CGF Letter to YMCA Encouraging a Stewarship Approach to Camp Jones Gulch

Lennie Roberts, CGF's San Mateo County Advocate, wrote this letter to the YMCA in December urging them to consider a more stewardship-based approach to managing the land at Camp Jones Gulch. The YMCA has now established a Stewardship Advisory Committee to review their timber harvesting plans and to help the camp develop alternatives to the NTMP permit the Camp filed last summer.

December 18, 2006

Charles Collins, President and CEO
Bill Worthington, Vice President, Property Development
San Francisco YMCA
631 Howard Street, Suite 500
San Francisco, CA 94105

Re: Alternatives to Proposed NTMP at Camp Jones Gulch

Dear Messrs. Collins and Worthington,

We are writing to outline an alternative plan for the YMCA that will meet the objectives of managing the Camp Jones Gulch property to reduce fire hazards, improve forest health and wildlife habitat, restore damaged or degraded areas, improve and maintain roads and trails, and enhance the outdoor education and recreation programs at the camp. This approach also can provide the YMCA with new sources of revenue and partners that will restore and enhance its stature with the community.

The YMCA and Committee for Green Foothills (CGF) have worked together during a number of meetings over the past three months. We have made considerable progress together, but as you know, CGF continues to be deeply concerned about the two threshold issues we have identified regarding the proposed Nonindustrial Timber Management Plan (NTMP) for the camp.

CGF’s first threshold issue is use of the NTMP, which would grant an entitlement to commercially log the redwood and Douglas fir forests at Camp Jones Gulch in perpetuity. The NTMP, once approved, does not allow for future public review or enforceable means to adapt the plan in response to new scientific knowledge or changed environmental conditions. The NTMP also commits the YMCA to land management that CGF believes is likely to have significant adverse environmental consequences. While reasonable people may disagree philosophically about timber harvesting, this particular NTMP has generated widespread opposition. Clearly there is tremendous public interest and concern that could be redirected to help the YMCA with the challenges of land management, stewardship, and financial support.

CGF’s second threshold issue is also a key component of our proposed solution to help meet the YMCA’s capital needs for upgrading the facilities and infrastructure. We strongly encourage the YMCA to pursue selling a forest Conservation Easement to a land trust such as Peninsula Open Space Trust (POST) or Save the Redwoods League, or to a public agency such as Midpeninsula Regional Open Space District. This Conservation Easement would generate capital funds, and also would allow the YMCA to carry out its programs and desired land management activities while protecting the forest.

We appreciate and commend the YMCA’s interest in managing your land in an environmentally responsible way. We hope that this letter can be the start of a strong partnership between the YMCA, its various constituencies, and the broader public. We pledge to use our time, expertise, and community contacts to help in this effort.

Resolution of current controversy

The YMCA is at a critical junction. If the YMCA continues on its present course of gaining approval of the NTMP, CGF believes the opposition will intensify and there will likely be challenges at every step of the timber harvest approval and implementation process. Based on our knowledge of the issues, we believe it is highly likely that if the California Division of Forestry (CDF) approves the NTMP, a legal challenge would be filed. Pursuit of the NTMP is counterproductive to the important goal of finding common ground and regaining the community’s support and trust. It is not too late to regain this support and trust. However, as long as the NTMP is pursued, it will remain as a focus of the opposition.

Restoration of the forest instead of a commercial tree farm

Instead of committing to operating a commercial tree farm (which is the basis of the NTMP), the YMCA should adopt an ecological approach to forest restoration. Wildlife Biologist Steve Singer, in his letter to CDF dated December 11, 2006, outlines more specifically the compelling reasons for this ecological approach, and the benefits of protection and enhancement of habitat for the federal and state protected marbled murrelet. Other benefits include avoidance of potential landslide hazards, erosion and sedimentation impacts, damage to water quality, potential adverse impacts to protected steelhead trout and Coho salmon, reduction of fire hazards, and improved aesthetics. A restored and preserved forest at Jones Gulch would be not only environmentally less damaging, it would be far more valuable to the YMCA and the constituencies it serves than the revenue from repeated cycles of timber harvesting.

Goals of a Stewardship and Restoration Plan

The goals of the Stewardship and Restoration Plan should be to protect and enhance the property’s natural biodiversity by preserving the old growth stands and restoring the second growth stands to resemble old growth conditions as much as possible. This would provide habitat for species dependent upon such older forest conditions. The restored second growth stands would have a continuous canopy that shades the forest floor and maintains cool and clear water in McCormick and Jones Gulch Creeks — necessary conditions for steelhead trout, Coho salmon, and other aquatic species. Mature second growth trees would provide potential habitat for the marbled murrelets that already occupy the nearby old-growth groves at the camp and in Pescadero Creek County Park. Typical understory plants in a mature second growth forest include hazelnut, ferns, huckleberry, and other low growing species. There would be few “ladder fuels”, a greater proportion of larger, fire resistant trees and moister ground conditions — elements that significantly reduce fire risk. The mature forest’s open, park-like quality could be more quickly achieved through selective removal of spindly conifers and the fast growing sun preferring species such as tan oaks and ceanothus that were stimulated by the last rounds of timber harvesting.


Steps toward a new approach:

1. While we have helped identify a number of potential candidates for a stakeholder planning group, this group should be revised and expanded to include people with expertise in wildlife and fisheries biology, forestry and fire ecology, forest restoration, geology and stream processes.

2. The YMCA should hire a consultant with an ecological background rather than timber harvesting to oversee the project, using grant sources from below to develop the Stewardship and Restoration Plan.

3. The YMCA should make sure the stakeholder group is encouraged to look broadly at ways the YMCA can meet its financial obligations to upkeep the camp while preserving and enhancing the natural biodiversity.

This approach has the potential to revitalize and expand the programs of outdoor recreation, nature study, and education at Jones Gulch. The YMCA’s mission, its partnership with the outdoor education programs of San Mateo and San Joaquin Counties, and its stature in the community would all benefit from this collaborative effort.

Key Issues:

Financing a Stewardship and Restoration Plan

The YMCA can obtain funding for implementing its Stewardship and Restoration Plan from state and federal grants, special restoration funds such as oil spill trustee funds, foundations, and private donors. The San Mateo County Resource Conservation District in Half Moon Bay is familiar with many funding sources, and works with landowners and public agencies to obtain grants for conservation planning and implementation.

