CGF journal

Observations and thoughts from Committee for Green Foothills.

Monday, December 14

"Extinct" native plant rediscovered in San Francisco

While extinction is forever, rediscovery can be the one reprieve:
A San Francisco native plant thought extinct by botanists has been discovered near the Golden Gate Bridge.

The last, wild Franciscan Manzanita was believed to have perished in the 1940s when the city cemeteries where it grew were moved south to allow for neighborhood expansion.

But when construction crews recently cleared eucalyptus trees in the city's Presidio area, it exposed the only specimen known to exist in the wild.

While it appears that cultured varieties of the plant have been kept alive in nurseries, it's even better to have non-domesticated, wild individuals to re-establish the plant in its habitat.


Good news for the beginning of the week.

-Brian

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Monday, September 7

CGF Comments on Admin Draft County Habitat Plan

(Below are CGF's comments on the Santa Clara County Habitat Plan's Second Administrative Draft. They're imported from an Excel file so may be hard to understand the context, bu the first number refers to the Draft Chapter number (e.g., Chapter 9), and further numbers if any refer to chapter sections (9.2.1) and/or page numbers in a particular chapter (page 9-27). Then the comment follows. -Brian)

9 There is a systematic problem with Chapter 9 failing to distinguish between funding for enhancement and funding for impact mitigation. For example,.page 9-7 discusses the possibility of donated lands to reduce costs. Any sophisticated donor will require the donation be used for enhancement only. Funding partners such as the Open Space Authority and non-profits will similarly limit their contribution to enhancement components only. Whether the budget is sufficient to pay for mitigation is unclear, and needs a separate accounting for mitigation and funding for enhancement.

9 3.2 45 Open Space Authority section should contain language similar to County Parks language, that the value of the OSA contribution can be used only to offset OSA impacts and to provide environmental enhancement.

9 3.2 9-44 Committee for Green Foothills and other environmental organizations do not support using Parks Charter fund acquisitions to offset mitigations that would otherwise be required of County Roads and Airports. We note that this is an unstable source of funding as it expires in 2021 and environmental organizations that have supported the Parks Charter fund will oppose use of parkland to mitigate road and airport impacts at the time of reauthorization. Furthermore, County Supervisors approved use of Parks funding for road mitigation in 2008 by a 3-2 vote which indicate the close margin could be reversed by a future Board of Supervisors. At a minimum, therefore, the Habitat Plan should discuss what funding sources would be used in case Parks Charter fund acquisitions cannot be used for Roads and Airports mitigation.

9 3.2 9-44 Amount of land and monies from Park Charter fund for land acquisition are based on historical acquisition rates and the 2003 Strategic Plan, but the 2006 reauthorization reduced the percentage required to be spent on acquisition. I don't know if the 2003 Strategic Plan anticipated this reduction, but if not, the "conservative" estimates need to be reworked.

9 Costs of mitigation of impacts should be identified separately from the costs of environmental enhancements

9 Costs to mitigate impacts caused by each permittee should be identified for each permittee

9 Costs to mitigate impacts caused by private development operating under the authority of each permittee should be identified as separate total amounts for each permittee (separate from the costs to mitigate that permittee's impacts). If costs exceed development impact fees, that excess cost should be identified.

9 9.1 9-1 "Adaptive management" should be reinserted as a bullet point, either independently or together with "remedial measures"

9 9.2.2 9-7 fn 5 The best use of sites with haz mat present may be as wildlife habitat. Suggest changing to "will not be added to the Habitat Plan Reserve System IF CLEANUP WOULD BE LEGALLY REQUIRED."

9 9.2.11 9-56 Creation of an endowment fund from cost savings over estimated Plan costs should be mandatory until and unless a funding plan for costs in perpetuity has been approved by DFG, USFWS, and NMFS.

9 9.2.11 9-56 One of the conditions of approval of the Plan should be acceptance of the post-Permit funding plan by the wildlife agencies.

9 general All cost savings over estimated Plan costs should be used for adaptive management or for an endowment fund for permanent reserve management. No fees should be reduced until a permanent funding plan for reserve management has been approved by wildlife agencies.

8 8.6 8-24 Draft says Stay-Ahead "will only apply two years after the last local ordinance takes effect." A time-certain deadline is needed or delays in local ordinances could postpone Stay-Ahead indefinitely. We suggest three years from Habitat Plan approval and permit issuance.

