approach are:

· General Plans are the best available surrogate for actual land use in already developed areas;

· Relating the 65/35 inventory to General Plan policy provides a clear and direct link to strategies for enforcing compliance with the standard;

· By measuring planned or allowable uses rather than only actual uses, we consider a “worst case” scenario and assure that the inventory reflects approved policy;

· Collecting parcel-specific information on parks, open space, and other public lands can account for the lack of detail in some General Plans and assure that such areas, which have essentially no chance of being converted to an urban use despite their land use designation, are counted as non-urban.

3) Steps in the Inventory Process

Step 1--Digitizing the Urban Limit Line: Since lands outside the ULL are virtually all non-urban, staff chose to begin the inventory by mapping the urban limit line in a computer over the parcel base. This way, areas outside the ULL could be omitted from subsequent inventory steps.

There are, however, three small areas within the County which have urban-type designations but are located outside the ULL. In each case, the land use existed well in advance of the ULL. ULL “islands” were not created around these areas so that requests for intensification of use in these areas would trigger a ULL review. These areas are:

· An industrial facility with a Light Industrial land use designation on Bollinger Canyon Road (24 acres);

· A residential area along the northern segment of Morgan Territory Road which is designated Single Family Residential Very Low Density on the General Plan (185 acres).

· Residential land east of Byron which is designated Single Family Residential Very Low Density (27 acres).

For the purposes of the 65/35 inventory, these areas were classified as urban and subtracted from the area outside the ULL.

Step 2, Mapping and Digitizing Non-Urban Land Use Designations from Current City and County General Plans: As summarized above, updated General Plan information from the cities was translated into County terminology, mapped over a parcel base, and entered into the computer. City General Plan information was used only for incorporated areas, not for areas within a city’s sphere of influence as such areas are within the County’s jurisdiction until such time as they are annexed. The current County General Plan was used for all unincorporated areas and was mapped and digitized by the same method used for the cities.

The first task in this process was the creation of a consistent city and County General Plan map. This had been done before during the 1986-1987 comprehensive Countywide General Plan program and for the 1990 County General Plan. Since that time, most of the cities within the County have updated or substantially modified their general plans. To make use of this general plan approach it became necessary to collect the revised city General Plan information. As a general rule, these city General Plan revisions have added more detailed and site specific information and are more consistent with the level of detail found in the County General Plan for the unincorporated area.

The same approach to translating city general plans to that of the County was utilized for the 1986-7 effort as for this update. The city General Plan categories were translated to the nearest County equivalent category. Conversions were guided more by the uses allowed under specific designations than by the actual names applied to designations. For example, some areas designated as “Open Space” in some city General Plans were translated to “Agricultural Lands” because the allowable uses more closely resembled that County designation. Also, in a few instances, city General Plans designate areas within their jurisdiction as areas for future development, but don’t specify the actual location or mix of future uses, some of which could be non-urban. Where possible, more specific plans were collected from the cities for these areas and used for the analysis. This was done for the two largest examples of this scenario, Antioch’s Future Urbanization Areas 1 and 2.

Distinguishing urban from non-urban land use designations: The 65/35 ordinance provides relatively clear guidance on how such distinctions should be drawn (see excerpts above). The County General Plan also provides guidance in this excerpt from the Land Use Element:

PUBLIC, SEMI-PUBLIC, LANDFILL AND OPEN SPACE USES

A total of eight land use designations have been defined for these uses. These include open space, agricultural and recreational uses, as well as public/semi-public uses such as schools; public offices; highways and major flood control rights-of-way; and railroads. These use designations generally comprise non-urban uses under the 65/35 Land Preservation Standard.

Based on these adopted policies, staff categorized each land use designation as either urban or non-urban for purposes of the 65/35 analysis. These classifications are presented in Table 2. Some of the less straight-forward classifications are explained below. Public and semi-public designations were classified differently depending on the actual use. These categorizations are explained in Step 3 where the parcel-specific inventory process is described.