Forest Protection through a Conservation Easement

POST or Save the Redwoods League could purchase a Conservation Easement to ensure the preservation of the forest. A Forest Conservation Easement could be structured to allow the customary and desired activities of the YMCA including repair and maintenance of roads as well as thinning of underbrush and fuels reduction for fire safety. Incidental selective cutting of larger trees that would help the forest regain its mature park-like quality, and removal of hazard trees could still be allowed under a Conservation Easement. The Conservation Easement would provide the YMCA with capital funds that could be used to upgrade the buildings and infrastructure.

Repair and restoration of roads and trails

Legacy roads from previous logging operations should be repaired and maintained where these roads are still needed for Camp operations, recreation, and fire protection. Other legacy roads and skid trails that aren’t needed should be put to bed. There are funds available through the Fisheries Restoration Grant Program of the California Department of Fish and Game for assessment of roads and for road repair and restoration projects. This is the grant program that has funded a road and trail assessment in Pescadero, Memorial, and Sam McDonald County Parks, and has to date provided funds to repair some of the identified sites in these three nearby parks. Potential partners in road and trail repair and restoration include California Conservation Corps, Americorps, and nonprofit organizations such as Acterra and Community Impact.

Fuels hazard reduction

Fuel hazard reduction and non-commercial thinning of the forest for fire safety purposes can be funded through grants from CFIP and state funds such as Proposition 42, which funded a community scale fuel reduction program in the Lake Tahoe area recently. This latter program was developed and implemented through a partnership with the local fire agency. Much, if not all of the work to remove dead and fire prone brushy species can be accomplished at very low cost through partnering with the California Conservation Corps, the San Francisco Conservation Corps, and/or non-profit organizations. Such low tech programs could have an educational component to include student participation from Camp Jones Gulch attendees. A conservation grazing program could be designed and implemented to reduce the fire hazard in the grasslands. Potential partners in developing such a grazing program include the San Mateo County Resource Conservation District (RCD), the federal Natural Resource Conservation Service (NRCS), and the state University of California Cooperative Extension (UCCE).

Repair, upgrade, and replacement of dilapidated buildings

Potential partners in this effort include community-based organizations such as Community Impact and Christmas in April. In San Mateo County, some larger construction companies have donated materials and labor to non-profits for repair and rehabilitation of buildings as well.

Potential new program possibilities

It appears that the camp facilities are not fully utilized. If the YMCA desired to increase its operating revenues, it could consider making its facilities available to research and/or education programs such as a field station for study of redwood ecology, marbled murrelet, and Coho salmon/steelhead trout recovery research. Potential partners in this effort include UC Santa Cruz, San Jose State University, non-profit organizations such as the Pescadero Conservation Alliance, and others. The facilities could be used on weekends as overnight accommodations for volunteers who could do restoration projects at the camp or on public and private lands in the vicinity.

Conclusion

The NTMP path has sparked much opposition from the very community that has been nourished and inspired by the programs and activities at Camp Jones Gulch. While this opposition may seem like a bad nightmare, it is clearly a testament to the stewardship values that have been nurtured in the community and the allegiance these individuals feel toward the coastal redwood forests and the unique habitat values they provide. The time is now for the YMCA to take advantage of this heightened public interest and concern. We urge you to withdraw the NTMP, expand the Stakeholder Working Group to include people with expertise in forest and fire ecologists, wildlife and fisheries biologists, geology and fluvial/stream specialists, and move forward with a Stewardship and Restoration Plan. Many of these professionals would also have specific knowledge of the criteria and funding cycles for grant funding.

We very much appreciate all the time and care you have taken to listen to the community’s concerns. We now hope you will respond to those concerns along the lines of our proposal. We wish you all the best in your programs and we stand ready to assist you in developing and implementing a Forest Stewardship and Restoration Plan at Camp Jones Gulch.


Sincerely,



Holly Van Houten Lennie Roberts
Executive Director Legislative Advocate


cc: Leslie Markham, California Division of Forestry
Rich Gordon, San Mateo County Board of Supervisors
Kellyx Nelson, San Mateo County Resource Conservation District
Paul Ringgold, Peninsula Open Space Trust
Ruskin Hartley, Save the Redwoods League
Steve Singer, Environmental and Consulting Services

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

Spreading environmental activism

Last week, at the last minute, we learned about an environmentally-destructive proposal in front of the San Jose City Council, one proposing a change in zoning for a parcel to allow development in a riparian buffer zone. I blasted off the following email and made some phone calls a few hours before the vote. Maybe it had an effect, because Mayor Reed postponed the vote:

Dear San Jose City Council members:

The Committee for Green Foothills asks you to support your staff and your Planning Commission in rejecting a developer proposal (Item 11.4 on tonight’s agenda) to rezone a property to allow more development than permitted under its current designation, which would then allow the developer to remove 91 trees on a two-acre lot and build deep within the riparian buffer zone (30 feet away instead of the city’s policy of 100 feet).

There is no reason to make this exception. The developer points to other exceptions but those in turn do not represent the City’s usual standard. City staff recommended a 75-foot buffer, which is seems overly generous. The developer does not deserve any more leeway.

The developer may wish to make more money off this project by changing the zoning, but he has no right to expect that change. Rewarding any money spent on this prospect will further open the floodgates for speculation in land, which will surely result in constant pressure to eliminate environmental regulation, just as this developer proposes. We urge you instead to reject the proposal.

In the alternative to outright rejection, the Committee requests the City contact the Santa Clara Valley Water District to see if the project conforms with the intent of the Water Protection Collaborative. That process kept the Water District from issuing its own riparian protection permits in return for a promise by cities to rigorously protect riparian corridors on their own. We strongly suggest the City ask the Water District’s opinion of this type of project, and of the developer’s apparent conclusion that there is no reason to enforce the City’s riparian buffer zone policy.

Please contact us if you have any questions.

