Yet another problem with the Parks Charter Fund/Habitat Plan issue

Yesterday someone pointed out to me a problem with counting parkland purchases as mitigation for road impacts that I hadn't thought of before: the Habitat Plan treats the amount of road impacts as a fixed quantity (somewhat simplified but accurate enough for these purposes), when in fact it could be higher or lower. If the County Roads Department uses parkland to count as mitigation for road impacts rather than paying for it from the Roads budget, it has just lost any incentive it has to minimize the impacts. In other words, we'll get far more impacts than would otherwise be the case. True, those impacts will be mitigated, but that's inadequate for two reasons: first, mitigation isn't as good as avoiding impacts, and second, the mitigation has the effect of eliminating a net benefit of more endangered habitat.

Let's walk through two cost scenarios as an example, where the County Roads Department has to choose between widening a road into endangered habitat riparian zone on one side, or encroaching into a hillside on the other:

Scenario 1: Costs of widening a road into riparian zone:
Construction and non-habitat costs: $1.0 million
Habitat mitigation cost: $0.5 million
Total: $1.5 million

Scenario 2: Costs of widening a road into a hillside:
Construction and non-habitat costs: $1.1 million
Habitat mitigation cost: none
Total: $1.1 million

The rational choice if the Roads Department considered (meaning, "had to pay for") all costs would be Scenario 2. But if the Roads Department just gets free credit for land purchased by the Parks Department, then Scenario 2 looks more expensive to it, and it will choose Scenario 1 instead. I was fumbling toward this idea when I repeatedly told the County that it's bad policy to shift costs between departments, but this points it out really well.

So what's the likely County response? If I were them, I'd point to toothless and unenforceable provisions in the Habitat Plan that say "where economically feasible, impacts should be avoided" and claim that meant something. I expect they believe that to be true in the abstract, but when it gets down to the specifics of each budget, the real choice will always default to Scenario 1.

(More reasons here for why using Parks Charter Fund is a bad idea.)
-Brian

Why Santa Clara County shouldn't reduce the benefits of the Parks Charter Fund

(Below is a display we used in a so-far-unsuccessful effort to get the County Roads Department to keep its hands off of the Parks Charter fund. -Brian)

Reasons why the Roads Fund, not the Parks Charter Fund, should pay for roads impacts

1. Parks Fund meant to be a net benefit, but used as a mitigation means the environment is no better off

2. Better management principle is to reduce cross-subsidies, in this case using Parks funding to subsidize road development.

3. Using Parks funding may interfere with the future selection of parkland in order to maximize mitigation of roads impacts.

Alternative:

Parks Dept. pays for park impacts

Roads Dept. pays for road impacts

Parks can purchase recreational use on lands bought by Roads Dept.

Bad decision by Santa Clara County Supervisors on Parks

We told them not to convert the Parks Charter Fund from an environmental benefit to a kind of mitigation bank that pays for environmental impacts from road widening. Unfortunately we haven't been able to persuade them so far.

Below is a recent letter on this issue in the Mercury News:

Parks Charter Fund not meant for roads

On Tuesday, the Santa Clara County Board of Supervisors decided to pilfer $14 million from the Santa Clara County Parks Charter funds to pay for non-park-related expenses. This is a dangerous precedent and goes against the will of the voters. The Parks Charter Fund was passed specifically by the voters, since 1972, to set aside funds to buy and maintain county parks and nothing else. But the supervisors (Pete McHugh, Don Gage and Ken Yeager - for; Blanca Alvarado and Liz Kniss - against) decided to use those funds to pay for obligations incurred by the county roads department to meet their mitigation obligation under the proposed county habitat plan. This is irresponsible, and the decision should be rescinded immediately.

Craige Edgerton
Member, Stakeholders Group Santa Clara Valley Habitat Conservation Plan/Natural Community Conservation Plan

When is a math error a real error?

Yesterday I went to a Planning Commission hearing to oppose a project for 26,000 square foot covered horse arena and barn on a 14 acre property that also has 6,000 square feet of residential development on it. This seemed to me to be a terrible precedent for massive development that would be used to push permits for monster mansions.

That was the main point I brought up, although it was rejected by County staff and the commission, both swearing up and down that it's not a precedent for other development. Hopefully they'll remember that when the time comes.

The other point though was about the environmental document from 2007 that they were using. It said the total development including the residence was 26,000 feet, not the 32,000 feet now being considered. I argued they couldn't use the document if the project had been expanded.

After some confusion among staff, they said that the project hadn't been changed, it always had been 32,000 square feet, and it was just the calculation of footage in the document that was wrong. Personally, I'm not all that happy with sloppiness or consider it meaningless, especially when it's a 25% underestimate. Too bad the Planning Commission didn't care.

This happens all the time. We'll just have to keep fighting.

-Brian

Great article about Stanford blocking the Bay-to-Ridge Trail

Palo Alto Weekly has a great article here about how a trail from Skyline to the Bay is all but constructed. The only missing part runs through Stanford. That part should have been constructed years ago - Stanford agreed to do it, but has since backed out. We'll keep working on them though.

-Brian

(An excellent map too is here.)