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The NAP EIR
THE NAP EIR
At the end of August 2011, the SF Planning Department released an Environmental Impact Review for the Significant Natural Resource Area Program Management Plan (NAP EIR) of the SF Recreation and Park Department (RPD). The Natural Areas Program (NAP) was established in 1995 to preserve the few existing remnants of San Francisco's natural habitat. Over the years, it has grown considerably and now claims over one-quarter of all San Francisco city-controlled parkland, with natural areas in 31 parks in San Francisco plus Sharp Park in Pacifica.
In 2006, the San Francisco Recreation and Park Commission approved a Management Plan for NAP. This massive plan provides detailed information about the existing conditions in each natural area, and describes how NAP will manage each area – what plants will be planted, which trees will be cut down, where trails will be closed or added, where dogs will no longer be allowed off-leash, and where access for everyone will be restricted.
The NAP EIR analyzes the environmental impact of the 2006 NAP Management Plan. It also analyzes the environmental impacts of four alternative plans. But unlike the GGNRA's Environmental Impact Statement for a new Dog Management Plan, issued earlier in 2011, the NAP EIR does not use the environmental analysis to select a Preferred Alternative for a Management Plan. Instead, the NAP EIR looks at the impacts of the NAP Management Plan and considers the alternatives as a way to consider that Management Plan in the context of other possible ways the property could be managed. It’s not really appropriate to consider any of the alternatives to be the “preferred” one. The purpose of the NAP EIR is to analyze the impacts of an already-agreed-upon plan, and to consider ways to mitigate those impacts, if possible.
The alternatives reviewed are:
1) The Project Alternative – This analyzes the environmental impacts of the 2006 NAP Management Plan.
2) The No Project Alternative – This analyzes the environmental impacts if the 2006 NAP Management Plan is not implemented, but the current NAP management plan, devised in 1995, is continued. Habitat restoration and tree removal would likely be less than in the Project Alternative. Fewer trails would be closed, but no new trails would be created. No off-leash areas would need to be closed or reduced in size. Ultimately, the natural areas would likely end up looking very similar to those managed under the Project Alternative, but the scale of restoration would be smaller.
3) The Maximum Restoration Alternative – This analyzes the environmental impacts of a management plan that would convert non-native to native habitat wherever possible throughout each natural area. This alternative would remove the 2006 Management Plan’s idea of dividing each natural area into three zones with different management strategies for each one, from the most sensitive zone with extensive habitat restoration, to a least sensitive zone with little restoration. The Maximum Restoration Alternative would manage the entire natural area as if it was the most sensitive habitat. It would prioritize the planting of endangered species in natural areas, and would result in closures of more trails, closures of much more off-leash space (up to 80% of the total currently available), and the cutting down of many more trees. It would significantly reduce public access to the natural areas.
4) The Maximum Recreation Alternative – This analyzes the environmental impacts of a management plan that focuses habitat restoration only in the most sensitive parts of each natural area, and would improve recreational access in the rest of each natural area. This Alternative would include substantially less tree and vegetation removal than the Project Alternative. There would be no closure or reduction in off-leash space. Multi-use trails would be added (accessible to mountain bikes, horses, and dogs), as would playgrounds and picnic areas.
5) The Maintenance Alternative – This analyzes the environmental impacts of a management plan that maintains the current distribution of native and non-native species throughout each natural area. There would be no conversion of non-native to native habitats, but maintenance of existing native habitats would continue as is today. This Alternative would include less vegetation and tree removal, and would not result in the closure or reduction of any off-leash space. No trails would be removed, but no new ones would be created.
The NAP EIR identifies the Maintenance Alternative as the Environmentally Superior Alternative because it results in the least amount of damage to the existing environment (less vegetation and tree removal, etc.), while preserving existing native habitat.
The Planning Department is taking public comments on the NAP EIR until the close of business (5 pm) on Monday, October 31, 2011.
Comments can be emailed to:
Or snail mailed (or dropped off in person) to:
Bill Wycko, Environmental Review Officer
SF Planning Department
1650 Mission St, Suite 400
San Francisco, CA 94103