Sincerely,
Brian Schmidt

I contacted our fellow conservation groups and encouraged them to get involved. Bob Power from Audubon wrote the following email that was even better than mine:

From: Bob Power

Date: February 1, 2007 1:24:54 PM PST

To:

Subject: Item 11.2 on your February 6th agenda: PDC06-062 Proposed 19 New residential units, Duckett Way

February 1st, 2007

Subject: Item 11.2 on your February 6th agenda

PDC06-062 Proposed 19 New residential units, Duckett Way

Dear Councilmember:

The Santa Clara Valley Audubon Society (SCVAS) has a taken a keen interest in the proposed 19 unit development at the terminus of Duckett Way in San Jose. We are clearly opposed to the use of your Discretionary Alternate Use policy to allow encroachment on the riparian corridor adjacent to this property.

We are in complete agreement with your planning staff and Planning Commission in denying this application and strongly urge you to support their clear deliberations, analysis, and previous decisions about this project.

You staff has spent four long years working with the planning staff of the other Santa Clara County municipalities, the county, and the Santa Clara Valley Water District to develop guidelines and a framework for protecting the riparian corridors of this valley and ensuring the health and vitality of our creeks and streams. A decision to allow this development to come within 30 feet of the adjacent riparian corridor “because the project isn’t financially feasible” otherwise, would be a slap in the face at this process. Financial feasibility should be ascertained at the outset of a project and should not be used as an “after-the-plans-are-drawn” piece of leverage to attempt to receive a variance.

I was struck by the applicant’s comments that the top goal of this project was “1. Preservation of the riparian corridor.” And how that goal was met with a plan to encroach upon that corridor and ask for a variance to bring development within 30 feet of that corridor. This seemed to make no logical sense. If “Preservation of the Corridor” is goal #1, why not bring forward a plan that supports that goal and shows a 100-ft. setback?

We are in complete agreement with Commissioner Zito’s comments indicating that a less diligent planning department in the past, does not justify making current and future bad planning decisions as they relate to Riparian Corridor Policies.

Your staff and Planning Commission are doing a good job and are making good decisions. We urge you to support them and the work they do by denying this appeal.

Sincerely yours,

Bob Power, Executive Director

Santa Clara Valley Audubon Society

This issue is going from one that slipped through the radar screen to one that is getting the criticism it deserves.

-Brian

Notes on Joint Venture Silicon Valley Conference

Just came back from the the Joint Venture Silicon Valley's State of the Valley Conference. Interesting speakers, some related to our work, others were more "just business", but it was useful to get out and meet folks. Thought I'd just repeat here some of the notes I took on what they said, and some editorial comments of mine.

-Brian
---------

• 25% protected of Silicon Valley is open space (didn’t define what that meant).
• Protected open space increased 1.5% and accessible protected land increased 3.3%. I consider that second figure to be very important – responsibly-managed public access reinforces public support for open space.
  
• New construction residential density increased markedly over the last 3 years. This is very good and contrary to the national trend. On the other hand, 3 years is a short time. I’ll speculate that it might be a reaction to the high price of housing.
  
• Says only 26% of households can afford a median price home. This is smaller than San Jose’s estimate of 33% - could reflect the larger geographic base, or one of the two estimates are wrong. If JVSV is right, there’s even less justification for San Jose’s assumption that house prices can continue to increase faster than household income.
  
• Household income went up in 2004-2005, but has gone down overall in the last five years.
  
• Panelist Aart De Geus made an interesting comparison between investing in education and ecosystem management, especially regarding global warming. In both cases, your payoff/punishment can be delayed for decades, so it’s hard but important to get sufficient investment in doing the right thing.
  
• A quote: “if everything you tried works, then you’re not trying hard enough.”
  
• Late-morning panel – Is Clean Technology Silicon Valley’s Next Wave of Innovation: lots of interest in solar power, which has tremendous potential to help the environment and stop global warming. Every good thing has its downside though. CGF welcomes new economic development that clean power can bring to the area. We see no reason why that new prosperity should expand sprawl in the area, though. The danger is that something good will be used as an excuse to do something bad. The model for that problem is Stanford University, which used the excuse of providing a location for Carnegie Foundation to push development up into the Stanford Foothills. We don’t want to see that problem writ large by clean power in Silicon Valley.
• Al Gore gave the keynote address. Had a lot to say about the importance of Silicon Valley in helping develop clean power, but nothing directly related to open space. He did, however, sign on to a petition by the environmental community opposing the logging proposal in Santa Clara County, so that kind of support was great to have.

Attend the CDF hearing tomorrow if you can - help stop the Los Gatos Creek logging project!

Below is an Action Alert that will be posted on the regular part of our website, but because of the press of time, I'm posting it here right away.

-Brian

---------

Dear Friends,

The San Jose Water Company wants permission to log, in perpetuity, 1,000 acres of redwood and Douglas-Fir trees near Los Gatos Creek in Santa Clara County. Please attend a hearing TOMORROW, January 31^st, if you can, and/or write both the California Department of Forestry and Santa Clara County to ask them to fight this destructive project.

What’s Happening

San Jose Water Company proposes to log 1,000 acres near Lexington Reservoir, in an area used as an important water source for thousands of County residents. The plan would give the company permanent rights to repeatedly log various parts of the property on a rotating basis – even if problems are discovered later, the plan cannot be amended by government authorities. The proposal would remove nearly half of the trees that are over three feet in diameter and many smaller trees, a controversial provision that maximizes profit but could significantly increase fire risk. The logging proposal will damage environmental values and threaten water quality, and could even bring sprawl development to the hillsides.

Why This is Important

While almost all of the old-growth forest is gone from this area, much of it was logged over a century ago and is now regaining environmental significance. Removing large trees can dry out the forest and increase the undergrowth that fuels dangerous fires, so the alleged fire benefits of the project are disputed by leading fire scientists. Besides potentially impairing water quality for thousands of people, the plan could destroy water sources for hundreds of rural residents – this would invite the extension of city services up into the Santa Cruz Mountains. Hillside sprawl could then follow. Ultimately, these lands should be purchased and protected, but that may be impossible if a destructive timber plan is approved.

What You Can Do

Attend the California Department of Forestry hearing TOMORROW, if you can, and send comments opposing the plan to CDF (something you can do even if you can’t go to the hearing).

