HomeMy WebLinkAbout10-04-2017 Public Comment - multiple authorsREC IV[ --D
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Date: September 30, 2017
To: The Parks and Recreation Commission
Subject: Draft project plan for the PARKS & RECREATION ELEMENT UPDATE
(and Master Plan)
Hearing Date: October 4, 2017
Dear Honorable Members of the Parks & Recreation Commission,
INTRODUCTION: NATURAL RESOURCE PROTECTION ADVOCATES AND
NEIGHBORHOODS ADJACENT TO OPEN SPACE ARE VERY CONCERNED THAT THE
LINE BETWEEN PARK & RECREATION AND OPEN SPACE IS BEING BLURRED BY THE
PROCESS THAT YOUR COMMISSION IS BEING ASKED TO TAKE.
WE HAVE VERY SPECIFIC RECOMMENDATIONS ON PAGES 3 and 4 THAT ADDRESS
THIS ISSUE.
Before getting to them, we want to give you a brief overview of the City Policy context
regarding the difference between PARK AND RECREATION and OPEN SPACE. It is
important that your Commission has read and understood the City's general plan 2006
OPEN SPACE ELEMENT. In case you have not had the opportunity to do that, we are
offering you a short overview and how it is different from the City's PARKS & RECREATION
ELEMENT.
IT IS FUNDAMENTALLY IMPORTANT TO RECOGNIZE THAT OPEN SPACE/ NATURAL
RESERVES and PARKS/ PARKS FACILITIES ARE DIFFERENT. HERE ARE
DIFFERENCES:
1.OPEN SPACE/ NATURAL RESERVES:
The State of California mandates that all cities adopt a general plan OPEN SPACE
ELEMENT. In San Luis Obispo this is the general plan "2006 CONSERVATION AND
OPEN SPACE ELEMENT" (2(06 "COSE").
"OPEN SPACE" is a land use designation. "This designation provides for land or water
areas that remain in predominantly natural or undeveloped state....". (2014 Land Use
Element, General Plan, City of San Luis Obispo). "NATURAL RESERVES" are
combined, contiguous OPEN SPACE LANDS, such as "The Bishop Peak Natural
Reserve".
THE PRIMARY PURPOSE of OPEN SPACE/ NATURAL RESERVES IS PROTECTION
OF NATURAL RESOURCES. (2006, "COSE") (footnote #1) The City's "1998 Open
Space Ordinance" additionally has specific wildlife, wildlife habitat, and other natural
resource protections.
"Lands acquired or otherwise controlled by the city for OPEN SPACE purposes are NOT
considered to be PARKS..." (1998 OPEN SPACE ORDINANCE,) OPEN SPACE/NATURAL
RESERVES are also NOT "Parks Facilities"
NATURAL RESOURCE MANAGER: The state -mandated and adopted 2006
CONSERVATION AND OPEN SPACE ELEMENT states this general plan program, "The
City will take the following action to protect Open Space:... maintain the position of
Natural Resources Manager so that Open Space functions are consolidated in one
existing City department under one person".
All City Councils since the creation of this Natural Resource Manager position have kept it
in Administration not in Parks and Recreation to insure that Open Space is not subsumed
by the Parks and Recreation Department.
2. "PARK" & "RECREATION"
"PARK" & "RECREATION" are land use designations, but the State does not require a
general plan "Parks and Recreation Element". It is optional and therefore secondary to
required elements.
The " Parks" land use designation "provides for public park facilities" and the
"Recreation" designation provides for "outdoor recreational facilities". (2014 LAND USE
ELEMENT)
"CITY RECREATION FACILITIES consist of mini -parks, neighborhood parks, community
parks, joint use sites (such as school playgrounds) non -joint use sites, recreation centers
and special facilities, including: Jack House, Swim Center, Senior Center, Recreation
Center, golf Course, historic adobes, and community gardens." (2001 PARKS &
RECREATION ELEMENT, City of San Luis Obispo) Note that "OPEN SPACE" is not a
"CITY RECREATION FACILITIES".
The primary purpose of "Parks" "Recreation" and "CITY RECREATION FACILITIES" is
recreation.
The above functions are under the direction of the Parks and Recreation Department
Director.
This is the proposed draft project plan for an update of the 2001 PARKS and
RECREATION ELEMENT not the subsequently adopted 2006 CONSERVATION and
OPEN SPACE ELEMENT.
PARKS & RECREATION COMMISSION PURVIEW: "The Parks & Recreation
Commission purview is to review and make recommendations for changes which
could have an impact on the City's parks and park facilities". (Project Plan for
PARKS AND RECREATION ELEMENT UPDATE (and Master Plan), Agenda Report, page 1,
paragraph 3)
3. CITIZEN PRIORITIES & THE 2014 LAND USE & CIRCULATION ELEMENTS
The massive City survey of all City residents which began the 2014 LAND USE &
CIRCULATION ELEMENTS UPDATE affirmed with more than 2,200 detailed written
responses that the highest priorities of City residents are to have more PROTECTION OF
OPEN SPACE and the only thing that they were personally willing to pay more for was
PROTECTION OF OPEN SPACE.
