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Home My WebLink About02-17-23 Public Comment - V. Saab - Fw_ Sacajawea Audubon Society comments on the PRATFrom:Addi Jadin To:Agenda Cc:Jesse Phillips Subject:Fw: Sacajawea Audubon Society comments on the PRAT Date:Friday, February 17, 2023 10:16:28 AM Attachments:SAS_Comments PRAT Goal 4 & Design Manual.pdf One more from Audubon Addi Jadin | Park Planning and Development Manager City of Bozeman | Parks and Recreation Department P.O. Box 1230 | Bozeman, MT 59771 | 406-582-2908 Pronouns: She/Her engage.bozeman.net/pratplan From: Victoria Saab <victoriaannsaab@gmail.com> Sent: Friday, February 17, 2023 10:13 AM To: Addi Jadin <AJadin@BOZEMAN.NET> Cc: Chris Nixon <pres@sacajaweaaudubon.org> <saschrisnixon@gmail.com>; John Edwards <jedwards@anchorqea.com>; Loreene Reid <loreener5@gmail.com>; Travis Kidd <magpie.chatter8@gmail.com>; Kyle Moon <kcm4moon@gmail.com>; Frank M. Marchak <fmarchak@vradc.com>; Janet <janetwinnie@msn.com>; Emma Narotzky <enarotzky@gmail.com>; Aaron Clausen <aaronjclausen@gmail.com>; Billy Burton <mtnhotspringer@gmail.com>; Paulette Epple <bigskyepples@msn.com>; Lou Ann Harris <montlou311@gmail.com> Subject: Sacajawea Audubon Society comments on the PRAT CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hello Addi, Please see the attached Sacajawea Audubon Society comments on the Bozeman PRAT plan. Thank you for the opportunity to comment on Bozeman's future. Sincerely,Vicki SaabSAS Board Member and Conservation Committee Victoria Saabvictoriaannsaab@gmail.com “Kindness is like snow. It beautifies everything it covers.”– Kahlil Gibran "La mejor red social es una mesa con amigos." 1 To: Bozeman City, Parks and Recreation Department and Urban Parks and Forestry Board From: Sacajawea Audubon Society (SAS) Re: Comments on the Bozeman PARKS, RECREATION, AND ACTIVE TRANSPORTATION PLAN (PRAT) Date: 15 February 2023 Sacajawea Audubon Society (SAS) is a group of over 800 members, and we appreciate this opportunity to comment on the City of Bozeman 2023 Comprehensive PARKS, RECREATION, AND ACTIVE TRANSPORTATION PLAN (PRAT; draft November 2022) Goal 4 (ADAPT to changing environmental pressures) and the PRAT Draft Design Manual (January 2023 update). The overarching goal of SAS is to promote the conservation of our natural environment for the benefit of wildlife and all that enjoy it. We are therefore pleased to see one of the City’s Unifying Principles for the Design Manual relates to Ecology & Environment: “The City should strive to maintain or enhance the ecological function and resiliency of its open space, trail, and recreation assets”(pg. 2). Comments PRAT Goal 4- P. 92 – Would be helpful for this section on Goal 4 to start by defining “open space”, “natural areas”, and “critical habitat” to help clarify the entire section. Would be helpful to be consistent throughout the document by using one term “open space” or “open land” but not both terms. p.94, “Pull best practices from past plans and local manuals as a guide, like the 2017 Gallatin Valley Hazard Mitigation Plan, 2018 Climate Vulnerability and Resilience Strategy…” Please provide URL’s for the referenced documents. p.94, “Rather than starting from scratch, the City can look to existing environmental standards and benchmark systems like SITES.” Please provide a URL (address to a webpage) for SITES. p. 95, “Parks are ideal places to prioritize environmental restoration and build awareness of natural systems. This can be accomplished by planting native vegetation, incorporating trails that immerse people in nature while staying on paths, reducing the use of machinery or chemicals in maintenance processes that can impact water and air quality, and communicating the ecosystem service values of natural areas.” Comment: require that paths are developed on the edge of riparian areas, no development of foot or bike paths through riparian vegetation, and require plantings to include at least 50% native vegetation. p. 96, “Promote the protection and enhancement of intact, contiguous critical lands through parkland acquisition ◊ Identify large areas of significant ecosystem benefit in areas of future City expansion and identify funding mechanisms or partnerships for acquisition.” Comment: We commend this strategy but need clarification. Please define “critical lands”. Do “contiguous critical lands” exist? Are contiguous critical lands referencing waterways and riparian areas? How is “significant ecosystem benefit” defined? 2 Please clarify. Ensure that development is minimized to maintain the ecological integrity of the critical lands. p.96 “… land dedication in new developments is limited to upland parcels that enable active uses, however these same dedication requirements do not include improvements to the park beyond irrigation infrastructure, sod, and perimeter trees and sidewalks. Incorporating critical habitats, riparian corridors, and wetlands into a portion of the land dedication requirement will enable the City to take on unified management of critical lands and increase the development’s responsibility to improve adjacent areas for more active uses with more elements than previously required.” Comment: Needs clarification, first sentence states that active uses will be on upland parcels but 2nd sentence talks about incorporating critical habitats and riparian corridors, will these be part of the land dedication in new developments? Also, note that the term “critical habitat” has a specific meaning in federal and state documents; needs clarification, the use in the PRAT document is not congruent with the U.S. Fish and Wildlife Service term as it relates to federally listed endangered or threatened species, see the fact sheet: https://www.fws.gov/sites/default/files/documents/critical-habitat-fact-sheet.pdf p. 97, “Not only will this change to dedication encourage responsible long term stewardship by the City, it will also reduce the burden on maintenance staff to mow large undeveloped open space parcels. ◊ Direct funding outside the City in areas of critical natural resource benefit to prevent