1. Attend the CDF hearing TOMORROW, if you can, and announce your polite-but-firm opposition to the plan when public comment is received. The hearing will be at 7 p.m. on Wednesday, January 31, 2007 at Santa Clara County Board of Supervisors Chambers, 70 W. Hedding St., San Jose.

2. Please write, fax or email CALIFORNIA DEPARTMENT OF FORESTRY by February 7^th and ask them to deny this plan. Ask instead of the logging that CDF and Santa Clara County support a “Community Fire Plan” that brings together multiple groups to determine the best ways to manage fire risks. Send your comments to:

Leslie Markham, CDF, 135 Ridgeway Ave, Santa Rosa, CA 94501

Fax: (707) 576-2608

Email: SantaRosaPublicComment@fire.ca.gov

Important! Be sure to reference Timber Plan #1-06NTMP-012 SCL

3. Santa Clara County residents should contact the Santa Clara County Supervisors and ask them to “non-concur” with a decision to approve this project. If the County takes this action, it puts the harvest under greater scrutiny. Write to:

Santa Clara County Board of Supervisors

County Government Center

70 W. Hedding Street, 10th Floor, East Wing

San Jose, CA 95110

Fax (408) 298-8460

Email all five Supervisors

4. Please send a copy of your message to CGF so we can track our efforts on this issue: fax 650-968-8431 or email: action@GreenFoothills.org.

To learn more:

Read the Fall 2005 Green Footnotes article warning about the upcoming plan.

Read the January 27, 2007 article in The Mercury News.

Visit the community website opposing the plan, Neighbors Against Irresponsible Logging (NAIL).

You can attempt to read the timber harvest plan, by clicking this here, and find Plan 1-06NTMP-012 SCL, although it is split into many files. You can also find comments from agencies here.

Thanks for speaking up for open space. Your voice does make a difference!

-the folks at Committee for Green Foothills

Not really our issue, but funny

A public service announcement on energy efficiency.

I could argue that efficient land use patterns are also part of a larger effort for energy efficiency, but mostly I'm posting this for the humor value.

-Brian

UPDATE: On a more serious and somewhat more-related note, San Jose wrestles with its ineffective tree protection ordinances and procedures. While street trees aren't a central part of CGF's mission either, it's related to the problem of people cutting down trees in sensitive areas without permits.

Prop. 90 returns, and it may be even worse

The Howard Jarvis Taxpayer Association has filed papers to circulate a new anti-environment Initiative to replace the failed Proposition 90 (interestingly, they don't make any mention of this on their own website). Proposition 90 would have stopped many new environmental regulations on destructive land use, and we joined many other environmental groups in successfully opposing the measure.

Original rumors were that the new version would just focus on taking private property for private economic interests, a less controversial issue, but the proponents seem to have decided instead that the problem with Prop. 90 is that it didn't go far enough in in stopping environmental regulation.

The petition is here. Some commentary on the proposal here:

The Howard Jarvis Taxpayers Association has filed a new initiative to amend California's Constitution. This is a repeat of the just-defeated Proposition 90, only worse. Like Proposition 90, the proposed initiative would hamstring government regulations of all kinds — from rent controls to land-use zoning. But unlike Proposition 90, it would apply to existing laws and regulations — not just future ones.

And here:

In the last election, opponents of Prop 90 successfully argued that it would throw out any new land-use or zoning regulations that prevented real estate developers from making as much money as they wanted. So the Jarvis Association put in some language in their initiative that sounds like it won’t apply to such protections. But by doing so it creates some extra hurdles for government to prove that their actions are constitutional – and would allow right-wing judges to throw out any land use regulations that they don’t like.

The Jarvis Initiative says that its new definition for “damages” would not apply to land-use, planning, zoning or use restrictions – if they “substantially advance a legitimate government interest.” But current law presumes that land use regulations are rationally related to a state interest, and property owners who challenge them have the burden to prove that it is not. While it sounds like the Jarvis Initiative is less extreme than Prop 90, it would actually force government to prove how each and every one of its land-use regulations advance a substantial interest. Even a unanimous Supreme Court in Lingle v. Chevron (2005) agreed that such a standard is excessive.

The website I just quoted has this statement that I'm not sure about:

But the worst part of this initiative is that it is retroactive. Whereas Prop 90 was careful to limit its scope only to new laws or regulations, the Jarvis initiative says that “any action by a public agency” that was passed before the election and “results in continued damage to private property” will be “null and void.” Sensible protections that have been in place before the Jarvis initiative goes into effect could be considered a “continuing damage” to private property. Every protection that Californians currently take for granted are in jeopardy because of this provision.

That language isn't in the petition posted on the State Attorney General website I linked to above (UPDATE: see bottom of the post, turns out I was wrong). There is another anti-environment initiative in circulation, Petition 1233, that "[r]equires public entity taking private property to compensate owner at owner’s stated value, without limitation or review." There may be confusion between the two versions. Even without the language though, this new version appears retroactive - it just requires compensation instead of nullification.

I've read through the initiative, and the key issue is that "damage" must be compensated if a land use restriction denies any "reasonable investment-backed expection" (amendment to Sec. 19(b)(2)(ii) of Article I). If someone's grandfather bought a ranch in the Mount Diablo Range in 1900 with the then-reasonable expectation of subdividing it into one-acre lots, Santa Clara County's decision in the 1970's to stop that kind of hillside development will subject the County to liability in 2008 - if this initiative passes.

I also agree that the procedural changes are significant. Section 19(c) gets rid of deference to governmental agency findings and allows evidence outside the administrative record. Allowing outside evidence is a two-edged sword, because the agency can use it to cure a finding not supported by the record. That particular provision will benefit rich corporations and individuals attempting to drown agencies in litigation, while working against poor landowners with few legal resources.

It remains to be seen whether this initiative will even make it to the ballot, but we'll obviously have to watch it.

-Brian

UPDATE: The "null and void" language is in the initiative after all, in the Effective Date section I had skimmed too quickly.

Welcome to 2007!

Lot's going on in this new year in Santa Clara County. Coyote Valley will be hot, as will the Santa Clara County LAFCo's decision whether to require mitigation for the loss of farmland. Developer proposals will come to the table and we'll have to decide what to do about them. There are even projects we're aware of but have not decided whether we should get more involved - Mountain View Farm, Evergreen development, and more. Some ongoing issues - water quality issues, and the County-wide Habitat Conservation Plan - will continue to require attention.