Off-Island Bonus Density Area: The Off-Island Bonus Density Area is a County General Plan designation for a large area south of Bethel Island (adjacent to Sandmound Slough). The underlying General Plan designation for this area is Agricultural Lands, but it has an overlay which allows density increases if certain criteria are met. Within the overlay area, covering approximately one-quarter of the bonus areas, a 686-acre project called Cypress Lakes, was approved by the Board of Supervisors but has not yet been built. Approximately 320 acres will be for homes, with the remainder being set aside for a golf course, parks, levees, and public and semi-public uses. The levee requirements from the Federal Emergency Management Agency may make development in this area extremely expensive, if not prohibitively so. For this reason, and because the base Agricultural Lands designation

Table 2: Classification of General Plan Land Use Designations

According to Requirements of Measure C (1990),

the 65/35 Land Preservation Plan

ABBREVIATION ON LAND USE MAP	LAND USE DESIGNATION	CLASSIFICATION FOR PURPOSES OF 65/35 INVENTORY
	Single-Family Residential
SV	Very Low	urban
SL	Low	urban
SM	Medium	urban
SH	High	urban
	Multiple-Family Residential
ML	Low	urban
MM	Medium	urban
MH	High	urban
MV	Very High	urban
MS	Very High-Special	urban
CC	Congregate Care-Senior Housing	urban
MO	Mobile Home	urban
	Commercial/Industrial
RC	Regional Commercial	urban
CO	Commercial	urban
ACC	Airport Commercial	urban
OF	Office	urban
BP	Business Park	urban
LI	Light Industry	urban
HI	Heavy Industry	urban
CR	Commercial Recreation	urban
M1, etc.	Mixed Use (M1, M2, M3, etc.)	urban
LC	Local Commercial	urban
MC	Marina Commercial	urban
	* classification explained in staff report
	Table 2 (continued)
	Other
PS	Public and Semi-Public	mixed*
LF	Landfill	non-urban*
PA	Off-Island Bonus Area	non-urban*
	Open Space
PR	Parks and Recreation	non-urban
OS	Open Space	non-urban
AL	Agricultural Lands	non-urban
AC	Agricultural Core	non-urban
DR	Delta Recreation	non-urban
WA	Water	non-urban
WS	Watershed	non-urban
	* classification explained in staff report

perhaps best defines future uses in this area for the foreseeable future, the Off-Island Bonus Area was categorized and tabulated as non-urban, with the exception of the urban portion (320 acres) of the Cypress Lakes project.

Landfill: The definition of non-urban uses provided in the above excerpts from the 65/35 ordinance and the General Plan, as well as the description of the Landfill designation on page 3-38 of the General Plan which indicates that Landfill should be considered non-under Measure C (1990), make clear that lands with this designation are to be considered non-urban in the 65/35 inventory. For purposes of the 65/35 inventory, the nearly-closed Acme landfill and the closed IT waste facility near Martinez were classified as Landfill. They were created before the County General Plan had a landfill category and are actually designated as Heavy Industrial. The West County Landfill has an open space General Plan designation and was counted that way.

Step 3—Mapping and Digitizing Parcel-Specific Information on Parks, Open Space, and other Public Lands: To add detail to the General Plan-based inventory, and to account for actual non-urban uses which might be missed if relying solely on the General Plan, current information on parks, dedicated open space, and other public/semi-public land uses was gathered and mapped on a parcel-specific basis. This parcel-specific precising is summarized below:

Updating of Public Park and Watershed Land Acquisitions: County staff initiated a program of gathering land acquisition information from the major park and watershed management agencies which serve the County, e.g. EBRPD, EBMUD and CCWD. While most of these acquisitions occurred outside the ULL, there was a substantial amount of parkland acquisition within the ULL. Other public agencies have also acquired substantial acreages, e.g. the Ironhouse Sanitary Districts acquisition of lands for treated water disposal on Jersey Island (though this example is outside the ULL). County and city parks were also included in the inventory. This information was mapped on County parcel base maps, digitized, and reflected in the analysis even when in conflict with General Plan designations.

Inventory of Deed Restricted and/or Dedicated Open Space areas: County staff cooperated with other agencies in trying to identify areas which had permanent restrictions limiting development either through actual easements, deeds of development rights, or restrictions imposed as part of final subdivision maps. Project specific development decisions quite commonly restrict development within areas which may be shown for development on an adopted general plan (it is common for cities and the County to designate these areas as open space on their general plans after the fact; but this may not occur until many years later). The inventory included lands where deeded development rights have been granted to the County, a city, EBRPD or private conservation organizations as well as lands restricted by notations on the final subdivision maps. Areas where wildlife easements have been granted to State or Federal regulatory or administrative agencies are also included.

