.
Comments on the
(Draft) Lake Merced Comprehensive Management Plan
(CMP)
Friends of Lake Merced, November 1997
Outline to the Comments:
Overview
First some background. Friends of Lake Merced (FoLM) first encouraged
the development of a plan for Lake Merced nearly three years ago.
For more than a year we worked with the San Francisco Recreation and Park
Department (SFR&P) to develop a "Comprehensive Plan for Lake Merced."
It finally became clear that SFR&P did not have full authority to integrate
the many elements needed to assure a comprehensive plan. Deborah
Learner, head of Planning for SFR&P, suggested approaching the Public
Utilities Commission (PUC) requesting that they play such a coordinating
role.
FoLM accepted that suggestion, and petitioned the PUC to adopt this
role. PUC accepted that commission, but has failed to execute its
terms. The "Draft Lake Merced Comprehensive Management Plan (LMCMP)"
that has resulted is neither plan nor comprehensive. No attempt has
been made to integrate the separate elements, water level and quality,
natural areas restoration and habitat, and recreation. As a result
each plan element attempts to stand on its own without regard to the needs
and influences of other planned activities. This obviously can not
be done effectively. More important, it ignores the intent of the
original planning goals entirely.
The PUC failed until very late in the process to state a water level
goal, and then adopted a preliminary finding from an earlier review (GeoResource
Consultants, 1993) without resolving the technical issues raised in that
review. As a result the shoreline location could not be determined,
and a natural resources plan was developed without any idea as to
where the shoreline will be located, what habitat will be inundated and
what remaining, and actions will be needed to protect endangered and threatened
species as well as to maintain the ecological and environmental value of
this marvelous space. Finally, no input was provided to the recreational
plan as to what areas will be available for human use in ways that will
not threaten the natural viability of Lake Merced.
In short, there has been no coordination, and consequently nothing that
can reasonably be considered 'planning', the resolution of conflicting
issues and points of view, and the allocation of limited available resources,
in charting a course toward a more desirable future. Friends of Lake
Merced believes that the residents of San Francisco, and of the greater
metropolitan area, will pay a very high price for this poor performance
if it is permitted to go uncorrected.
1. Introduction
(Note: Page numbers refer to location in the original draft document.)
Page 1: "The Lake Merced CMP has been developed with the cooperation
of several City agencies, involved citizens and community groups."
Friends of Lake Merced repeatedly offered our assistance and support
in developing this plan, and were turned down or ignored each time.
We feel strongly that a successful planning effort can be accomplished
only with the full involvement, in every aspect of plan development, of
community-based organizations such as our own. That involvement has
not occurred to date.
Page 4: "Workshop attendance ranged typically between 30 to 60
individuals."
This is a generous estimate. Workshops soon degenerated to presentations
by city employees followed by question and answer periods. Public
interest soon waned, and attendance dwindled to a few special interest
groups and an even smaller number of devoted citizens. Very little
that could be called work was actually accomplished.
Page 6: "SFR&P does not recommend Lake Merced capital improvements
without adequate maintenance provisions."
Experience does not support this claim. For example, no provision
was made for maintenance of the walking and jogging path constructed around
the periphery of Lake Merced in spite of a strong request from Bob Killian,
then the SFR&P manager responsible for Lake Merced. This is just
one example of the lack of maintenance support provided new capital investments.
In fact, it is the lack of adequate maintenance that is a primary cause
for the degeneration of the condition of Lake Merced, a fact acknowledged
in the first paragraph of the Draft Plan.
Page 6: "Other resources for the upkeep of City parks are being
explored, including volunteer programs."
The design of opportunities to capitalize on volunteer interest and
enthusiasm for the parks should have been a primary goal of this planning
activity. Instead, as this comment illustrates, this action has received
very low and belated priority. In fact, the single instance of reference
to volunteer involvement in a specific program is for “cleaning up litter,”
an activity that is supposed to “encourage public responsibility” (REC-4.2).
We regard this as an outrageous insult, reflecting an attitude on the part
of public officials that is destructive of true volunteer involvement and
which can never realize the full potential of community contribution.
Page 6: "It is anticipated that the SNRAMP will
fund the majority of the Lake Merced CMP Actions Items associated with
preservation and enhancements of the natural environment."
The majority of those action items do not have funding requirements
indicated. There is no way that a commitment for funding these Actions
can be assumed from any source.