We'll keep you informed, and we'll be asking for help - see you around, maybe both in the virtual and real worlds!

-Brian

Green Palo Alto, less-green farmlands, more-green ring tones, and a blog update

A grab-bag of news today:

Palo Alto commits to an eco-friendly plan to reduce greenhouse gas emissions. Reducing sprawl, and reducing monster mansions in the hillsides, will be a helpful step in fighting global warming.

Farm produce buyers link wildlife restoration to contamination fears, despite a lack of evidence. The E-coli problems are unlikely to trace back to wildlife. Hopefully these concerns will be managed appropriately.

Your cell phone can ring you with the call of the wild. Our endangered local animal, the California red-legged frog, can be your ring tone available for free at a conservation website.

And a brief update about this blog: spammers are trying to post unrelated comments selling products on this blog, so we've disabled the comments feature. We're very interested in hearing your (real) comments though - send them to brian at greenfoothills.org or holly at greenfoothills.org.

-Brian

Some successes are easy

I recently attended a meeting intended to help advise the new incoming mayor of San Jose about environmental initiatives he could take. The group was trying to limit the recommendations to a small number of items. At the end of the meeting, I tossed out as a last comment that the next General Plan revision should deal with the large land areas south of the city, near Almaden Reservoir and elsewhere. Those areas had been annexed during the foolish, expansionist years of the 1960s and 1970s but are not candidates for real incorporation into the city. City staff attending the meeting agreed, suggesting those places be rezoned from a residential to open-space designation (not exactly what I had in mind, but still a vast improvement). General agreement around the room, and the idea made it onto the list.

I think there's a good chance that this will go forward and eliminate some future developer's effort to put suburbs on hillsides. Something starting with a last-minute suggestion.

-Brian

Comments on the Castro Valley Ranch DEIR

CGF submitted two sets of comments on the proposed subdivision of the 8,000 acre Castro Valley Ranch, both of them reprinted below. This is a potentially dangerous project, so we'll need to watch it carefully.

-Brian
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December 6, 2006

Rob Eastwood, Senior Planner
Santa Clara County Planning Office
70 West Hedding Street, East Wing, 7th Floor
San Jose, CA 95110

Re: Comments on Castro Valley Ranch Subdivision DEIR

Dear Rob;

The Committee for Green Foothills submits the following comments on the Castro Valley Ranch Subdivision DEIR.

Missing analysis of growth-inducing impacts within the project.

The DEIR as currently written provides insufficient basis for the County to decide whether to approve the subdivision. The elephant in the room, but not in this DEIR, is that the 16 lot subdivision and road construction will induce the growth of future subdivisions. The less-than one full page discussion of growth inducing impacts of the project (DEIR pg. 154) entirely fails to disclose this impact. It says “Any future development on the project site would be governed by the land use policies and densities of development prescribed in the County General Plan, which is not proposed to change. These land use policies will limit the number of lots that can be created by subdivision each year and the minimum lot size.” The issue, however, is that the paved and extended road, together with lot line adjustments that facilitate future access and future subdivisions across the entire property, induce the possible growth in the form of new future subdivisions that could not occur without the newly configured parcels and new road infrastructure. It is the change to Castro Ranch created by this project that induces growth, the change that many groups are clearly worried about, and that effect is overlooked in the one chance for it to be analyzed.

The DEIR not only fails to disclose the growth inducing impacts, it fails to adequately describe the impacts of how much future subdivision can occur on Castro Ranch because of the new road and lot line changes. The failure to do a slope-density analysis, combined with the failure to indicate how future subdivision cannot feasibly occur without the road extension, means the scope of the impact has not been described.

These issues are the primary, but not exclusive, impacts from the proposed project. The “what’s next” issue is the shoe that we all are waiting and expecting will drop at Castro Ranch. A willful decision to ignore this concern that everyone acknowledges as existing is not only wrong but also a failure to comply with CEQA’s requirement to disclose growth-inducing impacts. For these and other reasons the DEIR as written cannot serve as a basis for the County’s decision over this project.

Other impacts and comments:

Contrary to the discussion on page 154 saying the project won’t provide access to any surrounding areas that lack access, it will provide alternative and improved access to properties served by Whitehurst Road, giving those properties a means to access Highway 101 (by agreement with Castro Ranch landowners) while avoiding Highway 152 traffic. A separate growth inducing impact will be from providing secondary emergency access for Whitehurst Road properties that could be a condition for future development there.

Because the lot line adjustment is treated as a subdivision, approval of this project is equivalent to improving a tentative map, or a parcel map for which a tentative map was not required. Government Code section 66474(e) states such approval is impermissible if the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat. The on-site and off-site growth-inducing impacts are likely to cause such impacts.

The DEIR raises several hydrology concerns (DEIR pg 52-55). It fails to analyze potential increases in impervious surfaces from residential development at Castro Valley. This potential increase can be analyzed using similar size project and recent permits to determine an estimate of impervious area from driveways and house sizes. Any change to runoff can be cumulatively significant in the Pajaro watershed, a stream that is impacted by erosion and sedimentation. Compliance with NPDES permits is insufficient to avoid cumulative impacts for sedimentation or other pollutants. NPDES permits set minimum project size and maximum cost levels for mitigations. Unless the County requires a no-net increase in peak flows, it has failed to analyze impacts that could be significant either individually or cumulatively. Reliance on compliance with an NPDES waste discharge requirement is insufficient in and of itself; CEQA mandates that all cumulative impacts be considered and NPDES requirements do not attempt to eliminate all such impacts.

Please contact us if you have any questions.

