The Coaliton's Comments on Pima County's Multiple Species CP

Comments on Pima County Multi-Species Conservation Plan

May 22, 2004

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

Dear Mr. Huckelberry:

The Coalition for Sonoran Desert Protection commends you for all the work done to advance the Sonoran Desert Conservation Plan, and in particular, the "Pima County Multi-Species Conservation Plan (PCMSCP)," a draft of which was released for public review and comment in January 2004. The PCMSCP document very admirably lays the groundwork for what promises to take habitat conservation planning under the Endangered Species Act to a new and exciting level - that which respects conservation biology as a framework for regional land use planning. The Coalition is pleased to have been a part of this process for the last six years, and we intend to continue work toward implementation throughout the life of the permit.

I would also like to extend our gratitude to all the county staff who have worked hard throughout this process. Their work has not gone unnoticed by the conservation community, and, I am sure, by the community at large.

The PCMSCP contains a number of elements that will significantly advance conservation of sensitive species and habitats in southern Arizona, including:

• Conservation Lands System

• Science Technical Advisory Team

• Comprehensive Land Use Plan

• Commitments to secure assured funding

The framework that incorporates these elements is sound. In order to bring details to flesh out this framework, we offer the following recommendations. Our detailed comments are attached (summarized below):

• Clarify anticipated extent of habitat loss and conservation / mitigation for the unincorporated County -- A clear presentation of anticipated habitat losses is essential in determining the extent of necessary habitat conservation / mitigation. A clear presentation of both anticipated habitat losses and conservation / mitigation is essential to secure take authorization.
• Clarify anticipated extent of take and conservation of "narrow endemic species" (refer to detailed comments) -- See above.
• Expand conservation of narrow endemic species, Critical Landscape.
• Connections, Important Riparian Areas, and the rarest Special Elements -- The rarest resources covered by the PCMSCP require a greater amount of conservation attention than others to achieve program goals and secure take authorization.
• Provide additional details on elements and assembly of the Biologically Preferred Reserve / Conservation Lands System -- "Conserved land" (see detailed comments) and the Conservation Land System should serve central roles in implementing PCMSCP goals and objectives.
• Expand discussion of the "Mitigation Program and Standards" consistent with a new, consolidated, and improved land use code to implement the PCMSCP -- PCMSCP implementation details are essential to meet program goals and secure take authorization.
• Expand conservation measures outside of the Conservation Lands System -- The loss of valuable resources outside of the CLS should generate increased conservation within the CLS.
• Prepare protective management and monitoring plans -- Conservation of land is only a first step. Management and monitoring is just as important to meet program goals and secure take authorization.
• Clarify the relationship between temporal mitigation priorities and duration of the take permit -- A clear presentation of the anticipated timing of habitat losses is essential in determining the timing of necessary habitat conservation / mitigation. A clear presentation of the timing of both anticipated habitat losses and conservation / mitigation is essential to secure take authorization.
• Specify the amount of necessary assured funding to achieve PSMSCP goals and commitments -- A clear, detailed presentation of the anticipated extent of necessary conservation / mitigation, management, and monitoring funding is essential to meet program goals and secure take authorization.
• Provide contingency funding and management planning in support of "no surprises" assurances -- Contingency funding should be provided for changed and unforeseen circumstances affecting resources under the PCMSCP, in exchange for federal government "no surprises assurances."

I hope you find the attached detailed comments useful as Pima County and the community at large work toward finalizing details of Pima County's Multi-Species Conservation Plan. The Coalition is excited about the opportunity this Plan holds for our community, and the future of habitat conservation planning throughout the country.

Thank you again for all your hard work, and for incorporating our comments into the final Plan.

Sincerely,

Carolyn Campbell
Executive Director

The Coalition's detailed "Comments on Pima County Multi-Species Conservation Plan" can be downloaded in Adobe Acrobat® format (250 kBytes).

Click here