net loss of open land.” Comment: Does this mean outside the city limits and into the county? Please clarify, does this mean in the city jurisdictional land area? P. 97, “Find more ways for people and children to interact with wetlands, waterways and forests.” Comment: We suggest replacing the word “interact with” to “value”. p. 98, Prioritize simple irrigation systems over advanced systems to reduce unnecessary water waste. Comment: Change to “require irrigation systems to reduce unnecessary water waste”. Not clear of the meaning of advanced vs. simple irrigation systems. p. 98, “◊ Increase the amount of drought tolerant and native vegetation and trees in the park system. Work with the Montana Master Gardener Program and other like minded organizations to confirm and update plant selection guidance, share low water best practices with city staff, and lead workshops with community members to promote residential drought tolerant landscape.” Comment: For like-minded organizations, include Sacajawea Audubon Society and Valley of the Flowers Chapter of the Montana Native Plant Society. Change “Increase the amount of drought tolerant and native vegetation” to “Increase the amount of drought tolerant vegetation by requiring a minimum of 50% native vegetation and trees in the park system.” p. 98, “… and lead workshops with community members to promote residential drought tolerant landscape.” Comment: suggested change to “promote residential drought tolerant landscapes using at least 50% native plant species.” 3 Comments Draft Design Manual- Pg. 10, Natural Areas (and natural areas within parks): It is wonderful to see the City recognizing Natural Areas as one of their primary park types. These are some of the most beloved parks as people seek a connection with nature during their park recreation time. Some of the Natural Areas and Community Parks with Natural Areas within them are recognized and greatly valued as “Birding Hotspots”. The discussion of the Natural Areas on page 10 of the draft makes some excellent points which should be maintained in the final document and implemented. Specifically: o Protecting parcels of natural vegetation, drainage ways, and ravines o Protecting lands such as wetlands, riparian areas, and ponds o Development should be kept to a level that preserves the integrity of the resource o Minimize development of hard surfaces, including bike trails and boardwalks and strategically place them to avoid dissecting, diminishing or disturbing natural areas within parks, ADD: this is particularly important within riparian areas. o Access points should be limited Note: Under Environmental Benefits the mention of tidal marshes should be deleted! Pg. 3, System-wide Park Standards: Within the section on Trees, the planting of native tree species should be encouraged. We recommend that within our parks at least 50% of the planted trees, shrubs, perennials and grasses be native species. The City of Bozeman Water Conservation Division is currently developing new Landscaping and Irrigation Standards for new construction which will be incorporated into a Water Efficient Landscape Ordinance. Their focus is on reducing the installation of high water use turfgrass, support the installation of functional turfgrass and increase the installation of drought adapted landscaping in future development. Native plants are some of the most drought- tolerant, most hardy species that can be planted. Native plantings fit perfectly with the stated goal on page 97 of the PRAT Draft Plan (November 2022 edition) that our park system should “mirror the greater natural context of Bozeman.” Native plants provide more than just drought tolerance. They are the basis for our sustainable local food web, make our community more ecologically resilient, and support biodiversity. There is a growing nation-wide movement to plant natives as we have learned how important they are to providing ecological services and support to a wide variety of insects, pollinators, and wildlife. Many pollinators and native bee species rely entirely on specific native plants. Pollinator populations are dropping dramatically, insect populations are plummeting, and songbird populations that rely on insects to feed their young are on a steady decline. Drought tolerant European and Asian exotic plants are commonly used in landscaping but they are often sterile additions to landscapes because many are not palatable to local insects. This is an easy opportunity to make an ecological difference as we set new landscape standards in our parks. The PRAT Draft Design Manual recognizes the need for native plantings in many park types (see examples below). This same language should be added into discussions of all park types. Or it could be placed in the System-wide Park Standards on page 3. Either way, we encourage the City to take an even more proactive role in supporting native plantings and require that 50% of new landscaping in parks be 4 native plants. The Water Conservation Division has already created a list showing the native plants recommended for our area. Pg. 6, Pocket Parks: recommends- “Plant native, hardier plants” Pg. 8, Community Parks: it is stated- “Whenever possible, these parks should increase planting areas that can capture stormwater and support water conservation measures citywide, through low irrigation, native plantings.” Pg. 10, Natural Areas: “Use the existing types of vegetation community present in natural areas,….. to guide the restoration design for adjacent sites and for site expansion within existing parks.” In conclusion, SAS supports all City efforts to conserve and protect natural areas as future parks are developed and we encourage the use of native plants in landscaping our parks. Thank you for considering these comments. Sincerely, Sacajawea Audubon Society Board of Directors: Chris Nixon, president, pres@sacajaweaaudubon.org, and members John Edwards, Emma Narotzky, Loreene Reid, Vicki Saab, Aaron Clausen, Travis Kidd, Frank Marchak, Janet Winnie, Billy Burton, Kyle Moon, and Conservation Co-chairs Lou Ann Harris and Paulette Epple