CGF Joint letter on protecting San Jose hillsides from sprawl

(CGF sent the letter below with other organizations on using the Draft General Plan to protect San Jose hillsides from sprawl.  We also sent a clarification that the support from city staff referred to staff's original March 21, 2011 position, and that staff's later positions have varied.  -Brian)

October 25, 2011  

San Jose City Hall

200 E Santa Clara Street

San Jose, CA 95112

To:  Honorable Mayor Reed and San Jose City Council,

We strongly support Open Hillside (Plan Option #1) as recommended by the Planning Staff and members of the Envision San José 2040 General Plan Task Force to modify Policy Goal LU-19 and add further restrictions on the allowable development intensity for lands with Open Hillside designation, keeping the proposed limitation of 10% of developable land.

We respect and support the hard work of the Staff and Envision San José 2040 General Plan Task Force over the past four years for transit oriented development which ties into AB32, SB375 and San José’s Green Vision Plan (GVP). The plan has strong goals for economic growth, environmental stewardship, and enhanced quality of life for San José residents by putting emphasis on infill development. The prioritization of jobs and housing within the Urban Group Boundary (UGB) and on transit corridors begins to correct past errors in land use policy. The General Plan update integrates San José’s GVP which includes metrics for water conservation and adopting a general plan with Measurable Standards for Sustainable Development. Staff’s comprehensive evaluation for Plan Option #1 reinforces the GVP and most importantly development of urban villages with transit oriented blend.

The Envision 2040 Task Force unanimously voted and approved the draft General Plan on Monday, September 12, 2011. Staff and the Envision 2040 Task Force requested that the Planning Commission and City Council consider five other options to the 2040 Plan Update as Task Force members were split on the Open Hillside land use policy. The Planning Commission met on Wednesday, September 29, 2011 and did not support Plan Option #1,


with one dissenting vote from the Chair, Hope Cahan.

Chair Cahan expressed concerns regarding environmental impacts on water issues. The discussion was limited and did not connect the Envision 2040 policies/goals or linkages to performance metrics in GVP for water conservation (Goal #6), open space or quality of life amenities.  Development outside of the UGB conflicts with water goals from the GVP and with water conservation goals in the Draft Plan under MS-3 which includes a metric for reducing city wide per capita water consumption by 25% by 2050 utilizing a baseline from the 2010 Urban Water Management Plans of water retailers. Water sustainability is a major concern not only for San José residents and businesses but also for the State of California. Staff’s analysis and recommendation to prohibit new development in the UGB should be supported.

LU19.6 recommends not providing urban services to new development outside of UGB. We agree that adding any type of development with the exception of agriculture outside of the UGB will overload already stressed police and fire departments, add financial burdens for capital investment from taxpayers and compete for existing public infrastructure funding for roads and maintenance as well as increase the water demands. Furthermore, it will not meet San José’s goal of creating vibrant, walkable communities with reduced greenhouse gas emissions and reduced traffic.

We support the recommendations in LU19.8, which limits environmental impact in the UGB. Adding new development outside of the city’s boundaries conflicts with many policy and goals in the plan. Below is a partial list of policies and goals that conflict with development outside the UGB:

Goal LU-17- Hillside/Rural Preservation.
Preserve the valuable natural resources of the hillsides, and protect their aesthetic
and habitat amenities to enhance the rural character of these areas.

Policies – Responsible Management of Water Supply. 
MS-17.2 Ensure that development within San José is planned and built in a manner consistent with fiscally and environmentally sustainable use of current and future water supplies by encouraging sustainable development practices, including low-impact development, water-efficient development and green building techniques. Support the location of new development within the vicinity of the recycled water system and promote expansion of the SBWR system to areas planned for new development. Residential development outside of the Urban Service Area can be approved only at minimal levels and only allowed to use non-recycled water at urban intensities. For residential development outside of the Urban Service Area, restrict water usage to well water, rainwater collection, or other similar environmentally sustainable practice. Nonresidential development may use the same sources and potentially make use of recycled water, provided that its use will not result in conflicts with other General Plan policies, including geologic or habitat impacts. To maximize the efficient and environmentally beneficial use of water outside of the Urban Service Area, limit water consumption for new development so that it does not diminish the water supply available for projected development within San José’s urbanized areas.

Goal MS-18 – Water Conservation.  Continuously improve water conservation
efforts in order to achieve best in class performance. Double the City’s annual water conservation savings by 2040 and achieve half of the Water District’s goal for Santa Clara County on an annual basis.

Policies – Water Conservation. MS-18.2 Require new development outside of the City’s Urban Service Area to incorporate measures to minimize water consumption.

