Blog Post < Previous | Next >
Marin County Parks
Comments on the Marin County Open Space Board's recent decisions on the use of toxic herbicides
The Marin County Open Space District Board recently decided to “accept” the Vegetation and Biodiversity Management Plan (“VBMP”) as an “informational” document, but decided not to certify the Final Programmatic Environmental Impact Report (“FEIR”) for that Plan. This leaves the community in an untenable situation where they have no way of monitoring or being notified of the use of toxic herbicides in our open space.
Community Venture Partners and Sustainable TamAlmonte, and hundreds of members of the community have been working to prevent the use of toxic herbicides in our open space and increase transparency about Marin County Open Space District operations.
Toward those goals and in response to the MCOSD's recent decision, CVP and Sustainable TamAlmonte have submitted the following comment letter and request for clarification to Marin County. In addition, Michael Graf, our legal counsel, has submitted the following comment letter, which is attached below.
Max Korten
Director and General Manager
Marin County Parks and Open Space
3501 Civic Center Drive, Ste. 260
James Raives
Senior Open Space Planner
Marin County Open Space District
3501 Civic Center Dr., Suite 260,
San Rafael, CA 94903
Re: Marin County Open Space District’s Vegetation and Biodiversity Management Plan
Dear Mr. Korten and Mr. Raives:
We are contacting you with regard to the Marin County Open Space District Board’s decision to “accept” the Vegetation and Biodiversity Management Plan (“VBMP”) as an “informational” document, and deciding not to certify the Final Programmatic Environmental Impact Report (“FEIR”) for that Plan.
Both staff and the Board have asserted that as an informational document, the Plan does not establish any programmatic direction one way or another about the District’s future use of herbicides. In addition, staff contends that under the District’s current strategy, herbicides will be used as a “last resort.”
However, as it stands, the District’s decision to ‘accept’ the Plan as a reference document leaves the community with a myriad of questions and concerns, and without any reasonable way to monitor or even stay informed about the activities of MCOSD with regard to future herbicide use. For example, how will MCOSD employees use this “reference document” to determine whether or not herbicides should be used in a specific situation? Conversely, how will the public be informed of those decisions in a timely manner? Finally, what will the mechanism be by which the public will be able to comment on or contest the use of herbicides in a particular situation, under this new arrangement?
The public has a right to have adequate public notice of each instance of future herbicide use to be able to determine if each instance is in fact, a situation where its use is the “last resort.” Furthermore, the public needs such notice in advance of such herbicide use, so as to have a reasonable amount of time to evaluate the facts and circumstances of each case, and to make public comments on its use.
All of this considered, we are writing to respectfully request that the MCOSD establish and publish guidelines for how it will provide public notice of each and every project proposed to be undertaken by the District, involving the use of herbicides on County lands, and a methodology for how such notice will be delivered to the public at large, how long the public will have to comment, and absent the “plan” what criteria will be used by staff to determine the use of herbicides.
Thank you for your careful attention to this matter.
Very truly yours,
Bob Silvestri
President - Community Venture Partners
Sharon Rushton
Chairperson - Sustainable TamAlmonte
Cc: Marin County Board of Supervisors