Very small open space areas, roughly 5 acres or less, were omitted. Likewise, open space areas which run through condominium and townhouse developments were mapped but omitted from the analysis even though such areas may have a relative significant total area. The reason for this was that such areas usually take the shape of very narrow ribbons of land and are perhaps more akin to yards than community open space. In addition to these intentional omissions, there are, no doubt, additional areas of restricted open space lands which were not identified in this effort but would have been suitable for the analysis had they been found. However, the dedicated open space which was captured by the inventory was substantial (almost 13,000 acres) and likely represents the vast majority of all such dedications.

Inventory of Public and Semi-Public Lands and Categorization of these Lands as Urban and Non-Urban: As with the other parcel-specific inventories, public facilities and private lands serving public purposes (these are referred to as “semi-public” in the General Plan and include facilities like private schools, hospitals, cemeteries, etc.) were inventoried, mapped on the parcel base, and entered in the computer.

However, unlike parks and open space, not all public and semi-public uses are intuitively non-urban. For instance, freeways and government office buildings can only be contemplated as non-urban uses because of the specific definition of “non-urban” provided in the 65/35 ordinance (… “and facilities for public purposes, whether privately or publicly funded or operated, which are necessary or desirable for the public health, safety or welfare or by state or federal law”). By any other standard, freeways and office buildings are clearly urban features.

Faced with this incongruity, County staff elected to categorize public and semi-public uses differently depending on the type of use. Two considerations drove this decision, as well as the decisions on how particular uses should be categorized:

1) The 65/35 ordinance does not indicate that all public facilities should be considered non-urban, only those “necessary or desirable for the public health, safety, or welfare…” (likewise, the General Plan states that Public/Semi-Public and other related land use designations “…generally comprise non-urban uses…” (emphasis added)).

2) The 65/35 inventory should reflect a reasonable, common sense interpretation of what types of uses are urban and what types are non-urban.

Based on these criteria, the following public and semi-public uses inside the ULL were categorized as non-urban for purposes of the 65/35 inventory:

· Schools and colleges

· Landfills

· Major sanitation facilities (most such properties contain significant wetland and undisturbed areas)

· Cemeteries

· Canals and flood control channels

The following Public and Semi-Public uses inside the ULL were categorized as urban for purposes of the 65/35 inventory:

· Freeways and highways

· Railroads

· BART property

· Other miscellaneous public and semi-public uses (government offices, community centers, public corporation yards, hospitals, etc.—separately mapping and tabulating each of these additional uses was beyond the scope and timeline of this inventory effort)

Inventory of Industrial Buffers: The final parcel-specific precising of the 65/35 inventory related to the concept of industrial buffers—areas adjacent to industrial complexes which are acquired and maintained primarily as a buffer to avoid potential future land use conflicts. Traditionally, industrial property owners have had their entire land holdings designated for industrial uses unless the land was constrained by, for example, wetlands, which might be designated for an open space category. Such plan limitations are more the exception than the rule. A consequence is that more land is generally designated industrial than is actually used and the amount of open lands within this designation is often very high.

In recognition of these factors and of the fact that the use of industrial land-use categories may not reflect non-urban uses, it was decided that several industrially designated large areas would receive the additional categorization of "Industrial Buffer" to reflect their open-space character. It was decided to only do this for the areas covered by the County General Plan where County staff had more information available than for other city areas, e.g. the Chevron refinery in Richmond. In city areas, the city plan categories were used.

The areas which received such treatment were:

· Tosco lands east of I-80 which are almost totally undeveloped. This includes 358 acres.

· Tosco lands north of the Highway 4 freeway expansion project. Some of this area will likely have conservation easements placed on it to protect special-status species as a condition of the freeway project. The rest of this area has not been proposed for any industrial use to date. This covers 121 acres.

· Shell Oil lands within the unincorporated area which are wetlands. This area is adjacent to Carquinez Strait. Regional, state, and federal regulatory agencies aggressively protect the wetland resources in this area. The wetlands area identified in the "Atlas of Tidal and Formerly Tidal Wetlands in Contra Costa County, California" have been designated as industrial buffer and include 50 acres.