Page 7: "Additional funding may be available through
private donations or grants. Future funding could be available through
bonds or special assessments or the solicitation of existing resources."
This is supposed to be a plan, a commitment to action, not a speculative
wish list. Clearly there is no commitment to support the action items
described in this document, and it fails in this basic way to qualify as
a plan.
Page 7: "This schedule is only a preliminary estimate . . ."
Again, this is not the purpose of a plan. There is no commitment,
nor any pretense toward supporting an effort to maintain a program consistent
with the action items described. Lake Merced is not going to improve
as a result of a collection of wishful thinks.
Page 8: "When the balance of water flowing into
the Lake is greater than the water outflow, Lake level rises. Lake
level falls when more water leaves the Lake than enters it."
It is reassuring to observe the perspicacity of our public servants.
Page 9: "Because of the relationship of Lake Merced
to the Westside Basin and the value of the Lake as a regional resource,
Lake Merced will be integral in the development of the Westside Basin Groundwater
Management Plan (WBGMP)."
Yes it should be. However, various action items listed in the
LMCMP ignore this relationship and the importance of the WBGMP. For
example, it is expected that the WBGMP will be complete before scenario
evaluating approaches to increasing the level of Lake Merced are evaluated.
Equally disquieting, the WBGMP newsletter (undated) mentions Lake Merced
only in the context of providing “stakeholders” additional information.
The urgent need to protect Lake Merced is not even mentioned in the “Six
Areas of Concern” listed in this document. Furthermore, in the presentation
document “Key Issues and Concerns” used in the introductory WBGMP Public
Workshop Nov. 20, no mention of Lake Merced, or any lake for that matter,
is included.
It seems clear that it is the PUC’s intent to ignore “the relationship
of Lake Merced to the Westside Basin and the value of the Lake as a regional
resource” when developing the WBGMP.
Page 10: "(S)ixteen special status wildlife species are known
to or have the potential to occur at Lake Merced."
The plan should specifically identify these species and indicate the
actions that will be taken to preserve habitat and in other ways support
their continued existence at Lake Merced. The plan does not address
this objective.
Page 10: "No inventory of the mammals, fish, amphibians,
or reptiles currently exists."
Clearly such an inventory is an essential baseline from which any constructive
planning must proceed. Without this baseline any 'plan' is at best
a statement of good intentions. Friends of Lake Merced recognized
this shortfall, and a similar lack of baseline information about the quality
of the water in Lake Merced as well, several years ago, and has been trying,
without success, to encourage and to support the development of these inventories.
2. Water Resources Program
Page WRS 1: "Goal 1, Maximize Water Level for Appropriate, Identified
Beneficial Uses"
Actions described to support this goal include “review”, “review”, “survey”,
“evaluate”, “assess”, and “plan.” These are in fact not actions at
all, but steps to be taken in the development of a plan. This deferral
of any commitment to specific goals and objectives, with supporting assignment
of responsibilities and commitment of resources, permeates the LMCMP.
This document does not in any sense deserve to be called a plan.
The only action described in this section, the intention to continue
a program of discharging imported water into the South Lake, is opposed
by Friends of Lake Merced. Lake Merced is a Lake, and should be returned
to a self-sustaining status. Reservoir water should be added to the
Lake only as an emergency action, and should not become a standard procedure.
Page WRS 3: "Review the Lake's 'Emergency Water Supply' status;
When: Spring, 1997 to Summer, 1998"
Fifteen months to conduct a 'status' review? This is just one
example of the many lackadaisical and lack luster implementation schedules
contained in this plan. Again, this is indicative of a document that
is neither plan nor commitment, but rather a tired attempt to forestall
action and appease community interests.
Page WRS 3: "Current resource (i.e., plant, wildlife, fisheries)
data at the Lake are needed to assess the impact of changing lake level
on the natural resources and to recommend a range of appropriate lake levels
consistent with the beneficial uses."
Yes that's true! And, as pointed out earlier, without that baseline
data no meaningful planning can occur. As this statement also makes
clear, there is a close relationship between water level, water quality,
and the entire gamut of natural resource and recreational plans that makes
it impossible to address any component of this plan without concern for
the others. That integration has not occurred. Nor can it occur
when the PUC has neither set lake level goals nor coordinated the activity
needed to gather baseline data needed to evaluate alternative goals.
The timetable provided in support of this action indicates that the
baseline data needed will not be available, if the schedule is maintained,
for another year or later. This after more than a year of essentially
non-productive activity assembling the current document. The condition
of the lake and its environs is deteriorating rapidly; the PUC does little
more than fiddle.
