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~ Development Reduction ~

Section 11.2


The Brooktrails Board of Directors, after receiving the reports of two separate community advisory groups and in conducting two well-attended community congresses, and after conducting numerous public hearings, determined that development at the level of 4,000 SFRs was the most realistic level of development within the Specific Plan Planning Area with reference to a balance between economic viability and environmental concerns. Upon adoption of the Specific Plan and certification of the accompanying EIR by the County, the County and District will have assumed responsibility for implementing the Specific Plan as the critical link between development in the Specific Plan Planning Area and the provisions of the Mendocino County General Plan. Brooktrails Township is, thus, obliged to take the necessary measures to see that the goals and policies of the Specific Plan are followed.

In selecting a 4,000-SFR level of development for preparation of the Specific Plan, the Brooktrails Board of Directors has implied a reduction of 2,000 SFRs from the existing 6,000-SFR total. If historical rates of growth continued, development of the Specific Plan Planning Area to 4,000 SFRs would take 60 to 70 years. By approximately year 2061, it would be necessary to retire development rights on 2,000 SFRs, or an average of about 30 SFRs per year, to cap development at the indicated level.

Therefore, the methods through which it may reduce the maximum development potential if the 4,000-SFR level of development is to be achieved must be considered. This section addresses the development reduction issue. Following some discussion of considerations for selecting an approach to development reduction, it reviews possible mechanisms that may be part of a comprehensive program to bring about a specified level of growth.

The appropriate methods to bring about development reduction in Brooktrails Township will depend upon the number of development rights to be retired and the rate of growth. Approaches to development reduction considered here are placed into two categories. The first approach, termed


attrition, involves no government involvement, recognizing that some lots cannot or would not be developed at all due to physical, economic, or ownership constraints. The second approach offers incentives for voluntary development rights retirement. The approaches are not exclusive and, in fact, the most effective program might include a combination of methods to appeal to a diversity of property owner preferences and objectives.

Implementation of the Specific Plan will involve monitoring progress on the goals and policies. Where development reduction is concerned, the District would periodically review the ratio of lots built to development rights retired, and adjust its approach accordingly. Initially it is envisioned that voluntary measures would be put in place. If these failed to achieve the desired level of development reduction, further incentives to retire development rights, or reconsideration of the development limit may be required.

The balance of this section briefly describes the two approaches mentioned above. Discussion of potential development reductions follow, with an outline at the conclusion of this chapter of how a comprehensive approach might be formulated.

In the absence of any governmental action, a certain number of lots are constrained such that development may not occur at all. A total of 985 lots lie in high development constraint areas. Some of these have slopes in excess of 40%. Others lie within the Maacama Fault Zone. Though special construction techniques can overcome seismic and other physical difficulties, enough alternative sites exist in the region that, in many cases, an owner of a high-constraint lot would find it economically advantageous to build elsewhere.

Also, in a subdivision characterized by disperse and often absentee ownership, it is probable that a small percentage of lots will not be developed at all, particularly if they are held in trust or under absentee ownership. Thus, even in the absence of governmental action, a certain amount of natural


attrition will occur, and growth would be limited somewhat by physical and ownership constraints that exist today.

Voluntary Measures
Attrition through physical and ownership constraints, however, is not likely to result in the full 2,000-SFR reduction needed to achieve the 4,000-SFR limit. Some involvement on the part of the District will be required to retire development rights if the desired level of growth is to be achieved. Under a voluntary approach, the District would take steps to encourage development rights reduction undertaken at the initiative of individual property owners.

A number of methods are available that the District could promote to encourage a voluntary reduction of development rights. The premise in this case is that, among the property owners, there exists the desire to undertake actions that would result in the retirement of development rights. For example, some owners may wish to merge with adjacent properties to achieve larger residential sites. To promote mergers, the District might coordinate with Mendocino County to administer a streamlined lot merger process to improve cost and convenience. This could include absorbing some of the administrative costs. Similarly, it could establish a procedure to retire development rights in exchange for income tax deductions, such as through conservation easements. Various financial incentives, such as low-cost loans, could also be considered. These methods are explored further below.

Administration and Cost
The nature of the program will also have a bearing on its cost. The voluntary approaches may be possible to fund out of the District's operating budget or administered at reduced cost with participation of the County.

Voluntary Programs
As noted, a number of voluntary programs could be implemented by the District to facilitate a reduction of potential development in the Specific Plan Planning Area. Lot mergers, conservation easements, market facilitation, and financial incentives are discussed in this section.


