CGF Letter on Camp Jones Gulch County Use Permit Application

Lennie Roberts, CGF's San Mateo County Representative, sent this letter to San Mateo County concerning the YMCA-Camp Jones Gulch's application for a use permit.

February 14, 2007

George Bergman, Zoning Hearing Officer
455 County Center
Redwood City, CA 94062

Re: PLN 2003-00377 – Item #5 on ZHO Agenda, February 15, 2007

Dear Mr. Bergman,

On behalf of Committee for Green Foothills (CGF) I have reviewed the Staff Report for the above-referenced project, and have the following comments:

1. Minor corrections to text and dates: On page 12, third paragraph, the Staff Report states that a Nonindustrial Timber Management Plan was submitted to the California Division of Forestry in 2005. The date of filing of the plan was actually June 5, 2006; the acronym should be corrected to: NTMP, not TMP. The last sentence of this paragraph should be corrected to refer to Attachment I, not H. Attachment I is not the most recent version of the Harvest Schedule map – it should be updated to include the 10/6/06 map.

2. Grading exemption for after-the-fact grading: The Staff Report, pages 12 and 13, make reference to unauthorized grading that was done on the property and also within San MacDonald County Park. It is stated: “the Applicant has already performed such work in 2005, and has recently worked with the County Resource Conservation District (RCD) to finalize these efforts of erosion control for one of these existing on-site roads which is adjacent to and crosses into San MacDonald County Park. This work was completed per the standards and under the supervision of the RCD….”

This statement is not correct. I have spoken with Kellyx Nelson, and she states that the RCD was never on site to review this grading, nor has a copy of the Staff Report been sent to the RCD for their review. Jim Howard, a representative of the Natural Resource Conservation Service (NRCS), a federal agency, was out on the site during the summer and made suggestions as to how the remedial work could be improved. According to Mr. Howard, the road is considered temporary, and if it is to be used in the future, it will need to be upgraded with more robust erosion control and drainage systems.

CGF has reviewed the Grading Ordinance Exemption 8603.18 that is cited in Finding # 4 of the Staff Report, which is copied below:

SECTION 8603.18. Repair of storm damage consisting of slide repair, debris removal and water impoundment replacement on agricultural lands carried out under the purview of the ASCS or RCD provided that such activity does not create hazards to other lands.

The subject grading was to clear a hillside of overgrown trees and brush and re-establish an old road for emergency ingress/egress, according to the Applicant. Attachment F shows the location of the road, with the title: “Secondary Access Road Improved with Grading Exemption.” The project did not entail “slide repair, debris removal, and water impoundment replacement on agricultural lands”. CGF does not believe the Finding can be made under this particular Exemption to the Grading Ordinance. It is possible that Section 8603.11 may cover this activity.

3. A Confined Animal Permit may be required for horses: The existing and proposed Plans show an equestrian area. The provisions of the Confined Animal Regulations may apply to these facilities.

4. Maintenance of roads and trails: It has become apparent during the review of the proposed NTMP that the Applicant has deferred important maintenance and repair of roads and trails. CGF suggests that the Use Permit be conditioned to provide for annual maintenance of the roads and trails that are used as part of the YMCA programs.

5. Relationship between Use Permit and NTMP: The YMCA, as stated earlier, has submitted an NTMP to the California Division of Forestry for review and approval. CGF is concerned that the NTMP would grant an entitlement for commercial harvesting of timber every 15 years in perpetuity without public review and approval. We have met with the YMCA several times, and have proposed an Alternative that would take a stewardship and restoration approach to managing the forested lands (see attached letter of 12/18/06). The YMCA is currently considering our Alternative, but they do not wish to withdraw the NTMP until they determine that the Alternative can meet their financial and other objectives.

If the YMCA received approval for the NTMP, CGF believes that it is not possible to foresee all environmental or public concerns over time. However, there is no provision in the Forest Practice Rules for public hearings unless the Plan is amended in a significant way. The YMCA has offered several measures that would inform the public of future entries for timber harvesting, but these are voluntary and not binding upon future Boards or Management of the YMCA, nor do they require the YMCA to change the Plan in response to public concerns. The only guarantee of a public review process that is enforceable would be through the Use Permit for the camp. Since the programs and use of the camp, would be affected by timber harvesting operations, CGF believes that the County has the ability to require a public review process for each entry on the property for commercial timber harvesting.

To this end, we suggest that a new Condition be added, or Condition 3 be amended to require the Applicant or his designee (such as the Registered Professional Forester or Licensed Timber Operator) to submit each Notice of Timber Operations (NTO) to the San Mateo County Planning Division with sufficient time for notification of the interested public. The Planning Division would hold a public hearing, and if necessary, the Use Permit could be amended to include provisions for protection of the facilities, including roads and trails, and natural resources, including the streams, that are part of the Camp’s operation and programs.

We are hopeful that the YMCA, through a collaborative planning process that they are initiating, will ultimately not pursue the NTMP as currently proposed. However, we would like to have a provision that, if needed, could be implemented to ensure that the greater community and environmental interests are accommodated in this Use Permit review process.

Thank you for consideration of these comments. We look forward to working with the YMCA and the County for the long term best management of the Jones Gulch property.

(signed)

Lennie Roberts, Legislative Advocate
Committee for Green Foothills

Copy (by email): Dave Holbrook, San Mateo County Planning
Peter Jones, Executive Director, YMCA Camp Jones Gulch