Comments on Draft II of the Pima County Multiple Species Conservation Plan

September 15, 2005

Ms. Maeveen Behan
Assistant County Administrator for Land, Water, and Environmental Policy
Pima County Administrator's Office
130 W. Congress, 10th Floor
Tucson, Arizona 85701

The Coalition for Sonoran Desert Protection would like to thank you and other Pima County staff, consultants, and the numerous scientists and citizens for all the work that has gone into the development of Draft II of the Pima County Multi-Species Conservation Plan (PCMSCP), released February 3, 2005. We appreciate the opportunity to provide comments on this draft, and offer the following overall recommendations. The attached document contains comments relating to specific sections of the PCMSCP.

OVERALL RECOMMENDATIONS:

1. Identify specific conservation goals for each covered species - All means should be identified by which each of the 55 Priority Vulnerable Species can qualify for coverage under the PCMSCP. The MSCP should articulate specific conservation goals and objectives for each species with special emphasis on the rarest "special species." The Science Technical Advisory Team (STAT), biological consultant Recon, and experts have dedicated significant time towards this task and the results should be presented in the next PCMSCP draft.
2. Update the Conservation Lands System to reflect latest scientific information - STAT has recently adopted a revised Priority Conservation Area (PCA) for the endangered Pima pineapple cactus. The CLS should be reflect this change and incorporate the PCA. The next PCMSCP draft should also reflect the change.
3. Clarify estimates of anticipated development impacts - A clear analysis and presentation of anticipated development impacts over the life of the permit and PCMSCP as part of the take analysis will be crucial to ensure an effective PCMSCP and transparency. The 2nd draft PCMSCP addresses this topic but should be clarified.
4. Provide clear conservation benchmarks - Conservation benchmarks for the Conservation Lands System and Priority Vulnerable Species should be identified to quantify required mitigation for anticipated development over the life of the permit and PCMSCP. The level of conservation benchmarks should clearly correspond to the level of any future development impacts (e.g. four acres of the Biological Core Management Area should be conserved for every acre impacted by development).
5. Specify conservation mechanism details - Details on planned conservation measures are crucial to determining the likely success of the PCMSCP. Additional details should be provided on how conservation will occur during new development permitting, how conserved land and covered species will be managed and monitored in perpetuity, and how conservation of land and species will be achieved in conjunction with other jurisdiction's activities.
6. Prepare management and monitoring plans for existing conserved lands - New management and monitoring plans will be necessary for any existing conserved lands to achieve the goals of PCMSCP. Existing conserved land should not be counted toward County mitigation obligations under the PCMSCP pending preparation of new management and monitoring plans.
7. Identify additional assured funding sources - The 2004 Open Space Bond was an important first step in providing assured funding for implementation of PCMSCP land conservation goals. Other assured funding sources will be necessary for management and monitoring and special species conservation among other measures and should be identified in the next draft PCMSCP.

Finally, Coalition staff and member group representatives are pleased to serve on Pima County's MSCP-IA Drafting and Implementation Committee. The Committee thus far has adopted a series of recommendations that it has sent forward to the county. The Coalition is in full agreement with these recommendations. The county should incorporate these in the next draft of the PCMSCP.

Thank you for your consideration of these comments, and incorporating our recommendations into the next draft of the PCMSCP. If you have any questions, or would like to discuss these comments in more detail, please contact me.

Sincerely,

Carolyn Campbell
Executive Director

Attachment

The Coalition's detailed "Comments on Draft II of the Pima County Multi-Species Conservation Plan" can be downloaded in Adobe Acrobat� format (82 kBytes).

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