October 3, 2014 Mayor Ed Honea and Councilmembers Marana Town Council 11555 W
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October 3, 2014 Mayor Ed Honea and Councilmembers Marana Town Council 11555 W. Civic Center Drive Marana, AZ 85653 RE: Lazy K Bar Ranch Rezoning and General Plan Amendment Applications Dear Mayor and Councilmembers: Thank you for the opportunity to provide comments on the Lazy K Bar Ranch Rezoning and General Plan Amendment applications. I am writing on behalf of the Coalition for Sonoran Desert Protection. Founded in 1998 and comprised of 41 organizations, the Coalition works to protect the long‐ term conservation of biological diversity and ecological function of the Sonoran Desert through comprehensive land‐use planning. The Coalition has worked productively with the owners of the Lazy K Bar Ranch for over a decade, and Coalition representatives met on two occasions at the request of the property owner and their representative to provide them feedback on the proposed development. We, along with other conservation experts and Saguaro National Park staff, provided them with specific guidance on how to best develop this parcel while retaining the values that make this parcel so important to regional connectivity and preserving the unique characteristics of Saguaro National Park and its significant contribution to local economies. This parcel has been designated in Marana’s General Plan as “environmentally‐ sensitive land,” (see Marana General Plan Map 6.1.A) which contains habitat for many special Sonoran Desert species that Marana intends to protect, including Lesser long‐nosed bat, burrowing owl, talus snail, Sonoran desert tortoise, and others, and targeted for 80% Natural Undisturbed Open Space (NUOS). As stated in the Marana General Plan: A regional effort is underway to create an effective wildlife linkage from the Tortolita Mountains to the Santa Cruz River and the Tucson Mountains (as described in the Marana Draft HCP). An application to the Regional Transportation Authority for funding a wildlife crossing study to evaluate crossing structures and placement at the junction of Avra Valley Road and Interstate 10 is currently being developed by a group that includes environmental organizations, Arizona Department of Transportation, and the Town of Marana. We specifically requested that a movement corridor for wildlife be preserved on both the west and north sides of the parcel. As the Town is aware, through its work toward a Habitat Conservation Plan, the wider the corridor width, the more effective (please see addendum). We suggested that should lots be relocated, they be relocated to the interior of the property, which will have very limited value for wildlife. We also suggested that the western portion of the trail loop be removed, and we understand that it has been. Unfortunately, there were only slight modifications to the configuration. The overall functionality of this proposal remains the same. Additionally, only 25% of the parcel (34.5 acres) is proposed to be conserved as NUOS, as opposed to the target of 80%. Overall, the Lazy K Bar development, as proposed, will create an obstruction for wildlife movement from the Tucson Mountains to the Santa Cruz River and the Tortolita Mountains. As such, we cannot support the Lazy K Bar Specific Plan and General Plan Amendment as it has been submitted. If the Mayor and Council would like to adopt recommendations to improve this configuration, we would respectfully request that you delay this item in order to work further with the property owners. We have attached background information that outlines the scientific importance of this specific location to regional wildlife connectivity, which the Town has long publicly supported, along with additional corridor information and a map of this wildlife linkage (Addendum). We hope you will consider these recommendations in your deliberations on this General Plan Amendment and Specific Plan. Thank you. Sincerely, Carolyn Campbell Executive Director Addendum Lazy K Bar Ranch and its Significance to the Tucson‐Tortolita Wildlife Linkage Because of its location, the 138‐acre Lazy K Bar Ranch property holds regional significance for the long‐term viability and movement of wildlife from protected areas such as Saguaro National Park in the Tucson Mountains to Tortolita Mountain Park and beyond. Although the proposal states that the property is “within 3 miles” of the Tucson‐Tortolita‐Catalina Linkage Design (Beier, et al 2006), it should be specified that the majority of the parcel is situated squarely within the middle of this wildlife linkage, and remains a critical piece of the landscape that is keeping wildlife movement viable (see Figure 1). Healthy and connected wildlife corridors are vital to counteract the effects of habitat fragmentation caused by the encroachment of development and other human impacts. Fragmentation can lead to loss of resources for survival, population isolation, and loss of genetic diversity. The entire parcel has also been identified as so biologically significant by a team of biologists as to be designated within a regional‐scale “Critical Landscape Connection” in the