Oppose New Development at Oso Flaco Lake Natural Area, Comments due March 18

Hello friends in conservation of biodiversity and habitat!
The draft Oceano Dunes Public Works Plan and Environmental Impact Report is out.
The plan is BAD NEWS for the Oso Flaco Lake Natural Area!

Please email your comments now to the California Coastal Commission and State Parks by March 18:

OceanoDunesReview@coastal.ca.gov AND OceanoDunes.PWP.EIR@parks.ca.gov

BACKGROUND:
State Parks wants to put in a HUGE campground next to Oso Flaco Lake, bringing an impact on water tables, water quality, trash, and the introduction of dog waste to the area. For example, in their "future" plan, it includes:

"3.3.7 Oso Flaco (Future) Improvement Project
Up to 200 RV campsites with 12 combination (restroom and shower) buildings."

See Appendix A1. - https://www.oceanodunespwp.com/en/documents/draft-eir

This good word from Kara at Friends Of Oso Flaco Lake:
"The California Coastal Commission just released its staff report on the State Parks draft PWP/EIR. See that report here:

https://documents.coastal.ca.gov/assets/oceano-dunes/Commission%20staff%20recommendation%20synopsis%20and%20executive%20summary.pdf

The report generally rejects the draft PWP/EIR and calls for the five-year phase out of off-highway vehicles at Oceano Dunes. As stated in the FOOFL (Friends Of Oso Flaco Lake) letter, this staff report and its recommendations have been a long time coming; it’s the right answer for the Central Coast, from the perspective of public health, economic vitality for the region, wildlife protection, environmental justice, community fairness, and access to the beach and coast, for all people."

See their great Power Point - https://drive.google.com/file/d/1cR8bLbpiaOvPM7RmW9bWBtKgazhPhgrm/view?usp=sharing

Sample Letter -
https://drive.google.com/file/d/1B0POqiCZn16_1wAb9cteXkyzY3TyiErv/view?usp=sharing

Now, to focus on threats to Oso Flaco Lake Natural Area species of concern!

Simply put, the water quality and water table levels are already an issue, especially with Cirsium scariosum var. loncholepis, the La Graciosa thistle.

Out of 23 known occurrences, 2 are extirpated (gone forever from that location), and 12 are presumed extirpated.

http://www.rareplants.cnps.org/detail/487.html

QUOTE": "Threatened by development, vehicles, groundwater pumping, and non-native plants. Possibly threatened by grazing."

I disagree with digging a new well for the State Parks proposed PWP that includes flush toilets, and staff offices and housing.

I think we need to instead, A) monitor water quality B) actively use technology to remove nitrates from the water entering the watershed from the agricultural fields.

In Santa Maria, there is a bio-filter that catches farm field runoff before the water enters the Santa Maria River. This greatly reduces nitrates. The microorganisms in the marshy areas of Oso Flaco Lake are the primordial lowest level food chain creatures, and they are sensitive to water quality also.

For decades people have been attempting to restore and protect Little Oso Flaco Lake, Oso Flaco Lake, and Oso Flaco Creek. These are rare dune lakes found in a rare habitat - The Guadalupe-Nipomo Dunes.
https://en.wikipedia.org/wiki/Guadalupe-Nipomo_Dunes

The Oso Flaco Lake Natural area, is part of this 18 mile dune complex, and is an 800 acre parcel to the immediate north of the existing Guadalupe-Nipomo Dunes National Wildlife Refuge.
https://www.fws.gov/refuge/guadalupe-nipomo_dunes/

QUOTE from the page:
"Did you know?
There are at least 26 imperiled plants and 118 imperiled animals that can be found on the refuge and surrounding dune habitats."

There was an extensive survey of much of the dune complex (aprox. 8,330 acres) that is eligible to be included in the Refuge, should the existing land owners cooperate. For example, The California Department of Parks and Recreation (aka State Parks) who owns the 800 acre Oso Flaco Lake Natural Area parcel, could, if they chose to do so, grant an easement, donate, or sell the parcel to become part of the existing refuge, and managed as a whole along with the existing land immediately adjacent to the south. The details and the comprehensive plans for conservation, as well as lists of species can be found here:
https://www.fws.gov/refuge/Guadalupe-Nipomo_Dunes/what_we_do/planning.html

When land is included in a National Wildlife Refuge, certain passive recreation, that is dependent on the resource, is usually allowed. These may include wildlife photography, hiking, fishing, hunting, and primitive camping. This would not include developed camping.

