December 20, 2002
Ms. Frances Sakaguchi
Outdoor Recreation Planner
Mr. Tom McCusker
United States Department of the Interior
Pacific Great Basin Support Office
1111 Jackson St., Suite 700
Oakland, California 96407
Re: Scherer Park Conversion/Environmental Assessment Report (LSA Project NO. RUT230)
Dear Ms. Sakaguchi and Mr. McCusker:
I am writing on behalf of Concerned Parents and Teachers of Long Beach a network of Long Beach residents, community and environmental activists from across the city who are concerned about public policy decisions that affect the lives of our city's children and economically disadvantaged families. On behalf of our organization, I am writing to respond to the Environmental Assessment report conducted by LSA Associates in regards to the Scherer Park Conversion (LSA Project RUT230).
The 185-paged document was made available to the public only days before the Thanksgiving holiday weekend and the response is now due only 5 days before Christmas. We certainly appreciate the 5 day extension over the original due date of December 16, 2002. However, due to the busy holiday season, we think both the City of Long Beach and National Park Service agencies should allow for an additional 30- day period. This would allow for greater circulation of the document and a reasonable time frame to respond that does not compete with the holiday season.
Equally confusing was the City's announcement that the public meeting held about to the Environmental Assessment report was being held and conducted by the National Park Service (NPS) when in fact it was being conducted and produced by LSA Associates, Inc. -- consultants hired by the City of Long Beach. We don't believe there was substantial or sufficient public notice of the meeting by the City of Long Beach or LSA Associates, Inc. Because of this, we concur with Stop Taking Our Parks (S.T.O.P) and request the following:
- An extended comment period of not less than 30 days or more to allow additional public comment and input.
- National Park Service should encourage and/or require that the City of Long Beach conduct additional public meetings, of not less than one (1) or more meetings, to be conducted within the extended public comment period, and said meeting held within the area of the 7th, 8th and 9th Long Beach City Council Districts served by Scherer Park.
- National Park Service should encourage and/or require that the City of Long Beach extend outreach efforts in accordance with the recommended procedures in the GUIDE
- Meetings should include attendance by representatives of The State Department of Parks and Recreation as well as the National Park Service.
Attached for your review is a listing of Long Beach neighborhood and community organizations. They are included as a reference to make the point that the continued taking of parkland does not only affect the North-end of Long Beach but the lack of recreation opportunities creates an added burden on the City's remaining parks. Long Beach city parks are used by children and adults for public recreation on citywide basis regardless of what district they live.
The West, Central and North areas of the City are severely underserved with parkland as the assessment report aptly notes. If NPS agrees to the conversion of Scherer Park from parkland to institutional use after taking Land Water and Conservation Funds (LWCF) for its maintenance, there appears overwhelming contradiction in both the premise and advocacy of promoting the development of public parkland and public recreation on behalf of both the National Park Service and the California Department of Recreation. It our opinion that if the National Park Service (NPS) allows/justifies this conversion -- it would be setting an egregious precedent in allowing other cities to convert parkland to institutional or other uses. We believe a standard policy should be set that declares immediate mitigation be provided and replacement land developed prior to any conversion or land taking. Further, we also believe that once land is parkland it should remain parkland in perpetuity and should not be annexed for development purposes not related to public recreation.
In a separate correspondence [ref # L3217(PGSO/PP], CPTLB President Traci Wilson-Kleekamp, sent to Ms. Francis Sakaguchi, numerous articles about Scherer Park, its history and the ongoing debate about the taking of Long Beach public parks for non-park uses. Documents requested under the California Public Records Act included correspondence which notes that mitigation was never in the offering as the City's position has been that it could not afford to provide equitably sized and valued land to replace what the police substation would remove.
Recently, City Prosecutor Tom Reeves, attempted to close a land trust meant to service the creation of wetlands and clean water development with funds collected from oil spill fines -- in an effort to divert money to the Long Beach Redevelopment Agency (RDA) to clean up a former land-fill dump which was neither equitable in price or accessibility to the public being served in the Scherer Park area. His actions were challenged by the U.S. Department of Fish and Game's Oil Spill Prevention Unit with representation by the State Attorney General Bill Lockyer's office. In the end, Prosecutor Reeves was not successful to diverting those funds to the RDA for the purpose of cleaning up proposed contaminated land at 55th Way to replace the Scherer Park taking.
The City is also projecting an $80 million plus deficit for fiscal year 03-04. With the State's deficit climbing near $40 billion it is questionable whether or not the City can afford to both build the police station and provide a developed replacement (equitable in size and value) to the loss at Scherer Park. The Environmental Assessment does not address the City's economic viability (budget or lack thereof for public parks and recreation) or a time certain for the replacement if NPS justifies that the loss of parkland in one of the most underserved areas of the City should be lost to a concrete fortress. Development of the police station in the park will forever change the face and permanence of the park whose trees, ponds, and birds are signatures that create an indefinite cultural and community asset.
The Environmental Assessment also attempts to use the City Strategic Plan, recently adopted Open Space and Recreation Element and Police Strategic Plan as being in congruence with the proposed conversion plans. Nothing could be further from the truth. We believe the basic elements of Strategic Plan have been largely ignored since none of the planning, budgeting or development recommendations have been implemented. The City's Open Space and Recreation Element is a policy decision meant to protect parkland from future non-park related or non-recreational encroachments. Only weeks after its passage, the City Council voted to fence off and limit access to 2.5 acres of Caesar Chavez Park from 7 am to 4 pm daily in an effort to provide joint use for a new school site adjacent to the Long Beach freeway and the sprawling Long Beach Port traffic and pollutants.
The Police Strategic Plan notes specific targets for police staffing of nearly 1,400 patrol officers by the year 2002-2003 but the LBPD only has budgeted 950 officers and actual numbers of officers are even lower. The move limits public access during winter months from the active recreation portion of the park and provides no accommodation for children who go to school year-round nor does it take into consideration the thousands of new residents being lured to the downtown area with new housing development. No new park development is available for the new residents who will most likely have children, nor will is there a plan to provide open space and recreation for the remaining 4000 students in the downtown area who are bused out of their area and remain without sufficient public parkland. The downtown area is ALREADY severely over-crowded with substandard housing and a lack of infrastructure to support the density of residents. The city continues to prioritize development using public parkland without providing replacement land.
If NPS supports the empty rhetoric of the environmental assessment Long Beach residents will continue to see their parkland dwindle because the rules and requirements are being altered to address commercial development rather than the human health benefits provided through parks, open space and public recreation.
We urge NPS extend the discussion and include the appropriate representatives from ALL agencies involved to fashion a permanent public policy decision on parkland that doesn't leave the residents EMPTY-HANDED.
s/ Traci Wilson-Kleekamp, President
Concerned Parents and Teachers of Long Beach
CC: CPTLB Board Members
Francis Sakaguchi, National Park Service, Jeff McMusker, National Park Service, Joshua Brady, California Department of Parks and Recreation, Mona DeLeon, LSA Associates, Jan Chatten Brown, Esq Mr. John Jarvis, National Park Service, Mr. Ray Murrary, National Park Service, Mr. Charlie Willard, California Department of Parks and Recreation