8 8.6.1 to 8.6.2 8-28 The "Jump Start" provision conflicts with the Stay-Ahead concept unless the baseline for measuring Stay-Ahead starts at the same time as Jump-Start, in October 2005. Failing to do so means the negative impacts of since 2005 are ignored while positive enhancements are counted, and a false impression of net benefit created. If this is rejected, planners should indicate what degree of uncompensated impact degradation is expected between October 2005 and plan issuance.

4 4.2 4-2 There is a conceptual gap between the definition of "permanent" and "temporary" impacts, because temporary impacts are defined as lasting less than three years. "Permanent" impacts should be defined as "impacts that permanently, OR FOR MORE THAN THREE YEARS, remove or alter a land cover...."

5 Table 5-14 and elsewhere I may have missed where the Plan discusses mitigating for temporary impacts, but fn1 to Table 5-14 states impact estimates are based on permanent impacts only. Temporary impacts also require mitigation. We suggest mitigation should at a minimum be dependent on the amount of time of impact in relation to the permit term, so that a one-year impact requires zt leasts 1/50th the mitigation of a permanent impact.

4 4.4.1 4-44 parcels "anticipated to be permitted by the time of Plan implementation" and excluded from impact analysis provides no context for analysis and could be extremely large. Only previously-identified interim projects that are still under consideration (thereby excluding the now-withdrawn Coyote Valley Specific Plan) should fit this category. Absent such a change, there should be identifying information about what parcels and projects form part of this category.

4 4.4.1 4-44 Regarding permitted parcels and anticipated permitted parcels, there should be clarification that because these parcels are excluded from impact analysis, these parcels and any future permits issued are not covered by the Habitat Plan and take permits. This discusssion should specifically reference the Coyote Valley Research Park (note this is not the Coyote Valley Specific Plan) and any potential reauthorization permits for the Research Park.

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Thursday, July 9

News roundup

Haven't done one of these in a while:

Home Buyers Are Drawn to Nearby Organic Farms - more evidence that urban edge agriculture has a niche:

Increasingly, subdivisions, usually master-planned developments at which buyers
buy home sites or raw land, have been treating farms as an amenity. “There are
currently at least 200 projects that include agriculture as a key community
component,” said
Ed McMahon, a senior fellow with the Urban Land Institute.


Careful though - the technique could be used as an excuse for sprawl, saving only a part of a farm while dividing the rest up in subdivisions.

Controlled Burn Planned - good use of prescribed fire:

The burn is similar to four others that have occurred since 1998 at Russian
Ridge, a 1,978-acre preserve known for its wildflowers and raptors, such as
red-tail hawks. The goal is to reduce overall fire risk by removing dead and
dying brush and grasses under controlled conditions. Controlled burns also can
limit the spread of non-native weeds and other invasive vegetation that choke
out native plants, thus providing more food and habitat for native wildlife as
well as improving spring wildflower displays.


Big plans for a little butterfly - endangered species reintroduction:

A team of researchers is proposing reintroducing a vanished butterfly
to the hills above Stanford University, a biological experiment with both
promise and peril.


If the experiment succeeds, it would return Bay checkerspot
butterflies to Jasper Ridge Biological Preserve and offer important lessons to
the fledgling science of species reintroduction, which aims to save thousands of
plants and animals from extinction.


No guarantee it will work, but the risk - losing a small number of butterflies - may well be worth it. We'll watch this with a lot of interest.

-Brian

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Tuesday, September 16

Opposing the Bush Administration attempt to weaken the Endangered Species Act

We sent out an Urgent Alert to supporters over the weekend, asking them to contact the Bush Administration and announce their opposition to proposed rules that would weaken the Endangered Species Act. We contacted the Interior Department as well, and wrote the following.

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.



Below is a copy of the Urgent Alert:

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.

What's Happening

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:

http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=09000064806c5826

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:

http://action.sierraclub.org/site/PageServer?pagename=ProtecttheEndangeredSpeciesAct

Thanks for speaking up for our coastal wetlands and environmental protections! Your voice does make a difference!

- The folks at Committee for Green Foothills

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Monday, June 4

Ten of the most endangered charismatic megafauna

Scientific American has a nice post and slideshow about ten endangered animals that may go extinct in the next 10 years. They all are found outside of the US (except for the leatherback turtle that occasionally enters US waters) and so the Endangered Species Act does relatively little to help them. Still it might indicate something about the ESA that no domestic species is shown.

It might indicate something else about the ESA and about the slideshow that the animals are charismatic megafauna. Species that are less charismatic, like endangered mussel species, have done less well, because they get less attention.

Our area has its share of endangered species. We like the term "charismatic microfauna" for the federally-threatened Bay checkerspot butterfly, and we're working hard to protect it.

-Brian

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