Conservation

A plan to develop a southwest-northeast artery through Fort Ord, known as the Eastside Parkway, has recently been revived. This would have a major impact on one of the Native Plant Reserves, appears to be in clear breach of the agreement between FORA and the Chapter and is being strongly opposed by the Chapter.

Similarly, a proposed realignment of South Boundary Road at the southern end of Fort Ord directly impacts one of the plant reserves and vigorous efforts are being made by CNPS to eliminate or at least minimize any such impact. A significant population of the endangered Seaside Bird’s-beak (Cordylanthus rigidus subsp. littoralis) is threatened by the proposed realignment.  Representatives of the chapter met with FORA representatives on January 18th.  Certain aspects of the proposals remain to be clarified before substantive discussions can take place.  Meanwhile, on February 11th, the Monterey County Superior Court heard a case brought by Keep Fort Ord Wild against FORA arguing that FORA breached state environmental laws in its approval of the South Boundary Road realignment proposals. The court decided against Keep Fort Ord Wild.

The Chapter has a long-standing interest in potential developments and road  improvements proposed in high quality habitats areas on lands given to the City when the former military base was decommissioned. CNPS has two biologically diverse plant reserves that flank South Boundary Road and include key habitat for the California Endangered Seaside Bird’s Beak and an exceptional area of maritime chaparral.

On October 11, 2019, members of the Chapter Board met with Del Rey Oaks Mayor Alison Kerr and City Manager Dino Pick to initiate a conversation about the status of the two CNPS Plant Reserves in the DRO City limits. Also in attendance was an attorney representing the Fort Ord Reuse Authority and legal counsel retained by MB-CNPS.  On December 13, 2019, members of the Chapter’s Conservation Committee met with representatives from Del Rey Oaks and the Fort Ord Reuse Authority (FORA) to learn about new proposals for widening of South Boundary Road. Plant Reserve 1 North and key populations of the California endangered Seaside bird’s beak will be severely impacted by proposed road improvements.

The Chapter submitted scoping comments for the FORTAG Environmental Impact Report.  We noted that the FORTAG project will pass through or near many sensitive plant communities such as riparian, maritime chaparral, and oak woodland, including CNPS Plant Reserve #1.  We requested that the EIR include a good baseline study of the native plant communities to identify disturbed areas that would be more appropriate for the route and asked that when surveying for sensitive plants and communities, that the list include all potential CNPS List 4 species in addition to List 1 rare plants.

Since trail construction has great potential to introduce or spread non-native and invasive plants over a large region of native plant communities, the Chapter requested that mitigation measures be carefully developed to prevent weed proliferation during and following construction.  In addition, we requested that Best Management Practices for long term trailside maintenance focus on methods to minimize disturbance on the edges of trails so that native plants can compete at the trail edge and weedy zones can be avoided.

Attachments:
1975 Resources Document
Map of Fort Ord Trails showing Native Plant Reserves
Fremontia Article – July 1976
Army Brochure on Fort Ord rare plants
7-Sept-17 letter to Ralph Rubio
20-July-18 letter to Michael Houlemard
27-Nov-18 letter to Jonathan Brinkman

The Chapter commented on the Draft Habitat Conservation Plan for the decommissioned Fort Ord military base. The HCP has taken more than 20 years to develop. Because the Fort Ord Reuse Authority will sunset in 2020, the HCP will have to be implemented and funded by a collaborative Joint Powers Authority that has yet to be developed.

The Chapter submitted comments to the Board of Supervisors on this $117k grant to remove fuel vegetation along park roads and around infrastructure. The project planner expressed willingness to accept input from CNPS during the planning process to protect special status plants, Central Maritime Chaparral, and high-quality Monterey Pine Forest.

Attachments:
Letter to Monterey Co Supervisors

The proposed project is a grading and vegetation removal effort in an area of Environmentally Sensitive Habitat. The Chapter submitted comments voicing major concerns regarding the lack of success criteria and monitoring for restoration to address grading on erosive slopes in excess of 25% and the removal of special status plants and Central Maritime Chaparral.

Another PG&E issue relates to power pole vegetation removal proposed in sensitive Maritime Chaparral habitat in north county  This is still being challenged by homeowners. CNPS asked the utility for clarification on the exact dimensions of the disturbance, which will impact rare manzanitas and Eastwood ‘s goldenbush.

