JHS Properties2173 D Francisco BlvdSan Rafael, CA 415-453-0212 April 24, 2001 Marshall JonesActing Director, Fish and Wildlife ServiceDepartment of the Interior18th & C St. NWWashington DC, 20240
Dear Mr. Jones:
Please suspend the current wildlife refuge study in Marin County, California. Marin County is already one of the most environmentally protected regions in the country. Development timelines are measured here in decades, not years or months. 84% of Marin County is already open space, parks, and ag land. Furthermore, Marin’s baylands are protected by wetland and conservation overlays which are part of the county and city general plans. Any proposed development within these overlay areas is already subject to review and approval of USFWS, State Dept. of Fish & Game, as well as the local jurisdictions. There is simply no demonstrated need for USFWS to declare a wildlife refuge in Marin.
Please allow the cities and counties to determine whether a
wildlife refuge is needed, and whether it is consistent with their General
Plans. USFWS did not consider these
local plans when creating the study area.
Three of the included properties are designated for workforce housing,
which is critically needed here.
Similarly, the multi-modal transportation plan passed by voters in 1998
was ignored, thereby threatening future rail, ferry, and aviation plans. We own one of the two existing airports
in Marin County. Our runway was
included in the study area!!!
Apparently the refuge study area was proposed in response to the Hamilton AFB wetland restoration project planned in Novato. The Coastal Conservancy is set to perform the restoration work, but they need a long term manager. USFWS is willing to do it, but to be efficient USFWS agents say they need more lands in the area to manage. If that is the case, then I suggest that USFWS decline the management responsibilities. There are other potential managers, including State Dept. of Fish & Game and local well-funded private environmental organizations. Wetlands consultants have even pointed out that USFWS’ role to protect endangered species is inconsistent with the wetlands restoration project. The reason is that clapper rail habitat will be destroyed when the levees are breached to create the wetland mudflats and tidal sloughs.
Another reason to reconsider USFWS involvement is cost. Purchasing even a small portion of the
17,600 acres in the study area would severly strain USFWS resources. Much of the land is commercially zoned in
the city and county general plans.
Commercially zoned land in Marin sells for $10-$30 PSF. PURCHASING ONLY 10% OF THE LANDS IN
THE STUDY AREA WOULD COST $7.6 - $23 TRILLION!!!
In summary, I respectfully request the termination of any USFWS study of a Marin County wildlife refuge until invited to do so by local governing bodies. At that time, USFWS should start the process by conducting a thorough study of environmental and economic impacts (including an EIS) before including any properties within a study boundary. Failure to do so will likely result in violations of the California Environmental Quality Act (CEQA) as well as the National Environmental Protection Act (NEPA). This would certainly cause legal challenges by local agencies and/or property owners here in Marin. No one will be the winner if both wildlife preservation and prudent land use are delayed by the courts. Thank you for your time.
Sincerely,
Joe
Shekou
Joe Shekou
cc
Mike Spear, Manager California and Nevada Fish & Wildlife Operations
Marge Kolar, Project LeaderCathy Osugi, Wildlife BiologistDan Ashe, Chief of the National Wildlife Refuge SystemThe Honorable Gale Norton, Secretary United States Department of the InteriorCongresswoman Lynn WoolseySenator Diane FeinsteinSenator Barbara BoxerMel Martinez, U.S. Department of Housing and Urban DevelopmentSupervisor Hal BrownSupervisor Steve KinseySupervisor John KressSupervisor Cynthia MurraySupervisor Annette RoseNovato City Councilman Michael DiGiorgio,Novato City Councilwoman Carole Dillon-KnutsonNovato City Councilperson Pat EklundNovato Mayor Jim HendersonNovato City Councilman John ManiSan Rafael Mayor Al BoroSan Rafael City Councilman Paul M. CohenSan Rafael City Councilwoman Barbara HellerSan Rafael City Councilman Cyr MillerSan Rafael City Councilman Gary PhillipsAssemblyman Joe Nation