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6a-c) (1) Met w.

Strozier- earlier input to CPC, BCC


Because we do not have a written document from our meeting with Consensus
Planning, we are including the following 2 earlier submissions to the CPC, one email
exchange with (then) Commissioner Wayne Johnson, and one Albuquerque article
that summarizes many remaining Santolina issues

To: Joe Chavez, Chair and members 3/22/2014


Bernalillo County Planning Commission

From: Paul Lusk


former Principal Planner, County of Bernalillo and City of Albuquerque (combined), 1969-78
Emeritus Professor of Architecture and Planning, School of Arch. and Plng., UNM, 1976-2002

RE: Proposed Santolina Master Plan and Level A Plan submission,


Review of Land Use, Density, Transportation, Water Supply, Drainage Strategy

Overview
The Santolina Master Plan, Level A Plan, should be denied. It does not fit the land, the cultural
setting, or the changing times. Despite the fluent planning jargon of the text, it would be,
essentially, a very large suburban development, with predominantly traditional land use areas,
separated from the City of Albuquerque, but dependent upon a significant extension of utility
systems and services from the existing Metropolitan Area. Unless or until an appropriate-scaled,
ecologically and economically superior alternative is presented, it should not be approved.

The Santolina Plan document, in more than one location, states that it is needed due to the lack of
developable space in the adopted Development Areas east of the West Mesa. This is not true.
A detailed study (200’ scale aerials, plus field reconnaissance) undertaken during the
development of the Comprehensive Plan showed sufficient capacity (at similar to adjacent
densities) for a population over one million within the adopted, utility-served or committed
Development Areas. Even with the population growth since, there would be capacity for 3 to 4
times the projected build-out population of Santolina. We “got space.” We may not have water.

It would appear that one motive for the Santolina Plan may well be expressed in the last
paragraph on page 17: “Property tax rates shall recognize the use of the land as agricultural until
such time as a Level C Plan … has been approved and vertical development occurs on an individual
final plated parcel or tract. The adoption of the Master Plan or subsequent Level B or C plan
approvals shall not be considered as a change in land use or agricultural status of the property for
tax purposes.“ What that says is: grant the high-density PC zone now; keep the Greenbelt Grazing
tax status until construction would begin. This area has been in Greenbelt Grazing tax status for
over 40 years. This long period of tax forbearance, without any payback requirement, does not
seem equitable to present or future taxpayers.

Further, the requirement in the CompPlan (Sect. II-11, Policy a), that “planned communities shall
not be a net expense to local governments”, is in the plural. The positive cost/benefit figures in the
Fiscal Impact Report (DTA, Exhibits A & B), however, show only costs and benefits to Bernalillo
County, and is based on the ultimate build-out (as of 2060) projections. They also appear not to
include external, induced costs, such as State funding for I-40 Interchanges and major arterials,
the Water Use Authority’s additional costs for trunk and reservoir capacity outside of the project
boundaries, or the City of Albuquerque’s increased costs for widening of connecting arterials, and
for the many additional departmental costs for additional services. These would be paid for,
largely, by the same taxpayers -- and would be a tax burden for many years before the projected
revenues would be realized.

This development, as presently proposed, is not needed; sufficient capacity for growth, including
the proposed industrial performances identified, exists in the utility-served and committed
Development Areas of the Comprehensive Plan. The development also incorrectly claims
excessive density; it would be located on a highly erodible area of large sand dunes; it proposes an
exorbitant level of water use; and would increase aquifer depletion in the Rio Grande Basin. The
document also does not present a carrying capacity analysis.

For Albuquerque and the surrounding metropolitan area to ‘live long and prosper’ in the 21st century,
our citizens must make careful and smart decisions about growth and change involving land use,
transportation, water supply, drainage and their related infrastructure systems. Accordingly, our
political representatives, as well as professional staff, the building community and, indeed, all members
of our community must look at the changing conditions of this new century and respond in a way that
looks at the greatest benefit to the entire community, not just one part at a time.