When City residents were subsequently asked to tax themselves through 2014 Measure G,
"Open Space Preservation" was the first funding priority listed on the Measure G Ballot. It
passed.
4. PUBLIC NOTICE:
THIS PROPOSED DRAFT PROJECT PLAN for "THE UPDATE OF THE PARKS &
RECREATION GENERAL PLAN ELEMENT (and master plan)" has been given PUBLIC
NOTICE as a proposed plan to "UPDATE THE PARKS & RECREATION ELEMENT (and
master plan)". This is also the "AGENDA SUBJECT" and the subject of the one page
"STAFF AGENDA REPORT". The words "OPEN SPACE" or "NATURAL RESERVES" are
never mentioned in any of these. It is only in the highly unlikely event that the general
public reads the "attachment to the Staff Agenda Report" that it becomes apparent
that this proposed plan significantly and improperly ranges into "OPEN SPACE"
issues. (footnote #2)
We support the request to update the PARKS & RECREATION ELEMENT IF it
does not attempt to improperly infringe upon and create OPEN SPACE/NATURAL
RESERVE GOALS, POLICIES, OR PROGRAMS. OPEN SPACE/NATURAL RESERVE
GOALS, POLICIES, OR PROGRAMS RESIDE PROPERLY IN THE STATE -MANDATED,
AND ADOPTED "2006 CONSERVATION AND OPEN SPACE ELEMENT".
THEREFORE; WE VERY STRONGLY REQUEST THAT THE PARKS AND RECREATION
COMMISSION RECOMMEND TO CITY COUNCIL THAT STAFF BE GIVEN THE
FOLLOWING DIRECTION:
1. The focus of this "PLAN FOR THE UPDATE OF THE 2001 PARKS AND RECREATION
ELEMENT" shall properly be "City parks and park facilities" and recreation associated
with them.
2. The UPDATE OF THE 2001 PARKS & RECREATION ELEMENT shall be consistent
with the goals, policies and programs of the City's subsequently adopted,
state -mandated 2006 CONSERVATION & OPEN SPACE ELEMENT. "Intending to be
consistent" with the 2006 CONSERVATION AND OPEN SPACE ELEMENT is NOT a
commitment. It is a weaker statement that, in reality, means very little. (see Staff Agenda
Report Attachment, pg. 2-3]
3. g."lgaislatiy-e-d=. QLQcess" shall be used to update the 2001 Parks & Recreation
Element so that all citizens are able to see clearly in one document throughout the update
process what changes, deletions, and additions are being proposed to the existing 2001
Parks & Recreation Element. At Council direction, this "legislative draft process" was used
in the 2014 UPDATES OF THE LAND USE & CIRCULATION ELEMENTS.
4. The m000sed Parks &_ Recreation Element update shall be primarily resident -based.
"Stakeholders" are often not City residents, and do not have to live with the impacts of the
updated Parks & Recreation Element (and master plan).
(FOOTNOTE #3
5. All surveys and questionnaires , including the proposed "on-line", "intercept", and
"community needs assessment" surveys and questionnaires shall pose questions that are
consistent with the state -mandated and adopted 2006 CONSERVATION AND OPEN
SPACE ELEMENT and with the existing wildlife, wildlife habitat and other natural resource
protections in the City's Municipal Code, OPEN SPACE ORDINANCE.
6. There shall be early and meaningful public consideration in this draft plan for the
concept of one or more creative, new, large parks as the City continues to expand.
These large parks could accommodate and support RECREATIONAL ACTIVITIES that
may have some level of public support, but which would degrade wildlife, their habitats
and other protected natural resources and/or create conflicts with neighborhoods if
attempted to be "retrofitted " into the City's established and protected NATURAL
RESERVES/ OPEN SPACES. Such RECREATIONAL ACTIVITIES might include
motorized mountain bikes, large group events, competitions or gatherings, large off -leash
dog areas, barbeques and significant nighttime hours of use; etc.. Such activities are
illegal in the City's NATURAL RESERVES/ OPEN SPACES because they degrade the
wildlife, wildlife habitats and other natural resources being protected AND may create
conflicts with neighborhoods.
These creative new large parks would also have the large advantage of being able to
incorporate landform changes, a variety of "built structures", lighting and paving. All of
these are NOT allowed in NATURAL RESERVES/ OPEN SPACE. Large, tourist -based
events, gatherings and competitions, which are illegal in NATURAL RESERVES/OPEN
SPACE, could also be held in these large parks and could raise significant funding for
them.
AS OUR CITY BECOMES MORE URBANIZED AND DENSELY DEVELOPED, THE
MEANINGFUL "PROTECTION OF OUR NATURAL RESERVES/ OPEN SPACE", A
HIGHEST PRIORITY OF CITY RESIDENTS, BECOMES EVER MORE IMPORTANT.
