Requests for phone conference concerning the need for a baseline inventory at Cotoni-Coast Dairies
Dear District Manager Heppe – Friends of the North Coast (FONC), Davenport North Coast Association (DNCA), and Rural Bonny Doon Association (RBDA), as well as Sempervirens Fund, are seeking a reasonable semblance of an effective baseline at Cotoni-Coast Dairies in the area where trails are already being constructed north of Warrenella, as well as a commitment for a more robust version south of Warrenella prior to opening Cotoni-Coast Dairies as targeted for this November. We would also like to understand BLM’s perspective on the application of BLM Manual 6220. In view of Field Manager Blom’s leaving BLM at the end of May, two or three of us would like to have a phone call with you. Could you provide me with a couple of dates and times in the next week when you could be available for a phone call with a small number of representatives on behalf of FONC, DNCA, RBDA, and Sempervirens to the extent we can make ourselves available?
As stated FONC’s February 25, 2022 email to the Coastal Commission staff and Field Manager Blom:
We wish to again emphasize that we would like to work with the Coastal Commission and BLM to find effective and practical solutions to our concerns.
On February 25, 2022, FONC, DNCA, and RBDA provided our Comment Letter regarding BLM’s Biological Monitoring Plan as provided to us by Coastal Commission staff. We are uncertain whether this made it to your level, so we have attached it, along with the BLM Biological Monitoring Plan itself.
We have some ideas about how to move forward on this subject. Some movement in the direction of data collection is underway. A couple of days ago I spoke with Sara Barth (Executive Director of Sempervirens Fund). Her organization continues to believe that a baseline is necessary and it has taken some steps toward achieving that, including obtaining BLM’s agreement on the scope of a Grant Application for very substantial wildlife monitoring on both San Vicente Redwoods and Cotoni-Coast Dairies. I indicated that FONC, DNCA, and RBDA would like to work collaboratively to fill in gaps or improve data collection and have taken steps themselves toward this end. For example RBDA’s Dave Rubin, an expert on sedimentation in streams had a phone call with Ben Blom (at Ben’s request) about Dave’s previously expressed desire for better data collection methods as to sedimentation. Dave provided Ben with contact information with two experts at USGS and a UCSC professor to help in this respect. There are other examples we could share in a phone call.
Excerpts from RBDA Meeting with Panel including Ben Blom and Grey Hayes
Below are a couple of excerpts from the 3-16-2022 RBDA Program on Trails at Cotoni-Coast Dairies at which Field Manager Blom was a Panelist and Baseline became a primary topic. We understand you are busy but hope you will have time to read them before our phone call.
Frans Lanting: Ben, if I may, I have a follow up question about monitoring. Does BLM have plans in place for any baseline biological assessments prior to opening up the property to public recreation? Because in my humble opinion, that needs to be part of the process, because you can't really monitor the changes without knowing what is there right now. What are your plans for doing that, and how can this be facilitated if that is not in place yet?
Ben Blom: So I think it depends on what you mean by baseline inventory. And we've had this back and forth with Friends of North Coast about this for many months now. We have developed a monitoring plan with the Coastal Commission and others. We feel like that will give us a good baseline of information to move forward so that we can determine before we go to phase two of development if we are successful in meeting the objectives of the plan. Now should we be doing a baseline inventory of every species on the property and how we would do that and what that would tell us? That's where I think there's a bit of a disagreement here, because we feel like we could certainly do an inventory and spend ten years inventorying every species on the property. But what is that going to tell us in relation to our management? We're trying to balance the most effective way to monitor with our desire to have more information, and we're certainly open to having more science done on the property and doing studies on specific species. If people have indicator species they want to study on the property, we're certainly open to those opportunities. But the best ways to develop this adaptive management plan? I think that's where there's some agreeing to disagree happening here between the BLM and the Friends of the North Coast, and we tried to work with the Coastal Commission, Fish and Wildlife Service, and all these other agencies to develop a plan that they agreed with and that they approved with. We're trying to figure out the best balance here between trying to understand everything about the property and also meeting our commitment to have public access on the property, which is also something that we're obligated to do.