Review of Land Use, Density, Water and Transportation

Land Use
The proposed Santolina Master Plan and the Level ‘A’ Plan, as submitted Aug. 21, 2013, however,
appears to represent what was called (back in the 20th century) a ‘wallpaper design’. It is, essentially, a
2-dimensional diagram of colored areas and lines referencing roads, with very little relationship to the
land that it would cover, or to the special culture and unique place in which it is located. It could be
anywhere. The written portions of the Plan are very smooth and, although some good, contemporary
buzzwords are used multiple times in the text descriptions, such as ’sustainable, multiuse areas, sense
of place, vibrant,’ etc., there is little evidence in the large, separated, single-use, colored areas of the
maps or text that these words are actually ‘grounded’ in this place or in this time.

For example, this entire area, with the exception of some headway-eroding arroyos on the eastern edge,
is characterized by very lightly vegetated, longitudinal sand dunes. They are from 5 to 15 feet high,
with many over a mile long (“Map showing present and potential sources of blowing sand in the La
Mesita Negra SE Quadrangle, Bernalillo County, New Mexico”, USGS Library Call Number: M(200) MF
no. 600, Centennial Library, UNM). They are Sahara-like, wave-formation dunes laid down more than
10,000 years ago by strong N/S winds. If disturbed, they are highly subject to wind erosion by the
present era’s predominantly westerly winds. The evidence of up-slope, west-edge dune depositing, the
down-slope, lightly-vegetated, east-slope sand dunes, as well as the crests of the many longitudinal
dunes between, are graphically shown on the referenced USGS map. (They also can be seen as the long,
grey, nearly E/W shadow lines on the aerial photo in Exhibit 2, pg. 14, of the Santolina M.P. proposal.)

The relevance here is that this area is NOT the NE Heights. The long, westerly slope of the NE Heights,
and much of the SE Heights, are underlain by larger-grain, predominantly water-deposited sand-and-
gravel-based soils from the more rapid erosion of the face of the Sandias. The Heights also have a high-
yielding aquifer beneath and are well suited for urban development. To seek to replicate this density of
development on this ancient, very-fine-grained, wind-deposited peneplain (and with a low-yielding,
poor-quality, and very deep aquifer beneath) would be an exorbitantly expensive and environmentally
risky effort. One reason for this is that to achieve such density on this portion of the West Mesa would
require leveling and grading-out thousands of acres of sand dunes. This would be needed to achieve
the dendritic drainage pattern, as used in the Heights, for the densities proposed in the Santolina Plan.
This would add significantly to lot-development cost as well as require an inordinate amount of soil
amendments (and water) to minimize soil loss and blowing sand. Pumping from the Rio Grande aquifer
for such a project is discussed below in the comments on ‘Water’.

Density
The 13,700-acre Santolina Master Plan proposes an ultimate build-out of 37,930 dwelling units with a
population of ~ 95,000 people. This would be larger than the present City of Santa Fe (2012 pop.
69,204). The A/BC Comprehensive Plan, however, requires a ‘carrying capacity analysis’ of each
planned community area (Section II, pg. 12, Policy b). We found no mention of this requirement, or
evidence from the maps and text of the Level A document, that the ‘carrying capacity’ for a development
of this magnitude in this location was considered, or could be met.

There also is a serious problem with the assumptions about allowable density in the development
proposal and, indeed, in the (now) text of the Comprehensive Plan. In the original A/BC CompPlan, as
adopted in 1975, the five development areas were defined by a range of allowable residential densities
(1-3 du/ac within the Semi-Urban, 3-6 du/ac within Developing Urban, etc.). In the process of review
and up-dating of CompPlan in 1985-87, there was vigorous discussion within the appointed ‘study
group’ as to whether this definition of residential density was meant to be ‘net residential’ (buildable
house lots), or ‘gross residential’ density (includes streets, neighborhood parks, etc.). The faction
favoring ‘gross residential’ prevailed. In practice, this would allow a ~25-30% bonus increase in
density. It is also a lot easier to plot and calculate. Evidently, though, this determination, when it was
printed in the 1988 version of the CompPlan, was written as ‘Gross Density’ -- the word ‘residential’
was perhaps assumed, but left out. This was an error.

