Brigit Bennington, Mayor 9700 Seventh Avenue Larry Bird, Mayor Pro Tem Hesperia, CA 92345 Cameron Gregg, Council Member 760-947-1000 Allison Lee, Council Member TD 760-947-1119 Rebekah Swanson, Council Member
Rachel Molina, City Manager www.cityofhesperia.us Gateway to the High Desert
City of Hesperia
Supervisor Dawn Rowe, Chair
San Bernardino County Board of Supervisors
385 N. Arrowhead Avenue
San Bernardino CA 92415
Subject: City of Hesperia Opposition to the Regional Conservation Investment Strategy (RCIS)
Dear Honorable Chair Rowe and Board of Supervisors:
The City of Hesperia appreciates and supports the goals set forth by the Countywide V ision.
Hesperia is a co mmunity dedicated to fostering sustainable growth and preserving our unique environment. As we work collectively towards realizing the goals of the Countywide Vision, we appreciate the steadfast commitment that the County and its leadership bring to these endeavors.
The Countywide Vision, with its idea of a complete and prosperous county, resonates deeply with us. We have actively engaged in collaborative initiatives to advance this vision and bring forth a balance between responsible development and envir onmental preservation. It is with this commitment to progress in mind that we communicate our concerns and position regarding the proposed Regional Conservation Investment Strategy (RCIS).
The City holds the values of transparency, open dialogue, and mutual understanding in high regard. We understand that the RCIS has undergone careful consideration and is intended to provide a framework that addresses both housing and conservation needs. Nevertheless, we feel it is essential to voice our concerns to ensure that the strategy aligns with the best interests of our community and region.
The City acknowledges the complexity of finding common ground between development objectives and conservation priorities. We appreciate the County's intention to streamline processes and create a balanced approach through the RCIS. However, we have apprehensions regarding potential unintended consequences such as the direct threat to local control and the need for careful evaluation before proceeding with its finalization and submission for approval to the California Department of Fish and Wildlife (CDFW).
In this regard, we propose a collaborative effort that considers the perspectives of all stakeholders involved. Prior to the final submission of the final RCIS to CDFW we urge the County Board of Supervisors and the San Bernardino County Transportation Authority (SBCTA) to revise the draft RCIS to (i) clearly state what the RCIS is intended to do and not intended to do, and (ii) appropriately circumscribe the potential use of the RCIS in connection with local land use decision-making.
More specifically, we strongly recommend that the County and SBCTA consider revising the draft RCIS to reaffirm the following points:
1. COUNTY supports the finalization and for mal submission to CDFW of the RCIS in ongoing reliance of the promise that the RCIS, once finalized, shall constitute voluntary, non -binding and non-regulatory guidance only and is not intended to and shall not be used in any CEQA context; and
2. COUNTY rec ognizes that the RCIS includes specific numeric targets that are based on landscape-scale planning and are therefore not appropriate to utilize in the analysis of individual projects, master plans, or large-scale future development planning; and
3. COUNTY will not use the RCIS as a tool to require additional mitigation for projects; and
4. COUNTY intends that the RCIS shall not be recognized as a tool to stop or limit development; and
5. COUNTY recognizes the important societal goal of approving new housing projects, updating housing elements, and facilitating the production of housing (and the infrastructure/public facilities needed to support such new housing), consistent with the State’s RHNA law and general plans, shall be prioritized over and above the conservation goals that are reflected in the RCIS.
In particular, the City encourages the County to clarify the intent and scope of the RCIS to prevent any potential misinterpretations and ensure responsible implementation. Revising the draft RCIS and reaffirming the purpose and limitations of the RCIS will provide a clear framework that minimizes ambiguity and guides application.
In conclusion, as highlighted in the statement of the Countywide Vision Housing Element, "The affordability of our housing has long been a moving factor in the attraction of new residents to San Bernardino County. It is key that we continue to expand our housing choices through new construction and preservation of our existing residential buildings to provide all our residents an opportunity to find their homes."
Regrettably, the current draft RCIS , in our opinion, undermines the essence of the Countywide Vision Housing Element. At its worst, it could worsen the housing shortage, as it might be used by individuals seeking litigation to exploit the conservation goals outlined therein. At best, it could cast a shadow of uncertainty over a considerable expanse of potentially developable land, adding more ambiguity to the land acquisition and entitlement process.
Should you have any inquiries regarding the attached comments, please don't hesitate to reach out to us. We appreciate your consideration.
Sincerely,
Rachel Molina
City Manager