Sample Letter to BOS re: LCP Update


By on Mon, April 12, 2010

Here is a sample letter based on, and consistent with, the MCC’s previous letter for those that would like to comment individually.

Please note that you will want to email, fax or hand deliver your comments on or before tomorrow, April 13, at 9:30 am at which time the Board of Supervisors will hear from the public whether or not to accept the Coastal Commission’s modifications.

President Rich Gordon          
FAX:  363-1856    
Email: [email protected]

Supervisor Mark Church        
FAX:  368-3012    
Email: [email protected]

Supervisor Carole Groom        
FAX: 366-6762    
Email: [email protected]

Supervisor Rose Jacobs Gibson    
FAX: 366-6720    
Email: [email protected]

Supervisor Adrienne Tissier        
FAX: 701-0564    
Email: [email protected]


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,

As a resident of the Midcoast,I appreciate the Board of Supervisors keeping the public involved over the past ten years and urge the board to accept the Coastal Commission’s suggested modifications to the Midcoast LCP Update.

I have the following additional specific comments based on the March 29, 2010 Staff Report:

a. Growth Rate

SMC Building and Planning Department acknowledges that “…over the past five years (2004-2008), an average of 38 units have been approved annually.” In light of this fact, and the strain on resources already pushing road and highway infrastructure beyond their limits, I do not find a compelling basis for raising the growth rate beyond the CCC’s proposed 40 unit limits.

I do not support SMC Building and Planning Department’s request for “deletion of the requirement that second units document an affordable sale or rental price in order to be exempt from the growth limit.” The argument that “…second units can be assumed to be affordable due to limits on their size, and because documenting and monitoring the affordability of second units places unnecessary administrative demands and challenges on limited staff resources” falls flat because the County has not yet accounted for the number of existing second units, permitted and unpermitted. While these future units may be affordable, they still create infrastructure demands that must be met.

b. Private Wells

I support the Coastal Commission staff recommendation for a temporary moratorium on private wells in the urban area extending from Miramar through Montara. Half Moon Bay does not allow new private wells to be drilled for residential development. The Midcoast Ground Water Study, Phase II shows that all of our aquifers are at risk from saltwater intrusion and overdraft from the 946 wells that have been drilled since 1989. There are over 1,000 if we count those that existed previous to 1989. Families dependent on wells have no guarantee from the County that their water supply is reliable. I recommend that the County work with Coastside County Water District and Montara Water and Sanitary District to create a sustainable supply to meet all the planning needs at buildout.

How many new houses can be developed on wells existing on undeveloped lots? What effect will these wells have on coastal resources and the aquifers once they start drawing water from the aquifers?

c. Public Works Capacities

I disagree with the County Staff’s assertion that “the need to ensure that public works projects do not generate growth that will result in significant adverse impacts or that conflicts with the County’s land use plans can be effectively addressed through the environmental review and permitting process.” Case in point would be the lack of limitations put on the Coastal Development Permit for the El Granada Water Transmission Pipeline for Coastside County Water District. It took the Coastal Commission many years of hard work to create CDP conditions that allowed CCWD to have its gravity fed pipeline and not induce growth from it. I recommend that each special district not expand beyond its current service area and that the LCP Update tables be modified to detail the number of connections and capacity allowed for each category of service allowed for buildout. Each CDP for public works expansion should follow the model created by Coastal Commission staff in the El Granada Water Transmission Pile Line CDP.

d. Prioritizing Service Capacities for Affordable Housing

I disagree with County staff’s assertion that “CCC staff changes which delete this additional set aside, and that revise the table to give existing priorities for affordable housing lower standing than Coastal Act priorities, are neither necessary nor appropriate.” The CCC changes are both necessary and appropriate, especially in light increasing traffic congestion, lack of adequate park facilities, trails, water supply, and storm drainage systems.

Under the County staff’s own admission, it will assume that second units fall under the affordable housing designation and yet it has no knowledge of how many second units exist. Further, the County added 227 affordable housing units to the coastside inventory and has yet to include them in it. Perhaps one or more of the other three affordable PUD’s can be reexamined with attention paid to ESHA resources and reduced in size. In short, the CCC’s proposed changes here are well placed and should not be revisited.

e. Lot Retirement

I oppose County Staff’s assertion that “CCC staff revise the lot retirement requirement so that it will only apply to land divisions that create five or more new parcels” Here again, County Staff is engineering an unnecessary and unwise way to increase development and the resulting traffic problems when both the LCP and its own policies specifically discourage subdivisions. The Update accounted for quite few substandard lots that would not have been allowed to be developed when the LCP was initially adopted. Not allowing further subdivision of lots deemed to not have been subdivided according to Abernathy and Witt will reduce the need to expand urban infrastructure services the lot retirement policy would be best served by rejecting the County Staff’s developer-friendly proposed loophole.

f. Rezoning of Bypass Lands

I recognize County Staff’s assertion that “… determining the rights-of-way that need to be reserved to provide access to private property, delineating areas needed by CalTrans for staging and maintenance purposes, and differentiating between areas that provide good opportunities for recreation and open space preservation and those that make sense for infill development” as those that are in “our mutual best interests” is disingenuous at best.

Preserving development rights at the expense of open space may be in the interests of some, but is not in the best interest of residents of the Midcoast who enjoy the open space afforded by this naturally scenic landscape, nor in the interest of the County, which should be seeking to create parks and play areas for the growing population to serve at buildout. CalTrans’ staging and maintenance needs do not rise to a superior claim on those lands trumping the broad policy favoring the preservation of open space that serves as the foundation of the LCP to create a state resource for residents and visitors alike.

3. “Grandfather Provision”

I find fault with the County’s current grandfather provision as it relates to the County’s own efforts to “streamline” a proposed major new development, the Big Wave Project, to fall under this grandfather provision. The County should not be allowed to usher in a project with projected future development timeline of up to 15 years (assuming no further legal challenges or delays which would add to this timeframe) under a grandfather clause in existence today. This would be inherently unfair as it would place developments completed many years ahead of Big Wave, for example, under more stringent requirements than a major development that will not be completed for many years to follow. The grandfather provision should be found inapplicable and patently unfair and I request that the County heed the Coastal Commission recommendations.

At several points county staff has noted the financial limitations that limit the ability to monitor conditions regarding affordable housing and other county interests. Many of the Midcoast’s unmet infrastructure needs are those that the County is responsible for. As San Mateo County is not structured to meet the urban demands of this community, it seems unwise for it to be allowing development that creates even greater infrastructure needs and environmental deficits. I hope that keeping the growth at its present rate will allow San Mateo County the opportunity to find solutions for the traffic congestion, lack of parks and trails, and underdeveloped storm water systems.

I recommend that the decisions on these issues be made with the interests of residents and visitors as the priority.

Sincerely Yours,

[Your Name Here]