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Oct 2, 2011 NAP Dog Play Area Update

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.

When 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.

This 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:


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?

Please 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.