Grey Hayes: Ben suggests that there's a demand for monitoring every species on the property. I'm very concerned that there are a list of very specifically outlined Objects of the Monument in the Proclamation, and they aren't every species. They're a very small subset, and I think they must have been very wisely chosen as good indicators for ecosystem health. It seems to me somebody did a brilliant job of informing the Monument Proclamation in that way because they're common species, they're not rare species, and it seems like you could easily monitor those species as indicators because you'd have enough data fairly easily to notice if there were changes. And after all, they are Objects of the Monument, and so one would think that they would be required to be monitored, as the 6220 Manual suggests.
****
Frans Lanting: Ben, I'd like to kind of probe around in that issue one more time because there's a historic process underway. Coast Dairies has been closed to the public for close to a century, and it's about to open up. So I think there's a really unique opportunity for a combination of volunteer naturalists, professional researchers, and other volunteers to band together for the sake of gathering information, first for baseline use and then for what you call adaptive management. And I've got to believe that there are enough people and entities here in the community that would participate in it. You mentioned previously that you referred to a couple of institutions, but what is your process? Are you Proactive about this or are you waiting for people to knock on your door? And if it is the latter, how could this be shaped in a more Proactive fashion so that we can actually get something going before the gates open at Coast Dairies?
Ben Blom: So in terms of funding specific research questions, we have research that happens all over our properties, all over the Central Coast, and usually it's related to a specific research question. That a professor or graduate student comes up with and approaches us with. …. And basically it needs to be a partnership, right? It needs to be a question that a University is interested in studying and interested in funding a graduate student for. But it also needs to be something that we're supportive and that wouldn't have overdue impacts of itself on the property. …. it's not us going to them or them coming to us. It's a partnership where we work together to identify kind of common interests and common goals that we can work towards in terms of research questions. So it's not as simple as us going to UC Santa Cruz or another entity and saying, we want you to study this. It needs to be, like I said, a partnership.
****
Mary Flodin: Sorry, but I don't think you have addressed the whole concern that many people have expressed that we need to have baseline data about the wildlife before the park opens, and I don't think that's possible with a summer ‘22 opening. I feel like you're just kind of not heard that. Many people have mentioned it this evening.
Ben Blom: Yeah, I hear what you're saying, that there's this desire in the RBDA that we need to do additional baseline monitoring of specific wildlife species or specific measures. From our perspective. The plan was finalized in June 2021, and we're meeting our obligations that the plan was approved by the Coastal Commission, US Fish and Wildlife Service, National Marine Fisheries Service, all these entities. And we are starting monitoring. But we don't feel like some of these research questions that are being asked, how is trail development going to impact the Grasshopper Sparrow? That's really interesting information that we would love to have, but it's not necessarily a prerequisite before we would open the property to the public. And that's where we, I think, are going to have to agree to disagree tonight about what is required before we can open the property of the public. We have an obligation to open the property to the public, just like we have an obligation to manage and protect the resources of the property. And so we have to meet both of those commitments. And so we've done a little bit of looking at what Friends of the North Coast has requested in terms of monitoring. We were talking the magnitude of millions of dollars just focused on a monitoring program for the property and many years of data collection before you would have an effective baseline inventory of the 42 species that are included in the Proclamation for the property. So our annual budget for our whole field office and all the counties that we manage is less than $3 million. So that just gives you a sense of where this agreeing to disagree. We feel like in the way we design the plan, we're minimizing impacts to wildlife, and a better approach to doing that is to do it from the beginning. As opposed to trying to establish studies to detect an impact, the better way to do it is to avoid impacts in the first place. And so we hang our hat on the way we developed the plan, including with the phased approach that we've taken to try to minimize and avoid impacts, as opposed to trying to establish multiple years of baseline monitoring of individual species on the property to develop individual carrying capacities for each of those species. We don't feel like that's actually a feasible approach to managing this property.