Sincerely,
Brian A. Schmidt

---
(sent via email)

Dear Rob;

I would like to add the following comments to Committee for Green Foothills’ previously-submitted comments:

First, as with other County EIRS, the DEIR fails to analyze the cumulative impacts of increased greenhouse gas emissions from the project, particularly from anticipated residential development and use. The DEIR does briefly mention the use of petroleum-based fuels for road construction will contribute greenhouse gases (DEIR at 153) but does no analysis of whether this impact is cumulatively significant, and ignores the greenhouse gas impact from increased road use. Carbon dioxide is the main pollutant causing global warming, which will have significant environmental impacts. The lack of a regulatory standard for carbon dioxide does not mean that it can be ignored, and other agencies take global warming effects into account. See, e.g., "Air Quality Analysis Guidance Handbook" (“The SCAQMD adopted a policy on global warming and stratospheric ozone depletion on April 6, 1990, that committed the SCAQMD to consider global impacts in its rule making and in drafting revisions to the AQMP”) available at www.aqmd.gov/ceqa/handbook/CH3_rev.doc.

Second, without a conservation easement granted to an appropriate agency prohibiting use of the road by persons attempting to get access from Whitehurst Road, there is no guarantee that the project will not promote access to other properties (DEIR at 154).

Third, the DEIR failed to analyze threats that increased tree harvesting would occur as a result of splitting the property up for estate purposes, or from improved road access. Such harvest would be an indirect impact effecting species habitat and hydrology.

Please contact me if you have any questions.

-Brian Schmidt

Commercial Timber Harvesting and Fire Hazards at YMCA Camp Jones Gulch

Lennie Roberts, CGF's San Mateo County Legislative Advocate, attended yesterday's hearing at Camp Jones Gulch about the YMCA's plans to log part of the camp. One of the issues has been how best to reduce the threat of fire within the camp. Lennie presented this information about the qualities of a redwood forest that make it less prone to fire, and the impacts of logging when the forest canopy is opened up and the forest floor dries out.

Commercial Timber Harvesting and Fire Hazards at Camp Jones Gulch

The NTMP (Nonindustrial Timber Management Plan) for Camp Jones Gulch proposes commercial logging in perpetuity. Up to 40% of the trees 18 inches and diameter will be harvested every 15-20 years. Old-growth redwood and Douglas fir trees in two groves are not proposed for logging, unless they are determined to be “hazards”. However, cutting of up to 20% of the second-growth trees within these areas is allowed by the Plan. The Plan can be amended in the future, without public comment.

Commercial Timber Harvesting will increase fire hazards

Redwood forests are dependent upon the cool, foggy coastal climate in the Santa Cruz Mountains. Mature redwood and Douglas fir trees create a canopy of continuous shade that discourages fire-prone shrubs, trees and other sun-preferring vegetation from growing. Summer fog drip replenishes water in the creeks, and maintains moist conditions that keep fire hazards low. In San Mateo County, up to half of the annual precipitation recorded in redwood forests comes from summer fog drip.

Cutting of the largest trees in a commercial timber harvest opens up the tree canopy and exposes the forest floor to direct sunlight. The resulting hotter, drier conditions on the forest floor increase the fire hazard. Logging debris and slash (tree branches, tops, and brush) from cutting of timber, up to two feet deep, is left on the forest floor, adding to the fire hazard. Increased sunlight encourages the growth of weedy and fire-prone species such as tan oak, California lilac (ceanothus), and broom. These fast growing shrubs and trees become “ladder fuels” which enable a fire to spread up into the canopy of the forest. As the forest recovers and the tree canopy grows back, the sun-preferring weedy species become shaded out and eventually die, adding to the fire hazard.

An additional hazard associated with the Camp Jones Gulch NTMP is the proposed use of herbicides on tan oaks. Tan oaks are not considered desirable in a commercially managed forest. They invade recently logged areas, and will re-sprout vigorously if cut. The NTMP proposes to use a method called “hack and squirt” in which herbicides are squirted into a cut in each tree trunk, killing the tree. However, unlike many other species, the leaves on dead tan oaks do not fall off. The leafy dead standing trees become virtual torches - one of the “ladder fuels” that the YMCA is concerned about.

Note: In its review of a 1976 Timber Harvest Plan for the Jones Gulch property, California Division of Forestry stated that the fire hazard will be increased for a period of 4 to 5 years rather than 1 or two years as the YMCA had predicted. In fact, the hazard is much greater than that due to the abundance of brushy shrubs and trees growing back after each timber harvest cycle. Yet, one of the YMCA’s stated purposes of this NTMP is to reduce fire hazards.

There are alternatives to Commercial Timber Harvesting

The YMCA should adopt and implement a strategic fire plan. This would include control of vegetation along Pescadero Creek Road, and the Camps’s ingress/egress road. Within 100 feet of the buildings in the developed area of the Camp, the YMCA should maintain 100 feet of defensible space required by State law. Within the next 200 feet, and other strategic locations such as ridge tops, the Camp should implement shaded fuel breaks. There are funding sources to assist landowners with fuel reduction, and there are potential partner organizations to implement fuel reduction programs.

-Lennie Roberts, Legislative Advocate

The son of Prop. 90

Via an email from Greenbelt Alliance, we learned that backers of the defeated Proposition 90, which would have decimated new land use protections, may try again with a new measure.

According to the article, the backers are now focusing on prohibiting eminent domain for private projects, rather than trying to block new environmental protections. If true, the new measure would be less relevant to CGF's work, but we'd have to look at the details to be certain.

-Brian

Success with MidCoast Local Coastal Plan Amendment!

I am very pleased to announce that today the san Mateo County Board of Supervisors unanimously supported Resolution #4 as the means by which they will submit the LCP Amendment package to the Coastal Commission. This vote signals the Board's willingness to work collaboratively with the Commission. They have agreed to request and consider adopting any of the Commission's suggested modifications to those Amendments that are found to be non-compliance, as submitted, with the Coastal Act. The Amendments that are found to be in compliance will be certified as submitted. By rejecting an "all or nothing" approach, the Board has demonstrated its commitment to a successful outcome for this seven-year, community initiated project.

The Board followed the course of action that Committee for Green Foothills and many of you recommended. Thanks so much for sending your comments to Board members over the past two days. It made a difference. In addition to adopting Resolution #4, the Board followed CGF's other recommendation and directed that all non-LCP Amendments (namely, those that do not require Coastal Commission certification) be implemented right away. This means that the lot merger program, the formation of a flooding and drainage committee and release of the Midcoast Groundwater Study will not be delayed.

The LCP Update is not yet finished but we reached a milestone today.

