LAW
OFFICES OF Stephen K. Butler HAND DELIVERED Sonoma County Board of Supervisors Re: Draft Sonoma County Outdoor Recreation Plan/Needs Assessment Dear Chairman Cale: The primary purpose of this letter is to discuss significant flaws in the needs assessment and financing assumptions which form the foundation of the draft Outdoor Recreation Plan ("DORP") presented to the Board. Upon review of these matters it appears that the DORP was prepared with flawed methodology. Specifically, the needs of the urban community for active neighborhood, community and regional parks have been ignored, while the ostensible need for a vast network of open space parks and trails has been artificially enhanced. As a result of this flawed approach, the Board has not been presented with a true recreation plan. With its flawed foundation, the DORP utterly fails to serve the recreational needs of the vast majority of the residents of Sonoma County. I. FLAWED NEEDS ASSESSMENT.
You cannot determine what you need without knowing what you have. Unfommately, on page 28 of the DORP, an asterisk appearing at the bottom of the page states that the DORP has excluded land banked property and trail acreage from the plan's inventory of public parkland. The exclusion of this information not only skews the 11 county analysis of publicly accessible land set forth in Table 5 on page 29 of the DORP, but also serves to deprive the Board and members of the public from having a fully informed basis upon which to make decisions on how and where public dollars ought to be spent to maximize recreational opportunities. There is no way that the drafters of the DORP could have made an intelligent needs assessment and corresponding recommendations to the Board without this critical information.
By its own admission, the DORP's analysis of the "need" for passive regional open space and trails is not based on any quantitative analysis. (DORP pp. 55-57). Rather, the entire need for passive open space parks and trails was determined by a subjective qualitative analysis. (DORP plan pp. 58-74). This subjective analysis results in a proposed plan which, out of a projected budget for acquisition and development of nearly 110 million dollars, devotes less than 6 million dollars to active recreational areas such as regional, community and neighborhood parks. When 95 percent of the total dollars are to be spent for projects which "need" is determined by a subjective analysis, it is critical to look at the methodology underlying that analysis. Essentially, the subjective conclusion of "need" for trails and passive parks is justified by five categories of information. Those are a 1995 SRI county survey, a 1997 statewide survey on public opinions and attitudes on outdoor recreation in California, a trends in use analysis of Sonoma County regional parks, a series of public workshops conducted in 1996 and a 1996 Outdoor Recreation Agency Conference. The quality of information developed through each of these categories will be discussed in this section of the letter.
The first support for the DORP's conclusion that the public needs open space parks and trails at the expense of urban recreational uses is a 1995 survey conducted by Strategy Research Institute ("SRI") through a contract with the Sonoma County Regional Parks Department. The SRI survey is advanced as a primary indicator of the community's "need" for the types and number of facilities recommended in the DORP. The DORP's discussion of the 1995 SRI survey can be found on pages 59 through 62 and in appendix number 3. Initially, it is interesting to note that while the information is contained in the DORP's appendices, the text of the DORP itself fails to note that the SRI survey found that 80 percent of those polled in the survey were satisfied with the number of public parks and recreation facilities available in Sonoma County. Ten percent were neutral. Ten percent were dissatisfied, of which only two percent were extremely dissatisfied. (Appendix p. 3-19). This information, in and of itself, draws into question the "need" for an extensive network of passive open space and trails which the DORP seeks to justify. Second, the demographics of the SRI survey skew its results. The first problem is that a representative sample of the population of Sonoma County was not polled. The survey was based on a poll of 600 county residents. (Appendix p. 3-1). One hundred residents were selected from each of the six regional park planning areas. Two of the six regional park planning areas are comprised of area number one, the Sonoma Coast, and area number three, Sebastopol and the Russian River. According to the demographic data in the 1989 General Plan, these areas comprise approximately 13 percent of the population of Sonoma County and yet had 33 percent of the input in the public opinion survey. When regional park planning area 6, Sonoma Valley, is added into the equation, 22 percent of the population had 50 percent of the survey's input. This sampling deficiency artificially reduces input from the county's urban population. Third, in addition to the disproportionalely large input from the rural areas, other information contained in the demographic breakdown calls into qucstion the validity of any conclusions drawn from the survey results. For example, 64 percent of the people polled have no children. 84 percent of the people polled have no teenagers, 76 percent of the people polled own their own residences, Ninety one percent of the respondents were Caucasian and 72 percent were over the age of 40. Based on this demographic data, it appears that there is a disproportionately low opinion response from younger urban families whose children would be better served by active recreational facilities such as regional parks, community parks and neighborhood parks in proximity to urban areas. Fourth, a careful examination of the SRI survey at pages 3-1 through 3-39 of the appendix reveals that the questions asked and answered do not lead to the conclusion that the "public" is clamoring for passive open space parks and trails at the expense of providing additional active recreation facilities such as regional, community and neighborhood parks. The three critical questions relating to the respondent's preference for park facilities can be found in on pages 3-26 and 3-27 of the appendix. Copies of these pages are attached as Exhibit "A" to this letter. Them is no way that you can reasonably conclude, by a reading of questions 9.0, 10.0 and 11.0, that the public is demanding passive open space parks and trails at the expense of regional parks, community parks and neighborhood parks. Nowhere did the survey ask whether the public would support trails across productive agricultural lands. Nowhere did the survey ask whether the public would support trails in agricultural areas if a detriment to agriculture could occur. Unfortunately, the flaws in the SRI survey render it useless for its intended purpose. The SRI survey does not support the recommendations contained in the DORP.