· The large buffer zone around the DuPont chemical plant in the Oakley area is the final case. The northern part of the buffer is wetlands or potentially reclaimable wetlands and there is a large area of previously Dupont-owned land that was sold to Oxfoot Associates for agricultural use, much of which is in vineyard use. The land is restricted to agricultural use by contract. These areas including 258 acres are included as industrial buffer.

Step 4—Tabulation Methodology: Once the ULL, the non-urban General Plan designations, and the parcel-specific inventory of parks and other non-urban features had been mapped and entered in the computer, the GIS software was used to query the data and measure areas.

After measuring the area of the County (excluding the water areas of the County west of Stake Point near the community of Bay Point, as specified by the 65/35 Ordinance) and the area outside the ULL, areas of the various non-urban data layers inside the Urban Limit Line were measured. The total area of these non urban uses inside the ULL plus the area outside the ULL divided by the County area provide the percentage measurement presrcibed by the 655/35 ordinance. These figures are presented in Table 1.

Because the 65/35 inventory process was conducted with an eye toward developing a GIS database on land use and public ownership, data was mapped in layers and areas of overlap were ignored during the mapping phase. For example, the Keller landfill area is mapped in its entirety as a Landfill designation even though the ULL bisects it and there is also a conservation easement over the eastern area. When the acreage measurements were performed, staff accounted for the overlap issue by prioritizing the data levels and ensuring that only the highest priority data level in an area of overlap was counted. The ULL had the highest priority, followed by the parcel specific data, and finally the General Plan data. In the case of the Keller Landfill, the portion outside the ULL was measured as area outside the ULL. The portion with an easement was measured as dedicated open space. The remainder was tabulated as Landfill.

4) Discussion of Results

A few basic points should be made here regarding the interpretation of the inventory results:

· The computer measures areas very accurately, but staff’s ability to map every feature we intend to map is not as reliable (though substantial work went in to proofreading and making the inventory as accurate as possible). The acreage figures should be viewed with a certain degree of uncertainty.

· The inventory method records planned development as urban even if the development has yet to occur, and, conceivably, may never occur. This was done to make the inventory conservative and predictive.

· Comparing this inventory with the one conducted in 1990 is not straightforward as the new computer technology enabled staff to use a different, more detailed method. This method identified more non-urban land within the ULL than was identified in 1990, though most of those uses probably existed in 1990.

5) Overview of Alternative Inventory Approaches Which Were Considered

As mentioned previously, the 65/35 ordinance sets a standard but does not prescribe a specific method for measuring compliance with this standard. To provide further context on why staff chose the method it did, we have included below a description of some of the alternative approaches which were considered. The ultimate method used was a combination of 3 & 4.

1) Build on 1990 inventory by documenting land use changes which have occurred since that time: The General Plan contains information on the outcomes of the land inventory conducted at the time the General Plan was approved in 1990. Rather than re-inventory the entire County, one approach for updating these percentages would be to research all land use or General Plan changes since 1990 and adjust figures accordingly.

The attractiveness of this approach is that it builds on what was done before and might require less work. However, it is unclear how much effort would be involved in researching land use changes throughout the County since 1990 and calculating the areas of converted land (it would also be difficult to ensure we had completely documented all such changes). Likewise, with our new computer mapping tools, we could conduct a more detailed inventory now than then and provide clearer documentation of how the inventory was conducted. These potential problems would persist if we needed to update the inventory again in several years.

2) Conduct inventory using a method of calculated estimation: The 65/35 land inventory could be efficiently conducted by estimating the extent of urban and non-urban uses in certain difficult-to-measure areas of the County. For instance, rather than measuring the area of each small park, ball field, golf course, and open space area within a city, we could rely on ABAG statistics concerning the typical percentages of lands within a city dedicated to parks and open space. Alternatively, we could perform detailed measurements for one city in the County which we believe to be prototypical, and use these figures to make estimates for other cities. The County General Plan could be used as the basis for inventorying areas of the County that are relatively easier to measure or not suitable for estimation.