Lot Mergers
Through Mendocino County's property boundary line adjustment process, it is possible to combine two or more lots into one. At the zoned density of one detached dwelling per lot, the combined lot will support one unit of development, effectively reducing the density of development that can occur on the same land area. To date, some property owners of contiguous lots have chosen to merge lots to achieve a larger residential site to increase the spacing between neighbors or permit better driveway access. County records indicate that 37 mergers have been undertaken since 1990. For owners of contiguous lots, there is also a property tax incentive to merge parcels. Insofar as the developmental right contributes to assessed value, the elimination of an unneeded development right would reduce the assessed value of the combined lots and the corresponding property tax exposure. Similarly, assessments or special taxes levied on a per parcel basis would be reduced.

In situations where the boundary change is comparatively small, such as erasing an interior boundary line to merge two lots, the changes are reviewed by the County's Minor Subdivision Committee. The property owner wishing to file a boundary line change must fill out a standard form, attach maps and a description of the properties under review.

Presently, the cost ($455 at the time this Plan was prepared) and effort involved in the boundary line adjustment process may serve as a disincentive for owners of contiguous lots to undertake a merger, and it is believed that some property owners inclined to merge their parcels are awaiting completion of the Specific Plan process. In way of promoting lot mergers, the Township could undertake a number of steps to streamline the merger process without any changes to the existing County procedure. Information, advice, and assistance in preparing the application could be available at District offices. The District could maintain maps for attachment to the application; assessor's maps may be appropriate. Further, the District could collect the fees and put the application on the County calendar for review. Steps where the Township could assist are as follows:

Assist in completing applications.

Prepare map and parcel descriptions.

Advise property owners.

Submit applications to the County.

Promote mergers through community bulletins.


Beyond assistance in preparing the application, the Township might seek special arrangements with Mendocino County. The processing fee is a flat charge representing the average cost to the county to process an application. Since the lot mergers in Brooktrails are normally fairly simple, in some cases amounting to erasing an interior line, the county may be able to review these at a minimum cost. Cost could be further reduced, perhaps even eliminated, if the County were to periodically, for example biannually, review a group of Brooktrails mergers at one time. The District might also consider absorbing some or all of the application costs as a further incentive. The District might also seek the authority to review and approve merger applications itself. Currently, this power resides with the county, though through special ordinance it might be possible for the county to delegate prescribed land use regulation powers to the District. In way of precedent, the county has already given the Township the power to prepare the Specific Plan.

Conservation Easements
The federal and state governments recognize conservation easements as tools to preserve land from development. Ownership of land entitles the holder to develop or otherwise extract economic benefit. Under a conservation easement, the owner accepts a restriction on the use of his or her property, and the foregone value of that use is treated as a tax-deductible charitable contribution. Only the right to develop is relinquished, and the original owner retains possession of the land, including the right to exclude public access. If the land is sold, the development restriction holds for subsequent ownership.

Conservation easements can be used for a broad range of purposes, including preservation of wildlife habitat, forests, farmland, historic buildings and sites, and open space. Open space is the most widely applied of the categories, and is relevant to Brooktrails' goals. According to the IRS, preservation of open space can apply to (1) the scenic enjoyment of the general public, or (2) pursuant to a clearly delineated federal, state, or local government conservation policy, and will yield significant public benefit (IRS, 1992). Under California planning law, the purposes justifying conservation easements can be established through a general plan (or through extension of a specific plan). This section of the Specific Plan identifies conservation easements as a means for achieving


Brooktrails' environmental goals, thus constituting its use pursuant to a delineated government policy.

Criteria for establishing conservation easements is set forth in IRS Code Section 170(h). Three basic elements apply, and use of this mechanism under the Brooktrails Township Specific Plan would require a program responsive to each. The criteria are as follows:

The easement must be for a qualified real property interest;

The easement must be granted to a qualified organization; and

The easement must be exclusively for conservation purposes.

The qualified real property interest of concern to Brooktrails is the right to develop. The easements, therefore, would amount to a deed restriction against developing on a particular lot. The Township or Mendocino County would count as an organization qualified to sponsor and receive the easement, both being political subdivisions of the State of California.