So, tell State Parks to do the right thing, donate the existing 800 acre parcel to be managed under the existing Guadalupe-Nipomo Dunes National Wildlife Refuge, and don't propose any development that is not in compliance with a National Wildlife Refuge plan. https://www.fws.gov/refuges/

As I mentioned, some of my main concerns with allowing what State Parks wants to do to the Oso Flaco Lake Natural Area include the impact to the La Graciosa thistle (federally listed as endangered). This plant already had populations extirpated in the area from illegal OHV use in the 1970's. Of course the Western Snowy Plover with only about 2,600 individuals left makes a home in the foredunes here.

As I mentioned in this journal post (https://www.inaturalist.org/journal/leafybye/29041-the-natural-resources-of-the-nipomo-dunes-and-wetlands-california-department-of-fish-and-game-1976) in 1976 a joint report from the California Department of Fish and Game and U.S. Fish and Wildlife Service, named "The natural resources of the Nipomo Dunes and Wetlands" explained that due to unregulated OHV use around Little Oso Flaco Lake, the vegetation was destroyed, and then the once stabilized dunes became active. Once the dunes started to move, scientists noticed excess siltation in Little Oso Flaco Lake (upstream from Oso Flaco Lake). The volume of the lakes was on the decline, and something needed to be done.

For decades after, The Nature Conservancy and volunteers were the ones who worked on the restoration, not State Parks. Then The Nature Conservancy handed over the restoration to State Parks, who promised to continue the work. History is here:

https://www.nature.org/en-us/get-involved/how-to-help/places-we-protect/guadalupe-nipomo-dunes/

I went to the Santa Maria Library and found the history on conservation, here are some scanned articles:
https://drive.google.com/drive/folders/1ESnFY5azKC718xgF59PQoCGfWarzkXSz?usp=sharing

https://www.fws.gov/refuge/Guadalupe-Nipomo_Dunes/Wildlife_and_Habitat/Wildlife.html

Some Federal Species of Concern in the Oso Flaco Lake Natural Area are;

Point Conception Jerusalem Cricket, Sandy Beach Tiger Beetle, Rude's Longhorn Beetle, White Sand Bear Scarab Beetle, Globose Dune Beetle, Morro Bay Blue Butterfly, Smith Blue Butterfly, Oso Flaco Patch Checkerspot Butterfly, Oso Flaco Flightless Moth, Oso Flaco Robberfly, California Toad, Western Spadefoot Toad, California Tiger Salamander.

Also, there are many species of year-round and migratory birds who visit the lakes.

California least tern (Sternula antillarum browni) - federally endangered
western snowy plover (Charadrius nivosus nivosus) - federally threatened
American peregrine falcon (Falco peregrinus anatum) - state fully protected
California brown pelican (Pelecanus occidentalis occidentalis) - state fully protected

golden eagle (Aquila chrysaetos) - state fully protected
white-tailed kite (Elanus leucurus) - state fully protected
northern elephant seal (Mirounga angustirostris) - state fully protected

I have also seen the Salmon running in the lake! Once entire parts of the lake were splashing with them a couple of years ago!

The report from 1976 mentioned that the invertebrates of the Oso Flaco Lake area are among the least studied organisms of the area.

So, before allowing developers to change the area forever, let us instead conserve it AS IS, and study it further.

Kara said:
"The California Coastal Commission hearing on the draft PWP/EIR is March 18, 2021, and it will be historic. Don’t miss it – for more details, visit: http://www.coastal.ca.gov/oceano-dunes/

check out this SLO Tribune article, hot off the press: https://www.sanluisobispo.com/news/local/environment/article249317740.html"

Thanks so much for helping save this international treasure,

Leif Behrmann

P.S. Again...

