HomeMy WebLinkAbout3/16/2021 Item 12, Santa Lucia Chapter of the Sierra Club
Wilbanks, Megan
From:Santa Lucia Sierra Club <
To:E-mail Council Website
Subject:RE: 3/16/22 meeting, Item 12: Open Space Winter Evening Hours
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Dear Councilmembers,
Last November, when your council was considering authorizing an extension of the open space evening hours
of use pilot program, we noted that, 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 the report 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.”
Then as now, the lack of the summary report that you were supposed to have in hand and an inability to
evaluate the data meant you could not know if you should extend the program or “scale back down if needed.”
Staff wrote at the time: “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 raised the concern that mitigation measures are being deemed sufficient with no evidence that they are
actually effective and have worked as intended, and a lack of awareness that the primary issue raised when this
project was proposed 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 have provided and evaluated was the impact on
nocturnal wildlife, as well as the impact on diurnal wildlife that may have altered their behavior patterns to
avoid human contact during the day, now further encroached upon at night.
In short, by November 2020 the pilot program had concluded but staff had not prepared the required wildlife
survey and report that would have allowed the Council to give “further guidance based on the levels of use
during the pilot program and evaluation of the data collected.”
That study is again lacking in the item before you. The current staff report indicates that the cause of its absence
appears to be the unanticipated drain on resources that this project has imposed upon the City. We again point
out that you should direct staff to provide a thorough analysis of the program’s impact on wildlife and habitat,
as per your authorization of the program. If acquiring that essential information would represent an additional,
unsustainable drain on City resources, the program should be suspended.
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Thank you for this opportunity to comment,
Andrew Christie, Director
Santa Lucia Chapter of the Sierra Club
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