The conservation purpose sought for Brooktrails would be relief from urban closeness and congestion. This is among the criteria recognized by the IRS. Originally, Brooktrails was conceived as a vacation community, as noted previously. As a community of part-time residents, the original 6,000-SFR development plan might have been environmentally sustainable. Today, however, it is occupied by full-time residents. Continued development and full-time occupancy will create an unanticipated demand on the Township's public and environmental resources. Therefore, the Specific Plan has set a growth limit of 4,000 SFRs to balance the supply of buildable lots with the preservation of environmental quality. The public benefit and conservation purpose derived from use of conservation easements is relief from urban closeness in Brooktrails that would otherwise be caused by development beyond 4,000 SFRs.

Conservation easements are voluntary. Their success, therefore, rides on attractiveness to owners of property suitable for donation. In most situations, conservation easements have been formed on a case-by-case basis. Typical procedures are shown in Figure 11.2-1. Initially, property owners and agency staff meet to discuss the provisions of the easement, followed by property owner consultation with legal and tax advisors. Qualification demonstrates the "significant public benefit" required for


eligibility for the tax deduction; this is satisfied by the Specific Plan. The owner and agency negotiate and finalize the terms of the easement and prepare an appraisal. The appraisal establishes the property's value with and without the easement to determine the size of the tax deduction. If the same owner holds an adjacent property, there may be some value added to the second property due to the preservation of open space which must be taken into account. The easement is concluded with the parties finalizing the documentation and filing the deed restriction with the County.

Figure 11.2-1

Conservation easements present some interesting opportunities for Brooktrails. Several factors work to Brooktrails' advantage, making it possible to construct a program that could be administered efficiently and with reasonable cost. All lots are set in the same community, the same jurisdiction, and are subject to the same economic forces. Thus, several steps could be standardized. Information and application materials could be available in a packet offered by the District. The District could retain local legal and tax experts to advise interested property owners. Title information and appraisals could similarly be provided by a local company with an ongoing knowledge of Brooktrails and the District's situation.

A conservation easement is being explored at the time of this writing for lands on the perimeter of the Township. Based on this experience, the cost for future lots is estimated to be around $700; formation costs are tax-deductible as well. To be feasible, the formation cost must compare


favorably with the tax benefit. Illustrating the potential income tax benefits, assume that a Brooktrails home owner has an adjacent lot at $10,000. (Average lot value is around $21,000, such that this example would represent a lot somewhere below the average in terms of desirability.) With a deed restricting development, further assume that the value drops to $3,000, representing a value of the development right of $7,000. Adding the approximate administrative cost of $700 to the foregone value results in a total economic cost of the dedication of $7,700. If the property owner is at the 35% income tax bracket, the resulting tax incentive is around $2,700. If this exceeds the owner's income tax liability on one year, the unused portion can be carried forward to subsequent tax years. In addition to the direct income tax benefits, the owner would pay lower property taxes on the two lots, since a new assessed value would reflect retirement of one development right.

In many cases, the conservation easement may be a desirable option. It has the benefits of (1) preserving space between dwellings, yet restricting public access; (2) compensation for foregone economic use; and (3) can be employed systematically in Brooktrails. For the existing home owner wishing to secure privacy through restriction on an adjacent lot, a conservation easement would be a suitable approach. Conservation easements may not be appropriate in all cases, however. The easement restricts any major improvement. This means that an owner wishing to build on a double lot would have to locate all structures on the unrestricted parcel. Such an owner might prefer a lot merger instead to retain the option of placing improvements anywhere he or she might wish.

Market Facilitation
Economic activity depends on the successful matching of buyers and sellers and the availability of information. With this in mind, the District could maintain planning and ownership data useful for market participants who might be interested in the lot merger and easement options. For example, a potential buyer interested in building on a double lot might wish to identify properties that could be purchased inexpensively and merged or restricted through a conservation easement. The District could further its goals by providing information or even promoting transactions under the available voluntary measures.


Absentee owners represent another source of potential interest for the development reduction program. Some might be interested in the conservation easement program, particularly if they have no immediate interest in locating to Brooktrails and/or own lots of marginal value. Monitoring on a lot-by-lot basis might reveal opportunities to sell absentee-owner parcels adjacent to existing built sites for the purpose of merging lots or establishing conservation easements. In this case, the District could contact neighboring owners and attempt to negotiate a merger.

Financial Incentives
Lot mergers and conservation easements appeal to the desire of property owners' to live in a low- density setting. The effectiveness of these approaches can be further promoted if the District would be willing to offer financial incentives. Financial incentives could take on two forms. First, the District might elect to absorb some of the administrative costs of mergers or easements to make these options more attractive. The costs could include surveys, appraisals, and legal documentation.