Jacob Pollock: So, Ben, you vastly overstated the amount of money and the amount of time that FONC has asked you to monitor. I just want you to be aware of that. You have a responsibility to the public to open up. You have an equal responsibility to ensure that these things aren't destroyed, the Objects [of the Monument]. Simply saying you're going to try to do something, you need to look and see if you're doing it. You’ve got to have feedback. You got to know what you're doing. You can't just say we tried in the beginning to do something well and cross our fingers. You’ve got to know what you're doing. You’ve got to have feedback. You can't just say we tried in the beginning to do something well and cross our fingers.
*****
Ben Blom: So we have priced out what it would cost to establish a wildlife camera monitoring program that would generate statistically significant data across both our property and the San Vicente Redwoods property. And we've been trying to get funding for that with Sempervirens Fund to pay for that. We price that out at half a million dollars. You can see numbers, okay, you can look at the numbers, but you can get presence/absence data on wildlife by setting up a smaller array of cameras. But our biologists have looked into it, and it's a big effort involving a lot of cameras in order to get statistically significant information on that. And then how you use that data to feedback in terms of some sort of a carrying capacity number is also something that is not as simple to develop as it would seem.
****
Frans Lanting: Hey, Ben, if your own calculations are that this monitoring effort would cost $500,000 or more, it seems to me like a no brainer for you to have a follow up conversation with Jacob if he has a proposition that comes in at a fraction of the cost. And I've got to believe that whatever you could work out together would be supported by other people, including several people who are present in this meeting right now. And I just want to say one more time that this is a historic opportunity. All the other publicly protected properties on the North Coast have seen major incursions from recreational use over the last couple of decades. Here is a unique case study, and I really would like the BLM to step up to the plate in a way that is commensurate with the opportunity and the responsibility. This isn't just any BLM property. This is Conservation Land status property that has been elevated to National Monument status. And I really think that as a parallel to the significant investment that is being made in trail development, that we need to see something as a parallel to that to invest in the natural resources. And I'm sorry, but I haven't heard anything yet in this conversation this evening that shows that you're willing to make a step forward to meet some of the people here halfway.
Thank you for your consideration of this email.
Jonathan Wittwer, FONC President
As stated FONC’s February 25, 2022 email to the Coastal Commission staff and Field Manager Blom:
We wish to again emphasize that we would like to work with the Coastal Commission and BLM to find effective and practical solutions to our concerns.
On February 25, 2022, FONC, DNCA, and RBDA provided our Comment Letter regarding BLM’s Biological Monitoring Plan as provided to us by Coastal Commission staff. We are uncertain whether this made it to your level, so we have attached it, along with the BLM Biological Monitoring Plan itself.
We have some ideas about how to move forward on this subject. Some movement in the direction of data collection is underway. A couple of days ago I spoke with Sara Barth (Executive Director of Sempervirens Fund). Her organization continues to believe that a baseline is necessary and it has taken some steps toward achieving that, including obtaining BLM’s agreement on the scope of a Grant Application for very substantial wildlife monitoring on both San Vicente Redwoods and Cotoni-Coast Dairies. I indicated that FONC, DNCA, and RBDA would like to work collaboratively to fill in gaps or improve data collection and have taken steps themselves toward this end. For example RBDA’s Dave Rubin, an expert on sedimentation in streams had a phone call with Ben Blom (at Ben’s request) about Dave’s previously expressed desire for better data collection methods as to sedimentation. Dave provided Ben with contact information with two experts at USGS and a UCSC professor to help in this respect. There are other examples we could share in a phone call.
Excerpts from RBDA Meeting with Panel including Ben Blom and Grey Hayes
Below are a couple of excerpts from the 3-16-2022 RBDA Program on Trails at Cotoni-Coast Dairies at which Field Manager Blom was a Panelist and Baseline became a primary topic. We understand you are busy but hope you will have time to read them before our phone call.
Frans Lanting: Ben, if I may, I have a follow up question about monitoring. Does BLM have plans in place for any baseline biological assessments prior to opening up the property to public recreation? Because in my humble opinion, that needs to be part of the process, because you can't really monitor the changes without knowing what is there right now. What are your plans for doing that, and how can this be facilitated if that is not in place yet?
