The following was forwarded to us by a sharp eyed dog and park advocate
who has taken the time to study this entire Natural Areas Program:
There is a HUGE mistake in the Environmental
Impact Report (EIR) for the Natural Areas Program (NAP), which will fundamentally alter the publics perception of the EIR.
I first informed you of the publication of the Environmental Impact Report IEIR) for the Natural Areas Program (NAP) I also
said that the EIR considers the Maximum Restoration Alternative the Environmentally Superior Alternative. The Maximum Restoration
Alternative proposes an aggressive expansion of the NAP that will destroy more trees, require more herbicide use, close more
trails and other recreational access, and permit NAP to plant legally protected species that could require more restrictions
in the future. When I told you about this proposed expansion of the program, I was reporting what the EIR says on page 2 in
the Summary of the EIR because I hadnt yet read the entire document.
The statement on page 2 is wrong. The Maximum
Restoration Alternative is NOT the Environmentally Superior Alternative. The Environmentally Superior Alternative is the Maintenance
Alternative. The correct statement does not appear in the EIR until the very end of the document:
The Maximum Recreation
and Maintenance Alternatives are the environmentally superior alternatives because they have fewer unmitigated significant
impacts than either the proposed project or the Maximum Restoration Alternative. Between the Maximum Recreation Alternative
and the Maintenance Alternative, the Maintenance Alternative would be the environmentally superior alternative for two reasons.
While the two alternatives have the same number of significant and unavoidable impacts under CEQA, the Maintenance Alternative
has fewer potential environmental effects than the Maximum Recreation Alternative. First, the Maintenance Alternative would
not create new trails, the construction of which could result in impacts to sensitive habitats and other biological resources.
Second, over time the Maximum Recreation Alternative would result in Natural Areas with less native plant and animal habitat
and a greater amount of nonnative urban forest coverage. The Maintenance Alternative, on the other hand, would preserve the
existing distribution and extent of biological resources, including sensitive habitats. For these reasons, the Maintenance
Alternative is the environmentally superior alternative. (EIR, page 525-526) (emphasis added)
The contradiction between
what appears on page 2 of the EIR and page 526 was pointed out to the staff of the Planning Department responsible for managing
the public comment period and certification of the EIR. That staff member confirmed that the statement on page 2 is wrong
and the statement on page 526 is correct. However, she refused to correct the error until the public comment period is over
and the Final Environmental Impact Report is published.
Unfortunately, this mistake and the refusal to correct it before
the public comment period is complete will jeopardize the fairness of the process. Native plant advocates are already recruiting
their speakers for the public hearing by the Planning Commission on October 6, 2011, and the written comments which are due
on October 17, 2011. They are urging their supporters to advocate for the Maximum Restoration Alternative and they are incorrectly
informing them that this is the Environmentally Superior Alternative. I have no reason to believe that they are aware of the
mistake on page 2 of the EIR. They are probably sincere in their belief that the Maximum Restoration Alternative is the Environmentally
Superior Alternative. Few readers are likely to read the entire EIR and will therefore be unaware of the mistake on page 2.
mistake will mislead the public into supporting the Maximum Restoration Alternative that expands the destructive and restrictive
aspects of the Natural Areas Program. Furthermore, and perhaps more importantly, this expansion is NOT legal because it violates
the requirements of the California Environmental Quality Act (CEQA), which requires that the Environmentally Superior Alternative
have the least negative impact on the environment of all proposed alternatives:
21002. APPROVAL OF PROJECTS; FEASIBLE
ALTERNATIVE OR MITIGATION MEASURES
The Legislature finds and declares that it is the policy of the state that public
agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available
which would be substantially lessen the significant environmental effects of such projects, and that the procedures required
by this division are intended to assist public agencies in systematically identifying both the significant effects of proposed
projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant
effects. CEQA Guidelines, page 2 (emphasis added)
This is a huge mistake which could profoundly prejudice the public
to support the Maximum Restoration Alternative that proposes an expansion of the Natural Areas Program. One wonders
Who wrote page 2 of the EIR, which incorrectly identifies the Maximum Restoration Alternative as the Environmentally Superior
Alternative and why?
· Why does the Planning Department refuse to correct this error before the public comment is complete?
inform the Planning Commission at their public hearing on October 6, 2011, of this error and write by the deadline of October
17, 2011, in support of the Maintenance Alternative which will do less damage to the environment than the proposed project
and the other proposed alternatives. Here are the details about the public comment opportunities:
A public hearing
on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City
Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a
recorded message giving a more specific time.)
Public comments will be accepted from August 31, 2011 to 5:00 p.m. on
October 17, 2011. Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning
Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing
will be responded to in a Summary of Comments and Responses document.