Goal ER-1 – Grassland, Oak Woodlands, Chaparral and Coastal Scrub.
Preserve, protect and restore the ecological integrity and scenic characteristics of grasslands, oak woodlands, chaparral and coastal scrub in hillside areas.

Goal ER-6 – Urban Natural Interface. Minimize adverse effects of urbanization
on natural lands surrounding the City’s developed areas.

Goal EC-4 – Geologic and Soil Hazards. Minimize the risk of injury, loss of life,
and property damage from soil and slope instability including landslides, differential settlement, and accelerated erosion.

Goal PR-1 – High Quality Facilities and Programs. Provide park lands, trails, open space, recreation amenities, and programs, nationally recognized for their excellence, which enhance the livability of the urban and suburban environments; preserve significant natural, historic, scenic and other open space resources; and meet the parks and recreation services needs of San José’s residents, workers, and visitors.

Goal PR-3 – Provide an Equitable Park System. Create a balanced park system that provides all residents access to parks, trails, open space, community centers, dog parks, skate parks, aquatics facilities, sports fields, community gardens, and other amenities.

Thank you for your continued efforts and leadership as indicated for your creative support for the Three Creek Trails project. We implore you to consider and restrict Open Hillside Development outside of UGB, and not develop them before 2040.  Please continue to focus development inside the urban growth boundary, positioning San José as a place for present and future generations to live, work and enjoy. 

Respectfully submitted,

Sierra Club Loma Prieta Chapter, San José Cool Cities, Committee for Green Foothills, Greenbelt Alliance, San José State Students and Alumni, David Marsland (District 1), Former Co-Chair San José Cool Cities, Susan Marsland (District 1) Helen Chapman (District 6), Megan  Fluke (District 7), and Jessica Gonzales (District 8)

Joint Organization letter on the San Jose General Plan

(CGF co-authored the letter below with a number of other environmental groups.  -Brian)

August 15, 2011

Mr. Andrew Crabtree, Envision Team Leader              

Planning, Building and Code Enforcement

San Jose City Hall

200 East Santa Clara Street

San Jose, CA 95113

Dear Mr. Crabtree,

On behalf of Greenbelt Alliance, the Loma-Prieta Chapter of the Sierra Club, San Jose Cool Cities, Silicon Valley Leadership Group, Committee for Green Foothills, Working Partnerships, USA, and The Health Trust, we are writing to thank the City of San Jose for this opportunity to comment on the Draft Program Environmental Impact Report (DEIR) for the Envision San Jose 2040 General Plan.

In many ways, this General Plan is a model that focuses on urban villages and corridors, infill development near transit, ambitious mode split targets and improved public health.

Our comments below reflect our desire to strengthen Envision 2040 even more and support San Jose on its path to becoming a more sustainable, equitable and healthier City.

Jobs-Housing Ratio

The environmental review acknowledges that significant environmental impacts result from the possibility of a Jobs to Employed Residents Ratio that exceeds 1:1 (see, e.g., Impact PH-1 and Impact TRANS-1, among others). The City has acknowledged that one reason for these impacts is not that it intends and prefers the highest possible J:ER ratio, but that it seeks to maximize the jobs capacity to increase the current J:ER ratio which is significantly below 1:1. 

Accordingly, our organizations jointly recommend an additional mitigation:  for purposes of avoiding environmental impacts or delaying environmental impacts, the City should require orderly development that prioritizes a J:ER ratio of 1:1 as long as housing is available to match job growth.  We recognize that ultimately job growth could exceed housing capacity, but this mitigation would at least postpone the impacts associated with the excess of jobs over housing, and postponing the impacts are feasible means of partially reducing their scale.

As a result of pursuing a J:ER ratio of 1.3:1, more people will be commuting into San Jose for work, exacerbating a regional housing problem. This combined with the fact that the DEIR shows a decrease in the percentage of jobs within walking distance of transit has a significant impact on Vehicle Miles Traveled (VMT).  

Additionally, San Jose proposes to expand vehicle capacity on a number of roadways which makes driving more convenient, inducing demand for more drivers on the road. This works directly against the City’s goals of reducing automobile emissions.

Our organizations jointly recommend mitigation that prioritizes transit friendly job development and thereby provides limits on development in areas that do not have transit. Such prioritization of development in transit friendly areas over areas that do not have transit yet have agricultural value, such as Coyote Valley, also functions as mitigation that reduces the impacts on open space and prime farmland by reducing the pressure for immediate development of those areas.

The Jobs to Employed Resident ratios in the environmental review, for the highest ratios at least, are not intended results so much as foreseeable impacts described in the document.  The environmental protections described in the document, by contrast, are expressly intended and planned.  We urge the City to reaffirm these environmental protections and we will work to assist and ensure that the City is able to fulfill its commitment to put these policies in place.