(footnote #4)
RESPECTFULLY SUBMITTED,
David Blakely, former County Supervisor representing the City of San Luis Obispo
Dr. Richard Krejsa, Emeritus professor of Biological Sciences
ECOSLO Co-Founder
Jan Marx, former Mayor of the City of San Luis Obispo
Former County Parks and Recreation Commissioner
Christine Mulholland, Executive Committee Member, Santa Lucia Chapter of Sierra Club,
Former City Councilmember
Kurt Kupper, ECOSLO, former Executive Director
Chairman, City's Environmental Quality Task Force
Former County Supervisor
Peg Pinard, former Mayor of the City of San Luis Obispo
Kathy Smith, former City Council Member
James apRoberts
Janice Elliott
Keith Elliott
Gail Karacsony
Alison Haupt
Gail Karacsony
Winona Smyth
Leslie Stanley
Kathy apRoberts
Peter Karacsony
Jim Smith
James F. Hall
Gina Hafemeister
Mary Kay Eltzroth
Cheryl McLean
Tom Eltzroth
Jimmy apRoberts, CEO / Co-Founder Subplot Studio
Carol F. Hall
Jan Smith
James R. Hall
Harry Busselen
Felicia Cashin
Carla Saunders
Jack Cashin
Dave Hafemeister
Dan Blanke
FOOTNOTES:
PREFACE: GENERAL PLANS, ORDINANCE, MASTER PLANS, STRATEGIC PLANS,
etc.:
City Ordinances, Master Plans, Strategic Plans, etc. are legally required to be consistent
with the City's General Plan. It is also required that there be consistency between
General Plan Elements. Some General Plan Elements are state -mandated, such as an
OPEN SPACE ELEMENT, and some elements are a only optional, such as a PARKS &
RECREATION ELEMENT. Some elements are also more current then others. For instance,
the state -mandated 2006 OPEN SPACE ELEMENT is more current than the previousy
adopted, 2001 PARKS & RECREATION ELEMENT.
FOOTNOTE #1. The 2006 CONSERVATION AND OPEN SPACE ELEMENT states
that the primarypurpose of NATURAL RESERVES/ OPEN SPACE is protection of natural
resources, including wildlife and their habitats. A secondarypu_r o�se of NATURAL
RESERVES/ OPEN SPACE is specified types of "passive" recreation that may be
permitted in designated areas of NATURAL RESERVES/ OPEN SPACE IF this passive
recreation does not degrade the natural resources being protected or create conflicts with
neighborhoods. (2006 CONSERVATION OF OPEN SPACE ELEMENT, including "Appendix
C, The Management of Open Space Lands")
PUBLIC NOTICE & PUBLIC PROCESS FOOTNOTES:
FOOTNOTE #2. Neighborhoods adjacent to NATURAL RESERVES, such as the Bishop
Peak/Ferrini Heights neighborhoods, and the City's major environmental organizations ,
The Sierra Club and ECOSLO were very disappointed when they were not given
meaningful public notice, and therefore the opportunity to participate in the recent, eleven
month "2020 Parks and Recreation Strategic Plan" process even though it contained very
significant specific goals and objectives for NATURAL RESERVES/OPEN SPACE. To
quote the Mayor at the City Council hearing, "I do think there was not enough specific
involvement by the environmental groups, the Natural Resources Roundtable, and the
neighborhoods around the trailheads. If you look at the title of this plan, it's the PARK &
RECREATION STRATEGIC PLAN, and if 1 were an OPEN SPACE advocate—really
interested in OPEN SPACE ---- I might not, looking at the notice of the PARKS AND
RECREATION STRATEGIC PLAN, even imagine that it did include OPEN SPACE. "
It is therefore, very disappointing that this same, inadequate public notice process has
apparently been chosen to inform the public of this "Draft project plan for the PARKS AND
RECREATION ELEMENT UPDATE (and master plan)". The public notice of this proposed
plan has even greater impacts, as approval of this plan sets the course and largely
influences the outcome of this General Plan update.
At the initial Parks and Recreation Commission hearing on this draft, public input
consisted of only one "agenda correspondence" and only one "public comment", and
they were both about parks ( the omission of a park in the north Broad neighborhood and
information on the formation of "Friends of SLO City Dog Parks")
FOOTNOTE # 3. We are disappointed that the process being proposed for this update of
The 2001 PARKS & RECREATION ELEMENT is fundamentally less "Citizen- based" than
the public process used in the City's recent updates of the general plan 2014 LAND USE
and CIRCULATION ELEMENTS. The proposed update process for the 2001 PARKS AND
RECREATION ELEMENT eliminates both the central role of a Council -appointed "resident
General Plan Task Force from diverse geographic areas of the City" and their series of
many publicly noticed public meetings specifically dedicated to public input gathering
and discussion , with recorded votes of the Citizen's Task Force on the individual issues.
FOOTNOTE #4. The proposed directions to staff would also provide increasingly needed
assurance to generous donors of NATURAL RESERVE/ OPEN SPACE lands and funding
that the City will continue in good faith to ensure the continuance of meaningful
protections of these lands, their wildlife, wildlife habitats, and other natural resources.