Attachments:
Letter to Monterey Co. Zoning Administrator

The Chapter submitted comments on the Draft EIR/EA for Phase 2. We stressed that successful mitigation for the loss of oak woodland requires that sufficient contiguous acreage be identified for preservation or planting for the full CCCVC buildout. We voiced concern that a suitable replacement site for the Phase 1 required mitigation still needs to be identified.  We also requested that locally-collected  native seed be used for revegetation.

Attachments:
Letter with Comments on Draft EA and IS/MND -July 2014
14-Dec-18 letter to Senior Environmental Planner re Draft EIR – Dec 2018

The Chapter interacted with the Parks Division of the Monterey County Resource Management Agency to discuss how to limit damage to trailside native plants during the race, especially on the Deer Trail segment. Ribbon was installed to keep runners on the trail on the lower section and proved helpful.  We will continue to work with Parks to identify ways to further protect the plants and to suggest alternate routes

The Chapter spoke at a City Council meeting to point out that the project Coastal Development Permit application failed to address consistency with Sand City’s own Local Coastal Program. The Draft Habitat Conservation Plan was acquired through a Public Records Act request. An important population of the endangered Monterey Gilia (Gilia tenuiflora subsp. arenaria) is threatened by this proposed development.

The chapter also commented on the Draft Habitat Conservation Plan prepared for the massive South of Tioga Project proposed for Sand City. 356 multi-family units, 216 hotel rooms and a restaurant are proposed for the 10.63-acre project site, with only 0.9 acres set aside for mitigating impacts to Dune Scrub habitat where federally endangered Monterey Gilia and threatened Monterey Spineflower  (Chorizanthe pungens var. pungens) occur. Mitigation measures fail to conserve any Monterey Gilia habitat in adjoining undeveloped property where future development will eliminate biologically significant Monterey Gilia habitat. The Sand City project sets a very bad precedent by not considering cumulative impacts to extremely important Monterey Gilia and Spineflower habitat immediately adjacent to the big proposed development.

Attachments:
Letter 4-Jun-18 to Sand City re Final Environmental Impact Report
CPRA Request to Sand City

Our chapter has been working at least since the 1980’s to modify activities at PBBSC that have been damaging the habitat of the rare Dudley’s lousewort (Pedicularis dudleyi). In November 2012,the chapter sent a letter to the various agencies having jurisdiction over rare plants urging that protective actions be taken. Since then the local scout council has merged with the Santa Clara Scout Council. The new leadership indicated that it wants to work with our chapter to resolve the problems, and in June 2013, various chapter representatives, along with CA Dept. of Fish & Wildlife biologist Jeff Cann, met with Ron Schoenmehl, Director of Support Services; Michael Wilson, Camping Manager; and biologist Andrea Edwards, who is working on a plant management plan for the camp, to look at some of the problem areas and discuss possible solutions. Of particular concern has been the removal of “hazard” trees, especially Douglas firs, which provide essential habitat for the lousewort; methods of protecting the existing plant populations, and plans for further removal of trees for fire safety. The chapter continues to play an active role in monitoring the progress of the plant’s population and habitat.

In January 2019, David J Keil published a treatment of Pedicularis rigginsiae (the Arroyo de la Cruz lousewort), a San Luis Obispo County endemic. See Phytoneuron 2019-2: 1-8. This population had formerly been treated as P. dudleyi, and its recognition as a separate species significantly decreases the known range of P. dudleyi. Professor Keil recommends that P. dudleyi retains its Rare Plant Rank of 1b.2.

The Chapter commented once again on the PG&E proposal to modify the right-of-way under one of the power towers in the Coastal Zone of North Monterey County. Apparently, the tower was installed years ago and is now considered too short to meet federal safety standards addressing distance between the ground and high voltage power lines. Rather than increase the height of the tower, the proposal was to dig out the ground below the tower to achieve distance requirements. The Biological Assessment was inadequate and the County’s initial resolution authorizing the project failed to document the actual square footage of the disturbance area in the extremely erosive sandy soils below the power tower. The disturbance footprint included rare Maritime Chaparral habitat and a number of extremely rare plants including Ericameria fasciculata, Eastwood’s goldenbush. PG&E withdrew their permit application at the 11th hour and project approval is pending the submittal of additional information, including the exact dimensions of the disturbance footprint and appropriate mitigations for the damage to Maritime Chaparral.

