Lakewood Tenants Association

655 John Muir Drive, #411, San Francisco, CA lakewoodtenants@hotmail.com (415) 334-0465

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on that email was the undersigned Mona Cereghino, our alternate representative to the LMTF, but the email address was outdated and was never actually received by Mona Cereghino directly.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 "members@lmtf.org."

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