April 9, 2010
President Rich Gordon and Members,
San Mateo County Board of Supervisors
400 County Center
Redwood City, CA 94063
Re: Board of Supervisors Meeting of April 13, 2010, Item 11: Consideration of the Midcoast Local Coastal Program (LCP) Update
Dear President Gordon and Members of the Board,
Committee for Green Foothills urges your board to accept the Coastal Commission’s suggested modifications to the Midcoast LCP Update. It has been over ten years since the County embarked on this important planning effort. CGF commends the County and Coastal Commission in working together to resolve many issues that were initially identified by the Coastal Commission staff.
Regarding the issues that are discussed in the March 29, 2010 Staff Report, CGF has the following comments:
1. Lot Retirement/Traffic Mitigation: Retirement of lots as a condition of new subdivisions is an important and necessary mitigation measure to offset the cumulative impacts of new development on the coastside’s already inadequate highways. There are not many lands in the urban midcoast that can be subdivided, and most of these areas are zoned for agriculture or open space. Nonetheless, any new land divisions will have impacts on the already overburdened public services, particularly coastal highways. CGF urges the County to institute a program to retire development rights on lots that are located within environmentally sensitive areas, including wetlands and riparian areas in Miramar and the Montecito Riparian Corridor, or in hazardous areas such as along the cliffs of Seal Cove, and lots that are underwater in the Princeton area. CGF could support an exception to the traffic mitigation program for conditional Certificates of Compliance (CCOC’s) that are now required to legalize antiquated subdivision lots per the Witt and Abernathy decisions (and that are also conditioned to maximize consistency with current zoning and other applicable LCP requirements), inasmuch as these lots have already been included in the LCP’s buildout numbers. CGF also urges the Board of Supervisors to adopt a traffic mitigation fee for new development in the urban midcoast, similar to Half Moon Bay’s. This would help fund necessary traffic and safety improvements.
2. Prohibition of New Private Wells: CGF strongly supports the prohibition of new drinking water wells (and septic systems) in the urban midcoast area. Allowing private wells within the boundaries of public water agencies places an undue economic burden on customers of the water districts, who must pay for costly infrastructure. The small, isolated groundwater basins in much of the urban midcoast cannot support wells over the long term. New wells near the Pillar Point Marsh could adversely impact this sensitive coastal resource. Already some midcoast wells have failed, and in future drought cycles we can expect many more to fail. Similarly, it makes no sense to allow private septic systems within the boundaries of public wastewater treatment agencies.
3. Growth Limits: CGF supports the growth rate limit of 40 (approximately 1%) residential units per year. The County Planning Commission recommended this limit, and it is consistent with Half Moon Bay’s annual limit as well. Over the past five years, an average of just 38 residential units have been approved annually. County planning staff has agreed that the limit of 40 residential units should not have an impact on the current rate of development.
4. Grandfathering: Although it has been County policy to “grandfather” projects where an application has been submitted to County Planning, the proposed modifications would still allow projects that have received a Building Permit to proceed under the existing LCP. As of December 2009, there were some 143 applications that had not received a Coastal Development Permit. These should be evaluated under the updated Midcoast LCP standards.
5. Public Works: The County’s existing LCP already requires new public works facilities to be phased with each other and to be sized so as to serve, but not exceed, the buildout allowed by the LCP. The Coastal Commission’s suggested modifications require that for public works expansion projects aimed at solving existing deficiencies for existing development, (i.e., to serve existing development on private wells or new infrastructure to solve the Sewer Authority Midcoastside’s wet weather flow problem), other public works deficiencies do not need to be solved first. If a proposed public works expansion project were sized to accommodate existing buildout, the permit for the project could, and should, be conditioned to allowing the phasing of new sewer or water connections, for example. CGF supports this approach.
6. Land Use Priorities: CGF supports the Coastal Commission’s suggested modifications that will set aside water and sewer capacities for affordable housing, through a two-tiered approach that maintains the LCP’s existing capacities for coastal act priorities.
7. Rezoning of Bypass Lands: CGF supports the rezoning of the former Caltrans Right of Way that is no longer needed for the Devil’s Slide Bypass. This is an important step to ensure that these lands will become a trail and park system that will provide public access and a scenic non-motorized transportation route.
CGF urges the Board of Supervisors to accept the suggested modifications. If there are outstanding issues you feel must be addressed, we suggest that you ask for an extension of time, not to exceed six months, so your Board of Supervisors can complete this planning effort that you and the Coastal Commission have invested a great deal of time and money in.
Thank you for consideration of our comments.
Lennie Roberts, Legislative Advocate
Committee for Green Foothills