The 2002 and 2012 versions of the Comprehensive Plan, apparently, have carried forward this mistake,
allowing misinterpretation, or opportunistic or intentional exploitation of this error. The common
sense evidence of this is, for example, if a developer submits a ‘multiple use’ plan of, say, 100 acres, 90
acres industrial, 10 acres residential, he cannot claim the right for 30 du/ac on the remaining 10 acres
(or if 99 acres industrial, 300 units on the remaining acre). I believe that this error has occurred in the
Santolina proposal, where 13,700 acres of diverse, multiple uses are claimed as the justification for
37,930 du’s. Although regrettable, I believe, that the intent to define allowable RESIDENTIAL densities
is clear from the earlier documents, and that a typographical error or omission would not be legally
actionable.

Additionally, the 2000+ acre blue-colored, industrial area in the far western portion of the Santolina
M.P. is a ghost of the 20th century, and is patently inappropriate on many levels. It seems to be located
there, not just because its neighboring uses are not compatible with the adjacent 6600-acre residential
area but, rather, to be able to claim the 75,000 (‘over 2 jobs per household’) job count. This is a very
expensive and job-distant location for such a concentrated, single use area. First, because of the 5000-
Gallons Per Acre per Day (Commercial, Light Industrial), up to the 10,000 ‘GPAD’ water demand by the
‘heavy industrial uses’ (Santolina Water Master Plan, p. 12), it is inappropriately located and would be
very expensive to service. Second, there already are more industrial or heavy commercial zoned large
acreage areas that are available within the existing metro area, with utilities in the ground or
committed, such as in the north and south I-25 corridor -- many with rail access, and in the I-40 area
below the West Mesa escarpment, west of the Rio Grande.

Water
Water is probably the pre-eminent factor in the determination of the existence or viability of, or if
so, the scale of development on this arid, wind-blown, high-desert mesa. Should it be a new, urban
“shining city on the hill” (and, perhaps, the first area to be abandoned if there is a long-term, or
increasing level of drought)? Or should it be a different model of 21st century development: a
moderate density cluster of carefully sited, plaza-centered villages, surrounding a shared
Community Center and providing an option for many of our young people who now might choose
to leave our State for creative opportunities elsewhere. It also could be seen as an opportunity for
many people from other areas who may be looking for environmentally sensitive, creative or
entrepreneurial opportunities in this rapidly changing century?

The water-use implications of these options are quite stark. The Santolina Water Master Plan, at
build-out (Table 3, page 12), shows that the “Average Day Water Use by Zone” (total) would be
19.66 Million Gallons per Day. On page 14, though, the M.P. states: “Under the Ultimate scenario
Santolina will have a total demand/capacity of 38.7 million gallons per day.” That capacity would
be ~43,350 acre feet/year. If fully used, it also would average of over 400 gallons per person per
day. If this were so, this 13,780-acre area would use (the equivalent of) about 90% of the total San
Juan/Chama water diversion (allocated, not guaranteed) for the entire City of Albuquerque. It
might be assumed that Albuquerque also would grow during this time period. The implications to
drawdown of the aquifer within the existing utility-served or committed (and adopted)
Development Areas of Albuquerque, or the de-watering of wells in the North and South Valleys are
more than can be addressed here.

Transportation
Due to the length of this document, I won’t address the shortcomings of the transportation issues
here. Rather, I would suggest the Commission, the Staff and all interested citizens check out:
< http://www.vtpi.org/CGOP_LOS.pdf >
A key point, though, in this context is: rather than LOS (Level of Service) which is primarily
vehicle-focused, to use QOS (Quality of Service) as the measure and guide for design.
As currently projected, the transportation patterns would have a major impact in the South Valley
and all major east-west corridors on and south of I-40.

Viable Alternative(s) to Development on the SW Mesa


The 20th century is over. One of the long-dominant patterns of 20th century development, though,
involved the strategy of building on more distant, often lower-cost land with the goal of optimizing
development profit and, when possible, to transfer much of the burden of utility extensions and
services to the public, often through G.O. bonds. The resulting pattern of catch-up, back-fill
development was often characterized by the unflattering but not inaccurate term ‘sprawl’.