The Chapter submitted comments on the Initial Study-Mitigated Negative Declaration (IS-MND) for the Palo Corona Regional Park General Development Plan.  We expressed concerns about the lack of a parkwide botanical survey.  A complete parkwide survey is needed for an accurate assessment of how significant the quality of a proposed project’s flora is in relation to the remaining undeveloped habitats in PCRP.  We advocated for the avoidance of impacting habitats that are of high quality as measured by the lack of non-native and invasive plants and the dominance of native plant cover.  In all cases, maximum effort should be made to steer development to areas of lesser quality that are without special status plants and are already degraded by invasive or non-native plants.  We also requested that the special status plant species include CNPS List 4 species.

The Chapter also expressed the need for a Basic Management Plan covering ongoing trail maintenance that would ensure that trailside brushing does not allow for non-native and invasive species to spread into high quality habitat. An expanded Worker Environmental Awareness Program should educate workers about which non-native species to remove and which native species to protect.

This is a project, dating back to 2009, on 870 acres adjoining Toro Park to create 212 homes and a 35-acre winery on 870 acres adjoining Toro Park. It would involve removing 921 oak trees and remove 3-4 acres of parkland for the access road. Despite strenuous objections, the Board of Supervisors approved the project in late 2014. Litigation is ongoing to try to reverse this approval.

In December 2019 it was announced that an agreement had been reached between the Developer and the Agricultural Land Trust for the latter to purchase conservation easements for the bulk of the 870 acre property, preserving it for agricultural use and protecting it from future development.

Attachments:
Monterey County Herald Article 24th-Dec-2019

In May 2012, the California State Parks Department announced the first public workshop intended to serve as the “CEQA scoping meeting” at which the issues to be covered in a general plan for the Carmel Area State Parks plan will be identified. This process was apparently initiated because many local residents opposed a proposal the previous year for a zipline in the unit across from Point Lobos without having a General Plan in place. In late 2018, our Chapter submitted comments on the Draft EIR and the Preliminary General Plan. Protection of sensitive plant habitats and continued access to the Gowen Cypress Forest were stressed.

Attachments:
1-Oct-18 letter to CA State Parks re Draft Environment Impact Report

First Solar Corporation met with members of our chapter to provide an update to the biological report for this 2,500 acre solar project just southeast of Parkfield. The project impacts 11 sensitive plant species and 500 acres of wildflower fields. Mitigation is proposed, but our chapter is not convinced it will be adequate. Unfortunately, the mitigation plan is deferred until after the project approval. Degraded agricultural lands would be much more appropriate than an area rich with sensitive plants. Conservation groups have been pursuing mediation with the Governor’s office to improve the mitigation.

This is an exceptional area of unusual serpentine barrens and habitats surrounding San Benito Mountain in eastern San Benito County. It is home to several endangered species and numerous sensitive species. This area was closed in May 2008 because of health concerns stemming from the presence of asbestos in the area. In March 2014, limited areas were opened for non-motorized access only. Our chapter had been involved for decades, trying to get BLM to limit damage to the environment caused by largely unchecked motorcycle and Off Highway Vehicle (OHV) usage. Pressure from a lawsuit, which our chapter was instrumental in, led to the BLM finally designating a route network and open play areas — about 15 years ago. Expanding usage and limited BLM enforcement, though, allowed erosion and damage to continue. BLM then issued an emergency closure due to concerns about asbestos exposure about ten years ago. In 2013 Rep. Sam Farr introduced a bill. HR 1776, to establish a Clear Creek Recreational Area and, among other matters, to reopen some 270 miles of routes and open areas to OHV usage. It is unclear how this proposal can be reconciled with the health concerns that caused the closure of the area in 2008. This bill did not proceed but a  new bill (HR 403) was introduced in January 2019 by Representative Jimmy Panetta to create a Clear Creek National Recreation Area.  The pre-existing concerns are still very much present and the Chapter, state CNPS and Calwild (the California Wilderness Coalition) have all expressed concerns about the current form of the bill and are opposing it unless a number of changes are made to it.

This was a project dating back to before 2005 to build over 280 houses on the site previously occupied by the Rancho Cañada West Course. There were numerous objections, by our chapter among many others to such a development in the flood plain of the Carmel River on both public safety and environmental grounds. A more modest proposal for 130 units was put forward in early 2014 and approved by the Board of Supervisors in December 2016. In September 2018, a Superior Court Judge Lydia Villarreal issued an intended decision that the board’s approval of this development on an 81-acre portion of the former Rancho Cañada golf course site was flawed because the proposal’s environmental impact report included a project description that was inaccurate and its analysis of project alternatives was inadequate.