Opposition to Significant Natural Resource Areas Management Program

San Francisco’s Natural Areas Program was to be one of the great urban conservation programs in America. But in 2011, San Francisco released a Draft Environmental Impact Report (“DEIR”) that will, if adopted, turn the program on its head.

The DEIR radically altered the management plan, particularly at Sharp Park: the new Sharp Park plan calls for redeveloping an 18-hole golf course within the “recovery” area for the San Francisco Garter Snake and the California Red-Legged Frog—even though the golf course is the primary threat to both species’ existence at Sharp Park.

In order to ensure that the good isn’t thrown out with the bad, the Wild Equity Institute and an array of environmental and community supporters are demanding that the Sharp Park Golf Course redevelopment plan be segregated out of the Significant Natural Resource Areas Program Management Plan, and considered separately through its own environmental review process.

Contact the SF Board of Supervisors and SF Recreation and Parks Department today and let them know that you oppose the inclusion of the Sharp Park Golf Course redevelopment proposal in the Significant Natural Resource Areas Management Plan.

The San Francisco Garter Snake: one of the endangered species that inhabits Sharp Park

Additional Background on SNRAMP

• In February 2006 the Recreation and Parks Department and the Planning Department began a California Environmental Quality Act (“CEQA”) process for the Significant Natural Resource Areas Management Plan (“SNRAMP”). The SNRAMP proposed projects in the City’s Natural Areas, including Sharp Park’s Natural Areas, but did not propose any changes to Sharp Park Golf Course.

• In November 2009 the Departments separately released a controversial proposal to redevelop Sharp Park Golf Course called “Conceptual Alternative A18 (“A18”). Scientists from San Francisco State University, the California Academy of Sciences, and other prominent institutions heavily criticized the proposal. San Francisco’s entire environmental community also opposed A18.

Letter from experts expresses concerns with Conceptual Alternative A18

• Until recently, the Departments consistently maintained that A18 was entirely separate from SNRAMP, and the two projects could not be considered in a single CEQA review process. For example, the SNRAMP Scoping Report states:

“Because redesigning or eliminating the Sharp Park Golf Course is a separate proposal being studied by SFRPD, it will not be included or evaluated as part of the proposed [Significant Natural Areas Management Plan] project analyzed in the EIR. Should changes to the Sharp Park Golf Course be proposed, they would undergo a separate regulatory review, including CEQA environmental review.”

Excerpt from the Scoping Report indicating that proposed changes to Sharp Park Golf Course would have to undergo a separate CEQA review

• Yet in 2011 the Departments released a SNRAMP Draft Environmental Impact Report (“DEIR”) that removed the original plan for Sharp Park and replaced it with A18, the Golf Course redevelopment project. Moreover, the DEIR declares the Golf Course a Historic Resource that CEQA must protect—even though the original design was washed away by ocean storms decades ago—and therefore refused to consider alternatives that would protect Sharp Park’s environment from this devastating and controversial project.

Map demonstrating proposed changes to Sharp Park Golf Course under Conceptual Alternative A18

• Even worse, the Golf Course project is analyzed at the “project” level, which means if the EIR is adopted the Golf Course project can move forward immediately, while the conservation projects at the City’s 31 other natural areas are all analyzed at the “program” level, which means none of those 31 projects can move forward until additional environmental review is conducted.

• Meanwhile, the Recreation and Parks Department Natural Areas program staff implemented many proposed SNRAMP projects by incorporating them into other capital projects. Adoption of SNRAMP today will therefore provide very few environmental benefits above and beyond what the Natural Areas program is already authorized to do.

• In contrast, Sharp Park, inarguably San Francisco’s most ecologically and biologically important natural area, would be devastated by implementation of A18.