The primary advantage of this approach is that it could require substantially less time than other methods. It may also be repeatable and verifiable, depending upon how clearly we define estimation procedures and the types of areas which should be included in the estimation process. Finally, one might be able to make the case that this less rigid approach is appropriate considering that the overall 65/35 analysis is very difficult and any approach will have significant uncertainty. However, one could also make the opposite case that, just because the ordinance doesn’t specify how the 65/35 inventory is to be conducted, it is nonetheless important to make a precise measurement. The primary disadvantage of the estimation approach is that it cannot provide such a precise inventory. It might be difficult to develop a 65/35 enforcement process around an estimated inventory when other, more precise, inventory methods exist.

3) Base inventory on city and county general plan land use designations: This approach would involve categorizing each type of city and county land use designation as an urban or non-urban use. In instances where a land use designation cannot be universally classified as urban or non-urban, the determination may be made on a case by case basis. To add greater detail to the method and to make it current, cases where current land use differs from the land use designation could be documented and factored into the inventory. For instance, land with an urban-type land use designation that has yet to be developed could be considered as non-urban rather than urban.

Closely linking the inventory to general plans has several advantages. First, general plans present the best available geographical interpretation of actual land uses (not only allowable land uses), and it makes sense to use these designations as a surrogate for measuring land use on the ground. Second, this method is verifiable and could be accurately replicated in several years (should an updated inventory be necessary) as the procedure could be quite precisely defined. Third, general plans are cities’ and the county’s primary tool for regulating land use and development, so relating the 65/35 preservation standard to general plans implicitly suggests a mechanism for enforcing the standard (i.e., requiring a finding of compliance with the 65/35 standard before approving an amendment to the County’s General Plan--though this enforcement mechanism doesn’t address the actions of the cities). Fourth, by measuring permitted uses rather than actual land uses even in those areas where anticipated development has not yet occurred, we can assure that the 65/35 inventory reflects approved policy. By adopting such a conservative approach, compliance with the 65/35 standard could managed at the Advanced Planning level rather than at the Current Planning level. When consistent with the General Plan, minor-subdivisions, land use permits, and building permits could be issued without making a finding of compliance with the 65/35 standard. Should a more detailed inventory be desired to account for areas with an urban-type land use designation that are currently being used in a non-urban manner, refinements should focus on projects which have yet to receive full entitlements in the development review process.

The disadvantages of relying on general plans include the following: actual land use may not be consistent with general plans in some instances; the general plans may present an oversimplified picture of land use (e.g., areas designated for heavy industrial use, for instance, may include substantial open space buffers, etc.); and this approach may not entirely match the process used in 1990.

4) Conduct inventory on a parcel-by-parcel basis: The 65/35 land inventory could be conducted on parcel-specific basis by designating each parcel in the County as either urban or non-urban. The Public Works Department parcel database or the Land Use Information System could be employed to determine which parcels are urban and which are non-urban, based on present use as well as zoning and General Plan land use designations. Some parcels might require more than one designation (i.e., and industrial facility with a large buffer).

The advantages of this approach are: a) depending upon how it was conducted, this approach could be considered a precising of the General Plan methodology (#3), b) it is repeatable, and c) the focus on parcels might help relate the inventory to actual uses on the ground and make the inventory current rather than a forecast, should this be desired . The primary disadvantage of this approach is that it would be labor-intensive and might provide unnecessary detail. Also, if the parcel-based inventory was based on current use, it might be difficult to integrate the inventory with the development review process (i.e. Current Planning participation would likely be required in any 65/35 compliance program to ensure that development applications on parcels already designated for an urban use do not violate the 65/35 standard).

5) Interpret a satellite photo of the County: This approach would involve development of protocols for distinguishing urban from non-urban land in a satellite photo. For instance, such protocols might define non-urban areas as those with densities below 1 structure per 5 acres, and could also define as non-urban those patches of undeveloped land within developed areas that are larger than 1 acre, etc. This approach would provide a very direct measurement of urban and non-urban land. However, the measurement would not be tied to any land use regulations. Likewise, it is possible that discriminating between urban and non-urban land in a satellite photo could be difficult in some instances, especially since the 65/35 ordinance considers certain public facilities to be non-urban. Should an additional inventory be needed several years from now, it would be hard to assure that this somewhat subjective method would be employed in exactly the same manner as before.

Staff from the Public Works Department provided substantial assistance with the computer mapping and area calculations. Their contributions are appreciated.

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[1] Excluding water areas west of Stake Point—see text for explanation.

[2] Excluding 3 small areas of pre-existing “urban” use outside ULL—see text for explanation.