HomeMy WebLinkAbout11/17/2020 Item 11, Christie
Purrington, Teresa
From:Santa Lucia Sierra Club <sierraclub8@gmail.com>
Sent:Monday, November 16, 2020 3:30 PM
To:E-mail Council Website
Subject:RE: 11/17/20 Consent Agenda: AUTHORIZE A TEMPORARY EXTENSION OF OPEN
SPACE EVENING HOURS OF USE PILOT PROGRAM
RE: 11/17/20 Consent Agenda item: AUTHORIZE A TEMPORARY EXTENSION OF OPEN SPACE
EVENING HOURS OF USE PILOT PROGRAM
Dear Councilmembers,
In the item before you, both recommended actions assume a third season of the two-year pilot program minus a
key requirement of the council’s approval of the two-year program. For this reason, both recommended actions
should be rejected.
Per the staff report, you originally “directed staff to bring back an approach for Council consideration that
would allow for limited, site specific expanded hours of use, including the possibility of a pilot program that
would allow for additional data to be collected and the ability to scale back down, if needed.… \[A\]t the
conclusion of the pilot program, staff will prepare a summary report of the pilot program for Council’s
consideration, and at that time would seek further guidance based on the levels of use during the pilot program
and evaluation of the data collected.”
But, as noted, “Staff have not yet had time or the opportunity to prioritize the preparation of a concluding two
year summary report due to the onset of the COVID-19 pandemic.”
That is a good reason why the report has not been done. It is not a good reason to add another season to a pilot
program without the report that you are supposed to have in hand at this time and an ability to evaluate the data.
Lacking that report, you cannot know if you should “scale back down if needed,” nor if you should extend the
program for an additional season.
Staff notes that “Written public comments received into the record in advance of the October 24, 2017 hearing
included concerns that it is problematic to conclude that potentially significant impacts in the area of Biological
Resources could be mitigated to less than significant levels when our review of pertinent scientific literature
found that the “extent and severity of those impacts is unknown.” To address this concern, a new mitigation
measure, BIO- 4, was introduced to limit visits to the Reserve to existing average daily baseline levels of 65
individuals during the expanded hours of use.” \[emphasis added.\]
This raises two concerns, the first being the implication that mitigation measures can be deemed sufficient with
no evidence that they are actually effective and have worked as intended. Second, the primary issue raised when
this project was proposed in 2017 was based not just on the additional number of individuals who would be
making use of the city’s natural preserves, but on the extension of the disturbance of wildlife from daylight into
nighttime hours. Among the most crucial data the pilot program should provide is the impact of its disturbance
of nocturnal wildlife, as well as the impact on diurnal wildlife that may have long since altered their behavior to
avoid human contact during the day, now further encroached upon at night.
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In short, the pilot program has concluded, but staff have not prepared the required report that would allow the
Council to give “further guidance based on the levels of use during the pilot program and evaluation of the data
collected.”
In light of this fact, we suggest that you direct staff to take no further action on the pilot program and return to
the Council next year to seek further direction based on an analysis of the program’s impact on wildlife and
habitat, per your authorization of the program, at such time as that information is available.
Thank you for your attention to this issue,
Andrew Christie, Director
Santa Lucia Chapter of the Sierra Club
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