Dec 18 Comments on the Draft Plan Bay Area 2050+

December 18, 2025

Metropolitan Transportation Commission (MTC)
Association of Bay Area Governments (ABAG)
375 Beale Street, Suite 700
San Francisco, CA 94105

Re:  County of Marin Comments on the Draft Plan Bay Area 2050+ and Draft Environmental Impact Report

Dear MTC and ABAG Boards,

On behalf of the County of Marin and the Board of Supervisors, we appreciate the opportunity to comment on Draft Plan Bay Area 2050+ and its accompanying environmental analysis. We recognize that Plan Bay Area 2050+ is an update to Plan Bay Area 2050, and that the region will begin work on the next comprehensive update – Plan Bay Area 2060 – in the coming years. We welcome early and continued collaboration with MTC and ABAG as that work moves forward.

With responsibility for local land use planning, housing element implementation, emergency preparedness, infrastructure delivery, environmental stewardship, and fiscal accountability, we are vested in ensuring that regional plans are both analytically sound and practically aligned with local conditions.

Our comments focus on four core themes:

1. Importance of sustained collaboration on Equity Priority Community definitions;
2. Need for clearer prioritization and partnership around sea level rise and climate resilience;
3. Value of realistic, transparent growth assumptions as the region looks ahead to Plan Bay Area 2060 and its implications for RHNA; and
4. Opportunity for regional plans, funding, and policies to more directly support local housing element implementation, priority development areas, and transit investments.

Together, these issues reflect where closer coordination between MTC, ABAG, and local governments can most meaningfully strengthen future regional planning outcomes.

1. Continued Coordination on Equity Priority Communities

We appreciate MTC’s engagement last year regarding the Equity Priority Communities (EPC) framework. During the Draft 2024 EPC Update, the County of Marin raised significant concerns when Marin City was proposed for removal as an Equity Priority Community. We appreciate MTC’s responsiveness to those concerns and emphasize the importance of maintaining EPC designations in a manner that recognizes historic disinvestment, structural inequities, and lived community experience – particularly in communities such as Marin City that have faced decades of underinvestment and exclusion.

Going forward, we strongly encourage MTC to continue partnering with local government and community stakeholders as EPC definitions evolve, including through the forthcoming EPC re-envisioning work. Ensuring that equity frameworks remain grounded in both quantitative data and qualitative, place-based context will be essential to achieving meaningful outcomes and maintaining trust with historically marginalized communities.

2. Sea Level Rise and Cross-Jurisdictional Climate Resilience

We support the inclusion of sea level rise mapping and climate risk considerations in Plan Bay Area 2050+. However, while the Plan identifies areas vulnerable to sea level rise, it provides limited prioritization or guidance for how jurisdictions should address these risks through coordinated, cross-jurisdictional strategies.

Given Marin’s extensive shoreline, low-lying communities, and constrained transportation network, sea level rise presents direct and immediate implications for housing, evacuation routes, transit reliability, and regional connectivity. We encourage MTC to:

• Develop clearer regional prioritization frameworks for sea level rise adaptation investments;
• Support multi-jurisdictional planning and governance models for shoreline and transportation resilience; and
• Better align regional transportation funding with climate adaptation needs, particularly where infrastructure serves both local and regional functions.

Climate resilience considerations must also account for wildfire risk and emergency evacuation capacity. While we recognize that MTC is not a regional wildfire authority, climate change, wildfire risk, and development feasibility are inextricably linked. Marin’s development opportunities are constrained by topography and climate vulnerability. Large portions of Marin are located in very high fire hazard severity zones with limited ingress and egress, placing heightened importance on transportation networks’ evacuation capacity and resilience.

MTC’s planning, funding, and investment decisions can play a meaningful role in addressing these challenges – including through support for evacuation routes, multimodal connectivity, system hardening, and complementary mitigation investments that reduce risk and improve safety. Integrating wildfire and evacuation considerations would support safer, more resilient development patterns over the coming decades.

Strengthening these aspects of the Draft Plan and its implementation would materially improve its usefulness to local governments facing near-term climate risks.

3. Growth Forecasts and Policy-Based Assumptions

We continue to have serious concerns regarding the population and employment growth assumptions reflected in Draft Plan Bay Area 2050+. Based on actual residency and demographic trends and recent employment patterns – we do not believe the projected levels of resident and job growth are realistic for Marin County.

Draft Plan Bay Area 2050+ relies on a policy-driven forecasting approach that differs materially from the demographic and economic models used by other state agencies. The Draft Plan’s population projections diverge significantly from those issued by the California Department of Finance (DOF), the State’s official source for population projections, which rely on a cohort-component methodology grounded in observed trends in births, deaths, aging, and net migration. For Marin County, the Draft Plan assumes population growth of approximately 22,200 additional residents by 2050, while DOF instead projects a population decline of 6,437 over the same period.

