May 6, 2024
Re: Item 1 on the Board Agenda of May 8, 2024: Parking Area Design Guidelines
Dear Board President MacNiven and Midpeninsula Regional Open Space District Board members,
The Santa Clara Valley Audubon Society and the Loma Prieta Chapter of the Sierra Club write this letter to thank the Midpeninsula Regional Open Space District (Midpen) for taking up the topic of parking lot placement and design. The desire to experience and enjoy the beauty of nature is at the root of our organizations’ missions, but as the numbers of visitors in parks and open space grows, it is more essential that we take care to protect the natural environment that draws these visitors.
Midpen's mission is to acquire and preserve a regional greenbelt of open space land in perpetuity, protect and restore the natural environment, and provide opportunities for ecologically sensitive public enjoyment and education. On the San Mateo County Coastside, the mission is expanded: to acquire and preserve agricultural land of regional significance, protect and restore the natural environment, preserve rural character, encourage viable agricultural use of land resources and provide opportunities for ecologically sensitive public enjoyment and education. We appreciate the opportunity to comment on the Parking Area Design Guidelines and offer the following observations that serve as examples of areas we think merit further study and consideration to be consistent with Midpen’s mission as stated above.
The document describes Values, Approach, and Elements (summary on page of the staff report).
- Values:
The Values statement considers “knitting together ecologically sensitive public access with the functional requirements of parking.” Midpen’s mission states “Enjoyment”, not “Access”, and these terms are not the same. Parking, as such, is inconsistent with the mission to “protect and restore the natural environment”, and is not mandated by the desire to “provide opportunities for ecologically sensitive public enjoyment and education”. We ask Midpen to minimize the number of parking lots and their size in nature preserves.
- Approach:
We are disappointed that in the design guiding document, Approach includes only “respects and complements the land’s physical, visual, and cultural integrity” and neglects to specifically consider biological and ecological elements, such as sensitive species and plant communities. Since this set of guidelines will be used during the initial site selection, feasibility study, and conceptual design phases, we fear that for special status species and vulnerable ecological communities, this Approach will result in accepting mitigation instead of prioritizing protection and conservation which is central to Midpen’s Mission. We believe that as stated, this Approach is inconsistent with Midpen’s mission, and with the public trust that the agency will protect our natural environment.
In addition:
- We appreciate the intent to “Respect the Natural Landscape and Cultural Setting”. However, we believe that any Midpen project should, at the very least, provide a net benefit to the biological environment: the fauna and flora on site. Please add a significant habitat enhancement element to the Values statement, and all projects that are subsequently considered.
- Our organizations agree that sustainability is an important and practical consideration in any project design. However, the Values statement on this topic seems to emphasize cost of installation and maintenance, which are not germane to ecological planning. Low-maintenance design elements may minimize long-term maintenance requirements but at the same time harm the biological environment. We believe guidance that ”...financial and staff resource impacts in design choices” again puts priority on cost vs the true value, which can be contradictory to ecologically sensitive access. “Select durable, low-maintenance design elements to minimize long-term maintenance requirements“ should be a second tier consideration, and not equivalent to the others in this section. Parking lot construction and maintenance costs should not be the determinants in siting and design considerations.
Further, in the Maintenance and Operations section it is stated, “Maintainability should be front and center to all decisions made through the design phases...” Again, it is a consideration but the District’s Mission should be front and center rather than maintenance costs.
- Locating parking areas in heavily forested areas should be avoided.
- We are concerned that the table on page 4 (Using the Guidelines—Quick Reference) seems to disregard the importance of the Guidelines Approach Section. It seems that this guidance is eliminated during the Construction and Maintenance phases of projects, even though these are the phases when environmental damage can be introduced in ways that negate any positive siting, design, and environmental elements. The Guidelines even state that design changes may occur at the construction stage.
- It is not clear what environmental documents are considered in the Guidelines because reference is to “environmental protection guidelines”. We believe that to be consistent with Midpen’s mission, the document should provide mandatory standards, not only guidelines.
- We appreciate the sensitivity stated about wildlife movement and habitat protection, including the consideration for culvert crossings. In general, we believe that new roads to parking should not cross waterways. Furthermore, we would like to see thoughtfully adequate minimum setbacks from creeks, ponds, wetlands and other water features as a required design criteria. The reference to such water features is not clearly stated in the document.
- While we are not commenting on the parking lot designs specifically, we note that the experience “in” the parking lot sets a tone for the experience of the preserves themselves. If the parking lots are particularly urban in design, they will surely detract from visitor experience and expectations.
Thank you for your consideration,
Shani Kleinhaus
Environmental Advocate
Santa Clara Valley Audubon Society
Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter