Draft MTP/SCS Comments Received - sacog

Further, while SACOG has used the best data currently available, it is roundly recognized that
comprehensive, accurate, up-to-date natural resource data does not exist for the region to do
sufficient analysis of these impacts.
The lack of data is demonstrated by the plan's simple justification that the 37,500 acres of habitat
impacted represents only "one percent of the 2,543,519 acres of habitat and land cover in the
region today," (MTP/SCS, 7-16). However, the vast majority of this regional habitat resides in the
National Forest in the mountains, while the vast majority of the impacts are in the valley and
foothills where viable habitat differs greatly and is much more sparse. In the future, a
proportionate analysis of habitat impacts on the valley must be undergone, at a regional level, to
adequately assess environmental sustainability of the MTP/SCS.
We believe that the interests of equity, public heath, and economic prosperity in compact transitoriented
urban planning are best served by complimentary planning for natural resource and
open-space conservation. Improved natural resource data, analysis and conservation strategies
need to be developed to compliment the SCS, to further incentivize adherence to the valuable
urban plan that SACOG has developed.
In the future, this data could be used:
As a public decision-support tool for targeting responsible and efficient investment for
development and conservation.
To enable participation in/development of a Regional Advanced Mitigation Program
To demonstrate co-benefits for ecology, public health, recreation and education, as well
as the economic imperatives for habitat/open-space conservation
To demonstrate co-benefits and economic imperatives to preserve ecosystem services,
(ie. carbon sequestration, flood management and groundwater recharge)
Conclusion:
To reiterate, we applaud SACOG's first joint SCS/MTP, and we hope the above comments are
constructive to implementation of the plan. We also commend the extensive efforts of SACOG
staff to engage the public throughout the MTP process. We greatly appreciate the time and
attention that has been provided us in addressing our concerns and suggestions in development of
this plan, and we look forward to our continued work with SACOG moving forward.
Sincerely,
Jonathan Ellison, President
ECOS Board of Directors
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