Ben Blom: So I think it depends on what you mean by baseline inventory. And we've had this back and forth with Friends of North Coast about this for many months now. We have developed a monitoring plan with the Coastal Commission and others. We feel like that will give us a good baseline of information to move forward so that we can determine before we go to phase two of development if we are successful in meeting the objectives of the plan. Now should we be doing a baseline inventory of every species on the property and how we would do that and what that would tell us? That's where I think there's a bit of a disagreement here, because we feel like we could certainly do an inventory and spend ten years inventorying every species on the property. But what is that going to tell us in relation to our management? We're trying to balance the most effective way to monitor with our desire to have more information, and we're certainly open to having more science done on the property and doing studies on specific species. If people have indicator species they want to study on the property, we're certainly open to those opportunities. But the best ways to develop this adaptive management plan? I think that's where there's some agreeing to disagree happening here between the BLM and the Friends of the North Coast, and we tried to work with the Coastal Commission, Fish and Wildlife Service, and all these other agencies to develop a plan that they agreed with and that they approved with. We're trying to figure out the best balance here between trying to understand everything about the property and also meeting our commitment to have public access on the property, which is also something that we're obligated to do.
Grey Hayes: Ben suggests that there's a demand for monitoring every species on the property. I'm very concerned that there are a list of very specifically outlined Objects of the Monument in the Proclamation, and they aren't every species. They're a very small subset, and I think they must have been very wisely chosen as good indicators for ecosystem health. It seems to me somebody did a brilliant job of informing the Monument Proclamation in that way because they're common species, they're not rare species, and it seems like you could easily monitor those species as indicators because you'd have enough data fairly easily to notice if there were changes. And after all, they are Objects of the Monument, and so one would think that they would be required to be monitored, as the 6220 Manual suggests.
****
Frans Lanting: Ben, I'd like to kind of probe around in that issue one more time because there's a historic process underway. Coast Dairies has been closed to the public for close to a century, and it's about to open up. So I think there's a really unique opportunity for a combination of volunteer naturalists, professional researchers, and other volunteers to band together for the sake of gathering information, first for baseline use and then for what you call adaptive management. And I've got to believe that there are enough people and entities here in the community that would participate in it. You mentioned previously that you referred to a couple of institutions, but what is your process? Are you Proactive about this or are you waiting for people to knock on your door? And if it is the latter, how could this be shaped in a more Proactive fashion so that we can actually get something going before the gates open at Coast Dairies?
Ben Blom: So in terms of funding specific research questions, we have research that happens all over our properties, all over the Central Coast, and usually it's related to a specific research question. That a professor or graduate student comes up with and approaches us with. …. And basically it needs to be a partnership, right? It needs to be a question that a University is interested in studying and interested in funding a graduate student for. But it also needs to be something that we're supportive and that wouldn't have overdue impacts of itself on the property. …. it's not us going to them or them coming to us. It's a partnership where we work together to identify kind of common interests and common goals that we can work towards in terms of research questions. So it's not as simple as us going to UC Santa Cruz or another entity and saying, we want you to study this. It needs to be, like I said, a partnership.
****
Mary Flodin: Sorry, but I don't think you have addressed the whole concern that many people have expressed that we need to have baseline data about the wildlife before the park opens, and I don't think that's possible with a summer ‘22 opening. I feel like you're just kind of not heard that. Many people have mentioned it this evening.
