Hello Coastal Commission Staff ~

We write to express our opposition to the agenda item on the November 2010 hearing, granting the City of Santa Cruz a waiver on its application for a project identified as the Arana Gulch Master Plan, as long as it contains the controversial "Broadway-Brommer segmented trails connections" component.

Our reasons for opposition are:

1. We wonder why the City should be given special treatment and not be required to wait the 6 months that is ordinarily required for developers of projects, especially projects that will create "significant and unavoidable impacts" (dEIR) in an ESHA.
   
   
2. The City has been before the Commission twice already, in the last seven months, at two hearings.
   
   
3. The tie vote at this month's hearing proves how very controversial the bike project component of their application remains.
   
   
4. The Commission has raised many good questions and made several suggestions, again, that the City could put to good use to develop a meaningful response to said suggestions, if it is not rushing to get back on an upcoming agenda.
   
   
5. Tarplant management is ongoing and is not jeopardized, whatsoever, by a six month wait for re-application. We can send you digital pictures that show the extensive management applications performed last month, in preparation for winter rains. And the Spring treatments are already planned by the Santa Cruz Tarplant Management Program botanist. Just as important, small-scale, experimental grazing (cow, goat, sheep) could be applied after the first of the year.
   
   
6. Tarplant management is ongoing and is not jeopardized, whatsoever, by a six month wait for re-application. We can send you digital pictures that show the extensive management applications performed last month, in preparation for winter rains. And the Spring treatments are already planned by the Santa Cruz Tarplant Management Program botanist. Just as important, small-scale, experimental grazing (cow, goat, sheep) could be applied after the first of the year.
   
   
7. The extremely eroded trail above the entrance from the harbor can, and should be stabilized, anytime, without a permit, without a waiver, without a hearing!
   
   
8. Steve Hammack, the City's Parks & Recreation (P&R) assistant director has just given two week's notice to the City and will be gone even before the November hearing. To remind you, Hammack has been deeply involved with the City's application up to this point. The City must have time to replace Hammack, one way or another, and to bring his replacement up to speed as well using said replacement as a much needed resource.

In summary, we feel there is no justification for granting the waiver for the City of Santa Cruz.