Public Record Letter on General Plan Records and AI Policy City Council Study Session September 22 2026
September 22, 2026
Mayor and Members of the Laguna Beach City Council
c/o City Clerk
505 Forest Avenue
Laguna Beach, California 92651
Re: Records first and required attachments before General Plan RFP release and AI policy implementation
Dear Mayor and Councilmembers:
Please do not release the Comprehensive General Plan Update RFP or move beyond limited AI pilot activity until the Council establishes the records, consistency, and accountability requirements in the attached documents. The City must make recordkeeping its first priority. It cannot reliably determine whether a plan, ordinance, project, permit, or consultant deliverable is consistent with adopted policy if the governing records are scattered, unsearchable, incomplete, or unsupported by source citations.
General Plan consistency is not established by citing one supportive policy in isolation. Government Code section 65300.5 requires the General Plan and its elements and parts to function as an integrated, internally consistent, and compatible statement of policy. The Forest Avenue Promenade illustrates the problem. The City relied on the Land Use Element, but did not provide the public with a project-specific crosswalk to the other General Plan elements, maps, and policies the project may implicate. A citation to one element does not establish overall General Plan consistency.
Many residents, including me, have lost faith that the current Council understands how to carry out this work without putting the City into another costly mess. Too often, the City begins spending money, adopts an ordinance, or launches a project before it defines the governing rules, record, budget, scope, and public decision points. That is reactive government, not comprehensive planning. The Council must set the framework now in public, rather than leave it to later staff interpretation, consultant scope changes, or an AI tool.
The Comprehensive Zoning Code Update shows why this matters. Its authorized contract ceiling increased from $321,449 to $709,749. That does not prove the full amount was paid, but it does require a public accounting of actual invoices, scope changes, work products, acceptance, remaining budget, and work still unfinished before the City enters another multiyear planning contract.
Attached requests for Council direction
• Attachment A requires a reliable public record, a complete General Plan consistency method, a public deliverables ledger, and an interim process for policy conflicts. • Attachment B identifies the specific revisions that should be inserted into the General Plan RFP and consultant agreement before procurement begins.
• Attachment C sets the records, human-review, public-transparency, and pilot controls that must accompany any AI policy.
This request does not ask the City to stop comprehensive planning or responsible technology use. It asks the City to use the correct sequence: establish the record, identify the governing policy, make conflicts visible, and then decide what work to fund. Residents and taxpayers deserve a public record that lets them see what the City contracted for, what it received, and why it acted.
I am copying Stu News and the Laguna Beach Independent because the public should be able to see these commitments before the City issues a new RFP or expands AI use.
Respectfully,
Karen Martin
Laguna Beach resident, urban planner, and candidate for City Council cc: Stu News Laguna; Laguna Beach Independent
References: General Plan Update staff report and RFP attachments; Government Code sections 65300.5, 65454, 65860, 65943, and 7920.530; Public Resources Code section 30604.
Attachment A
Records and General Plan Consistency FIRST
Required direction before General Plan RFP release and AI policy implementation Records are the threshold requirement. The City cannot demonstrate that a proposed action is consistent with the General Plan, certified Local Coastal Program, zoning regulations, specific plans, prior approvals, or state law unless it can identify and cite the actual governing records. A consultant and an AI tool can organize information, but neither can repair an incomplete or unverified record after the City has already made a decision.
1. Establish and publish an authoritative planning and project record.
Before issuing the RFP, staff shall publish a source inventory for the General Plan and its elements, maps, and implementation programs; certified LCP; zoning regulations; specific plans; objective standards; active ordinances; final project approvals; technical studies; and all prior contracts and work products relevant to the update. Each item must identify its official source, adoption or effective date, current status, accessible location, searchability, and any known gap. The City must distinguish a record that has not been found from a record that does not exist.
2. Use a complete General Plan consistency method.
For every City-initiated planning action and project that requires a General Plan consistency finding, the public record must identify all relevant elements, policies, maps, diagrams, and implementation programs, not only a single favorable provision. It must also identify whether zoning, the certified LCP, a specific plan, a final approval, or state law raises a conflict or additional requirement.
Government Code section 65300.5 requires an integrated, internally consistent, and compatible General Plan; Government Code section 65860 separately requires zoning consistency with that plan.
The Forest Avenue Promenade is a current case in point. The City cited the Land Use Element, but that alone does not show how the project relates to the other relevant General Plan elements and policies.
The public record should include a source-cited consistency crosswalk, explain any policy tensions, and state the decision path for resolving them. A selective citation is not a comprehensive consistency analysis.