Thanks again for staying with this process over the past seven years and speaking out -- clearly, eloquently and often -- in support of our Coast. While we did not prevail on all of the issues, we have ensured the adoption of stronger, more protective policies in many areas. Please continue to communicate, motivate and participate!

April Vargas, Board of Directors

MidCoast LCP Amendments before San Mateo County Board of Supervisors, November 14th

April Vargas of the CGF Board of Directors submitted these comments to the Board of Supervisors concerning what method the Board uses to seek approval of the Amendments by the Coastal Commission, who needs to provide the final approval.

Committee for Green Foothills Comments on
Midcoast LCP Update Project
County Counsel Memo November 14, 2006

County Counsel has identified four alternative forms of the resolution submitting the proposed changes to the County’s Local Coastal Program (LCP) to the California Coastal Commission.

Committee for Green Foothills supports Resolution No. 4 (Separate Amendments, Modification Possible) for the following reasons:

* Resolution Nos. 1 and 2 would involve an “all or nothing” approach to certification of the LCP Amendments. The entire package would either be certified or denied. While it is likely that most of the proposed LCP Amendments will be certified by the Coastal Commission, some may not. It would not be in the county’s best interest to risk a denial of the entire LCP amendment package if this is the case.

* Resolution No. 3 would allow the Commission to certify each Amendment separately, which would not risk denial of the entire package. However, the Commission would be precluded from suggesting modifications. Assuming the county would want to revise the Amendment so it could be certified, it would be helpful to know what modifications would meet the Coastal Act requirements.

* Resolution No. 4 allows the separate certification of Amendments that meet the requirements of the Coastal Act, and gives the County the additional benefit of the Commission’s suggestions for modifications. The County does not have to adopt those suggested modifications, and can always suggest other revisions, or provide additional background information that supports the County’s Amendment as originally submitted. Resolution No 4 allows for a process of give and take, and collaboration between the county and the Coastal Commission which reflects the partnership between our local government and the Coastal Commission).

Resolution No. 4 provides the most flexible approach to the certification process and will honor the extensive, seven-year public process that produced the set of Amendments to be certified. Hundreds of county residents, numerous staff members, the Planning Commission and your Board have all devoted countless hours in good faith efforts to draft essential changes to our Local Coastal Plan. These revisions have been crafted to address current conditions within the Midcoast area. Underlying this whole process is the requirement that these revisions meet the standards of Chapter Three of the Coastal Act. Resolution 4 provides the most effective method for meeting these requirements and we urge the Board to adopt it.

We also encourage the Board to adopt modifications that will allow the Non-LCP items to become effective immediately. County staff has proposed a comprehensive and balanced process for implementation of the substandard lot merger program and there is no reason to delay on this or any of the other Non-LCP items.

Don't forget to go out and vote!

CGF sent the Action Alert below to remind people of issues on tomorrow's ballot. For more information, you can also see our earlier Action Alert, here.

-Brian
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Dear Friends,

I’m sure you’ve already received many reminders to get out and vote in tomorrow’s election. I can’t remember a time when there are more measures on the ballot with the potential to impact the things we care about most: open space, park lands, clean air and water. The biggest concern now is that a low voter turnout could make the difference between winning and losing some of these crucial measures. Please take the time to vote tomorrow, your vote does make a difference! We wanted to remind you of the endorsements the Committee for Green Foothills’ board of directors has made this election season:

* Yes on State Proposition 84, the parks bond measure that provides funding for open space and parkland acquisition, watershed restoration, water quality, fish and wildlife habitat, and flood control.

* No on State Proposition 90, the “eminent domain reform bill” which is the most far reaching measure on the ballot with the potential to stop all environmental protection measures. If passed it would effectively abolish the passage and enforcement of basic laws that protect the environment.

* Yes on San Mateo County Measure A to fund our parks “for the future” with a small 1/8 cent sales tax increase, money that could be used in city and county parks for anything from acquisition to maintenance to park programming.

* Yes on Santa Clara County Measure A to protect against sprawl paving over our hillsides and agricultural lands.

Three local ballot measures in San Mateo County also threaten open space areas; if you live in Menlo Park, Pacifica, or Brisbane, your vote is needed to:

* Oppose Measure J, in Menlo Park, an advisory measure that asks voters whether the City should proceed with a major sports complex at Bayfront Park.

* Oppose Measure B in Brisbane that would authorize building housing in the Guadalupe Valley Quarry.

* Oppose Measure L in Pacifica that would authorize a zoning change to allow housing in the former Rockaway Quarry.

Many thanks for speaking up for open space!

Holly Van Houten
Executive Director

Letter to San Jose requesting updated fiscal analysis

We submitted the following letter to the Coyote Valley Task Force, and we'll just hope it gets some results.

-Brian
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October 30, 2006

Coyote Valley Specific Plan Task Force

Re: Need for an accurate update of the Draft Fiscal Analysis

Dear Members of the CVSP Task Force:

The Committee for Green Foothills submitted several comments about the Draft Fiscal Analysis for Coyote Valley that came out earlier this year, and we understand that the City’s consultants are revising their analysis. We repeat our request that all our comments are specifically addressed in a “Response to Comments” format similar to that used in EIRs. Equally important, we urge the City to require updated house pricing information as part of the analysis, rather than rely upon the same starting price information used in the April Draft.

As you recall, the Draft assumes house prices and that are the basis for residential taxes will increase 3% over and above inflation every year for over 50 years, while assuming that costs of providing services will grow much more slowly. We already can see this is wrong in the short term – 2006 prices have not increased at the rate the analysis expected, and there is no reason for 2007 to be different. If the revised Draft does not update the house price information, it will begin analysis with information already known to be incorrect. Even in the nearly-impossible event that the long-term expectations of the Draft are correct for every year after 2007, the current price correction should lower housing revenue projections by around 5%. That should be reflected in the consultant analysis.

Furthermore, there is likely to be a significant time gap between the revised analysis and final City Council consideration of Coyote Valley. When the issue reaches the City Council, there should be one more revision of the house price numbers with the updated information at that time. Neither of our requested updates should require much work – just plug the revised numbers into the existing model, and run the projections into the future. There is no reason not to provide the Task Force and City Council with the most current information.