Power Point - https://drive.google.com/file/d/1cR8bLbpiaOvPM7RmW9bWBtKgazhPhgrm/view?usp=sharing

Sample Letter -
https://drive.google.com/file/d/1B0POqiCZn16_1wAb9cteXkyzY3TyiErv/view?usp=sharing

Posted on February 27, 2021 06:53 PM by leafybye leafybye

Observations

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Branching Phacelia (Phacelia ramosissima)

Observer

leafybye

Date

January 2021

Description

dormancy is over

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Arroyo Willow (Salix lasiolepis)

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leafybye

Date

January 2021

Description

both types, pistillate and staminate catkins are flowering now

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Red Sand-Verbena (Abronia maritima)

Observer

leafybye

Date

January 26, 2021 04:03 PM PST

Description

Abronia maritima spans from near the city of Pismo to at least Point Sal. At least most of the 18 mile range of the Guadalupe-Nipomo Dune complex.

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Red Sand-Verbena (Abronia maritima)

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leafybye

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January 26, 2021 04:01 PM PST

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Dunedelion (Malacothrix incana)

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leafybye

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January 2021

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Silver Beachweed (Ambrosia chamissonis)

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leafybye

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January 26, 2021 03:58 PM PST

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Beach Suncup (Camissoniopsis cheiranthifolia)

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leafybye

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January 26, 2021 03:57 PM PST

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Chamisso Bush Lupine (Lupinus chamissonis)

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leafybye

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January 26, 2021 03:53 PM PST

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Chamisso Bush Lupine (Lupinus chamissonis)

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leafybye

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January 26, 2021 03:50 PM PST

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Hooker's Evening Primrose (Oenothera elata ssp. hookeri)

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leafybye

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January 26, 2021 03:50 PM PST

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Beach Strawberry (Fragaria chiloensis)

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leafybye

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January 26, 2021 03:50 PM PST

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Coast Paintbrush (Castilleja affinis)

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leafybye

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January 26, 2021 03:49 PM PST

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Pacific Wax Myrtle (Morella californica)

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leafybye

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January 26, 2021 03:49 PM PST

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Silver Beachweed (Ambrosia chamissonis)

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leafybye

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January 26, 2021 03:48 PM PST

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California Goldenbush (Ericameria ericoides)

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leafybye

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January 26, 2021 03:46 PM PST

Description

Wind shaped

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Yellow Sand Verbena (Abronia latifolia)

Observer

leafybye

Date

January 26, 2021 03:39 PM PST

Description

In foredunes with A. maritima. I think this is A. maritima x A. latifolia

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Coyote (Canis latrans)

Observer

leafybye

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January 26, 2021 03:34 PM PST

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Beach Suncup (Camissoniopsis cheiranthifolia)

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leafybye

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January 26, 2021 03:31 PM PST

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Sea Bindweed (Calystegia soldanella)

Observer

leafybye

Date

January 26, 2021 03:29 PM PST

Description

Or Abronia latifolia

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Dunedelion (Malacothrix incana)

Observer

leafybye

Date

January 2021

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Red Sand-Verbena (Abronia maritima)

Observer

leafybye

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January 26, 2021 03:20 PM PST

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Southern Goldenrod (Solidago confinis)

Observer

leafybye

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January 26, 2021 03:11 PM PST

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Chamisso Bush Lupine (Lupinus chamissonis)

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leafybye

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January 26, 2021 03:10 PM PST

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Blochman's Ragwort (Senecio blochmaniae)

Observer

leafybye

Date

January 2021

Description

Some upper stems are flattened... are they infected somehow?

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Rosilla (Helenium puberulum)

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leafybye

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January 26, 2021 02:53 PM PST

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Northern Shoveler (Spatula clypeata)

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leafybye

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January 26, 2021 02:59 PM PST

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California Bulrush (Schoenoplectus californicus)

Observer

leafybye

Date

January 26, 2021 02:52 PM PST

Description

According to The Dune Mother’s Guide (book of plants)

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What

Hoary Nettle (Urtica gracilis ssp. holosericea)

Observer

leafybye

Date

January 26, 2021 02:50 PM PST

Description

Young

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Coast Twinberry (Lonicera involucrata var. ledebourii)

Observer

leafybye

Date

January 26, 2021 02:49 PM PST

Description

Coast twinberry

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Greenspot Nightshade (Solanum douglasii)

Observer

leafybye

Date

January 26, 2021 02:48 PM PST

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Bobcat (Lynx rufus)

Observer

leafybye

Date

January 26, 2021 03:59 PM PST

Description

Tracks

Comments

@serpophaga @flygrl67

Posted by leptonia over 3 years ago

@leptonia Thanks for pointing me to this. @leafybye Thanks for your post! I had not heard of this. It's awful and would be an environmental disaster! That's one of my favorite spots, and part of the reason is because there aren't a ton of people. We don't need to direct 200 RVs to that sensitive wetland and dune environment. I am on the road right now. At my next destination I think I'll have more time to read this and the articles to which you linked.

Posted by torres-grant over 3 years ago

Thanks friends! I know, I believe Oso Flaco Lake Natural Area is best kept as a quiet spot without a huge new coastal development. I heard about one of the public input planning meetings, and I attended it in December of 2019. At that meeting, I asked why and who decided to create a campground at Oso Flaco Lake, but the hired P.R. person could not tell me, and seemed nervous. Before and since then, the California Coastal Commission staff has released several reports which give the history of the permit given to the State Parks for running their recreational activities. What surprised me is that the use permit has been temporary since 1982, and the intensities of use were never finalized. The State Parks intends for their PWP to be the permanent permit for the next 40 years, and that's the big problem.

Specifically for Oso Flaco Lake, the area just to the south is the 2,553 acre Guadalupe-Nipomo Dunes National Wildlife Refuge. There was a big survey of Flora and Fauna of a larger area (the 8,900) acres, which includes the Oso Flaco parcel, to potentially be included in the Refuge. I feel as part of the existing Refuge to the south, the Oso Flaco area would be better managed as a whole. I submitted comments to that effect to the Oceano Dunes PWP last year, but when they released their "summary of comments" there was no mention of the Refuge.

Here is a scan of the press release with a map of the dune properties, as well as a table with acreage. I was lucky enough to find this document and scan it in: https://drive.google.com/file/d/1axgTOTF7qCo9tosqv9RWRjXX5V8X1nEp/view?usp=sharing

Posted by leafybye over 3 years ago

Also, you may be wondering why there are two emails to comment to. One is the official comment email for the State Parks Oceano Dunes PWP, the other was set up by the California Coastal Commission specifically to CC: the same email, in an effort to have more transparency. There is a danger that left to State Parks, our comments could be censored, as were mine in 2020.

Posted by leafybye over 3 years ago

Thanks for sending this out to a wider audience!

Posted by dkincmbria over 3 years ago

Thanks Dave, I hope it does reach those who care enough to type out a quick email.

Correction, the Coastal Commission email is due March 17. The State Parks PWP was due March 2, but I think it got moved to later.

I think in the local coastal law, the Oso Flaco Lake area is designated a Sensistive Resource Area (SRA) and I though that any development needed to be under a separate permit. Of course under the California Coastal Act of 1976, the entire dune complex is ESHA, Environmentally Sensitive Habitat Area and supposed to be protected. The California Coastal Commission is charged with ensuring those who use coastal resources comply with the law. The staff writes recommendations, then a hearing is held, and the coastal commissioners vote to approve or not approve the State Parks Plan. This happens March 18, so it is probably better to get comments in sooner than later so they can read them.

Also, it should be noted that also under consideration is the future of OHV on the dunes. The CCC Staff has recommended a 5 year phase out. There are other elements to the public works plan, and anyone may comment on any of it. Personally, I am sticking to Oso Flaco Lake mostly.

Here are some ideas for comments:
Leave Oso Flaco Lake Natural Area Primitive. Don't dig a new well. Don't put in septic. Don't put in electricity. Keep it primitive. It doesn't need improvement, it needs to be left alone. We don't need more foot traffic and vehicle traffic. It should be part of the Guadalupe-Nipomo Dunes National Wildlife Refuge, so grant U.S. Fish and Wildlife an easement to manage it as part of the existing Refuge to the south.

Posted by leafybye over 3 years ago

Folks, here is the California Coastal Commission Web Page about the Oceano Dunes PWP and the upcoming hearing.

http://www.coastal.ca.gov/oceano-dunes/

Posted by leafybye over 3 years ago

https://www.oceanodunespwp.com/en/meetings

"The comment period for the Draft PWP and Draft EIR has been extended until March 18, 2020."

However, the hearing is the very same day, so if you want the CCC to actually read what you write, get it in sooner than later.

Posted by leafybye over 3 years ago

If nothing else, the slide presentation gets to the heart of the matter!

https://drive.google.com/file/d/1cR8bLbpiaOvPM7RmW9bWBtKgazhPhgrm/view?usp=sharing

Posted by leafybye over 3 years ago

Wow, their own BioDiversity Management Plan states the extreme danger to the extremely rare plants, such as the Nipomo Mesa Lupine, which is ONLY found in the Phillips 66 Refinery Buffer area (formerly known as the Tosco Refinery buffer). This piece of property would be the next in line to the north for inclusion in the GNDNWR.

Please see here: https://www.oceanodunespwp.com/en/documents

the document named "Oceano Dunes Biodiversity Management Plan (January 2021)"

PAGE 32
"6. Oso Flaco Lake Complex
The Oso Flaco Lake Complex (OFLC) is a unique ecosystem of dune lakes
located at the southern end of ODSVRA. OFLC encompasses approximately
380 acres including Oso Flaco Lake, Little Oso Flaco Lake, Oso Flaco Creek and
includes 134 acres of CSP-owned lands – some of which are currently leased for
agriculture uses. An existing ½ acre parking lot provides pedestrian access to an
approximately one-mile foot trail at Oso Flaco Lake. CSP also holds a lease,
which prohibits public access, on 658 acres of dune habitat on private land in
the vicinity of the OFLC.
CSP is currently preparing a Public Works Plan (PWP) for ODSVRA which includes
the potential development of a new campground, CSP maintenance yard
facilities and a new southern entrance for OHV access. The proposed
campground would be sited on the CSP-owned lands adjacent to Oso Flaco
Lake. The specific access route from the campground to the southern entrance
has not yet been determined, but the currently proposed alternative in the PWP
would include acquisition of land and/or easements on private lands adjacent
to ODSVRA and major road improvements to provide for a southern entrance
for OHV use. Campground development would occur in two phases. Phase 1
would include 15 environmental campsites, construction of the maintenance
facilities, pedestrian trails around Oso Flaco Lake, and restoration activities to
provide a minimum 150-foot riparian buffer from existing riparian areas.
Development of a southern entrance for OHV access and the necessary land
acquisition and road improvements to facilitate the development will occur in
Phase 2. Phase 2 would include the development of 200 RV sites, 100 tent sites,
and 25 cabins."

Posted by leafybye over 3 years ago

AND THE BAD NEWS GOES ON FROM HERE:
Page 32 Oso Flaco Lake Complex (OFLC)

"6.1.Known Resources Present
The OFLC is one of the last remaining locations for two extremely rare and
endemic plants, marsh sandwort (Arenaria paludicola) and Gambel's
watercress (Nasturtium gambelii). Both species are listed as endangered under
both CESA and FESA and persevere at only one other location outside of OFLC.
Major threats to these species at OFLC include eutrophication/siltation of the
lakes and creek, upstream stream channel maintenance conducted by third
parties, and in the case of Gambel’s watercress, hybridization with a more
common species. The OFLC and its freshwater marsh community are also
important for several sensitive wildlife species. OFLC is an important feeding area
for least tern chick fledglings and is occupied by California red-legged frog
(Rana draytonii, CRLF), which are listed as threatened under FESA and a
California Species of Special Concern (CSSC). In addition, several other CSSC
including southern western pond turtle (Actinemys pallida), two striped garter
snake (Thamnophis hammondii), yellow warbler (Setophaga petechia), and
least bittern (Ixobrychus exilis) are routinely found in OFLC. While the CESA and
FESA listed Nipomo Mesa lupine (Lupinus nipomensis) is not found within the
OFLC, its only remaining known population persists on private lands and lands
leased by CSP which are being considered for acquisition to provide southern
access to ODSVRA."

Posted by leafybye over 3 years ago

BOO, NO NCCP!

