COMMENTARY | COLUMNISTS | CAROLYN CHASE

Here we grow...

Would you move into a skyscraper if you knew the fire department didn't have the hook and ladder equipment required to rescue people from an incident?

Consider a major intersection. If traffic is backing up during every signal cycle, should you add more traffic to that intersection without any infrastructure improvements to absorb the trips?

These are simple concepts related to complex systems and decisions being made in the city -- and the region -- every week. It's common sense and good planning that infrastructure should be required to support projects going in, but common sense is not the standard for most political decisions.

Public testimony at the Planning Commission recently claimed that indeed, the fire equipment downtown was not adequate to service the new skyscrapers going in. Public testimony from the development industry also requested that decision makers reject a proposed requirement that police and fire response times must be able to be met for a project to be approved.

Consider what that means. They want decision makers to vote for projects while acknowledging the projects don't have the infrastructure and public safety equipment and personnel to support them.

Problem is, the projects we're voting on each week have no such finding now, so it's likely we're voting for projects every week where police and fire cannot meet response times or have inadequate equipment.

If you've ever wondered why there's traffic -- or other "cumulative impacts" -- it's because we keep adding growth to the system without funding the infrastructure required to support it.

Traffic is no accident. Decision-makers routinely approve projects adding traffic to overloaded intersections and freeways without either "fair share" payments or even, in many cases, mitigation. State law requires that development not be charged anything above its "fair share," but unfortunately does not establish that they actually need to pay that fair share. The city does not routinely apply fair-share impact fees for the needed infrastructure.

City impact fees are a hodgepodge that varies widely between the "Urbanized Communities" and the "Planned Urbanizing Communities." They have no fees for regional transportation infrastructure -- though most projects come with a comment letter from Caltrans stating, "If traffic impacts from a project are identified as significant, then the Department supports a 'fair share' contribution from the developer for future interchange improvement projects and/or other mitigation measures on state transportation facilities."

What's to be done about this? It may be possible to inject a small amount of sanity by improving the city's review process, which is supposed to identify project impacts from the outset. The city of San Diego is updating its California Environmental Quality Act "Significance Determination Guidelines."

This is the process by which staff is recommending adding a "finding" for projects related to emergency response times. They are also proposing changes to many other areas that undergo environmental review including transportation, parking, air quality, biological resources, growth inducement, noise, solid waste, neighborhood character -- most if not all of the areas that relate to any project's impact on all public infrastructure.

What's all this fuss about significance? When an issue is significant, projects have to mitigate -- i.e., reduce the impacts to below a level of significance. If they claim they are unable to reduce the impacts below the level of significance, then decision-makers can adopt a "Statement of Overriding Considerations" declaring why the project should be approved without dealing with its impacts.

The California Environmental Quality Act, while its costs and benefits are hotly debated, was not designed to stop projects, but to allow the public and decision-makers to be informed about the impacts and give them the power to seek to reduce them -- or, as a last resort, to approve the project anyway.

This was the suggestion from the development industry on how to deal with not being able to meet emergency response times: to adopt Statements of Overriding Considerations, meaning the project goes in even though we know it's going to have unmitigated impacts.

Which brings us back to the issue of how the city defines what a significant impact is. The fact that past and most current growth policies have given rise to "dumb growth" should be apparent by the rising levels of traffic, water pollution and decreasing open space.

What must "smarter growth" be about? Defining significance thresholds rationally and matching appropriate infrastructure with projects. It's fundamentally -- and still theoretically -- the only way to accommodate job/population growth imperatives and still provide acceptable levels of quality of life.


Chase, editor of the San Diego Earth Times, is a planning commissioner and chair of the mayor's Environmental Advisory Board. Comments regarding this column can be sent to editor@sddt.com. All comments are forwarded to the author.

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