3. Create a public contract and deliverables ledger.
Before any General Plan Update invoice is paid, the City shall maintain one public dashboard showing each task, subtask, amendment, and optional study; approved scope; not-to-exceed amount; contingency; invoice and payment information; scheduled and actual milestone dates; nonconfidential work products; written staff acceptance; remaining budget; and explanation for each material delay, scope change, or cost change. The same dashboard should provide a retrospective status of the Comprehensive Zoning Code Update, including the original and amended scope, expenditures, completed and remaining work, transfer work, duplication, and gaps.
4. Adopt an interim Policy Conflict Record process.
When staff, an applicant, a member of the public, or an AI tool identifies a possible conflict among state law, the certified LCP, General Plan, zoning regulations, specific plans, objective standards, or prior approvals, staff shall prepare a source-cited Policy Conflict Record. It must state the exact texts or approvals involved, effective dates, affected matter, legal or policy framework, statutory deadline, responsible reviewer, and proposed resolution path. The process may not create a new substantive standard or an undocumented delay. Matters that require legal interpretation, a plan or code amendment, CEQA review, Coastal Commission review, or a noticed Planning Commission or Council action must be routed accordingly.
Required recordkeeping controls
• Assign responsibility for maintaining the authoritative inventory, records-gap register, public dashboard, and conflict records.
• Preserve source citations and version dates so a resident can verify the basis for a staff recommendation or Council action.
• Ensure that searches, exports, retention, and public-records review can be performed for material project files, consultant deliverables, and AI-assisted work product. • Use a written correction process when the City discovers that a record, policy citation, or project history is incomplete or incorrect.
Council direction at the study session
• Direct staff to publish the authoritative inventory and records-gap register before RFP release. • Direct staff to establish the public contract and deliverables ledger before consultant selection. • Direct staff to return with the interim Policy Conflict Record process and responsibility assignments.
Legal framework: Government Code sections 65300.5, 65454, 65860, 65943, and 7920.530; Public Resources Code section 30604. These requirements seek an accurate record and an identified review path; they do not direct a legal conclusion in a pending matter.
Attachment B
General Plan RFP Requirements
Required revisions before release of the Comprehensive General Plan Update RFP The RFP should begin with an accountable public baseline, not a consultant effort that must reconstruct missing records after procurement. The following requirements should be inserted into the RFP and consultant agreement before release. The consultant's work must be source-cited, publicly reviewable, and coordinated with the records and Policy Conflict Record process in Attachment A.
1. Make the authoritative records and consistency baseline the first notice to proceed.
The first deliverable shall verify the City's published source inventory and records-gap register. It shall establish the source hierarchy for state law, certified and adopted local policy, final approvals, historical evidence, and draft research. It shall identify incomplete, conflicting, image-only, or inaccessible records that affect the work plan and create a public plan for resolving those gaps.
2. Add a public handoff and duplication crosswalk to Task 14.
The consultant shall prepare an early crosswalk between the Comprehensive Zoning Code Update and the General Plan Update. It shall identify the original and amended scope; completed and remaining deliverables; expenditures and remaining budget; responsible parties; transfer work; duplication; and gaps. The crosswalk must be presented publicly to the full Council before the consultant begins policy drafting.
3. Strengthen Task 2 into a full internal and cross-document consistency audit.
The audit must compare the General Plan against itself, including elements, policies, maps, diagrams, and implementation programs, as well as compare the General Plan with the certified LCP, zoning regulations, specific plans, active ordinances, objective standards, final approvals, and relevant state law. For each inconsistency, identify the affected text, governing issue, recommended correction, required CEQA or Coastal process, cost, responsible department, and interim decision rule that follows Attachment A. Publish the audit and misalignments table before major policy alternatives are selected.
4. Make Task 12 capacity and fiscal analysis required base scope.
The base scope shall include reproducible analysis of water, sewer, storm drainage, roadway operations, emergency access and evacuation, seasonal visitor demand, public-service needs, capital facilities, lifecycle maintenance, operating costs, funding restrictions, and financing options. It must test existing conditions and future development assumptions, including RHNA and infill assumptions, and directly inform policy and implementation decisions.
5. Make Task 15 a funded implementation program.
Require a 20-year capital and fiscal implementation plan tied to each General Plan action. It shall identify the responsible department, time frame, dependency, capital cost, operating and maintenance cost, funding source and restrictions, required zoning or LCP action, performance measure, and public reporting schedule.