Similarly, the Plan’s employment projections do not reflect recent and ongoing structural shifts in Marin’s economy. Over the past decade, Marin has experienced the departure or consolidation of several major employers, including Autodesk, Glassdoor, and Fireman’s Fund, reflecting broader regional trends toward consolidation, remote and hybrid work, and reduced demand for traditional office-based employment.

We recognize that the Draft Plan’s growth assumptions were approved earlier in 2025 as part of the adopted Plan Blueprint, and that revisiting those assumptions at this stage would require extensive re-modeling that is not feasible within the current planning cycle.

However, it is important to clearly acknowledge the implications of relying on growth assumptions that are not aligned with observed demographic and employment trends. While Plan Bay Area 2050+ itself does not directly determine Regional Housing Needs Allocation (RHNA) numbers, future forecasts developed for Plan Bay Area 2060 will inform the next RHNA cycle and will carry significant regulatory and legal consequences for local governments.

Accordingly, we strongly requests early and close collaboration with MTC as Plan Bay Area 2060 assumptions are developed, including transparent evaluation of alternative growth scenarios such as lower-growth, remote-work, and technology-driven productivity scenarios; clearer articulation of how policy-based forecasts should be interpreted by local jurisdictions; and greater alignment, where feasible, with other state demographic frameworks so that local governments are not required to plan against inconsistent datasets.

4. Priority Development Areas, Transit-Oriented Communities, and Housing Element Implementation

As MTC revisits the Priority Development Area (PDA) framework in coming years, we ask that frameworks reflect recent state housing legislation, evolving Transit-Oriented Communities (TOC) policies, and the realities of local implementation.

In Marin, we recognize that PDAs and TOCs will continue to play a central role in accommodating housing growth. While Marin City has recently paused aspects of its PDA process, the County remains committed to long-term planning and anticipates significant development activity countywide in the years ahead.

We urge MTC to ensure that regional plans, incentives, and transportation investments are explicitly designed to support local Housing Element implementation – including:

• Aligning regional transportation funding with identified Housing Element opportunity sites;
• Supporting infrastructure investments necessary to unlock housing development in constrained or under-resourced areas; and
• Ensuring PDA and TOC policies reflect wildfire risk, evacuation capacity, and climate constraints alongside housing and transit objectives.

Additionally, many communities in Marin that are identified for housing growth in certified Housing Elements do not qualify as Transit-Oriented Communities (TOCs) or fall within other regional program categories that direct MTC transportation and infrastructure funding. Despite this, these communities still need meaningful investments in transportation, utilities, and public services to support new housing. We encourage MTC to consider how regional funding frameworks can more flexibly support housing-supportive infrastructure in communities that may not neatly align with existing programmatic definitions, but are nonetheless essential to meeting regional housing goals.

5. Regional Partnership Opportunities and Priority Investments

Finally, we encourage MTC to continue strengthening its role as a regional partner in supporting local economic vitality, equitable access, and climate-aligned transportation investments. In Marin, this includes opportunities to advance priority projects and initiatives such as:

• Improved Highway 580 transit connections;
• Expanded green transit incentives and zero-emission mobility options; and
• Investments that better connect North Bay communities to the regional core while recognizing distinct geographic and economic conditions.
• Alignment with regional economic development plans, such as Comprehensive Economic Development Strategies (CEDS)

We believe there is significant opportunity for MTC’s regional planning and funding programs to more directly support local implementation outcomes while advancing shared regional goals.

Conclusion

We support the overarching climate, equity, housing, and mobility goals of these regional planning frameworks, and we remain committed to doing our part to address the region’s housing and transportation challenges. Over the past decade, our Board has committed over $49 million in General Fund resources toward affordable housing and has supported the creation or preservation of more than 1,400 affordable housing units through new construction, acquisition, conversion, and preservation. The County’s Housing Element -- certified by the State in June 2023 following extensive research, outreach, and public engagement -- plans for the addition of over 3,500 new affordable housing units in unincorporated Marin.

Recognizing the scale of the housing challenge, the Board has doubled its ongoing investment in the Affordable Housing Trust Fund, committing an additional $5 million annually beginning last year. Given that the cost of producing a single affordable unit in Marin often approaches $1 million per unit, sustained local investment and strategic partnerships are essential.

Our comments are intended to clarify local conditions, identify opportunities for improved coordination, and underscore the importance of grounding future regional plans in realistic assumptions that local governments can responsibly implement.

We appreciate the opportunity to comment and look forward to continued partnership with MTC and ABAG as the region moves toward Plan Bay Area 2060.

Sincerely,

Derek Johnson
County Executive

CC:      Marin County Board of Supervisors 
Chief Jason Weber, Assistant County Executive (Interim)
Sarah Jones, Director of Community Development
Talia Smith, Director of Legislative Affairs