Housing

We applaud the plan for establishing social equity as a planning goal including promoting quality job opportunities and an equitable park system.  However, more can be done to support the plan’s guiding principle of social equity. 

The DEIR seems to treat lightly the potential for voluntary displacement as a result of new development at transit stations driving up prices. People will move further afield to places like Tracy in search of more affordable homes. This in turn forces people to commute back to the community in which they may work.  It is therefore critical that San Jose has strong affordable housing policies.  San Jose has an excellent record in building affordable homes and we recognize that the future is uncertain when it comes to building more homes affordable to a range of incomes.  That said, Envision 2040 is planning out to the year 2040 and the economy will go through many cycles. 

We jointly recommend that strong protections are in place to preserve the existing affordable housing stock in transit zones, which provides people with access to opportunity. We also recommend that as large planning projects move forward, such as Diridon Station, that the affordable housing requirements are met on site, including for rental affordable housing.

Transportation

Envision 2040 has very ambitious mode split goals, proposing that the percentage of trips made by bicycle will increase from 1.2% in 2008 to at least 15% in 2040 while the number of those driving alone will decrease from 78% to no more than 40%.  San Jose should be applauded for pursuing these goals. However, Table 3.2-14 on page 270 shows that with the proposed Envision 2040 General Plan policies, the percent mode share increase in bicycle trips is 1% for a total of 2% of all trips made by bike. This is evidence that stronger, more holistic balanced transportation policies are necessary. As such, we support policies that prioritize walking, cycling and riding transit.

Our organizations recommend pursuing more aggressive complete streets and parking policies as a way to achieve the commendable and ambitious mode split targets, including a 40% reduction in VMT. This includes expanding the Protected Intersections Policy to all Planned and Identified Growth Areas and reducing the number of streets slated for expansion. Also, we encourage the consideration of Parking Benefits Districts that establish performance pricing of street parking and then return the revenues to the neighborhood.

Public Health

We commend San Jose for its leadership in including community health as a major theme in the draft General Plan.  Recognizing the growing body of evidence showing the link between land use patterns and health outcomes, this plan lays out a strong commitment to promoting community health as San Jose grows over the next 30 years.  In particular, the Plan’s emphasis on improving access to healthy food in low-income neighborhoods and access to medical services is thoughtful and visionary and can serve as a model for other communities looking to address health challenges as they grow.

We appreciate Envision 2040’s support for the development of a Community Risk Reduction Plan that will reduce air pollution exposures in communities located near busy roadways and industrial sources and inclusion of specific health-protective mitigation measures for development in those areas.

The General Plan is an opportunity to build healthy, livable complete neighborhoods, communities that intentionally support the well-being of all ages, strengthen families and enable seniors to remain in their homes as they age with independence, dignity and the ability to remain engaged in their community. 

We support the village concept that is the cornerstone of the draft General Plan.  We strongly encourage the Task Force to include language in the General Plan that prioritizes development of village plans for low-income neighborhoods, oftentimes those with the greatest need for increased access to walkable communities, safe streets, physical activity opportunities, and healthy food. 

Additionally, we also support policies to review and revise diesel truck routes to minimize exposure of harmful diesel exhaust to sensitive receptors, including children and the elderly.

Open Space

For lands outside the Urban Growth Boundary (UGB), it is important that they remain as undeveloped open space. Lands outside the UGB play an important role as natural infrastructure, cleaning our air and water.

For non-agricultural uses, our organizations support minimal disturbance to lands located outside the UGB so as to preserve the rural nature of this greenbelt and to provide a viable wildlife corridor.

Conclusion

Overall, the Envision San Jose 2040 General Plan update has set exceptional economic, environmental, and social equity goals for the City of San Jose thanks to the hard work of dedicated task force members and city staff. We hope decision makers honor this hard work as they implement the General Plan over the next 10-20 years.

San Jose can be a better city tomorrow and the General Plan sets the framework to do so. Once the plan is passed, our organizations will support the City in its implementation. Thank you for the opportunity to make public comment.

Sincerely,

Michele Beasley                      

Senior Field Representative                  

Greenbelt Alliance                   

Charles Schafer

Chair, Executive Committee

Sierra Club Loma Prieta Chapter

Frederick J Ferrer, M.S.

Chief Executive Officer

The Health Trust

Shiloh Ballard                                                                          

Vice President, Housing & Community Development    

Silicon Valley Leadership Group                      

Brian Darrow

Associate Director of Land Use and Urban Policy

Working Partnerships, USA

Brian Schmidt                                                  

Legislative Advocate                                        

Committee for Green Foothills

Erica Stanojevic

San Jose Cool Cities