March 4, 2008
Suzanne Gautier
Communications and Public Outreach
Public Utilities Commission
City and County of San Francisco
1145 Market Street
San Francisco, CA 94103
Dear
Ms. Gautier:
Our
comments on the presentation at the Lake Merced Watershed Plan Facilitated Work
Group Meeting # 1 meeting of February 14, 2008 at San Francisco Public
Utilities Commission offices are as follows:
1.) It
is our understanding that the subject meeting was not noticed to the entire
membership of the Lake Merced Task Force (LMTF). We received, from others, a
copy of one email from PUC noticing the meeting to a list of specific
individuals, some of whom are members of the LMTF. One of the addressees on
that email was the undersigned Mona Cereghino, our alternate representative to
the LMTF, but the email address was outdated and was never actually received by
Mona Cereghino directly. Ross Wilkinson, our LMTF primary representative, was
not on the list at all. We believe the subject of the meeting was at the very
heart of the interests of the Lake Merced Task Force and email notice should
have been made to "[email protected]"
2.)
We do not believe that it is appropriate to evaluate hypothetical potential uses
of Lake Merced on the same footing with actual current uses. Displacing
longstanding uses would cause harm to people that have used the lake for many
years. That actual harm could be out of proportion to the perceived harm that others
proposing new uses might feel they would incur were their new uses not to be
established. While we are not saying that every current use at the lake is
sacrosanct, PUC's current criteria needs to be changed to consider both the
fairness as well as the cost to current users of eviction from the lake vs. the
potential benefit to others of establishing new uses.
3.)
We do not believe it is rational or appropriate to exclude Harding Park Golf
Course from the evaluation criteria. Doing so is patently discriminatory,
shielding those that play golf at Harding Park from defending their use to the
same standards as everyone else. The land area occupied by the golf course is large
and we understand that that use represents a net loss to the City, which means
that those of us that are excluded from that area nevertheless have to subsidize
the recreation of the golfers, which could include city officials, some of whom
may be interested in excluding the golf club from a balanced and fair
evaluation to their own personal advantage.
4.)
We believe that the San Francisco Police Department gun range should also be
included in the watershed plan. That use is not recreational but it is a use
that is not entirely dependant on its location and, therefore, a use that
should be evaluated against potential competing uses.
5.)
We do not necessarily accept the "Evaluation Criteria for Recreational
Activities" distributed at the meeting as appropriate. For example,
Criterion #3, "complementary/synergy with other uses" includes the
following illustrative questions:
a)
"Does the activity support or encourage participation in other activities
that are or could be present at the lake?"
b)
"Does the activity enrich the experience of other users of the watershed?"
c)
"conversely, would the activity constrain or diminish the experience of
other users at the lake?"
We do
not believe any recreational use needs to be justified on the basis of it "supporting
and encouraging" other uses. We do not believe the rowers (crew), for
example, need to justify their existence by any claim that rowing
"supports or encourages" sailing, fishing, walking or any other use
at the lake. Valid recreational uses may and typically do exist independently.
Criterion
# 4 is titled "Affect [sic] on increasing general public use" and is
illustrated with the following questions:
a) "would
a casual visitor be able to participate in the activity?"
b) "does
the activity appeal to a broad cross-section of San Francisco residents?"
c) "conversely,
does the activity require special equipment, knowledge, or skill?"
We
believe that rowing, sailing, horseshoes and even volleyball would score low on
an evaluation to this criterion because they all require special equipment and
are not necessarily available to the casual visitor. Try telling one of the
rowing clubs you'd like a place in one of their boats. Tell someone who brings
their own volleyball equipment that you want in on the game they organized
using their own equipment. The whole concept of public parklands such as Lake
Merced is that there is sufficient room for multiple activities. Special
equipment for some of the differing activities is a given and is wholly
irrelevant to the question of legitimacy.
