As stated in our comment letter reproduced below, City staff isn't taking seriously the environmental effects of losing the farmland. We hope the City Council decides differently.
-Brian
(one other note: after submitting the letter below, I re-read the original document and realized I had misunderstood the section discussing "Black Rock," so in my oral comments, I asked the City to disregard that one paragraph in my comment letter)
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March 28, 2006
Community Development Department
City of
The Committee for Green Foothills submits the following comments on the Mitigated Negative Declaration (MND) for the Urban Line Limit and Greenbelt Study General Plan Amendment and Related Actions (ULL). We understand from communications between City Consultant David Bischoff and Michele Beasley of Greenbelt Alliance that comments submitted today would be considered timely.
The Committee supports the comments submitted by the Greenbelt Alliance in its March 27th letter. These comments state that it is reasonably foreseeable that establishment of the ULL will ultimately lead to a conversion of farmland. In fact is more than reasonably foreseeable, it is quite obvious. The MND itself states “the implementation of Part A could lead to eventual conversion of farmland within the ULL area, since the nature of establishing a ULL boundary is to provide an envelope for future development.” MND at 45. The MND then incorrectly states this possibility is speculative. It is not – rather, it is the clear intent and purpose of establishing the ULL. Where the MND states the “nature” of establishing the ULL is to outline future development, that is really the end purpose of the project, and if this purpose is not even a remotely foreseeable possibility, there would be no reason to include it as the major component of this project.
Furthermore, the cumulative impact of this new designation for land as bounded by the ULL together with future actions to annex and convert away from farmland the parcels within the ULL is reasonably foreseeable as a cumulative impact. From a practical viewpoint, it should be clear to City Staff and the Planning Commission that landowners within the ULL will seek annexation when possible, and will loudly trumpet the fact that they are inside the ULL as an additional reason for their annexation to proceed. This cumulative impact is foreseeable, and must be addressed.
We agree with Greenbelt Alliance that a feasible mitigation measure of 1:1 ratio for permanent farmland preservation to compensate for lost farmland should be included in this project. We wish to add that while farmland preservation can feasibly reduce the impact of farmland loss, it cannot reduce that impact to a level of insignificance. As the Greenbelt Alliance letter makes clear,
For the same reason, the conversion of farmland in the Black Rock subarea, which the City acknowledges is a “real” impact, cannot be mitigated to a level of insignificance through agricultural preservation, and also requires preparation of an EIR.
Please contact us if you have any questions.
Brian A. Schmidt
Legislative Advocate,
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