Ben Blom: Yeah, I hear what you're saying, that there's this desire in the RBDA that we need to do additional baseline monitoring of specific wildlife species or specific measures. From our perspective. The plan was finalized in June 2021, and we're meeting our obligations that the plan was approved by the Coastal Commission, US Fish and Wildlife Service, National Marine Fisheries Service, all these entities. And we are starting monitoring. But we don't feel like some of these research questions that are being asked, how is trail development going to impact the Grasshopper Sparrow? That's really interesting information that we would love to have, but it's not necessarily a prerequisite before we would open the property to the public. And that's where we, I think, are going to have to agree to disagree tonight about what is required before we can open the property of the public. We have an obligation to open the property to the public, just like we have an obligation to manage and protect the resources of the property. And so we have to meet both of those commitments. And so we've done a little bit of looking at what Friends of the North Coast has requested in terms of monitoring. We were talking the magnitude of millions of dollars just focused on a monitoring program for the property and many years of data collection before you would have an effective baseline inventory of the 42 species that are included in the Proclamation for the property. So our annual budget for our whole field office and all the counties that we manage is less than $3 million. So that just gives you a sense of where this agreeing to disagree. We feel like in the way we design the plan, we're minimizing impacts to wildlife, and a better approach to doing that is to do it from the beginning. As opposed to trying to establish studies to detect an impact, the better way to do it is to avoid impacts in the first place. And so we hang our hat on the way we developed the plan, including with the phased approach that we've taken to try to minimize and avoid impacts, as opposed to trying to establish multiple years of baseline monitoring of individual species on the property to develop individual carrying capacities for each of those species. We don't feel like that's actually a feasible approach to managing this property.
Jacob Pollock: So, Ben, you vastly overstated the amount of money and the amount of time that FONC has asked you to monitor. I just want you to be aware of that. You have a responsibility to the public to open up. You have an equal responsibility to ensure that these things aren't destroyed, the Objects [of the Monument]. Simply saying you're going to try to do something, you need to look and see if you're doing it. You’ve got to have feedback. You got to know what you're doing. You can't just say we tried in the beginning to do something well and cross our fingers. You’ve got to know what you're doing. You’ve got to have feedback. You can't just say we tried in the beginning to do something well and cross our fingers.
*****
Ben Blom: So we have priced out what it would cost to establish a wildlife camera monitoring program that would generate statistically significant data across both our property and the San Vicente Redwoods property. And we've been trying to get funding for that with Sempervirens Fund to pay for that. We price that out at half a million dollars. You can see numbers, okay, you can look at the numbers, but you can get presence/absence data on wildlife by setting up a smaller array of cameras. But our biologists have looked into it, and it's a big effort involving a lot of cameras in order to get statistically significant information on that. And then how you use that data to feedback in terms of some sort of a carrying capacity number is also something that is not as simple to develop as it would seem.
****
Frans Lanting: Hey, Ben, if your own calculations are that this monitoring effort would cost $500,000 or more, it seems to me like a no brainer for you to have a follow up conversation with Jacob if he has a proposition that comes in at a fraction of the cost. And I've got to believe that whatever you could work out together would be supported by other people, including several people who are present in this meeting right now. And I just want to say one more time that this is a historic opportunity. All the other publicly protected properties on the North Coast have seen major incursions from recreational use over the last couple of decades. Here is a unique case study, and I really would like the BLM to step up to the plate in a way that is commensurate with the opportunity and the responsibility. This isn't just any BLM property. This is Conservation Land status property that has been elevated to National Monument status. And I really think that as a parallel to the significant investment that is being made in trail development, that we need to see something as a parallel to that to invest in the natural resources. And I'm sorry, but I haven't heard anything yet in this conversation this evening that shows that you're willing to make a step forward to meet some of the people here halfway.
Thank you for your consideration of this email.
Jonathan Wittwer, FONC President
Email to Coastal Commission Dr. Huckelbridge and Environmental Scientist Barrera
Dr. Huckelbridge and Environmental Scientist Barrera – FONC, DNCA, and RBDA, as well as Sempervirens Fund, continue to seek to have BLM provide a Baseline prior to opening Cotoni-Coast Dairies as targeted for this November. Two or three of us would like to have a phone call with the two of you ASAP. Could you provide me with a couple of dates and times in the next week when the two of you could be available for a phone call with a small number of representatives on behalf of FONC, DNCA, RBDA, and Sempervirens to the extent we can make ourselves available?
As stated in then FONC/DNCA/RBDA February 25, 2022 email to the two of you and Mr. Blom:
We wish to again emphasize that we would like to work with the Coastal Commission and BLM to find effective and practical solutions to our concerns. Please let us know how we can best participate in this process.