6. Require a public contract and deliverables ledger.
For every task, subtask, amendment, and optional study, the ledger must show the approved scope, not-to-exceed amount, contingency, Council approval date, invoice amount and payment date, milestone dates, nonconfidential work products, staff acceptance, remaining budget, and a plainlanguage explanation for each scope, cost, or schedule change. The dashboard must be updated at least monthly, and milestone payments should follow written acceptance and public posting of the related deliverable except where protected by law.
7. Set public cost and decision controls before consultant selection.
Before award, the Council should approve a task-level not-to-exceed budget, separately priced optional studies and environmental review, deliverable acceptance criteria, and a clear contingency rule. No task substitution, contingency draw, scope expansion, budget increase, or material policy change should occur without a noticed public staff report to the full Council that identifies the dollars, work added or removed, reason, and schedule effect.
8. Correct the schedule and preserve meaningful future Council review.
The RFP must include a realistic critical path for the Housing Element, Coastal Commission review, CEQA, public review, Planning Commission recommendation, and Council adoption. It should include public Council decision gates after the records and consistency audit and after the capacity and fiscal findings, so the Council seated in 2027 and later can make informed choices rather than inherit a fixed process without the evidence.
Agenda packet references: Staff Report, pp. 1 and 7-9; Attachment 2, Tasks 1, 2, 12, 14, and 15; Attachment 2 anticipated schedule, pp. 19-20.
Attachment C
AI Policy Requirements
Records governance human review and pilot controls for Community Development The City should not treat an AI policy as a general permission slip. Responsible AI begins with trustworthy information. Before the City expands AI use in planning, permits, code enforcement, public works review, or public-records support, it must establish what records the tool will use, where they are stored, how the City can verify them, and who remains accountable for each decision.
1. Put records governance before routine AI use.
The City shall identify the records an AI system may access and publish a records-lifecycle plan for material prompts, outputs, source-cited packets, corrections, logs, and vendor reports. The plan must identify storage, search, export, retention, deletion, access control, and public-records review. A record that is used or retained in public business may require retention and disclosure analysis; the City should not assume that an AI-generated draft is exempt or outside the records system.
2. Require a source hierarchy and exact citations.
AI outputs must distinguish governing authority from historical evidence and draft research. State and federal law and binding standards come first; then certified and adopted local policy; then final project approvals; then staff and historical records; and finally AI-generated research. Every material factual statement must link to the underlying document, page, sheet, code section, policy, permit, or resolution so staff and the public can verify it.
3. Define permitted and prohibited uses.
AI may help locate, organize, cite, summarize, and flag records or possible policy conflicts. It may not make a formal completeness determination, interpret law, select a controlling policy, impose a condition, make a CEQA finding, determine what is disclosable or privileged, make an enforcement determination, or approve or deny an application. Staff and authorized decision-makers must verify any output before relying on it.
4. Use the interim Policy Conflict Record process.
When AI identifies a possible conflict, it shall generate a source-cited flag for staff review, not a decision.
The City shall use the Attachment A process to identify the exact sources, effective dates, affected matter, applicable framework, deadline, reviewer, and resolution path. The Planning Director and City Attorney should determine whether the issue can be resolved under existing law or requires a noticed action, amendment, CEQA review, or Coastal Commission process.
5. Require vendor controls and portability.
Any contract must protect City data and prohibit training on City records by default unless expressly approved. It must address confidentiality, cybersecurity, data ownership, audit logs, retention, deletion, correction workflows, and the City's ability to export its data, prompts, outputs, metadata, and logs if it changes vendors. Vendors must demonstrate source citations and staff verification on actual City records before expansion.
6. Use a limited, transparent pilot before expansion.
The Council should authorize narrowly defined pilot uses such as records retrieval, property and permit history packets, interdepartmental review packets, and source-cited policy conflict matrices. The City shall publish the pilot purpose, data sources, responsible staff, vendor, safeguards, evaluation criteria, accuracy results, false-positive and false-negative findings, records performance, cost, and recommendation before expanding use.
7. Maintain public accountability.
The City should publish an inventory of active AI uses, identify the department and purpose for each, and provide a way for residents and applicants to understand when AI-assisted information materially informed a staff process. Human staff and elected decision-makers remain responsible for public explanations, legal compliance, and final action.
Policy foundation: Karen Martin, A Roadmap for Trusted Information and Responsible AI in Community Development, Peer Review Draft v0.9, August 2026. The roadmap is a vendor-neutral framework, not legal advice. Relevant legal framework includes Government Code sections 65300.5, 65860, 65943, and 7920.530.