CEQA compliance and $20 million dollar question?
Sat, 4 Sep 2010 16:50:01 -0000 (UTC)
"Craig Dremann
CC:,, "Kevin Bryant" <>, "Paul Heiple" <>, "Drew Shell" <>, "Donald Mayall" <>, "Kevin Bryant" <>, "Judy" <>


Dear Clerk and Board of Midpeninsula Regional Open Space District,

After reviewing your Resolution No. 01-29, "Resolution..adopting
guidelines pursuant to the California Environmental Quality Act, " I am
requesting that District begins to comply with CEQA, by taking the
following actions:

1.) Pass a motion at your next meeting, declaring that Section 5
Categorical Exemptions of Resolution No. 01-29, Part (iv) "Maintenance of
existing native vegetation," is null, void, unenforceable, vague, and is
illegal under CEQA as it does not contain any thresholds of significance.

2.) Pass a motion at your next meeting, that the Board will comply with
CEQA Guidelines Section 21082 regarding the maintenance of existing native
vegetation on their preserves. That the Board shall adopt by the end of
2010, by ordinance, resolution, rule or regulation, the objectives,
criteria and procedures for the evaluation of projects involving native
plant maintenance and weed management, and the preparation of
environmental impact reports and negative declarations pursuant to this

3.) Pass a motion at the next meeting, that the District will publish,
with public review and adopt, thresholds of significance as part of the
CEQA guidelines, using technical thresholds that are based on measured
scientific facts. A factual basis may be developed as part of the process
of preparing thresholds. Further, the standards or regulations upon which
the thresholds are based must be enforceable.

4.) Pass a motion at your next meeting, that contained in the new
thresholds of significance, a clause stating that the District will revise
thresholds promptly upon the receipt of pertinent new information.

5.) Pass a motion at your next meeting, that the District will place all
the thresholds in a single document and in a format that encourages their
use during the initial environmental review and study process for each

6.) Pass a motion at your next meeting, that District-wide, that all
currently approved native vegetation maintenance projects, plus all of the
weed management, eradication or control projects, will immediately cease
until the District has the thresholds of significance written, reviewed by
the public and adopted by the Board.

$20 MILLION DOLLAR QUESTION. I would also be interested the Board
responding to my question: Which agency or agencies are going to come up
with the $20 million in mitigation costs for the fire damages to the
wildflower fields and bunchgrasses at Russian Ridge, that have occurred
from the burns conducted by CAL FIRE in 1998, 1999, 2002, 2007, and 2009
without any EIRs or vegetation monitoring ?

I would like to receive a copy of your motion when passed, an answer to
the $20 million dollar question, as well as a copy of the new guidelines
and thresholds of significance.

Sincerely, Craig Dremann (650) 325-7333
Box 609, Redwood City, CA 94064