Why County Parkland Shouldn't Be Considered Mitigation for County Road Impacts
Observations and thoughts from Committee for Green Foothills.
The Committee for Green Foothills represents over a thousand families in Santa Clara and San Mateo Counties in its mission of protecting open space and natural resources in those counties. We at the Committee oppose the proposed revisions to Section 7 consultations. These revisions will reduce the use of valuable expertise and bias evaluation of endangered species impacts against their actual import, as the action agencies will be inclined to downplay environmental impacts. For the above reasons, we oppose the proposed rule revisions.
The endangered species of the Bay Area and of the rest of the country need your help. In its last months in office, the Bush Administration proposes to dramatically weaken the Endangered Species Act by letting federal agencies considering actions that harm species avoid consultation and oversight from with expert wildlife agencies. This reverses 30 years of federal regulation designed to restrain federal agencies whose mission and political culture is focused on other things besides protecting species. Please use the website below to submit a comment opposing the proposed changes. Comments must be submitted by Monday, September 15, to be considered.
The Interior Department has proposed the change to limit "Section 7" consultations between federal agencies considering an action ("action agencies") and the expert wildlife agencies (the Fish and Wildlife Service and the National Marine Fisheries Service).
Why This is Important
Contrary to Administration claims, the action agencies do not have the same level of expertise about effects on endangered species as the wildlife agencies. In addition, the action agencies inevitably prioritize achieving their main missions over endangered species so they will often interpret evidence in such a way as to reduce its significance. Locking out the agencies with the most expertise and the most interest in protecting species will mean more species will fall through the cracks.
What You Can Do
In another change to previous policy, the Interior Department refuses to accept emailed comments on its proposed rule, but it will accept comments submitted on a government website. Tell them you oppose the proposed new rule and that the Endangered Species Act should be strengthened, not weakened.
To submit the comments, click on this link:
You will need to fill out the submitter information at the top of the web page, and then at the bottom of the page you can inform them of your comment opposing the proposed rule.
For more information, see the Sierra Club's Take Action webpage:
Thanks for speaking up for our coastal wetlands and environmental protections! Your voice does make a difference!
- The folks at Committee for Green Foothills
Reasons why the Roads Fund, not the Parks Charter Fund, should pay for roads impacts
1. Parks Fund meant to be a net benefit, but used as a mitigation means the environment is no better off
2. Better management principle is to reduce cross-subsidies, in this case using Parks funding to subsidize road development.
3. Using Parks funding may interfere with the future selection of parkland in order to maximize mitigation of roads impacts.
Parks Dept. pays for park impacts
Roads Dept. pays for road impacts
Parks can purchase recreational use on lands bought by Roads Dept.
Parks Charter Fund not meant for roads
On Tuesday, the Santa Clara County Board of Supervisors decided to pilfer $14 million from the Santa Clara County Parks Charter funds to pay for non-park-related expenses. This is a dangerous precedent and goes against the will of the voters. The Parks Charter Fund was passed specifically by the voters, since 1972, to set aside funds to buy and maintain county parks and nothing else. But the supervisors (Pete McHugh, Don Gage and Ken Yeager - for; Blanca Alvarado and Liz Kniss - against) decided to use those funds to pay for obligations incurred by the county roads department to meet their mitigation obligation under the proposed county habitat plan. This is irresponsible, and the decision should be rescinded immediately.
Member, Stakeholders Group Santa Clara Valley Habitat Conservation Plan/Natural Community Conservation Plan