CGF journal

Observations and thoughts from Committee for Green Foothills.

Wednesday, July 15

Tackling the rise in SF Bay levels

Climate change-induced sea level rise will have a similar effect on San Francisco Bay, leaving planners, taxpayers, and environmentalists with a difficult problem in how to manage the rising Bay. The Chronicle covers some interesting and highly speculative ideas entered in a recent contest:
Once they would have been the stuff of science fiction: shimmering levees of
water that shield cities, or laser beams slicing across water through the
night.

In fact, these are two of six winners announced Tuesday in a
design competition that responds to a real-life threat - scientific projections
that in the century to come, the sea level of San Francisco Bay could climb 55
inches beyond today's high tide.
"We need to rethink how we build along the
shoreline, but we didn't have the answers," said Will Travis, executive director
of the San Francisco Bay Conservation and Development Commission, which
organized the competition. "So we decided to cast the net for ideas."

The ideas can be seen here. I skimmed through a few, and any solution is going to be expensive. This is something that both San Mateo and Santa Clara Counties are going to have to deal with, soon.

It would be interesting to see how much could be saved if aggressive action on climate cut the Bay level increase in half.

-Brian

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Tuesday, March 11

Great news for Santa Clara Valley Water District - all environmental recommendations were enacted

I just wanted to follow up on the Urgent Alert we wrote up (and sent out by our diligent Office Manager Wendee on Saturday afternoon). The day before, the Water District finalized a decision to consider a number of recommendations made by the District's Environmental Advisory Committee (I'm the current chair of the EAC). More information is here, but suffice it to say that all recommendations were accepted, so the Water District is on record that industrial producers should be responsible for pollution from their products, and that the District will focus more closely on the environmental problems from erosion.

The District Board commented on the letters they received from the public, and said they appreciated and read the comments, all of them favoring our position.

Thanks everyone!

-Brian

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Wednesday, January 16

Brian to chair Environmental Advisory Committee

Just publishing a note here that I've been elected the chair of the Environmental Advisory Committee for the Santa Clara Valley Water District. I've been vice-chair for the last two years.

A little more work, but it's an important committee in terms of emphasizing the environmental restoration that the District needs to do.

-Brian

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Tuesday, October 16

Santa Clara County Creeks Coalition (and CGF) event on November 17

CGF is a participating member of the Santa Clara County Creeks Coalition, an umbrella group coordinating stream protection in our county. I'll be mentioning SCCCC activities from time to time.

A big event coming up next month is the Creeks and Watershed Conference, an all day conference on November 17th in San Jose to educate the public about watershed protection efforts. More information is available here - please come for any part of the event, or for the whole day!

-Brian

(I should note that children are welcome, but the presentations will be geared to an adult level.)

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Wednesday, April 11

What you can say in three minutes about impervious surfaces

I had three minutes yesterday to talk at a mini-workshop for the Santa Clara Valley Water District about how local governments in Santa Clara County (and probably, statewide) are violating the California Environmental Quality Act regarding impervious surfaces - paving over our watersheds. As a little blogging experiment, I'm seeing if I can attach a readable PowerPoint presentation and text below. Let's see how it goes.

-Brian
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Slide 1:
Good afternoon, Brian Schmidt from Committee for Green Foothills and the Creeks Coalition. This morning you have been hearing about the problems from erosive forces; I will discuss a very specific solution that is available now and is legally required…


Slide 2:
…which is tracking cumulative impacts regardless of project size, and mitigating those impacts.

Current and proposed regulations, including those discussed today, do not limit the erosion impacts from small projects, but only those adding large amounts of impervious area.

However, small projects in combination can create significant problems. The City of Palo Alto found that much of its increase in impervious surfaces came from these small projects.

Additionally, permits allow large projects to have impacts when mitigation exceeds cost limits. These small and large project impacts are ignored.


Slide 3:

A policy tool already exists that requires analysis and feasible mitigation of these impacts, the California Environmental Quality Act. CEQA requires analyzing cumulative impacts that result from individually minor but collectively significant projects taking place over time. Land use agencies must do this analysis – they might choose to do it proactively, or they could end up being forced to do it.