Loans are another avenue to consider. The District could make low-interest loans available for property owners who wish to purchase adjacent lots with the intent of undertaking a merger or conservation easement. Similarly, the Township might provide mortgage security or refinancing. In cases where a mortgage is outstanding on a parcel considered for merger or deed restriction, the land value will drop due to the elimination of the development right. If borrowed principal is outstanding in excess of the lot value after development right retirement, it may create a conflict between security for the loan and the development right retirement. The District could ease this conflict by assuming or extending loans for some or all of the outstanding principal to bring the loan held by the private lender in line with the remaining lot value.

For example, a lot considered for merger or conservation easement could have a value of $3,000 after development rights are retired. If a $5,000 balance is outstanding on the mortgage, a discrepancy of $2,000 would be created as the lot became worth less than the amount owed. A merger would, therefore, conflict with the mortgage. To overcome this problem, the District might provide a secondary financing of $2,000 to prevent the merger from conflicting with the borrower's agreement. In this case, the District would take a lien subordinate to the primary mortgage, secured


by other means, or lent at an appropriate rate. Various District resources could be used to fund any loan programs. If a charge identified for development reduction were applied to new development, these proceeds could be used as loans. Similarly, it is possible that balances in other Township funds could be used as well.

Greenbelt Adjustments
Given the amount of open space owned by the Township, it is possible that greenbelt adjustments could make land available to be used as incentives for property owners to retire development rights. For example, an owner of two or more marginally buildable lots might exchange these lots for a more desirable site on the edge of the greenbelt, resulting in a two-for-one swap and reducing development by one or more SFRs. Though such swaps would have to be reviewed on a case-by-case basis with respect to the locations of the retired and newly created lots and the integrity of the greenbelt, it is possible that greenbelt adjustments may permit owners to upgrade their development sites while at the same time reducing development potential.

Estimated Sources of Development Reduction
Naturally, the question arises as to the potential success of a program that relies solely on voluntary development reduction measures emphasizing mergers. To address this question an examination of the characteristics of different categories of lots in Brooktrails Township offers some indication of the potential success the District may expect. Beginning with a review of existing developed and undeveloped lots, the following discussion identifies sources and motivations for mergers, and estimates the approximate level of development reduction the District must achieve through the proposed program. Note that mergers are referenced in the discussions, though development reduction through conservation easements would apply as well.

Table 11.2-1 shows the existing developed and undeveloped lots in Brooktrails Township. Of the total 6,188 lots in the Township, 1,150 are developed, leaving 5,038 lots undeveloped.


Maximum development in the Township has been measured according to water usage on the basis of equivalent single family residential units (SFRs). The Township has chosen to limit development to 4,000 SFRs, which translates into 3,673 actual lots. The difference between the number of lots and SFRs is explained by (1) the presence of multiple family lots which hold potential for more than one SFR of development, (2) 50 to 100 SFRs allocated to public uses, and (3) 35 SFRs reserved for Spring Creek. An additional 2,523 lots can be developed to reach the maximum of 3,673. The 2,515 lot difference between maximum development and the total number of lots in Brooktrails is the number of lots that would have to be merged or otherwise left undeveloped.

Table 11.2-1

Development Potential and
Development Reduction

Brooktrails Specific Plan

Total Lots 6,188
Existing Developed Lots 1,150
Undeveloped Lots 5,038

Developed Lots Equaling 3,673
Existing Developed Lots 1,150
Remaining Lots 2,523

Undeveloped Lots 5,038
Remaining Lots 2,523
Difference 2,515
Lot counts as of December 1995.
Source: Brooktrails Township CSD; EIP Associates..


Development Reduction Without Incentives
Even in absence of a development reduction program, some lots can be expected to be excluded or removed from total development potential due to a variety of conditions. The first source of development reduction is attrition. Attrition is attributable to physical and ownership conditions that result in a certain number of lots remaining undeveloped. Many lots in the Township are subject to severe physical constraints, including slopes in excess of 40%, or locations in dam failure inundation areas, unstable hillsides, sensitive habitat, or the Maacama Fault Zone. The number of lots in the high constraint areas totals 985. Of these, only 157 have been improved, leaving 828 unimproved. The first part of Table 11.2-2 shows development reduction due to physical and ownership constraints. A specific group within the high constraint category includes 285 lots without sewer service, which are regarded as unbuildable due to physical conditions that would not support a septic system. For the purposes of this analysis, substantially all of these lots are assumed to remained unbuilt.