"2.4.Recommended Additional Conservation Actions
In the event that CSP pursues projects that could impact one or more special
status plants, including but not limited to proposed projects such as a new
southern entrance, CDFW recommends that CSP establish a NCCP and receive
a related permit authorization in advance of any such related project impacts.
With an NCCP, CSP could consider the entirety of the conserved landscape, the
various natural communities present, and CSP’s existing and future
11
management activities to meet permit issuance under the NCCP Act’s
conservation standard. Furthermore, with a comprehensive view of CSP’s
management and development activities in an approved NCCP, future actions
are already authorized.
The landscape level approach with an NCCP avoids the need for
project-by-project permitting (and mitigation) required by a CESA Incidental
Take Permit (ITP) issued pursuant to Section 2081(b) of the Fish and Game Code.
It is important to note that CSP would need “take” authorization pursuant to
CESA prior to any take of these State listed species, including but not limited to
their seedbank. Given the extreme rarity of some of these plant species,
including but not limited to Nipomo Mesa lupine, meeting the ITP issuance
criteria would require special consideration. In contrast, an NCCP would
consider the populations (both plants and wildlife and the habitats they rely on)
as a whole and would better accommodate additional management actions
as mitigation elements. This “broader ecosystem” approach supports
considering as a possible mitigation action in the NCCP the connection of
existing fenced vegetation islands (e.g., additional permanent enclosures),
which would facilitate population expansions (recolonizations) of these species.
For any future projects that CSP proposes in the Oso Flaco Lake area, CDFW
recommends avoidance and minimization of impacts to special status plant
species that are associated with the wetland influence of the lake, such as
Gambel’s watercress. These plants are particularly susceptible to impacts like
alteration of the hydrological regime, degradation of habitat, and hybridization
with the widespread and invasive common water cress. Any proposed projects
should adequately address issues associated with increased sedimentation from
additional disturbance. Further, any siting of future infrastructure, including
roads, should avoid rare plant populations."

Posted by leafybye over 3 years ago

NO NEW SOUTHERN ENTRANCE!

Posted by leafybye over 3 years ago

In other words, specifically oppose Appendix A8. here: https://www.oceanodunespwp.com/en/documents/draft-eir

Posted by leafybye over 3 years ago

Their terrible A8 concept plan includes;

NEW; OHV trail to the beach, kids track, 4x4 pro track, Pro track 1, Pro track 2, Pro track 3, OHV staging area 1, OHV staging area 2, OHV staging area 3, a new driveway from highway 1, entry kiosk, day use parking, visitor center, training center, maintenance public safety and storage building, ranger building, environmental education center, shooting range, resources building, OHV staging area 1, concessions, multi-use special event space, oh and new pedestrian trails.

I know what instead? This: https://drive.google.com/file/d/1axgTOTF7qCo9tosqv9RWRjXX5V8X1nEp/view?usp=sharing

The Tosco Refinery Buffer is now known as the Phillips 66 Refiner Buffer, and that is where the extremely rare Nipomo Mesa Lupine lives, and only there. It is that rare. So, a plan to build a new southern entrance on the habitat for this plant? Extremely opposed.

Check out the good article opposed by SLO-CNPS:

https://cnpsslo.org/2020/02/project-a-of-the-oceano-dunes-state-vehicle-recreational-area/

Posted by leafybye over 3 years ago
Posted by leafybye over 3 years ago

The CCC page and summary really sum it up:

http://www.coastal.ca.gov/oceano-dunes/

Basically, the permit is under review, the environment is being damaged, the California Coastal Act is not being adhered to, so CCC told State Parks to reduce impact.

In response, State Parks created the Oceano Dunes Public Works Plan which they intent to take the place of the temporary permit and make all the plans in the PWP the permanent permit.

The CCC found that the Oceano Dunes PWP draft plan does not adhere to the Coastal Act, and is going in the completely wrong direction.

It it obvious to anyone else that the OHV industry, lobby, and profit are the interests that guide the goals of State Parks? Tell them habitat conservation, not profit is also their mission!

Posted by leafybye over 3 years ago

Here is what I wrote to both email address. There is a lot more I could say, but I wanted to focus on the rarity of the Nipomo Mesa Lupine -

https://drive.google.com/file/d/1pD_UGyTpImAY8SBZXqc3JjMNttFvch09/view?usp=sharing

Posted by leafybye over 3 years ago

I watched the Coastal Commission Hearing for 12 hours today, start to finish. 10 out of 10 Coastal Commissioners voted to adopt their staff recommendation, amended to a three year transition instead of five. OHV use will cease in ESHA after that time! This is great news! They reject the way the Oceano Dunes PWP is going also and the plan is still in draft form. No vote on the PWP happened today. Several commissioners expressed great concern with the Oso Flaco Lake project.

Again, this is the staff report whose recommendations were adopted, as amended:

https://documents.coastal.ca.gov/assets/oceano-dunes/Report.pdf

Posted by leafybye about 3 years ago

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