However, it is not acceptable to forego some semblance of an effective baseline and thresholds for adaptive management where trails are already being constructed north of Warrenella, as well as a more robust version south of Warrenella. We are also aware, and assume you are as well, that Field Manager Ben Blom will be leaving BLM at the end of May.
On February 25, 2022, FONC, DNCA, and RBDA provided our Comment Letter regarding BLM’s Biological Monitoring Plan as provided to us by Coastal Commission staff. Our cover email included a few questions for BLM. On March 15, 2022 We received an email from Mr. Blom “confirm[ing] receipt of [our 2-25-2022] email [with Comment Letter]” and concluding with the following statement:
“We had a coordination call with the Commission today [3-15-2022] to discuss our shared (BLM and CCC) response. You should hear back from us in the next few weeks.”
As of the date of this email we have had no response to our Comment Letter on BLM’s Biological Monitoring Plan. We believe we have some very constructive ideas to share, including about efforts already underway. We unsure whether BLM has communicated any of these to you.
Yesterday I spoke with Sara Barth (Executive Director of Sempervirens Fund). Her organization continues to believe that a baseline is necessary and it has taken some steps toward achieving that, including obtaining BLM’s agreement on the scope of a Grant Application for very substantial wildlife monitoring on both San Vicente Redwoods and Cotoni-Coast Dairies. I indicated that FONC, DNCA, and RBDA would like to work collaboratively to fill in gaps or improve data collection and have taken steps themselves toward this end. For example RBDA’s Dave Rubin, an expert on sedimentation in streams had a phone call with Ben Blom (at Ben’s request) about Dave’s desire for better data collection methods as to sedimentation and Dave provided Mr. Blom with contact information with two UCSC professors to help in this respect. There are other examples we could share in a phone call.
Excerpts from RBDA Meeting with Panel including Ben Blom and Grey Hayes
Of concern to us, and of possible interest to you as Coastal Commission staff, are some statements made and exchanges Mr. Blom had as a Panel member for the RBDA Program on Trails at Cotoni-Coast Dairies for its public meeting held virtually on March 16, 2022. We understand you are busy but hope you will have time to read them before our phone call.
Ben Blom: And we've been working with the Coastal Commission to identify which indicators we're going to monitor on the property. And so some of that is underway. We certainly don't have the funding to monitor everything on the property. And so we've tried to pick and choose looking at kind of a landscape approach.
[Later] Lee Otter: You mentioned in your presentation that there were some indicators that you agreed with the Coastal Commission on, and I wondered if you could summarize what those indicators are.
Ben Blom: To answer Lee's question there. So we developed this plan to have phase development of trails on the property. And in order to go from phase one to phase two, we included some triggers in the Management Plan having to do with how effective we are at managing the phase one trails. And this was part of our work with the Coastal Commission. So, for example, we have to show that we're able to address social trails. ….. We[also] need to prove that we're effective in managing preventing people from going into sensitive habitat areas. So those zones that we said we didn't want public access, we don't want to see public visitation to those areas. …. We also have committed to monitoring our parking …. And I think there's a fourth one, … the trail condition. So we've committed to monitoring the condition of the trails for erosion features and basically ensuring that our trails are hydrologically disconnected from all the waterways, and that if there are issues with trail erosion that they're addressed quickly and effectively. So those are the four triggers that we agreed to with the Coastal Commission.
****
Frans Lanting: Ben, if I may, I have a follow up question about monitoring. Does BLM have plans in place for any baseline biological assessments prior to opening up the property to public recreation? Because in my humble opinion, that needs to be part of the process, because you can't really monitor the changes without knowing what is there right now. What are your plans for doing that, and how can this be facilitated if that is not in place yet?
