San Mateo Local Agency Formation Commission
c/o Martha Poyatos, Executive Officer
455 County Center
Redwood City, CA 94063
April 7, 2008

Subject: Comments on Half Moon Bay and Midcoast Municipal Service Review Draft

Honorable Commissioners:

Thank you for the opportunity to comment on the March 18, 2008 Municipal Service Review Draft (“Draft”) for Half Moon Bay and the unincorporated Midcoast prepared by Matrix Consulting Group. Coastside Community First is a nonprofit, non-partisan 501(c)(3) public benefit corporation founded in 2006 to promote the best overall long-term interests of our community. One of our emphases is to encourage the improvement of local public services and infrastructure.

LAFCo’s central mandate is to ensure the logical and orderly formation of local agencies, in particular special districts. It is instructive to note that LAFCo’s creation did not precede the  statewide development of special districts and local agencies; instead, LAFCo was created decades after hundreds of special districts and local agencies had proliferated, many times in an illogical and disorderly fashion. In other words, LAFCo was created largely to bring order after-the-fact to often chaotic and inefficient pre-existing local government.

The Municipal Service Review Draft offers an accurate and detailed description of the Coastside’s inefficient local government structure – developed over decades in a piecemeal, excessively localized fashion – precisely the sort of patchwork that LAFCo was created to remedy. Just last year our two local fire districts were rightly consolidated to improve and streamline an essential public service.

The recommendations below are based on the following principles:

•Our local special utility districts – water and sewer – are too small and balkanized. This has resulted in an absence of economies of scale, competing directorships and bureaucracies, a consequent lack of cooperation between utility districts, and a narrow ‘turf’ perspective on the management of scarce, essential resources. Our utility districts should be consolidated and regionalized, a necessity that some or all of the affected districts may tenaciously resist. Single-purpose special districts – especially when providing complicated services such as water or sewer – are more efficient than multi-purpose special districts that attempt to juggle the administration of more than one essential service. So whereas the extent of our local special utility districts should be increased, the purpose of the utililty districts should be simplified and specialized (to provide either water or sewer service, not both).

1. Implement Option 2 (Draft, p. 92), Consolidating Half Moon Bay and Midcoast Sanitary Service into One Special District.

As the Draft describes, the Sewer Authority Mid-Coastside (SAM), a joint powers authority, handles all wastewater treatment for our area. Granada Sanitary District (GSD) and Montara Water & Sanitary District (MWSD) are primarily “pass-through” agencies, who contract out their sewerage-related work. Eliminating GSD and MWSD as sanitary districts and transforming SAM from a joint powers authority to a special district would achieve economies of scale and minimize bureaucracy. Also, solid waste services could then be unified and competitively bid, potentially lowering consumer costs.

SAM’s board of directors, in a newly constituted special district, could be elected district-wide, but perhaps with  a requirement that two of the five directors reside in  Half Moon Bay, and two in  the unincorporated Midcoast. A fifth director, who could reside anywhere in  the district, would be elected as an at-large member. The sole at-large position might be for a two-year term, with the other directors elected for four-year terms.

2.  Implement Option 3 (Draft, p. 93), Consolidating Half Moon Bay and Midcoast Water Service into One Special District.

Consolidation of Coastside County Water District (CCWD) and Montara Water & Sanitary District into one special water district is the most important and urgent improvement that LAFCo can make to our local government structure.  Our water situation is dire: not only have there been no water connections available in MWSD’s service area for over two decades, MWSD is unprepared for either a drought or conflagration. As the Draft documents, MWSD has only 700,000 gallons of storage capacity available to fight fires or endure a drought. CCWD stores over 8,000,000 gallons of water, more than eleven times MWSD’s storage capacity.

MWSD’s financial and organizational burdens – its bond debt, aging infrastructure, and lack of adequate water capacity and storage – create an ongoing public safety concern that consolidation would predictably ameliorate.  The Draft documents that CCWD has the proven ability to repair and replace aging lines at a rapid rate, and deliver water service at generally much lower rates than MWSD. The Draft also points out the mutual benefits of an intertie between the two water systems.  An additional intertie with  Pacifica’s North Coast County Water District (NCCWD) at the Devil’s Slide tunnel, most easily achieved during the next three years of tunnel construction, would complete the loop, providing access to Hetch Hetchy water from both Pacifica and Crystal Springs.

Consolidation would also provide economies of scale, reduction of bureaucracies, and reduced need for administrative facilities. MWSD could sell its historic oceanfront headquarters, adjacent to the Montara Lighthouse, to a public agency for recreational use, a purpose long envisioned by  the County’s Local Coastal Program for the unincorporated Midcoast. The building  might also double as a community center. Proceeds from the sale could be used to pay down and accelerate MWSD’s bond debt. The consolidated district could then use CCWD’s Half Moon Bay offices, and retain CCWD’s name for the consolidated special district, since a “Coastside County” water district accurately describes the regionalized nature of the consolidated district.

