October 25, 2010
I would encourage consideration of specific examples to see whether the protection the District sought through expanding Ordinance 83-2 has been achieved under present conditions. Several examples that immediately spring to mind include:
· Los Altos Hills, with a 25-foot riparian buffer policy.
In each case the District might analyze whether it could help with riparian protection under current policies. For example, in the case of the Guadalupe Mines Road project, the District submitted a useful comment letter prior to the initiation of CEQA review for the project, but the District did not comment on the CEQA document itself and did not provide comments when the project approval was appealed by environmental groups and another governmental agency, the Guadalupe Coyote Resource Conservation District.
We believe that more can be done to improve riparian protection. Because we are aware of interest in different cities for improving policies (for example, San Jose's proposed Draft General Plan revision to reduce exceptions to its 100-foot buffer policy), we think this could be advanced in a way that shows the District's concern but is still productive and cooperative.
Please contact us if you have any questions.