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Comments on Draft III Pima County MSCP

Download a PDF of the commnets (here)

Cover letter below:

July 20, 2006

Mr. Chuck Huckelberry, Pima County Administrator
130 W. Congress, 10th Floor
Tucson, Arizona 85701

RE:     Pima County Multi-species Habitat Conservation Plan, Draft III
The Coalition for Sonoran Desert Protection would like to applaud Pima County for all of its work over the last 8 years on the Pima County Multi-Species Conservation Plan (PCMSCP).  Please consider the following comments on Draft III of the PCMSCP, released January 3, 2006. 

Since the draft was released in January, Pima County, along with the Science Technical Advisory Team, Recon, the Conservation Acquisition Commission, and interested members of the public such as the Coalition, has refined much of the language included in Draft III.  We realize and appreciate this work, which includes updated species accounts, an updated take analysis, management plans for suites of species, a draft biological monitoring work plan, language for allowable uses on conserved lands, and more.  We are appreciative of the detailed Public Works Preliminary Work Plan (March 2006), which outlines and sequences further steps necessary to conform to the MSCP.

Although the Coalition has been involved in providing input to Pima County over the last few months that is reflected in numerous documents and processes, we do feel that it is important to submit to the County specific recommendations on the last written draft of the MSCP, January 2006.  In preparing these recommendations, we revisited previous comments that the Coalition has submitted which have not yet been fully addressed.

The following topics are addressed in the attached comments, with discussion of each topic followed by specific recommendations by the Coalition for inclusion in the next draft:

• ·         Comprehensive Plan / Regional Plan Policies
• ·         Conservation of the Rarest Species
• ·         Conservation of the Rarest Special Elements
• ·         Preparation of Management Plans
• ·         Assured Funding for Management and Monitoring
• ·         Additional Comments

In terms of our “rarest species” and “rarest special elements” recommendations, please refer to an article that appears in the current issue of BioScience magazine, entitled, “Species Coverage in Multispecies Habitat Conservation Plans: Where’s the Science?”  The report studied the effectiveness of many already-approved multi-species conservation plans in protecting species.  The conclusions support the importance of both landscape scale conservation measures and species-specific conservation measures, especially for the rarest species, and echo concerns voiced by the Coalition throughout development of the PCMSCP.   The Coalition provides specific conservation recommendations for rare species and special elements, found on pages 4 through 16 of the Coalition’s attached recommendations.  We are confident that Pima County’s plan will strike the right balance of landscape-level and species-specific measures, effectively providing both.  Pima County will continue to provide leadership and example to other communities struggling with similar concerns.

We hope you will find these recommendations useful.  Thank you once again 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

 

cc:        Recon Consulting

            Ms. Maeveen Behan, Pima County Administrator’s Office

            Ms. Sherry Barrett, U.S. Fish and Wildlife Service

Attachment (17 pages)

 

 

Page last modified: December 15, 2008 at 02:21 PM

Coalition for Sonoran Desert Protection
300 East University Boulevard, #120
Tucson, Arizona 85705 (USA)
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