Brookhaven Guidance Package comment letter, Dec. 11, 2007
The Merced County Board of Supervisors voted not to approve this project, one more attempt in the county to turn small farm villages into upscale commuter labor camps. For this act of sanity we probably have the foreclosure crisis to thank. However, the letter below lays out the arguments against this kind of project well. --eds.
December 11, 2007
Merced County Board of Supervisors
2222 M Street, 3rd Floor
Merced, CA 95340
Re: The Brookhaven Guidance Package/Public Hearing December 11, 2007
Via: Hand Delivered
Dear Members of the Board,
There are eight compelling reasons why you should reject the Brookhaven Guidance Package:
1) This is a proposal in search of a need: Depending on the week, Merced County is currently 1, 2, or 3 for subprime lending foreclosures. We also hold the distinction of leading the nation in providing unaffordable housing for our demographic profile.
Creating affordable housing for Bay Area commuters is not the same as creating affordable housing for folks who attempt to live and work in this community: hence the embarrassing, national distinction. Finally, according to experts from the Building Industry Association – the inventory of homes in Merced County will take at least three years to absorb – and then only after the current slump is over. Assuming the same (unprecedented) flurry of speculation that brought us to this crippling point today, this could be a very, very long time. In the best case, BIA (Land of Oz) scenario – five years at a bare minimum to absorb the current inventory (not including pre-approved developments in the pipeline) while assuming the best of markets. Alternatively, economists further away from the Valley estimate fifteen to twenty years for us to fully recover and to fully absorb our current housing surplus. We trust that Merced County has finally learned the painful lesson that building more residential housing developments is not tantamount to bolstering economic development in the county; in point of fact, it is an inverse relationship.
2) So, what is the rush? The County and the City of Los Banos are currently in the process of updating their General Plans. Whether a phased in operation or not there is simply no need to support a proposal that leaps in front of two relevant policy directives that will certainly arrive well before a need to build more homes.
3) Compact Growth? Improved revenue sharing agreements, not prospecting on an additional 396 acres for 253 unneeded homes in unincorporated Merced County is not in sync with our current General Plan. Combined with the recent approval for the Turlock Golf and Country Club, the county is creating islands of urban growth on productive farm lands and open spaces – contravening the clearly stated goals in our current General Plan (Land Use Chapter,Objective 1.A: Compact urban development boundaries which utilize land efficiently and reduce conflicts with agricultural and open space lands).
4) A Guidance Package Isn’t Simply A Study: It is the first approval to invest thousands upon thousands of dollars in a project. Moreover, as part of this package “study” what constitutes Volta’s current SUDP is expanded. The investment in time, money, and advancing the concept of an expanded growth boundary in turn provides the rationale for future approvals. There is a built in momentum which cannot be denied.
5) Volta’s infrastructure issues will not be solved by more houses: Whether or not the area of Volta needs a Community Plan or a better way to arrange its infrastructure for water and sewer with a reconfigured service district is a separate issue from deciding whether or not to approve this guidance package. Moreover, simply requiring developers to study a problem is not tantamount to fixing it or to collecting the fees that represent the cumulative impacts on our already severely impacted roads, water supply, air, ag and open space. As recent as last week, a Merced County developer successfully petitioned the Merced City Planning Commission to delay road repairs – a condition for approval of this project. This should be reason enough to pause. Finally, BIA representatives have publicly cried foul when other communities and this county in particular has attempted to collect fees for impacts that were created and yet not paid for during the housing boom – at a time when –literally -- billions were made in this county by private interests. Yet, Merced County residents are stuck with empty houses and rapidly deteriorating road systems.
6) Listen to the Community: Although the Volta community does not have a MAC, according to staff, 40 people showed up to a meeting to discuss this issue in a community that does not exceed several hundred. Respect their comments. They do not see the need, but they clearly anticipate the impacts.
7) The Williamson Act Preserve: Not only does land contracted through the Williamson Act need to be considered in land use decisions, but lands within The Preserve require special consideration. I quote from Christopher J. Butcher of the University of California at Davis from The Forgotten Intent of the Williamson Act, where he used Merced County as one of his case studies: “By incorporating land into an agricultural preserve, new procedural hurdles are attached to development of the land and additional restrictions are placed on the government and landowner’s entitlement for use.” (page 48).
8) This Guidance Package Obfuscates Rather Than Clarifies: This particular guidance package earns an “A” for exceeding vagueness or an “F” for meeting its own objectives. According to the consultants preparing this proposal:
The purpose of this Guidance Package is to clarify the project goals and milestones and establish both the expectations and responsibilities of all participants. This document will accomplish this by clarifying the relationships and roles of various participants in the planning process and the expectations and parameters of their individual efforts.
One cannot read this and fully comprehend what is being proposed.
In closing, we don’t need this project. Careful consideration of any one of these points should be sufficient to reject this project – it doesn’t meet Volta’s needs or those of the county.
Thank you for your consideration.
Sincerely,
Maureen McCorry
on behalf of Valley Land Alliance, et., al
P.O. Box 158
Planada, CA 95365