The second support for the DORP's subjective "need" analysis is a 1997 statewide survey on public opinions and attitudes on outdoor recreation in California. It is impossible to determine from the data presented in the DORP whether this survey in any way supports the recommendations of the DORP. The statewide survey is not reproduced in the DORP's appendix volume. The only material presented appears on pages 63 and 64 of the DORP and is characterized as a "summary" of key findings from the survey. The level of information presented is simply not sufficient to support an argument justifying the heavily weighted recommendations of the DORP in favor of open space parks and trails at the expense of regional parks, community parks and neighborhood parks.
The third support for the DORP's conclusion that the public overwhelmingly needs open space parks and trails, at the expense of urban recreational needs, is the discussion appearing at pages 65, 66, 78, and 79 summarizing trends in use of regional parks from 1988 to 1997. Great emphasis is placed on the increase in visitors per acre or mile for trails outside park boundaries. The DORP states:
This discussion is somewhat misleading. First, there is serious question as to how these numbers were arrived at given the difficulty of counting trail users outside of parks. Putting that aside, however, the discussion in the DORP masks the true significance of the statistics relating to increased trail use outside of parks. By reference to appendix 4, the real significance of these statistics may be seen.
The population of an urban trail link located within two miles from 50 percent of the population of Sonoma County does not support a vast trail system in remote and agricultural areas of the County. Similarly, the popularity of trails at a destination recreation community, Sea Ranch, does not support the DORP's recommendation for its far reaching network of open space parks and trails. To the contrary, the entire increase in trail usage noted in the DORP's appendix supports the conclusion that recreational facilities should be located in proximity to urban service areas where a majority of the population of Sonoma County can benefit. One additional point should be made. A comparison chart appearing at page 66 of the DORP purports to stand for the proposition that increased recreational users are gravitating more toward trails and open space parks. As will be discussed in Section C of this letter, that chart fails to accurately assess the demand for neighborhood and community parks with the result that the comparison of percentages set forth in the chart are inaccurate and unuseable.
The fourth support for the DORP's recommendations favoring open space parks and trails are the results of nine public workshops held in 1996. Unfortunately, the results of these workshops cannot be extrapolated to support a subjective conclusion that the "public" of Sonoma County wants open space parks and trails at the expense of regional, community and neighborhood parks. By the DORP's own admission, only 300 people attended these workshops, an average of 33 people per workshop. Again, by the DORP's own admission, "Attendees at the workshops included representatives of organizations such as the Sierra Club Trails Committee, the Sonoma Horse Council, the Sonoma County Trails Committee, the Bay Area Ridge Trail, Greenbelt Alliance, COASST and Citizens for Lafferty Ranch. Many of these organizations joined together as the Coalition for the Outdoor Recreation Plan ("CORP") in 1997." While it cannot be disputed that the members of CORP are highly orgznlzed and motivated, it is obvious that the public workshops were dominated by these special interest groups. These individuals are not representative of a broad spectrum of Sonoma County and cannot presume to speak for the "public" at large when it comes to the question of spending available public monies to achieve the maximum recreational benefit possible.