Page WRS 4: "The Lake Merced Water Resource Planning Study, May
1993 recommended that a lake level of 26 feet 'would generally satisfy
most beneficial uses.'"
This study stated that “a preliminary level to satisfy most lake uses
is suggested at 26 feet.“ At the same time it identified a set of
“mitigations” regarding lake level and water quality. These issues
have not been addressed in the current study, and must be before a meaningful
lake level target is available.
Page WRS 4: "Develop five alternatives to raise lake level to
within an acceptable range of 26 feet."
As just noted, there has been inadequate scientific basis established
for accepting this target (26 feet). That must be accomplished first.
When a target is set, however, a much more aggressive program is needed
to establish a course toward its attainment. The current proposal
suggests that no action intended to develop and evaluate alternatives will
be started for at least one year, and that it will be at least one more
year before any report is prepared. Two years to make a list; how
much more time will be required to select a course of action? This
is simply not acceptable.
It appears that it is the intention of the PUC to proceed with the Westside
Basin Groundwater Management Plan (WBGMP) without regard to the impact
on Lake Merced resulting from decisions made in support of that plan.
Neither is this course acceptable.
In the meantime, however, a number of steps directed toward protecting
the Lake can and should be taken, now. Implement PUC resolution No.
95-0082, enabling the golf courses to use tertiary reclaimed water, now
(WRS-2.7). Implement an aquifer relief program with Daly City, now
(WRS-2.3). Stop any program to increase withdrawal from the aquifer
until a program to protect Lake Merced is in place (San Francisco Groundwater
Master Plan).
Page WRS 4-5: "Discharge surplus imported surface water to South
Lake."
Lake Merced is a lake, not a reservoir. It's continued existence
should not depend upon input of reservoir waters. Friends of Lake
Merced opposes this policy as a long term program for two reasons:
1. Reliance on reservoir water to maintain Lake Merced
is based upon an ecological imbalance created by human intervention.
We should repair that imbalance and return Lake Merced to its natural support,
not compensate for that imbalance through artificial infusion of reservoir
water.
2. Reservoir water will be available only during those years of
substantial surplus. During drought years political forces opposed
to such programs will be most influential, at times when the Lake is most
in need of support. We can't count on this program when it is needed
most.
The cost for this action is estimated to be "0.77 $/Ccf of water".
That's a little like estimating the cost of a 'review' at $10.50 per hour.
In other words, no estimate of cost has been provided at all. Again,
no plan can be based on this form of circuitous pretext.
Page WRS 6: "Develop a Westside Basin Management Plan."
As described above, the timetable for this plan indicates that it will
be complete by Summer, 1998, three months before the assessment of alternatives
to evaluate programs to increase the level of Lake Merced is to begin.
This is evidence of an unacceptable lack of planning coordination within
the PUC.
Page WRS 7-8: "Encourage groundwater conservation efforts."
The only action described in this section is to "Encourage local governments
to participate in the Memorandum of Understanding Regarding Urban water
Conservation in California." This action has been given a budget
of $50,000. That's a lot of jaw-boning. With another $25,000
earmarked to "encourage natural recharge of the aquifer" we ought to be
able to send a lot of PUC folks to attend a lot of meetings.
It's not clear, however, that anything's going to get done as a result.
Page WRS 8: "Implement groundwater monitoring in the vicinity
of Lake Merced. . . This will be especially important when assessing the
actual impacts to groundwater levels resulting from the planned Sunset
district wells and the planned increase in production at the San Francisco
Zoo."
This raises an entirely separate set of issues, those that relate to
the coordination of plans affecting Lake Merced with other PUC plans, in
this case the San Francisco Recycled Water Master Plan and the San Francisco
Groundwater Master Plan. As is clear, commitments have been made
to substantially increase the withdrawal of water from the Westside Basin
in the area north of Lake Merced with no assurance that this will not have
a deleterious affect on Lake Merced, and without adequate monitors in place
to evaluate that impact. As we pointed out in our comments on the
SFGMP environmental impact report, the promise to monitor does not constitute
adequate or acceptable environmental protection.
Page WRS 8: "Train existing Lake Merced maintenance staff to
collect quarterly water level data."
The 'existing Lake Merced maintenance staff' constitutes one person
half time, and that time is seldom available to Lake Merced. Why
should the PUC expect SFR&P to support this activity when such limited
resources are available?
