Local Coastal Plan Public Comment from Fred Allebach

Fred Allebach
9/14/15

Local Coastal Plan Public Comment
PRMD-LCP-Update@sonoma-county.org

My comment is of a general nature and has to do with how you are integrating academic/ scientific sustainability concepts into your plans.

I went through your glossary looking for how you included concepts for sustainability and found the overall sense to be weighted too heavily to economy, growth and development.

Your definition of sustainability equals exactly one sentence from the 1989 UN Agenda 21 definition, “That which meets our current needs without compromising the ability of future generations to meet their needs.”

What is missing here policy-wise, for starters, is a definition of the Triple Bottom Line, Full or True Cost Accounting, Carbon Footprint, Food Miles, Ecosystem Services and Systems Literacy.

My sense from your glossary is that PRMD tacitly presumes that economic values outweigh all other values and that sustainable means economically sustainable. From your definition, sustainable could be spun to mean only economic needs even if such needs were actually unsustainable for society and the environment.

A full definition of sustainability for PRMD and the Local Coastal Plan seems in order, especially for such a diverse and key area as the Sonoma Coast. Sustainability is an earth systems concept having to do with human activity and resource use at the planet level and the negative effects that our aggregate carbon emissions have on the atmosphere and on life itself. This is where sustainable conversation and policy work should be focused, wide net and systemically. If your plan were to adhere to an actual sustainable framework, you have to address what the full carbon footprint of all activities is. Otherwise it is just talk.

You do introduce some sustainable concepts in the glossary under indicators and smart growth, but this is a back door way to demonstrate your systems literacy and knowledge of sustainability.

With indicators you touch on what the Triple Bottom Line (TBL) is but do not explicitly say it. The TBL is like a policy stool with three legs, economy, society, environment; each leg has to have integrity and be in proportion to the others or the stool will fall, i.e. be unsustainable.

The smart growth PRMD definition: Development that is environmentally sensitive, economically viable, community-oriented, and sustainable.
These goals are reached through planning that incorporates the following principles:
(1) Encourage infill development of urbanized communities
(2) Create range of housing opportunities and choices
(3) Encourage compact building design
(4) Protect agriculture and open space
(5) Create walkable neighborhoods
(6) Enable choice in transportation modes that are integrated and consistent with land use objectives
(7) Create fair and equitable rules for development.

You start to open up the TBL but again, seem to define sustainable as not more than about economic development. Yes, PRMD is about planning and economic sphere development, but it also oversees resource management, and resources are: the environment and society as well. Ecosystem services should be a prominent feature of this coastal planning discussion.

What I’d like to see is for you to integrate actual sustainable principles into your glossary and then begin to work with such concepts in this Local Coastal Plan and in general. This will serve PRMD well also in the area of groundwater management, for example, where the number of well permits issued, to be sustainable, has to take into account if resources are being diminished at an unsustainable rate.

My comment: bone up on your sustainability studies. Sustainable is not just a word or something to be spun to be politically correct; this is a serious global issue. We in the Bay Area can become world leaders on this issue but in order to do that, we have to take it seriously and that can start with improving the glossary so that it reflects what academic, scientific definitions of sustainability really are.

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