As you may also recall, the Committee for Green Foothills did not consider the Draft’s revenue projections to be credible. New information over the last six months reinforces the idea that housing prices cannot forever increase faster than income, the underpinning of the Draft’s rosy scenario. We hope this problem will be addressed in the revision.

Please contact us if you have any questions.

Sincerely,

Brian A. Schmidt
Legislative Advocate, Santa Clara County

Sometimes, it's simple

Yesterday, I attended a "Yes on Measure A" rally, complete with a lot of "Yes on Measure A" signs. Afterwards, I walked back to my car as a one-man parade, with a sign held high in each hand.

A man stopped me on the sidewalk.

"What's that sign about?"

"It's supporting Measure A in Santa Clara County, which protects rural areas outside of cities by limiting the amount of new development that can happen there."

He paused a moment.

"That's a good thing to do. They shouldn't be putting lots of houses up in the hills."

It's a pretty straightforward message - I just wish we had a chance to have a similar conversation with every voter in the County.

-Brian

Letter to Sunnyvale City Council about Measure A

We sent the following letter on Tuesday to the Sunnyvale City Council urging support for Measure A. They ultimately decided to take no position, not because they disagreed with it (mostly they support it), but because they felt it wasn't a city-level issue. As you can see from our letter, we disagree.

-Brian

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October 24, 2006

Sunnyvale City Council

Re: Sunnyvale General Plan Policies that support taking an official position endorsing Measure A, the Land Conservation Initiative

Dear Members of the City Council;

We understand that you have already heard a great deal about Measure A, the Land Conservation Initiative, enough to convince six council members to endorse it individually. Rather than repeat the many reasons why Measure A is a good idea, we wish to address the recommendation by City staff to not take a position on the Measure.

Staff does not make this recommendation based on whether Measure A is a good or bad idea, but rather on the assertion “Generally, staff only recommends a position on a ballot measure if there is an existing City policy on the issue or significant impact on the City.”

In fact, multiple General Plan policies address the issue, and protecting the City from Los Angeles-style sprawl is a significant beneficial impact on the City.

A cursory review of Sunnyvale General Plan policies shows several relevant provisions:

Policy Goal R1: “PROTECT AND SUSTAIN A HIGH QUALITY OF LIFE IN SUNNYVALE BY PARTICIPATING IN COORDINATED LAND USE AND TRANSPORTATION PLANNING IN THE REGION.”

Policy Goal R1 references specific goals and action statements that clearly apply to Measure A:

Policy R1.1 Advocate the City’s interests to regional agencies that make land use and transportation system decisions that affect Sunnyvale.

Policy R1.2 Support coordinated regional transportation system planning and improvements.

Policy R1.3 Promote integrated and coordinated local land use and transportation planning.

Action Statements

R1.3.1 Participate in intergovernmental activities related to regional and sub-regional land use and transportation planning in order to advance the City’s interests.

R1.3.2 Promote shorter commute trips and ease congestion by advocating that all communities provide housing and employment opportunities.

R1.3.3 Monitor significant land use and transportation decisions pending in other communities to ensure that Sunnyvale is not adversely affected.

Because Measure A stops sprawl that could adversely affect Sunnyvale’s interest in sound land use and effective transportation, the City’s policies require support.

Other City policies also apply:

Policy 3.1A.1c. Support legislation which would enhance the availability of adequate water from Sunnyvale's existing sources of supply.

Water conservation 3.1B.2d. Coordinate planning with local, state and federal agencies.

And policies on creek protection:

Surface Runoff Sub-Element

Goals and Policies

Protect Beneficial Uses of Creeks and South San Francisco Bay

Goal 3.4A. Assure the reasonable protection of beneficial uses of creeks and South San Francisco Bay, established in the Regional Board's Basin Plan, and protect environmentally sensitive areas.

Policy 3.4A.2 Comply with regulatory requirements and participate in processes which may result in modifications to regulatory requirements.

3.4A.2c. Review proposed changes in regulatory requirements and comment as appropriate.

Measure A protects water quality and water quantity.

For all these reasons, and the general beneficial impact Measure A will have on County land use that is crucial for keeping Sunnyvale part of an area that does not resemble Southern California, we urge the City to endorse Measure A.

Please contact us if you have any questions.

Sincerely,
Brian A. Schmidt
Legislative Advocate, Santa Clara County

Getting information on the Santa Clara County HCP

Want more information on the Santa Clara County Habitat Conservation Plan? CGF has been heavily involved and we'll stay involved, and it's a big issue for the County.

To see what they're planning, go to their website.

-Brian

Seems like everyone hates Proposition 90, but it's still very dangerous

Last night I attended a debate between the Santa Clara County Farm Bureau and the Yes On Measure A Campaign, something CGF strongly supports. Both sides did a good job (clearly we think Measure A is a great idea, though).

What struck me was how even the Farm Bureau stated they oppose Proposition 90, something CGF also opposes. In retrospect, it makes sense - Prop. 90 will likely block "Right to Farm" ordinances if it passes.

Proposition 90 is an under-the-radar disaster that has very little to do with the eminent domain issue it pretends to be about. The concern is that people won't see the trap, and will pass it. We certainly hope that won't happen.

-Brian

The problem with Coyote Valley, in one paragraph

I've been struggling to state clearly why Coyote Valley is such a mess of a proposal under the both current and future economic situations. Holly came up with this definition in preparation for materials to present at Nature's Inspirations, which I think is excellent:

The stated reason to build Coyote Valley is to bring needed jobs to San Jose while providing some housing for people employed in Coyote Valley. Currently the Bay Area has massive office vacancies, so there is no demand for new office construction. However, if all the office space planned for development there were actually built, there wouldn’t be enough housing. Developing new office space this far south of the city central just serves to exacerbate sprawl south through Gilroy, San Benito County and the Central Valley.

Now to get that understanding through to the decision-makers....

-Brian

A victory for environmental education about the Bay

In August, CGF wrote to the Water District, asking them to help sponsor the KTEH public television documentary, Saving the Bay. We've just received a letter from the Water District Board of Directors saying they're providing sponsorship.

CGF has a long history of working on San Francisco Bay protection issues, most recently concerning Bayfront Park in San Mateo County. It's great that Bay protection will get the attention it deserves, and kudos to the Water District for making that possible.

-Brian