September 27, 2010
Re: Item 20, Study Session on the County Parks Acquisition Plan – comment for the Study Session and response to the Draft Summary of Public Workshops
Dear President Yeager and Board of Supervisors:
CGF submits the following comments on the County Parks Acquisition Plan as well as some disagreement with the Draft Summary of Public Workshops ("Summary") for the Parks Acquisition Plan. As an initial matter, we thank County Staff
On page 8 of the Summary, the document states there was confusion in the public comments relating to "the appropriateness of using the Park Charter Fund monies to acquire lands for [County Habitat Plan] mitigation not related to the mission of the Parks and Recreation Department." We don't believe this summary captures the point that CGF and others were expressing.
We have two concerns regarding the relationship between the Park Charter Fund and Acquisition Plan on one side, and the County Habitat Plan on the other. First, to the extent that the Park Charter Fund is used to mitigate impacts created by other County government agencies, an environmental benefit that would otherwise accrue to the taxpaying public has been lost. This is because to the extent used as mitigation, the benefit of preserving endangered species habitat will be balanced with an equivalent level of harm caused to endangered species habitat by other County agencies.
Second, the criterion in the draft Acquisition Plan that would support acquiring parkland that fulfills the County Road Department mitigation requirements under the County Habitat Plan (phrased as fulfilling "Valley Habitat Plan Priorities" on Page A-4 of Supp. Info. 1a on the agenda), has the exact negative effect that Committee for Green Foothills predicted three years ago when we opposed this use of Park Charter Fund. We said the effect would be to skew the acquisition process, from the endangered habitat that is most in need of preservation to habitat the Roads Department and other County agencies want purchased. This appears to be happening. We also anticipate that removing the obligation of County agencies to pay for habitat mitigation will also remove their incentive to minimize the impact.
For the above reasons, the Committee for Green Foothills supports an increased emphasis on parkland acquisition that protects endangered habitat, but not one that changes the benefit of increased protection into the neutral value of mitigation that only balances habitat destruction. We request that acquisition emphasize the protection of endangered species habitat that is not needed by other County agencies to mitigate their habitat impacts.
We also request that the Draft Summary be amended to reflect the concerns listed above, concerns that were presented at one of the Public Workshops.
Please contact me with any questions.
Sincerely,
Brian A. Schmidt
Legislative Advocate, Santa Clara County
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