Ben Blom: So I think it depends on what you mean by baseline inventory. And we've had this back and forth with Friends of North Coast about this for many months now. We have developed a monitoring plan with the Coastal Commission and others. We feel like that will give us a good baseline of information to move forward so that we can determine before we go to phase two of development if we are successful in meeting the objectives of the plan. Now should we be doing a baseline inventory of every species on the property and how we would do that and what that would tell us? That's where I think there's a bit of a disagreement here, because we feel like we could certainly do an inventory and spend ten years inventorying every species on the property. But what is that going to tell us in relation to our management? We're trying to balance the most effective way to monitor with our desire to have more information, and we're certainly open to having more science done on the property and doing studies on specific species. If people have indicator species they want to study on the property, we're certainly open to those opportunities. But the best ways to develop this adaptive management plan? I think that's where there's some agreeing to disagree happening here between the BLM and the Friends of the North Coast, and we tried to work with the Coastal Commission, Fish and Wildlife Service, and all these other agencies to develop a plan that they agreed with and that they approved with. We're trying to figure out the best balance here between trying to understand everything about the property and also meeting our commitment to have public access on the property, which is also something that we're obligated to do.
Grey Hayes: Ben suggests that there's a demand for monitoring every species on the property. I'm very concerned that there are a list of very specifically outlined Objects of the Monument in the Proclamation, and they aren't every species. They're a very small subset, and I think they must have been very wisely chosen as good indicators for ecosystem health. It seems to me somebody did a brilliant job of informing the Monument Proclamation in that way because they're common species, they're not rare species, and it seems like you could easily monitor those species as indicators because you'd have enough data fairly easily to notice if there were changes. And after all, they are Objects of the Monument, and so one would think that they would be required to be monitored, as the 6220 Manual suggests.
****
Frans Lanting: Ben, I'd like to kind of probe around in that issue one more time because there's a historic process underway. Coast Dairies has been closed to the public for close to a century, and it's about to open up. So I think there's a really unique opportunity for a combination of volunteer naturalists, professional researchers, and other volunteers to band together for the sake of gathering information, first for baseline use and then for what you call adaptive management. And I've got to believe that there are enough people and entities here in the community that would participate in it. You mentioned previously that you referred to a couple of institutions, but what is your process? Are you Proactive about this or are you waiting for people to knock on your door? And if it is the latter, how could this be shaped in a more Proactive fashion so that we can actually get something going before the gates open at Coast Dairies?
Ben Blom: So in terms of funding specific research questions, we have research that happens all over our properties, all over the Central Coast, and usually it's related to a specific research question. That a professor or graduate student comes up with and approaches us with. …. And basically it needs to be a partnership, right? It needs to be a question that a University is interested in studying and interested in funding a graduate student for. But it also needs to be something that we're supportive and that wouldn't have overdue impacts of itself on the property. …. it's not us going to them or them coming to us. It's a partnership where we work together to identify kind of common interests and common goals that we can work towards in terms of research questions. So it's not as simple as us going to UC Santa Cruz or another entity and saying, we want you to study this. It needs to be, like I said, a partnership.
****
Mary Flodin: Sorry, but I don't think you have addressed the whole concern that many people have expressed that we need to have baseline data about the wildlife before the park opens, and I don't think that's possible with a summer ‘22 opening. I feel like you're just kind of not heard that. Many people have mentioned it this evening.
Ben Blom: Yeah, I hear what you're saying, that there's this desire in the RBDA that we need to do additional baseline monitoring of specific wildlife species or specific measures. From our perspective. The plan was finalized in June 2021, and we're meeting our obligations that the plan was approved by the Coastal Commission, US Fish and Wildlife Service, National Marine Fisheries Service, all these entities. And we are starting monitoring. But we don't feel like some of these research questions that are being asked, how is trail development going to impact the Grasshopper Sparrow? That's really interesting information that we would love to have, but it's not necessarily a prerequisite before we would open the property to the public. And that's where we, I think, are going to have to agree to disagree tonight about what is required before we can open the property of the public. We have an obligation to open the property to the public, just like we have an obligation to manage and protect the resources of the property. And so we have to meet both of those commitments. And so we've done a little bit of looking at what Friends of the North Coast has requested in terms of monitoring. We were talking the magnitude of millions of dollars just focused on a monitoring program for the property and many years of data collection before you would have an effective baseline inventory of the 42 species that are included in the Proclamation for the property. So our annual budget for our whole field office and all the counties that we manage is less than $3 million. So that just gives you a sense of where this agreeing to disagree. We feel like in the way we design the plan, we're minimizing impacts to wildlife, and a better approach to doing that is to do it from the beginning. As opposed to trying to establish studies to detect an impact, the better way to do it is to avoid impacts in the first place. And so we hang our hat on the way we developed the plan, including with the phased approach that we've taken to try to minimize and avoid impacts, as opposed to trying to establish multiple years of baseline monitoring of individual species on the property to develop individual carrying capacities for each of those species. We don't feel like that's actually a feasible approach to managing this property.
