Good afternoon, Brian Schmidt from Committee for Green Foothills and the Creeks Coalition. This morning you have been hearing about the problems from erosive forces; I will discuss a very specific solution that is available now and is legally required…
…which is tracking cumulative impacts regardless of project size, and mitigating those impacts.
Current and proposed regulations, including those discussed today, do not limit the erosion impacts from small projects, but only those adding large amounts of impervious area.
However, small projects in combination can create significant problems. The City of
Additionally, permits allow large projects to have impacts when mitigation exceeds cost limits. These small and large project impacts are ignored.
A policy tool already exists that requires analysis and feasible mitigation of these impacts, the
CEQA also requires reducing the impacts where feasible, and reducing impervious surface impacts is feasible. It’s easy to reduce the impervious surface area, especially for small projects that have not been required in the past to limit this impact. Using permeable pavement that allows water to percolate through it is also very feasible. Finally, CEQA allows paying into a fund for offsite mitigation that could reduce pavement elsewhere, or otherwise help mitigate the erosion impacts. Water District staff has expressed interest in off-site mitigation in other contexts.
So, how to move forward? Ideally, land use agencies would do a programmatic analysis of all their watersheds to analyze cumulative impacts and propose mitigations, but they also may be forced to do an analysis. For our purposes today, though, we are asking the Water District itself act proactively by providing the technical information that agencies or advocacy groups could use to determine whether cumulatively significant impacts exist in various stream reaches. As a neutral provider of environmental information, this step would be invaluable.
Slide 6:Committee for Green Foothills did an extensive legal white paper pursuant to a grant we received from the Water District. The white paper is available at this website address, as is my contact information for any follow-up questions.