area that spans the Tucson Mountains, across the I‐10/Santa Cruz River corridor to the Tortolita Mountains. As such, it is eligible for purchase as “Wildlife Corridor” open space in the upcoming county bond program. Its close proximity to Saguaro National Park also contributes to its importance as a “transitional” buffer from the park to higher density development to the east. The western and northern portions of the Lazy K Bar parcel present topographic features that are challenging for wildlife movement. Along the western property boundary, the landform rises in a cliff formation leading to a natural pass at the northwestern corner where there are rocky outcrops leading southward to more level land. The northwestern portion of the property contains mature, old growth ironwood trees which, due to their “evergreen” nature, provide some visual screening. However, due to the natural landforms and the other factors mentioned above, the current development configuration does not provide adequate space and cover for sensitive wildlife movement. Lastly, this parcel has been identified in the following evaluations as important for wildlife: 1) the Lazy K Bar HCP, 2) as a Critical Landscape Linkage in the Sonoran Desert Conservation Plan, 3) the statewide Arizona Wildlife Linkages Assessment, 4) Dr. Paul Beier’s Tucson‐Tortolita‐ Santa Catalina Mountains wildlife linkage design, and 5) the 2014 Conservation Bond, among others. Additional Wildlife Corridor Information Habitat fragmentation, where human activities such as roads and urbanization split up habitat areas, causes animals to lose both their natural habitat and the ability to move between regions to use all of the resources they need to survive. Habitat fragmentation due to human development is an ever increasing threat to biodiversity. Wildlife habitat corridors are a means of mitigation for development impacts. A wildlife corridor is an area of habitat connecting wildlife populations separated by habitat 1 fragmentation. This allows an exchange of individuals between populations, which may help prevent the negative effects of inbreeding and reduced genetic diversity that often occur within isolated populations. Corridors help facilitate the re‐establishment of populations that have been reduced or eliminated, such as cougars in the Tucson Mountain range. According to the best available science to date, the larger the width of the wildlife corridor, the better. Species can be categorized in one of two groups: passage users and corridor dwellers. Passage users occupy corridors for brief periods of time. These animals use corridors for such events as seasonal migration, dispersal of a juvenile, or moving between parts of a large home range. Usually large herbivores such as mule deer, medium to large carnivores such as bobcats and cougars, and migratory species are passage users (Beier & Loe 1992). One common misconception is that the corridor only needs to be wide enough for the passage users to get through. However, the corridor still must be wide enough to be safe and also encourage the animals to use it, even though they do not live out their entire lives in it. Corridor dwellers can occupy the passage anywhere from several days to several years. Species such as plants, reptiles, amphibians, birds, insects, and small mammals can spend their entire lives in linear habitats. In this case, the corridor must include everything that a species needs to live and breed, such as soil for germination, burrowing areas, and multiple other breeding adults (Beier & Loe 1992). Ideally, wildlife corridors, especially in the Sonoran desert where visual screening is sparse, are at least one kilometer (0.62 mile) in width, per the Tucson‐Tortolita‐Santa Catalina Linkage report1 and as demonstrated by the planning process for connecting the eastern Tortolita Mountains, across Oracle Road (SR 77), to the western Santa Catalina Mountains. To remain functional, regional wildlife corridors should be, at minimum, 500 meters or greater in width. Wildlife are sensitive to human encroachment due to a number of different factors known as edge effects: what they can see, hear, and smell as well as the topography of the land. Wildlife corridors are susceptible to edge effects; habitat quality along the edge of a habitat fragment is often much lower than in core habitat areas. Wildlife corridors are important for large species requiring significant sized ranges such as cougars; however, they are also vital as connection corridors for smaller animals and plants as well as ecological connectors to provide a rescue effect. Without a buffer zone, corridors become susceptible to harmful outside factors, or edge effects, such as invasive plants and weeds, predators (outdoor dogs, feral or domestic cats), light intensity, sounds associated with traffic and other human activities, odors and chemicals, from streets, suburban development, rural homes, and grazing allotments. Additional Research and Sources The Lazy K Bar was first identified as important habitat when the current owners completed the first Habitat Conservation Plan for the cactus ferruginous pygmy‐owl under the federal Endangered Species Act.