6.) Several slides were presented to illustrate
how particular uses stack up against PUC's evaluation criteria. (Copies of only
some of those slides were handed out.) The determinations as to
"Low," "Medium," or "High" conformity to the
criteria were unsupported by any actual evidence and appear to be both subjective
and biased. For example, it is determined that the dependence of the activity
of natural/scenic appreciation on the lake environs is "High." In
actual fact, other natural/scenic opportunities abound in San Francisco.
Consequently, the evaluation of this item would more rationally have been
determined as "Low." It is also determined that the dependence of
"Walking" on the lake environs is "Medium" when there is
utterly no connection between the two at all. There is no end of places to walk
in San Francisco.
7.) We
believe the real purpose of the PUC criteria are made quite clear by the
evaluation of skeet and trap shooting, the determination of conformity to the
criteria, as we recall being depicted during the slide presentation, were
determined to be "Low" to every single criterion. For example: skeet
shooting is determined to be "Low" as to dependence on lake environs
yet, assuming there is no other place in the city for the skeet shooting to move
to (other than, perhaps, Harding Golf Course), the dependence on the lake
environs is obviously complete so the determination more rationally should have
been "High." Also, "Compatibility to Natural Resources" is
determined to be "Low" while the truth is that there is no
significant incompatibility of skeet shooting with the lake environment. In
addition, the rod and gun club has always had a sign welcoming the public so
the criterion for "Affect [sic] on Increasing Use" could rationally
be determined to be "High," not "Low" as suggested by the
slide. A quick internet search revealed to us that both Trap and Skeet are
current Olympic events. Therefore, it cannot be argued that the gun club
activities are not significant and legitimate recreational uses.
8.)
We are concerned that an inherent conflict of interest exists with the
consultants, Wallace, Roberts & Todd, L.L.C., which PUC has selected to
assist in their watershed planning because those consultants are already
employed by an individual special interest, San Francisco State University, in
designing a master plan for that interest. San Francisco State may seek to
enlarge its physical footprint in the Lake Merced neighborhood. As such, it is
not possible for PUC's consultants to remain unbiased in advising the City and
County of San Francisco on land uses at Lake Merced while they also serve the
interests of an individual entity that has its own designs on that same land
area.
Our
overall impression of the presentation was that we were witnessing a PUC-led
ambush of the rod and gun club. We see this as no different than PUC's lead
study of several years ago that Ross Wilkinson, Paul Callahan and others made
critical comments of at that time as to its scientific validity.
We
question whether the advisory committee to the PUC on the watershed plan is
representative of the real stakeholders in Lake Merced. Our organization participated
in the LMTF ad hoc master planning committee from its beginning. That committee
reported back to the LMTF at large with an outline or framework for a master
plan plus a recommendation that further work be performed by the city to fill
in more details: the so-called "gap analysis." It was decided at one
of the LMTF quarterly meetings a year or two ago that a new LMTF committee be
formed to monitor that process and a representative of San Francisco's Public
Utilities Commission, the only volunteer, was approved to lead that effort. The
following is our best recollection but there could be some errors or omissions.
If any are found, please let us know. It is our recollection that, after not
hearing from PUC's representative for a period of months, we requested that the
committee be called together for a meeting. One meeting was held at which time
we believe PUC's representative stated that she was forming a separate
committee to advise her on the master planning (by then re-termed
"watershed planning"). To our knowledge, PUC's representative never
called any further meetings of the LMTF committee that was created to monitor
the master planning, effectively killing it. Mona Cereghino informed PUC's
representative that Mona wished to be included on the PUC's new advisory
committee but never heard another word about it and we note that our
organization was not identified as a member when the supposed members of the
advisory committee were disclosed at the February 14, 2008 meeting. We were
unaware until that presentation that such meetings were proceeding behind
closed doors and without notice to us and we believe that PUC should now
disclose to the LMTF at large the dates of any and all watershed advisory
committee meetings, the persons/organizations in attendance and the minutes of
such meetings.
We suggest
that PUC go back to the drawing board and assure that the process of evaluating
recreational alternatives at Lake Merced and the more general planning
involving Lake Merced be performed in a more transparent and fair manner.
Sincerely,
Mona
Cereghino, President
cc:
David Behar, PUC Ross Wilkinson, Vice-President