Saturday, July 16, 2005

Comments on the preparation of a Draft Environmental Impact Report for Coyote Valley

San Jose has solicited comments on what it should study when developing an Environmental Impact Report for Coyote Valley. We submitted the following comments. While saying what the City should study, we continue to oppose this environmentally-destructive project.


Darryl Boyd
Department of Planning Building and Code Enforcement
City of San Jose
801 N. First St., Rm 400
San Jose CA 95110-1795

Re: Comments on the Coyote Valley NOP

Dear Mr. Boyd,

The Committee for Green Foothills submits the following comments on the NOP for the Coyote Valley Environmental Impact Report:

· We reaffirm our March 4, 2005 letter to San Jose regarding Coyote Valley (attached), and we request that the DEIR address the letter’s concerns.

· Current development “triggers” found in the San Jose General Plan that restrict residential development in San Jose must be included as part of the environmental baseline for assessing the project’s impacts.

· Any changes to development triggers that function as replacements, in whole or in part, of these triggers must be analyzed in the DEIR. Analyzing changed triggers separately would constitute improper segmentation of the project.

· In light of the California Supreme Court’s depublication of Friends of the Kangaroo Rat v. California Dept. of Corrections (2003) 111 Cal.App.4th 1400, the City should consider agricultural preservation as a feasible mitigation for the loss of agricultural land. Preservation should be at least at a one-acre-for-one-acre ratio. Preservation in Coyote Valley Greenbelt is preferable, but preserving farmlands in other areas of Santa Clara County should also be considered for purposes of determining feasible mitigation.

· For purposes of examining the project’s effect on housing demand, the number of employed residents per residence should be determined based on the size of anticipated residences, not simply a County-wide or City-wide average that reflect larger residences than will be found in Coyote Valley.

· The NOP referenced 3,000 additional jobs will be expected beyond the 50,000 figure for retail and government support work. This contrasts with the City’s own transportation consultant, who had stated at a Coyote Valley Technical Advisory Committee meeting in 2004 that the 50,000 jobs would produce an additional 17% more support jobs. The DEIR should address which of these two figures is correct and give the reasons why, for purposes of determining housing demand.

· The DEIR should identify the amount secondary jobs created outside of Coyote Valley as a result of the business brought to the area at buildout, for purposes of identifying housing demand created by the project.

· The DEIR should consider the net effect of other development projects on housing demand, and specifically address the housing demand concerns expressed in our December 20, 2004 letter (attached).

· The DEIR should address growth inducing and cumulative impacts from the project, especially in relation to the net increase in housing demand from the 50,000 jobs, whatever number that is correct for retail and government jobs, and the secondary jobs created outside of Coyote Valley. This analysis should extend beyond San Jose to all of Santa Clara County, as well as all neighboring counties and to Monterey County.

· The DEIR should address the effect of nitrogen deposition on nearby serpentine soils habitat from development in Coyote Valley, including that coming from increased congestion on Highway 101.

· The DEIR should address how it will conform to the planned County-wide HCP. We suggest a mitigation statement to the effect that “all aspects of the CVSP are subject to change based on the requirements of the forthcoming County-wide HCP.” The DEIR should justify any statement of conformance to the future HCP that is less sweeping.

· The DEIR should examine the feasibilility of an east-west wildlife migration corridor in the vicinity of the North Coyote area and Tulare Hill, as a mitigation for impacts to wildlife. This examination should include the elimination or relocation of the athletic fields north of Tulare Hill.

· The DEIR should address a wider floodplain for Fisher Creek as an alternative flood storage mechanism than the proposed Coyote Valley Lake, as well as consideration for mitigation of various biological impacts.

· The DEIR should address an empty greenfield as an alternative to the Coyote Valley Lake for flood-control purposes. This greenfield was described by City consultants in early CVSP Task Force meetings.

· The DEIR should address potential spread of perchlorate contamination as it might affect water supplies.

Please contact me if you have any questions.

Brian A. Schmidt
Legislative Advocate, Santa Clara County

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