An additional allowance is included to account for lots in the remainder of the high constraint areas, as well as areas outside of the high constraint areas, that may remain unbuilt. Although some of the high constraint lots have sewer service, and can be developed with appropriate design and construction measures, some lots are unlikely to develop at all due to the severity and cost of overcoming other physical constraints. Absentee ownership will also contribute to some lots remaining undeveloped for an indefinite period of time as owner circumstances interfere with development plans. As a result of absentee ownership and severe physical constraints, it is assumed that 500 lots, or about eight percent of total lots, will not be developed at all.

In way of supporting the assumption that 500 lots are unbuildable, two historic events can be noted. First, in 1976 the original developer of Brooktrails commissioned a study to assess the security for improvement assessment bonds. The study concluded that 250 lots were sufficiently unbuildable as to warrant their exclusion from the assessments. Subsequently, 300 parcels were acquired through tax lien sales by Brooktrails Township in the 1980s. The owners of these lots clearly viewed the value of their property below the outstanding taxes and assessments. In the


context of the former improvement assessments and tax levies alone, experience has indicated that at least 550 lots are not viable for development.

Allowing for physical and ownership constraints, and including a specific consideration for the unsewered, high constraint lots, the total attrition is estimated at approximately 785 lots.

Table 11.2-2

Sources of Lot Reduction

Brooktrails Specific Plan

Unsewered High Constraint Lots 285
Other Physical and Ownership Constraints 500
Development Reduction 785

Undeveloped Unsewered Lot 388
Merger Rate for Unsewered Lots 67%
Development Reduction 259

Sewered Lot Development Potential 2,394
Merger Rate for Sewered Lots 15%
Development Reduction 354

Undeveloped and Merged Lots 1,398
1 Lot counts as of December 1995.
2 Unsewered lots outside of high constraint areas.
3 Total development potential of 2,523 unbuilt lots
less 129 lots in unsewered areas.

Source: Brooktrails Township CSD; EIP Associates; Town Hall Services.


Unsewered, high constraint lots were included in the attrition category. A total of 388 unsewered lots exist outside of the high constraint areas, and are potentially buildable with the addition of septic systems. The key consideration where septic systems are concerned is the availability of a suitable area for a leach field. Minimum lot sizes for septic units are governed by a number of factors, including the soil type and slope. For the purposes of this calculation, a minimum lot size of three-fourths of an acre is used, indicating an average lot combination ratio of 3 to 1 to render the unsewered lots buildable. Applying the combination ratio to the 388 unsewered lots leaves an approximate potential of 129 development sites, or equivalently, a reduction of 259 lots. This calculation is shown in the second section of Table 11.2-2.

In addition to the physical, ownership, and infrastructure constraints to development that will result in some measure of reduction, there already exists a level of interest in developing on merged sites; a certain level of merger activity can be expected even in the absence of a lot reduction program promoted by the Township. According to Community Services District Files, 250 lots have been built since 1990, with 37 corresponding lot mergers. Said differently, a lot reduction of about 15 percent above the number of developed lots has taken place due to "natural" merger activity.

Projecting the "natural" merger rate forward suggests that a measurable amount of development reduction will take place in the absence of an incentive program. This estimate is shown in the third section of Table 11.2-2. Above, it was shown that remaining development potential to reach 4,000 SFRs totals 2,523 lots. Subtracting the 129 lot development potential of the unsewered areas, the development reduction of which has already been taken into account, leaves development potential of 2,394 lots in the remaining areas of the Township. Applying the 15 percent merger rate observed in recent years indicates a reduction of 354 lots even without a program.

Combining attrition, combinations of unsewered lots, and "natural" merger activity, the total development reduction in the absence of a township-sponsored program is estimated at about 1,398 lots.


Reductions Required From Merger Program
The forgoing analysis indicates that a substantial portion of the development reduction sought to achieve the 4,000 SFR level of growth may be accomplished even without intervention by Brooktrails Township. The remaining question, then, is whether the development reduction programs proposed will provide the incremental retirement of development rights necessary to meet the Specific Plan's growth objective. The three sources of development reduction described above are combined in Table 11.2-3. Together, they total a reduction of 1,398 lots. Compared with the total reduction of 2,515 lots required to meet the 4,000 SFR target, this leaves a shortfall of 1,117 lots. The 1,117 lots represent the approximate level of additional development reduction that must be achieved through the proposed program.

Table 11.2-3

Development Reduction Program Target

Brooktrails Specific Plan

Attrition 785
Unsewered Lot Mergers 259
Sewered Area Mergers 354
Development Reduction Without Program 1,398

Development Reduction Target 2,515
Reduction Without Program 1,398
Reduction Required From Program 1,117

Source: Brooktrails Township CSD; Ell? Associates; Town Hall Services.