To continue these 20th century patterns for growth, development patterns and building methods, I
believe, would put us at a competitive disadvantage in relation to other Southwestern metropolitan
areas. The unfolding evidence in this early portion of the 21st century regarding water availability,
changing patterns of weather and energy strategies, as well as building and financing methods, requires
that a more holistic, entire-community-based strategy should inform the vision of our collective well-
being, and our identity, as a Unique and Great place to live in the Southwest!

It is our view that an appropriately scaled development IS possible on this portion of the West Mesa. It
even could be ‘sustainable’, include ‘multiuse areas’, be rooted in a ‘sense of place’, and actually ‘be
vibrant’. For example, it might be anchored by a Community Center (as defined in the Comprehensive
Plan), not an urban center, and be surrounded by unique and diverse Villages, not by over 6600 acres of
wall-to-wall, green-lawn, drive-to-work housing that might be hard to distinguish from any other
suburban development. The Community Center, though, should be adjacent to the primary arterial
serving this area, rather than cut in half by a multi-lane, limited-access arterial.
The Villages actually would be physically separate, located on the high-ground areas of the natural
landform. They would require only a minimum of land grading, and that grading would be configured
in such a way as to capture, direct and infiltrate the rainfall runoff created by the hardscape portions of
the development. It might even capture the purified, constructed-wetland-treated wastewater from
each Village to provide nutrients to sustain the low-flow drainways. The Villages might take their
form(s) from the truly unique, indigenous building strategies of this area: the historic Pueblos and the
early Hispanic settlement patterns of New Mexico.

‘Sense of place’ does not mean copying some superficial details, such as fake viga ends sticking out of a
stucco wall. Rather, it suggests recognizing the climate-protecting, security-increasing, common-space
and micro-climate-creating, as well as the community-sharing effects of two-to-three story structures
surrounding and forming a shared interior space, or plaza. The Villages also would have adjacent
additional housing and service and workspaces. The dance-ceremony spaces of indigenous Pueblos, or
the historic Plazas of Santa Fe and Albuquerque’s Old Town are not just cute, or photogenic or tourist-
draws. They are Fundamental. Indeed, these Villages can be work-live places that are ‘Unique and
Great places to live in the Southwest’ -- in the 21st century! The 1st industrial age is over. It got out-
sourced. These can be prototypes of the 2nd industrial age, fueled by brainpower, creativity and with
technology as the industry, and with a great view of the mountains.

The Cluster/Village concept, of course, doesn’t yet have such specific numbers. The guiding
principles, though, would be: (first option) Sufficient deep-wells within each Village, and the
Community Center (if tests and yields allowed), for treatable–to-potable water for all users.
Greywater would be cleaned in constructed-wetlands, purified and returned through vegetated,
just-off-contour drainways to the existing, low-gradient arroyos. All arroyos would be stepped,
using vegetated filter-dams, to reduce volume and velocity, and to infiltrate, at minimum, the
equivalent of the 100-year design storm. The requirement for not impairing downstream users
would not pertain because (with the exception of Amole arroyo), at present, most runoff in the
down–slope areas is absorbed before reaching users (except where vehicle tracks, or other
disturbances, have caused deep, fast, erosive cutting). Again, this area is not the Heights, which
has, in some arroyos, more than 4-6,000 cubic feet per second flows out of the Sandias during
major storms. The arroyos here, on the West Mesa, are low-flow, low gradient and, with proper
design, the range of a few hundred cubic feet per second flows easily can be absorbed.

Option two would be: If the well yields were not sufficient or water-quality not appropriate, then
to use water from the A/BC Water Utility Authority, but at a much lower volume, and with the
requirement that the equivalent of all water pumped (calculation for storm water would be
included) must be infiltrated and returned to the aquifer.

Development on the West Mesa is possible, but only if it recognizes that to be truly ‘sustainable’, it
must adapt to the rapidly changing patterns of climate, available water resources, economic
conditions and social preferences of the 21st century.

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