Friends of Lake Merced has offered repeatedly to support this water
monitoring activity in Lake Merced. At one point a volunteer from
our organization was involved with San Francisco State University, through
a PUC financed program ($50,000 was awarded SFSU to support this activity).
The goal was to establish a volunteer-supported water quality monitoring
program. We agree with the PUC that the results were completely unsatisfactory,
but that did not result from the ineffectiveness of the volunteer effort.
Page WRS 9: "Encourage the use of recycled water."
Page WRS 10: "Implement storm water best management practices
. . ."
These constitute the only references to the conservationists hierarchy,
'reduce, reuse and recycle.' Clearly even this has low priority at
the PUC, as no program is described, other than anecdotally, and no budget
is established.
Page WRS 11: "Develop and conduct a quarterly limnological monitoring
program."
Friends of Lake Merced was instrumental in supporting a program to attain
this objective two years ago. San Francisco State University was
commissioned to design this program, and $50,000 was allocated to its support
(see above). We have seen little if any beneficial impact from this
expenditure. Nor do we understand how an additional $5,000 a year
is likely to significantly improve upon this performance.
What happened to the money already spent, what was produced, and what
needs to be done to put an effective program in place?
Page WRS 12: "Recommend lake management techniques to improve
the Lake Merced fishery."
Good idea, and should be an integral part of a "Comprehensive Management
Plan for Lake Merced." So it's available now, correct? Not!
When? Spring 1999, if we're on schedule.
Consistent to the last drop, the PUC has failed to produce a plan, and
has no clear intent of producing a plan in a reasonable time period.
The PUC has failed in its mission, and should not be trusted to continue
this course without meaningful community oversight and involvement in the
planning process itself.
3. Recreational Use Program
It is clear that SFR&P has not taken seriously the charge to prepare
a comprehensive plan for Lake Merced. Rather they have decided to
devote their attention to the disposition of a budget of approximately
$1.1 million still available for the support of Lake Merced as a result
of a bond issue passed more than ten years ago. While much of the
original amount has been spent, and another $500K was committed while this
plan was being developed, SFR&P has finally decided that it is timely
to involve the public in evaluating the allocation of that small portion
that is remaining.
As a result, major questions regarding the management of the grounds
surrounding Lake Merced have not been addressed:
1. What is the budget for maintenance and improvements
for the next 5 to 7 years? How will that budget be expended?
The introductory paragraph of the Draft Plan describes “decreased maintenance”
as a major contributor to the deterioration of “the Lake and its surrounding
environs.” Still this plan fails to address this most important issue
in any constructive way.
2. What is the budget for golf course activities? That budget
represents an estimated 90% of the total expenditure by SFR&P in the
vicinity of Lake Merced, and isn't even referenced in the RuP. How
will that budget be expended so as to maximize the beneficial impact on
issues of environmental concern and recreation?
3. What is the nature of relationships with concessionaires?
What income will be derived from those concessionaires, and how will this
money be directed toward the overall enhancement of Lake Merced?
How are the responsibilities of the concessionaires defined in agreements
with SFR&P; how will improved enforcement of those agreements result
in improved conditions at Lake Merced?
4. What has been the deleterious effect of inadequate facilities
at Lake Merced, especially in areas such as human fecal contamination of
the water and of surrounding shoreline? How will those effects be
addressed in the short term before new facilities can be budgeted and constructed.
The plan as prepared inadequately reflects the discussion at the series
of planning workshops. Members of Friends of Lake Merced who participated
in these workshops stressed the urgency of providing restroom facilities
around the Lake. This is not merely an issue of comfort or convenience,
but one of public health. SFR&P recently renovated picnic tables
in an area that is used as a public bathroom by fishermen from the nearby
Impound Lake. In fact the whole shoreline in the vicinity of the
Impound Bridge is little more than a public toilet.
It is not sufficient merely to build public restrooms. Provision
must be made for their maintenance. The suggestion in this document
that "SFR&P does not recommend Lake Merced capital improvements without
adequate maintenance provisions" is a sad joke. Anyone not familiar
with the SFR&P maintenance standards should visit the washroom facilities
at Golden Gate Park, Balboa Park, Crocker Amazon Park, or at many other
locations around the city. Often the SFR&P finds it simply easier
to keep these facilities locked than to attempt even a minimum level of
maintenance.
