Dear Dr. Schmader:

I am writing to provide comments on the draft SWCA Environmental Monitoring Plan and Baseline Monitoring Report.  Thank you for the opportunity to comment.  I appreciate the City's willingness to consider the views of City residents and to take those views into account as it proceeds with its Bosque planning process.

I am very concerned about the ability of the monitoring undertaken by SWCA to detect any adverse environmental impacts should such impacts occur from any projects that will be constructed.  The monitoring protocol does not monitor mammals, reptiles, or amphibians.  It only monitors birds.  With respect to the bird monitoring, the proposed monitoring protocol is very limited and appears to be inadequate to accurately capture the true state of bird populations.  The proposed monitoring will only have a small number of survey visits (one visit only to each site, four times per year), it will only monitor small transects, and it does not appear able to account for the mobility of birds, particularly at certain times of year, and the variability that may exist on sites in any given survey visit, such that a single visit may not accurately reflect what is happening at the site.  SWCA is putting all of the animal monitoring eggs in the bird basket, but its bird monitoring protocol does not appear adequate to accurately capture changes that may occur.  The surveying protocol needs to be adequate to detect adverse environmental impacts on animal populations.

I am also extremely concerned that the report has been drafted not solely for a scientific purpose, but also for a political purpose.  The report concludes at page 84: "Given the already environmentally disturbed condition of the MRG bosque, the proposed project is not anticipated to have a significant negative environmental impact on the area."  This conclusion is highly inappropriate.  The study did not evaluate the environmental impacts of any proposed project.  The conclusion of no negative environmental impact is unsupported by any scientific study or evaluation in the report.  Further, the premise of the sentence is misleading.  It is true that the Bosque is an ecosystem that is very altered from its condition prior to extensive human development, but that does not mean that there is not a lot of terrific, native habitat in the area of the proposed development.  There is.  The alteration of the Bosque over the centuries should not be used as an excuse to ignore negative impacts on a wonderful and beautiful habitat.  Finally, there is no "proposed project" at this point, so it is impossible to say whether any project does or does not have adverse environmental effects. 

The blatantly political nature of the report's conclusion calls into question the scientific impartiality of the entire report.  It is not possible to trust a report that would insert a conclusion for a purely political purpose.  The sentence should be removed from the final report.

I am also concerned about various other statements in the beginning of the report that purport to describe the project.  For instance, on page 1, the report states that "The trail cross-section is proposed to vary from approximately 1.2 meters to 2.4 meters (4 to 8 feet) in width."  This statement is highly disturbing, because it indicates someone is telling the consultants what the trail will be before, we are assured, the project has even been designed and before public comment has even been taken.  The City needs to take into account the wishes of the public before any decisions about the project is made.

Finally, it is my understanding that the City has also agreed to assess the effects of the project alternatives before it makes a final decision about the project that will be constructed, so that we can choose a project plan that will not have an adverse environmental effect.  I commend this City for agreeing to undertake this assessment and for taking seriously its obligation to protect the Bosque.

Thank you again for the opportunity to submit these comments.

(signed)