The last support for the DORP's recommendations favoring open space parks and trails at the expense of regional, community and neighborhood parks is the result of an Outdoor Recreation Agency Conference held in 1996. The DORP states that 30 organizations involved with providing or regulating recreation in Sonoma County convened for a conference and workshop. The list of the attendees is not provided. The limited text on page 73 and 74 of the DORP do not support the grossly weighted recommendations of the DORP favoring open space parks and far flung trails.
A close scrutiny of the DORP's subjective "qualitative" analysis in no way supports the conclusion that the majority of Sonoma County residents favor open space parks and trails in remote and agricultural areas of the County at the expense of active regional, community and neighborhood parks more conveniently serving the County's urban population and children. The manner in which input to the DORP was solicited does not reflect an unbiased and broad public outreach. The DORP's subjective conclusion identifying a staggering public "need" for open space parks and trails, reached in a vacuum given the lack of an accurate inventory of existing land banked parks and trails, is grossly overstated and untenable. The DORP does not stop with an inflation of the public "need" for open space parks and trails. The text of the plan goes further by denigrating the "need" for regional parks, community parks and neighborhood parks in proximity to urban populations. That topic will be discussed in the next section of this letter.
An assessment of the "need" for regional, community and neighborhood parks supporting active recreational opportunities for the urban population of Sonoma County was approached from a "quantitative" standpoint. (DORP, p. 46). This quantitative analysis ostensibly provides an objective assessmere of the "need" for neighborhood, community and regional parks based on empirical standards. Unfortunately, the DORP fails to employ existing general plan needs criteria and intentionally down plays the demand for neighborhood, community and regional parks.
The DORP concludes that there is no need for additional neighborhood parks, (DORP, p. 49). However, in order to reach this conclusion, tortured reasoning is employed. First, the DORP utilizes a quantitative standard of one acre of neighborhood park per one thousand population. This quantitative standard is significantly less than the two and one half acre standard for one thousand persons set forth in Section 3.1 of the Public Facilities Element of the General Plan. By reducing the objective quantitative criteria already set forth in the Counry's adopted General Plan, the DORP artificially reduces the need for neighborhood parks by 60 percent. The fact that the DORP is utilizing a significantly reduced objective criteria in its assessment of need for neighborhood parks is not mentioned in the DORP. Second, the DORP downplays the "need" for neighborhood parks by reducing the segment oft he population included in the acreage/1000 population equation. The DORP apparently excludes the County's population living in incorporated cities. With respect to the unincorporated population, the DORP only counts those portions of the population residing within unincorporated communities, as opposed to the total population of the unincorporated area. (DORP p. 46). Third, the DORP suppresses the "need" for neighborhood parks by counting facilities owned by elementary schools and recreation districts in the unincorporated areas as part of the one acre of neighborhood parks per 1000 population equation. (DORP, p. 46). This questionable approach, apparently developed without the acquiescence of the affected superintendents and boards, further artificially reduces the "need" for neighborhood parks. Fourth, the DORP downplays the "need" for neighborhood parks by failing to accurately account for increased demand associated with these facilities. On page 66 of the DORP, there is a chart which purports to compare the percentage increase in various types of recreational facilities around the County. However, in compiling that comparative chart, the DORP only accounts for increase usage associated with the 23 acres of neighborhood parks owned by the County. Given the fact that the DORP counts elementary school and recreation district facilities toward the County's population/acreage goal, a fair accounting of increased demand for neighborhood parks may only be achieved by assessing increased use associated with these elementary school and district sports facilities. By failing to account for these facilities, the DORP reduces the percentage of increase in the use of these facilities and the percentage of use of neighborhood parks compared with other types of recreational facilities included in thc chart. Interestingly enough, even though the chart low balls the increased usage of neighborhood parks, it still concludes that there was a 40 percent increase in the use of these facilities over the ten year time frame in question. This percentage increase in visitors is second only to the 172 percent increase discussed in connection with trails outside of parks in Section B(3) above. Notwithstanding this significant increase in use, the DORP still concludes that additional neighborhood park facilities are not really needed. It is only as a rcsult of the tortured methodology set forth above that the DORP can conclude that there is no demand or need for neighborhood park facilities over the 10 year life of the plan.