SFR&P seems not to know what maintenance support is needed for Lake
Merced. Action Item 4.1 (A) proposes to "Determine the number of
regular maintenance personnel (gardeners and custodians) and equipment
needs for Lake Merced." SFR&P has been responsible for the maintenance
of Lake Merced since 1950 and they still haven't figured that one out!
Until there is an adequate maintenance program for Lake Merced, provided
for in a Comprehensive Plan for Lake Merced, Friends of Lake Merced believes
that no further capital improvements should be made, including the provision
of bathroom facilities
SFR&P does not have a comprehensive plan for the use of volunteers.
Action REC-4.2 states that they will "Encourage Volunteer Efforts To Assist
The SFR&P In Cleaning-Up Litter And In Other Park Maintenance Tasks."
Why? "To encourage public responsibility. . ." Friends of Lake
Merced has had an active clean-up campaign committee since our formation.
But we're not going to accept that this is our "public responsibility."
Nor do we accept the notion that this is the end all of volunteerism.
Again SFR&P demonstrates an awesome disdain for the public, and for
the ability of volunteers to make a meaningful contribution to the health
of our city and our environment.
Finally, we challenge anyone to compile an ordered list of investment
priorities from the convoluted itemization provided in the RuP. Good
Luck! The list provided in Appendix K should be integrated into the
body of the plan.
This section of the LMCMP represents more than eight years work by SFR&P
personnel (the user survey referenced in this document was conducted in
1989) in assembling this plan. Still, individual points are so poorly
described as to defy comment. Major planning elements are simply
missing. It seems clear that the process is completely inadequate,
and that some new planning format, involving extensive input from knowledgeable
community-based organizations, will be required before an adequate LMCMP
can be prepared.
4. Significant Natural Resource
& Education Program
The Significant Natural Resource & Education Program (SNR&EP)
provides an outline for planning. Important issues are identified,
e.g., the need to inventory natural resources, the need to coordinate operations
of the Harding Park Golf Course, the need to coordinate the activities
of concessionaires. Again, however, while these issues are
raised, answers are left to some future date. Developing answers
to these questions is the process of planning. Without answers there
is no plan.
The SNR&EP underscores the lack of communication between the plan
elements. Action NRE-1.5 observes "After a Lake level has been determined
. . ." (page NRE 5) It is clear that the PUC has not advised SFR&P
that they have selected a water level target. Action NRE-2.2 is intended
to "Determine Appropriate Human Use In Sensitive Natural Resource Areas."
(page NRE-5) What are the actions? "Identify sensitive areas"
and "Determine appropriate human use." (page NRE-6) A very good idea,
but shouldn't that be done before a recreational use program is developed,
let alone finalized? Or don't the departments within SFR&P even
talk to each other?
Again it is futile to address individual points in this section of the
LMCMP. Friends of Lake Merced discovered very late in this planning
process that SFR&P will retain a consultant to develop a natural areas
restoration plan for all natural areas in San Francisco, including Lake
Merced. That consultant is not required to pay any attention to the
work that has been done, and that has involved many hours of citizen participation.
SFR&P personnel assure us that any consultant hired would naturally
want to incorporate all of this good work; we can understand why said consultant
would want to start over.
Several references are made in this section to the "Public" and to "Volunteers"
both as the "Who's" and the sources of funding. We appreciate
this attempt to achieve a more constructive approach to volunteerism, and
agree that such an effort is necessary to assure effective implementation
of a Comprehensive Plan for Lake Merced. We do not feel that listing
'public' and 'volunteers' as the who's is sufficient. Planning entails
the design of projects, the description of tasks, and the assignment of
roles and responsibilities. Some, in fact many, of those assignments
may be assumed by volunteers.
Friends of Lake Merced offered repeatedly to be involved in the planning
process, and suggested that other community-based organizations should
be involved as well. One of our principal goals was to assist in
defining specific opportunities for volunteer participation. We believe
that incorporating volunteer input to these plans will provide strong motivation
for subsequent volunteer follow-through in the implementation of those
plans. The public hearing format that has been followed in the preparation
of this document has failed to accomplish that goal. The PUC and
SFR&P have demonstrated a hard-nosed refusal to include community groups
in the planning process. The result is a document that has little
community support.
We think that the solution is not to ask PUC and SFR&P to try again.
Rather, we need to get much more specific in providing community inputs
as to what constitutes a plan and what is its content. A new forum
for developing a plan is needed, one that addresses the several issues
raised in this commentary.