Analogous to the consolidated sewerage district as described above, a consolidated water district could have a board of directors that are elected district-wide, but with a requirement that two of the five directors reside in Half Moon Bay, and two in the unincorporated Midcoast. A fifth director, who could reside anywhere in the district, could be elected as the sole at-large member. Again like the sewerage district, the at-large position could be for two years, with the other four directors elected to four year terms.

3. Table Option 5 (Draft, p. 94), Annexation of the Unincorporated Midcoast to Half Moon Bay.

There is an undeniable attractiveness and logic to the idea of Half Moon Bay and the unincorporated Midcoast becoming one municipality. The problem – which cannot be overstated – is that given recent events in Half Moon Bay (whose effects will play out for a number of years), annexation of the unincorporated Midcoast is a political non-starter. For the foreseeable future, any attempt at annexation would likely run into a breathtaking buzzsaw from the residents of the unincorporated Midcoast.

That is not to say that the two halves of our community cannot be eventually coaxed into the same tent, and the first two recommendations above are designed to give residents of Half Moon Bay and the unincorporated Midcoast the transitional experience of working together to achieve important goals, such as improved, regionalized water and sewer service. The intervening years would also allow Half Moon Bay the opportunity to heal its present wounds, and work to establish a stable, successful magnet for the unincorporated Midcoast. As the Draft emphasizes, Half Moon Bay should also be encouraged to integrate services with the County where desirable, including the possible contracting of police services to the County Sheriff’s Department.

4. Reject Option 1 (Draft, p. 88), Creation of a Community Services District.

A community services district that bundles “a full range of services including parks and recreation, streetlights, water and wastewater utilities, solid waste collection, etc.” into one local agency, is a dangerous and unrealistic option for the unincorporated Midcoast. It would complicate the delivery of public services, which instead needs to be simplified and specialized. While other communities may have succeeded with this approach, our community, with its history and political culture, could not be expected to manage a broad range of services through one district.

It is more likely that a bundled and overburdened district would break down bureaucratically under the complexity, causing public services to suffer simultaneously on a number of fronts. Imagine a typical evening district meeting, with a number of agenda items on water, a few more on sewerage issues,  then more agenda items on parks and recreation, streetlights, solid waste, and so on. As a community we are simply unprepared to shoulder that level of organization and responsibility.

A community services district for the unincorporated Midcoast would also not achieve the desired regionalism, especially with respect to water and sewerage services. This would complicate relations with Half Moon Bay, possibly creating walls where we need bridges. For example, if the community services district included only the unincorporated Midcoast, would CCWD then shrink to include only areas within Half Moon Bay? How would it be compensated for its lost infrastructure? Our community at present is bifurcated between incorporated and unincorporated segments: a bundled special district in the unincorporated Midcoast would have the predictable effect of exacerbating the divisons between the two halves.

5.  Do Not Restructure the Delivery of Roads, Streetlights, and Parks and Recreation Services.

Concerning roads and road maintenance, the Draft describes a perpetual shortfall of funding for road improvements for both the County and Half Moon Bay, with few opportunities to make up that shortfall, due to the non-enterprise (i.e., non-revenue-generating) nature of this public service. Unless we entertain the possibility of charging tolls over 92 or through the new Devil’s Slide tunnel, the few opportunities for cost containment involve increased cooperation between the County and Half Moon Bay (for example, in joint invitations to bid contracts).

Street lighting, another non-enterprise service, is being handled effectively by both the County and Half Moon Bay, and does not require any changes in governmental structure.

The provision of Parks and Recreation services is an instance where the County can take a page or two from Half Moon Bay, which is rightly praised by the Draft for its joint use agreements with area schools and Pillar Point Harbor. The County does not have joint use agreements with the two schools in the unincorporated Midcoast, although they have an impressive list of playground facilities (Draft, p. 21), however dilapidated. A joint use agreement between the County Parks Department and those schools could provide funding to improve and expand the playground facilities, while ensuring the general public access to enhanced active parkland on the unincorporated Midcoast. Although the Draft explains that the County Parks Department’s mission is to provide “regional passive recreation opportunities, and not for providing park and recreation services comparable to those of Half Moon Bay,” the department does currently spend County money on maintenance of the neighborhood Quarry Park in El Granada. That is not a qualitatively different mission from providing the funding to improve school playground facilities, to which the general public is then guaranteed access.

As we all know, most studies do not lead to significant changes in public policy. They gather dust on a shelf. It is Coastside Community First’s hope that this very capable Municipal Service Review Draft, which frankly recognizes the need to reorganize and consolidate our local government structures, will be used as a basis for action.  In particular we underscore the need to ensure public safety through near-term improvements to our water situation: by substantially increasing water storage and capacity, and by creating system interties, both between CCWD and MWSD, and with NCCWD at the new tunnel.

Respectfully submitted,



Charles Gardner, CCF President