Thc DORP next concludes that there is an overall surplus of community parks at this time. (DORP p. 52). Again, to reach this apparently objective conclusion, unsound logic and inconsistent methodology is employed. Initially, the DORP employs a quantitative guideline of 2.5 acres per thousand population. This is nominally consistent with the standard set forth in Section 3.1 of the General Plan. [l]
With respect to population, the DORP includes, unlike the methodology employed for neighborhood parks, the entire population of Sonoma County. On the face of it, this would appear to be generous. However, by including the entire County, the DORP then justifies crediting the acreage of existing municipal parks and middle and high school sports fields toward the County's goal of providing community parks at a ratio of 2.5 acres per 1000 population. The inclusion of these areas, again without the apparent endorsement of affected cities and school districts, significantly reduces the "needs" assessment for community park facilities in the County as a whole. As with its assessment of neighborhood park needs, the DORP erroneously reduces the need for community parks through utilization of the comparison chart on page 66 of the plan. While municipal and middle and high school facilities are included as counting toward the acreage which should be devoted to commuuity parks, the DORP's analysis of increased use of community park facilities fails to include the increased use of facilities owned by the cities and schools. By focusing solely on the 30 acres of community parks owned by the County, the DORP mistakenly reduces the assessment of"need" associated with community parks. Even though the DORP suppresses the need for community park facilities by including city parkland and middle and high. school sports fields, the DORP is still forced to conclude that there are presently community park deficiencies in park planning areas one, two, three and six. (DORP, p. 52). These areas are the Sonoma Coast, the Sonoma Valley, the Cloverdale, Healdsburg and Windsor planning area and the Sebastopol and Russian River planning area. Notwithstanding this identified deficiency, the DORP, in a curious leap of logic, concludes that there is an overall existing surplus in community parks by stating that there is "relatively large surplus acreage provided by cities in park planning areas four and five" (Santa Rosa and Petaluma). Additionally, even though the DORP concluded that there will be a deficit of 80 acres of community parks County wide by the year 2010, the DORP only proposes an additional 10 acres of community parks. One additional point is salient, The DORP states that it is generally not County Regional Park's role to provide community park facihties as a justification for proposing only ten new acres of community park facilities over the ten year life of the plan. How can the Rcgional Parks Department continue to collect fees pursuant to the Quimby Act for neighborhood and community park facilities at a ratio of five acres per one thousand people if it does not intend to actually provide these facilities? Presumably, Quimby Act fees would be funneled in the direction of other identified "needs" in the DORP, although such transfer may be of dubious legality. As with neighborhood parks, the DORP suppresses the true demand for community parks and is uuresponsive to urban recreational needs.
The DORP's last use of ostensibly
objective quantitative analysis is in connection with the
provision of regional parklands providing a broad range
of recreational activities. (DORP p. 53). In this regard,
the DORP utilizes a quantitative standard of five acres
per one thousand population. In contrast, the General
Plan Public Facilities Element utilizes a rate of 20
acres per one thousand persons. (Section 3.1). This
artificially reduces the "need" for Notwithstanding using a ratio which is only 25 percent of the standard set forth in the General Plan, the DORP, by its own admission, projects an active regional park deficit of 1,91733 acres over the life of the plan. (DORP p. 55). The DORP also acknowledges a current deficit in all six planning areas of 1,468.3 acres of regional parks, (DORP, p. 55). Notwithstanding the significant deficit identified by the DORP, the DORP proposes to add only 398 acres of additional regional recreation areas. (DORP p. 118). This is completely unresponsive to urban needs. This unresponsiveness cannot be justified, particularly in light of the fact that the general plan projected additions to the County's active regional park system of 5,923 acres over the life of the general plan resulting in a ratio of 19 acres per 1000 population in year 2005. [2]
The foregoing discussion indicates that the DORP erroneously suppresses the demand for regional, community and neighborhood parks when formulating its overall "needs" assessment. By reaching its ponderous conclusions that the demand or "need" for these facilities is not great, the DORP attempts to internally justify its radical recommendation that 95 percent of the money proposed to be spent will be devoted to a trails and passive open space park system. II. ERRONEOUS FINANCING ASSUMPTIONS. The DORP, in responding to its "needs" assessment, makes a number of mistaken assumptions regarding the financing of the proposed network of trails and open space parks. These will be discussed in this section.
