JHS Properties
2173 D Francisco Blvd
San Rafael, CA 
415-453-0212
 
April 24, 2001
 
Marshall Jones
Acting Director, Fish and Wildlife Service
Department of the Interior
18th & C St. NW
Washington 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 Leader
Cathy Osugi, Wildlife Biologist
Dan Ashe, Chief of the National Wildlife Refuge System
The Honorable Gale Norton, Secretary United States Department of the Interior
Congresswoman Lynn Woolsey
Senator Diane Feinstein
Senator Barbara Boxer
Mel Martinez, U.S. Department of Housing and Urban Development
Supervisor Hal Brown
Supervisor Steve Kinsey
Supervisor John Kress
Supervisor Cynthia Murray
Supervisor Annette Rose
Novato City Councilman Michael DiGiorgio,
Novato City Councilwoman Carole Dillon-Knutson
Novato City Councilperson Pat Eklund
Novato Mayor Jim Henderson
Novato City Councilman John Mani
San Rafael Mayor Al Boro
San Rafael City Councilman Paul M. Cohen
San Rafael City Councilwoman Barbara Heller
San Rafael City Councilman Cyr Miller
San Rafael City Councilman Gary Phillips
Assemblyman Joe Nation