Felton Pump Track: Wrong Location
Dear Honorable Members of the Board of Supervisors,
I am writing about the subject proposal, which is scheduled to be heard on your Consent Agenda on Tuesday, December 12th, 2023.
It is a fine proposal, but it is proposed for the WRONG LOCATION! I support parks, I support recreation, and I support such a proposal for a location outside of the FEMA-mapped 100-year floodplain and floodway.
1) This is a controversial matter. It should be pulled from the Consent Agenda by your Board, and a public hearing should be scheduled for a future meeting of the Board of Supervisors, on this subject. Alternatively, the County Parks Department could withdraw the proposal and look for a more appropriate location.
2) Floodplain and floodway construction proposals are complex engineering matters. I do not believe that the Parks Department is receiving solid engineering advice about this proposal. It is an attractive proposal to the County Parks Department administration due to the proposed donation of construction and maintenance, but overall it could be very unattractive to the County if the construction of a pump track in violation of FEMA flood plain and floodway rules caused increased financial liability, due to a future increase in flooding. A future increase in flooding from this proposal seems very likely, regardless of the unproven assertions of the CEQA document and the staff report.
*****
| CODE OF FEDERAL REGULATIONS: CFR 60.3(c)(10) states that until a regulatory floodway is designated:“no new construction, Substantial Improvements, or other development (including fill) shall be permitted within Zones A1-30 and AE unless cumulative effect of the proposed development, when combined with all other existing and anticipated development, will not increase the water surface elevation of the base flood more than one foot at any point within the community.”Once FEMA has mapped a floodway, then no development in the floodway can cause increases to the BFE.*****(BFE = Base Flood Elevation. The 100-year flood plain and floodway appears to have been mapped by FEMA for this location.)***** |
That should have been the end of the discussion about the proposed pump track at the Covered Bridge County Park. It is the right recreational proposal located in the wrong place.
3) The entire Covered Bridge Park is located within a federally designated and mapped (FEMA) 1% (100-year) flood plain and floodway, as defined in the Code of Federal Regulations, CFR 60.3.
4) No buildings have ever been constructed within the Covered Bridge County Park, due to the 100-year flood plain and floodway designation. This proposed structure would stick up through flood waters, deflecting flood water toward adjacent areas, such as an adjacent gasoline station, the Felton Grove neighborhood, Gail Drive, River Lane, Beth Drive, the Felton Equestrian Center, the Santa Cruz City Inflatable Dam site, the confluence of Zayante Creek and the San Lorenzo River near the parking and contractors yards area adjacent to San Lorenzo Lumber along the river, Covered Bridge Road N and S, several resorts and travel trailer parks downstream, and even the foundation footings of the Covered Bridge itself. Has the City of Santa Cruz Water Department been consulted on this matter? Have all of the other downstream property owners been consulted? (Also, there is no septic tank system there for potential restroom buildings anyway, due to prohibitions by the Central Coast Regional Water Board regarding new on-site sewage disposal systems in 100-year flood plains.)
5) The impact of the proposed pump track on flooding would be the same as that of a installing new building of equivalent footprint and height within the park. So far, no buildings have ever been allowed to be constructed within Covered Bridge Park, due to FEMA regulations.
6) Floods in the San Lorenzo Valley can be caused by rainfall that can occur over as many days as a week or more; however, flooding can continue for days after the rainfall ends, due to the large size of the San Lorenzo River Watershed. The overall watershed, including the Branciforte Creek watershed, is about 138 sq. miles. The watershed above the park elevation is probably about 90 square miles, or so. The drainage basin above the park is a large land area.
7) Simple suggestions like dry wells, or excavating a low area around the proposed pump track equivalent to its volume, in order to accommodate flood flow, are ludicrous since they do not mitigate the entire time period of the flooding, which could be over two weeks in a 100-year storm event, or even in a 50-year storm event. Dry wells would be under water during a flood, and so would an excavated low area. Furthermore, such an excavation would have to be sized equivalent to a two-week flood flow to be meaningful, and that would be a ridiculously huge undertaking not even worth considering. The storm water quality treatment mitigations proposed are for a two-year two-hour storm event, and those mitigations are a design issue unrelated to flooding issues. Balancing cut and fill does not mitigate a flood event for the two weeks of flooding that can occur during a 100-year storm event and the resulting residual flow emanating from the watershed. There are good reasons that FEMA, through the Code of Federal Regulations, prohibits projects that will increase the Base Flood Elevation.
8) This proposal should not be considered as exempt from environmental review under CEQA. The 100-year floodplain and floodway issues alone present a significant environmental impact. The proposed CEQA exemption document is basically untrue with regard to the environmental impact of the proposal on flooding.
9) If the County Board of Supervisors approves this proposal within the 100-year flood plain and floodway, will FEMA refuse to participate or limit participation in recovery of future flooding events made worse by this proposal? Has FEMA been consulted? Will approving this proposal affect the administration of the Federal Flood Insurance program locally?
10) Has the County Counsel’s Office reviewed this proposal, with regard to future flooding liability that the County might assume by approving this proposal?
11) Attached is a County Planning form called a “No-Rise Certificate” (SCCO Form No-Rise Cert 2011) that requires a licensed Engineer (or Engineering Geologist) to sign that:
“…I hereby certify that the attached technical data supports the fact that the proposed
development will not impact the 100-year flood elevations, floodway elevations, or
floodway widths at published sections in the Flood Insurance Study and will not impact the
100-year flood elevations, floodway elevations, or floodway widths at unpublished cross-sections
in the vicinity of the proposed development.
Attached are the following documents that support my findings:
Note: This document must be wet-stamped with the certifier’s appropriate Engineering stamp….”
Does the Parks Department have a qualified expert that will sign such a form? Has the Parks Department developed the technical data to support such a finding?
13) The Covered Bridge Park was designed by the residents of Felton and by renowned architect, Jeff Oberdorfer, with the guidance of the County Planning Department. The design of the park should be governed by both the existing Town Plan and the existing Covered Bridge Park plan, both previously approved by the Planning Commission. No attempt has been made to amend these plans. The planning for this proposal was apparently conducted privately between Parks Department staff and the proponents of the pump truck, for around sixteen months, before the concept was revealed to the public. The planning for this proposal has been flawed, since it ignores the past will of the public, the past guidance of the Planning Department, the Planning Commission approved plans, and the requirements of the Federal Government, namely CFR 60.3(c)10. Copies of the Felton Town Plan and the Covered Bridge Park Master Plan are attached for your review.
Please either schedule a public hearing for this proposal or send it back to the drawing board to find an appropriate site that does not violate FEMA CFR flood plain and flood way regulations.
Thank you.
Stephen D. Homan
Bonny Doon, ca
Santa Cruz County Resident since 1973
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