The DORP proposes to utilize SCAPOSD funds for purposes of financing the acquisition of additional parks and trails. Indeed, the District's revenue stream is the only one realistically capable of achieving any significant portion of the proposed recreation plan. Unfortunately, for the DORP, it is not merely sufficient to amend the Sonoma County General Plan to add the proposed recommended priority projects. [3] In order to utilize SCAPOSD funds, the expenditure must be found by the SCAPOSD Authority to be consistent with the District's expenditure plan. That expenditure plan specifically refers to the 1989 General Plan. In our opinion, it is highly unlikely that a legal finding of expenditure fund consistency could be made if the funds were to be utilized in connection with the acquisition of a trail which was specifically deleted from the 1989 General Plan in response to identified agricultural concerns. [4]
Accordingly, at a minimum, with respect to those trails which were specifically deleted from the 1989 General Plan by the Board of Supervisors, we do not believe that SCAPOSD funds can legally be spent to acquire such trails. No other funds are realistically able to make up this revenue shortfall.
The DORP proposes to spend some $55,000,000 in connection with the acquisition of recommended priority projects. Approximately $18,000,000 are earmarked for trail acquisition across privately held property. (DORP appendix p. 8-1). In establishing a projected value, the DORP used an approach "that uses the average cost of land acquired for parks or by the Open Space District in fee to develop a likely 'value." This assurnption is wrong. If the County proposes to buy a 100 foot swathe through the middle of a piece of property, it will not only have to pay for the value of the fee interest taken, but also the reduction in value to the remainder of the property in resulfmg from the existence of a trail. This reduction in value, or severance damage, is likely to be significant. The DORP needs to more accurately assess acquisition costs related to proposed trails.
The DORP estimates development costs at $54,000,000. We believe this figure to be extremely conservative. Given the fact that the DORP proposes to include trails across private propeary in remote and agricultural areas, it is not unreasonable to expect that affected property owners will take an active interest in any proposed trail development. Soft costs, such as environmental processing costs, need to be realistically assessed. Hard costs, m the form of road improvements, fire protection measures, agricultural compatibility measures, drainage improvements and other foreseeable project expenses need to be more accurately identified.
Maintenance and operation costs are underestimated. First, the only cost included are those to be borne by the Regional Parks Department. Presumably, the Sonoma County Water Agency will have significant maintenance and operation responsibilities if a large number of its drainage easements are converted to multi-use trails. Second, the DORP relies on information received from East Bay Regional Parks to predict future operation and maintenance costs. We believe that operation and maintenance costs on large tracts of land owned by a public agency will be lower than costs associated with the maintenance of 210 miles of trails over private property. The remoteness of many of the trails over private land will result in increased ma!ntenance costs. Additionally, a greater level of improvements, with associated maintenance costs, will be necessary to minimize conflicts between the public trail and the remainder of the property held in fee by the affected property owner.
The DORP characterizes the responses to a number of questions asked in the SRI poll as evidence that the voters might approve an additional tax to pay for the cost of the proposed recommended priority projects. (DORP, appendix p. 3-7, 3-8; DORP, p. 127). However, no real conclusions regarding the success of a ballot measure may be drawn with the information presented. First, the SRI survey notes that accurate polling of the electorate, as opposed to a residents survey, would be necessary to derive any definitive conclusions. (DORP, appendix p. 3-7). Second, as indicated above, the demographic flaws in the SRI study undercut its conclusions. Third, it would be naive to assume that a tax could be passed for the DORP's intended purposes given the County's recent experience with transportation measures and continuing problems with Highway 101. Fourth, the DORP's conclusions regarding taxation assumptions are premised on no organized campaign against the proposed tax. (DORP, appendix p. 3-8). The result of all of these factors is that accurate conclusions regarding taxation may not be drawn from the SRI study. Interestingly enough, the responses to the SRI poll on Appendix page 3-32 further undercut the DORP's overall assessment of a need for the acquisition of additional trail and open space parks. (DORP, appendix p, 3-32). In response to question 1.4, 54 percent of those polled stated that they would be willing to pay additional taxes for the Sonoma County Regional Parks Department if the funds were used entirely for maintenance and operation. In response to question 14.5, the affirmative response to a tax rose to 66 percent if the funds were used for maintenance, operation and facility development costs. In response to question 14.6, the affirmative response actually dropped 5 percentage points if the funds were to be used for maintenance, operations, facility