One additional figure is advanced to indicate potential sources of development reduction that may come about in response to the proposed program. A manual count of developed lots by the District shows that 140 owners of developed lots also own at least one adjacent undeveloped lot. Expressed as a percentage, this is a multiple ownership rate of over 12 percent. Given that the developed lots already include a number of merged lots, this would appear to represent an


additional source of potential mergers. Across the maximum development of 3,673 lots, this would imply an additional reduction potential of roughly 440 lots whose owners might be willing to merge if the development reduction incentives were responsive to their objectives. If a substantial number of owners of adjacent lots merged, this could account for up to about 40 percent of the development reduction sought from the program.

Two other considerations are also relevant to the performance of the development reduction activities, though are not easily expressed numerically. First, the capital costs assigned to new development will provide an additional incentive to merge less desirable lots, particularly if assessments are used to finance a portion of the community facilities. Second, development patterns are typically such that the most easily developed lots are built first. As development of the Township progresses, there is likely to be increased demand on the part of property owners to create larger development sites, particularly in the areas of rougher topography. The merger ratios applied above, therefore, may be conservative if applied to development occurring in remote years.

Development Reduction Monitoring
Implementation of the Specific Plan will require that the District or County be responsible for monitoring, and, unless the Specific Plan in amended, taking the necessary actions to see that development reduction proceeds in a manner consistent with the goals of the Specific Plan. A monitoring program therefore would need to be established to measure progress of the development reduction activities. The periodic review process will provide the District the opportunity to adjust the major capital improvements and development reduction incentives in response to prevailing conditions.

Development reduction should proceed in rough proportion to the rate of development. Table 11.2-4 calculates this rate. Setting aside the 785 lots left unbuilt through attrition leaves 1,730 lots to be removed. The 1,730 figure refers to all merger activity, including those that


Table 11.2-4

Development Reduction Program Target

Brooktrails Specific Plan

Total Development Reduction Target 2,515
Attrition 785
Net Reduction Through Mergers 1,730
Remaining Lots to Develop 2,523
Net Reduction Through Mergers 1,730
Ratio of Lots Reduced to Lots Built 0.69

Lot counts as of December 1995.
Source: Brooktrails Township CSD; Ell? Associates; Town Hall Services.

would happen in absence of a program, the combinations of the unsewered lots outside of the high constraint areas, plus those attributable to the activities of the township and the county. Compared with the remaining development potential, this results in a development reduction rate of 0.69 lots removed for each lot built. Note that this figure includes the aggregate mergers of both sewered and unsewered lots. The Township should monitor these lot groups separately with the appropriate corresponding merger rates, recognizing that a higher rate of mergers is expected for the unsewered lots. Also, the township should monitor development in the high constraint areas to insure that the attrition assumptions are consistent with the actual development in these areas.

Specifics of any programs considered would be refined prior to implementation to respond to public input and prevailing circumstances. The description of the program under the Specific Plan is intended to (1) summarize the available development programs for public review, and (2) through the Specific Plan process place the program under the purview of the County's


General Plan to assure consistency as Brooktrails or Mendocino County elects to implement measures designed to reduce development in the Township.

Actual performance of development reduction activities is impossible to predict at this time. Economics of developing in Brooktrails, congruency of property owner objectives with the development reduction incentives, and the feasibility of developing on the remaining unbuilt lots will all have a bearing on the future development levels. The calculations presented here are not intended to represent a precise forecast of development reduction, but rather are designed to illustrate that significant categories of lots can contribute to the Township's development reduction goals.

Given the luxury of a significant time line to at least 2010 at 40 SFRs per year to make the decision as to the necessary size of a potential new reservoir, Mendocino County and Brooktrails Township have ample opportunity to evaluate the yearly progress of the development patterns and reduction activities. As necessary, the Specific Plan can be revised in the future to harmonize the development reduction objectives and measures to meet the Township's circumstances as they evolve.

In conclusion, Brooktrails Township is faced with a unique situation. Review of planning literature has returned no directly comparable development reduction program. Although a number of communities have redirected growth through transfer of development rights programs, none were discovered that sought to reduce the absolute level of development under the auspices of a Specific Plan. Correspondingly, the District should promote the goals of the program and keep the community informed of its progress. The extent to which Brooktrails' property owners see the development reduction activities as consistent with their interests will play a large role in the success of the voluntary development reduction measures.

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