Slide 4:

CEQA also requires reducing the impacts where feasible, and reducing impervious surface impacts is feasible. It’s easy to reduce the impervious surface area, especially for small projects that have not been required in the past to limit this impact. Using permeable pavement that allows water to percolate through it is also very feasible. Finally, CEQA allows paying into a fund for offsite mitigation that could reduce pavement elsewhere, or otherwise help mitigate the erosion impacts. Water District staff has expressed interest in off-site mitigation in other contexts.

Slide 5:

So, how to move forward? Ideally, land use agencies would do a programmatic analysis of all their watersheds to analyze cumulative impacts and propose mitigations, but they also may be forced to do an analysis. For our purposes today, though, we are asking the Water District itself act proactively by providing the technical information that agencies or advocacy groups could use to determine whether cumulatively significant impacts exist in various stream reaches. As a neutral provider of environmental information, this step would be invaluable.

Slide 6:

Committee for Green Foothills did an extensive legal white paper pursuant to a grant we received from the Water District. The white paper is available at this website address, as is my contact information for any follow-up questions.

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Friday, April 6

CGF Comments on the Water District Performance Audit

(We submitted comments on a performance audit for the Santa Clara Valley Water District. I'm the environmental representative on an advisory committee, discussed briefly here.

-Brian)
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The following are my comments on behalf of the Committee for Green Foothills regarding the Watershed Operations Audit Memorandum of the March 2007 Comprehensive Performance Audit Final Report prepared for the Water District.

(The following page references are to Appendix E of the Final Report.)

Page 2: fieldwork listed for the Watershed Operations Audit does not include interviews with outside stakeholders. I was interviewed by the auditors, primarily concerning watershed issues. My interview is listed elsewhere in the Audit, but I hope the omission here does not mean my interview was left out of consideration for the Watershed Memo. Some of my comments would have fallen into the category of “Opportunities for Improvement,” although I did not take notes when I was interviewed.

Page 4 and Page 18: Strength Finding No. 1, praising the Watershed Permit Management System, appears to conflict with Opportunity for Improvement Finding No. 6, stating the District “is not fully prepared for future permit-driven monitoring.” More explanation is needed as to why the current system will be inadequate, and if so, why the current system is not currently inadequate.

Page 6 and 7: Strength Finding No. 2, praising the “partner” relationship with the City of San Jose over Coyote Valley, is troubling. The District should be a neutral provider of information regarding environmental protection, water quality, water supply, and flood protection. If San Jose ultimately approves Coyote Valley development and the project goes forward, then a partner relationship could be appropriate, but right now this highly contentious project divides the people that the District works for – the voters of Santa Clara County. There are limits to the Baldrige business model when applied to governments, and this may be an example. At this point in time, the District should not be taking sides.

Page 8 and 9: as it appears that no one on the Clean Safe Creeks Independent Monitoring Committee was interviewed, I would like to know the basis the auditors have for concluding that the program is successful. I am not for my part stating it is successful or unsuccessful overall, and the parts I am familiar with appear to be successful, but am interested in what the basis is for this determination.

Page 11 and 12: the statement on p. 12, “the perception local agencies have of the District with respect to floodplain management probably does not match the services the District provides” is unclear as to what exactly is the problem. The worst-case scenario is that the District and the agencies both believe the other side has taken on a responsibility that it has not, and something is not being done that should be done. This needs to be clarified.

Page 15 and 16: The discussion of the Watershed Resources Protection Ordinance misses that this is primarily an environmental protection issue, and the possibility of damage to flood control structures is a secondary issue. It further misses the issue that the Environmental Advisory Committee made recommendations that were not incorporated into the final ordinance (as I understand it). The comparison between the recommendations and the final ordinance would have been a useful place for an outside auditor to determine whether performance could be improved. Issues such as whether the District gave up too much authority that it legally could have exercised to agencies that are unwilling to protect the environment could also have been discussed as part of a performance audit.

My suggestion is the District react to this report by clarifying its role as a neutral provider of information. The District should also clarify that it is allowed to take a policy position supporting or opposing major projects like Coyote Valley, and clarify when it is acting as a “partner” and when it is acting as an expert agency.

I further suggest that any monitoring program tracking overall mitigation required of the district, also track when the District is supposed to be consulted by others. Many land use agencies, for example, will issue conditions to permits requiring landowners to consult with the District before proceeding with certain actions. While compliance in these cases is not the District’s responsibility, it would be very useful to have a single place to go to try and track down when consultation is required.

Please contact me with any questions.


Sincerely,
Brian Schmidt

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