development, and acquisition of new parklands. The conclusion to be drawn is that, of those polled, a greater number favored development of existing publically held parklands and trails. The responses to questions 14.4, 14.5, and 14.6 also reveal that the DORP erroneously concludes that "According to the SRI survey, in order to get over two-thirds majority support for any tax measure, development and acquisition of new parks had to be part of the purpose of the tax. [emphasis added]" In summary, we believe that the DORP does not accurately project potential fiscal impacts resulting from the recommended priority projects. Fiscal impacts need to be objectively and accurately quantified. Under the best of scenarios, the budget of the parks department would have to be increased nearly $8,000,000 a year over the next ten years simply to respond to identified development and operation costs. The need for these funds for the identified purposes must be evaluated in terms of competing budget considerations elsewhere in the County. Given the absence of other tangible financing options, the likely source of money for development and operation is the County's general fund. III. CONCLUSION AND RECOMMENDATIONS. The DORP erroncously suppresses the "need" for active regional, community and neighborhood park facilities in deference to an alleged subjective "need" for a network of open space parks and trails. Demand for open space parks and trails has been inflated. Demand for regional, community and neighborhood parks has bccn deflated. An adequate inventory of existing land available for park and trail development has not been provided. The result of the flawed methodology of the DORP is to devote 95 percent of the capital resources proposed by the DORP away from regional, community and neighborhood parks. Only 428.7 acres of additional regional, community and neighborhood park facilities are proposed over a ten year time period, far less than that called for in the 1989 general plan. In contrast, 3,560 acres of linear trails are proposed. An additional 5,246 acres of County open space parks arc proposed. When comparing the percentages of total acreage of regional, community and neighborhood parks against open space parks and trails, one finds that 95 percent of the acreage proposed for acquisition is for open space parks and trails. The DORP is historically repeated. In October 1988, upon coasideration of the then pending 1989 General Plan, this Board was presented with an open space element which contained a significant network of public trails across private property in agricultural areas of the County. In response to concerns identified by the agriculture community, the Board removed a number of trails from the then proposed open space element and modified policies stressing the primacy of viable agriculture in this County. The same article in the Santa Rosa Press Democrat which reported this Board's deletion of trails in agricultural areas also quoted then Supervisor Nicholas' lamentations as follows:
Regrettably, the DORP has brought this Board back to the same point. The DORP's ambitious, but conservative, price tag of $135,000,000 over a ten year period all but ignores urban recreational uses. Rather, the DORP treads on a variety of general plan policies designed to protect agriculture in this County and proposes to filch the income stream of the SCAPOSD to fund the enterprise. There is no doubt that there is a need for additional recreational facilities in the County. We support additional recreational facilities in the County. However, we urge that the Board reject the DORP and redirect its staff to develop a plan which is more responsive to the needs of Sonoma County's urban populations. As evidenced by the Joe Rodota/West County Trail, recreational facilities in proximity to the urban population will be used. The acquisition and development of additional regional parks or expansion of existing regional parks providing multi-level recreational opportunities in proximity to urban populations should be encouraged. Greater County participation in the provision of community and neighborhood recreational facilities should also be encouraged. With this in mind, we make the following specific suggestions to the Board.
We implore the Board to give direction to staff to prepare a more balanced plan and to avoid trails in agricultural and remote areas which will be available only to a select few members of the public. Thank you for your consideration of these comments.
SKB:cg LAW OFFICES
OF Stephen K. Butler HAND DELIVERED Chairman Michael Cale Re: Sonoma County Draft Outdoor Recreation Plan/Lafferty Ranch Dear Chairman Cale: The purpose of this letter is to request that the Board give direction to staff to delete recommendation number 4 on page 99 which states "Encourage the City of Petaluma to develop a preserve at Lafferty Ranch with trails." There are a number of important reasons to delete this language from the draft plan which are as follows:
Thank you for your consideration of this requests.
SKB:cg LAW OFFICES
OF Stephen K. Butler HAND DELIVERED Chairman Michael Cale Re: Draft Sonoma County Draft Outdoor Recreation Plan/Requests for Modification Dear Chairman Cale and Members of the Board: Pursuant to the Chairman's direction given at the last workshop, we include herein requests for action in connection with the Draft Outdoor Recreation Plan. This letter is intended to supplement requests made in previous correspondence to the Board.
Thank you for your consideration of these requests.
SKB:cg |