Jacob Pollock: So, Ben, you vastly overstated the amount of money and the amount of time that FONC has asked you to monitor. I just want you to be aware of that. You have a responsibility to the public to open up. You have an equal responsibility to ensure that these things aren't destroyed, the Objects [of the Monument]. Simply saying you're going to try to do something, you need to look and see if you're doing it. You’ve got to have feedback. You got to know what you're doing. You can't just say we tried in the beginning to do something well and cross our fingers. You’ve got to know what you're doing. You’ve got to have feedback. You can't just say we tried in the beginning to do something well and cross our fingers.
*****
Ben Blom: So we have priced out what it would cost to establish a wildlife camera monitoring program that would generate statistically significant data across both our property and the San Vicente Redwoods property. And we've been trying to get funding for that with Sempervirens Fund to pay for that. We price that out at half a million dollars. You can see numbers, okay, you can look at the numbers, but you can get presence/absence data on wildlife by setting up a smaller array of cameras. But our biologists have looked into it, and it's a big effort involving a lot of cameras in order to get statistically significant information on that. And then how you use that data to feedback in terms of some sort of a carrying capacity number is also something that is not as simple to develop as it would seem.
****
Frans Lanting: Hey, Ben, if your own calculations are that this monitoring effort would cost $500,000 or more, it seems to me like a no brainer for you to have a follow up conversation with Jacob if he has a proposition that comes in at a fraction of the cost. And I've got to believe that whatever you could work out together would be supported by other people, including several people who are present in this meeting right now. And I just want to say one more time that this is a historic opportunity. All the other publicly protected properties on the North Coast have seen major incursions from recreational use over the last couple of decades. Here is a unique case study, and I really would like the BLM to step up to the plate in a way that is commensurate with the opportunity and the responsibility. This isn't just any BLM property. This is Conservation Land status property that has been elevated to National Monument status. And I really think that as a parallel to the significant investment that is being made in trail development, that we need to see something as a parallel to that to invest in the natural resources. And I'm sorry, but I haven't heard anything yet in this conversation this evening that shows that you're willing to make a step forward to meet some of the people here halfway.
Thank you for your consideration of this email.
Jonathan Wittwer, FONC President
As stated in then FONC/DNCA/RBDA February 25, 2022 email to the two of you and Mr. Blom:
We wish to again emphasize that we would like to work with the Coastal Commission and BLM to find effective and practical solutions to our concerns. Please let us know how we can best participate in this process.
However, it is not acceptable to forego some semblance of an effective baseline and thresholds for adaptive management where trails are already being constructed north of Warrenella, as well as a more robust version south of Warrenella. We are also aware, and assume you are as well, that Field Manager Ben Blom will be leaving BLM at the end of May.
On February 25, 2022, FONC, DNCA, and RBDA provided our Comment Letter regarding BLM’s Biological Monitoring Plan as provided to us by Coastal Commission staff. Our cover email included a few questions for BLM. On March 15, 2022 We received an email from Mr. Blom “confirm[ing] receipt of [our 2-25-2022] email [with Comment Letter]” and concluding with the following statement:
“We had a coordination call with the Commission today [3-15-2022] to discuss our shared (BLM and CCC) response. You should hear back from us in the next few weeks.”
As of the date of this email we have had no response to our Comment Letter on BLM’s Biological Monitoring Plan. We believe we have some very constructive ideas to share, including about efforts already underway. We unsure whether BLM has communicated any of these to you.
Yesterday I spoke with Sara Barth (Executive Director of Sempervirens Fund). Her organization continues to believe that a baseline is necessary and it has taken some steps toward achieving that, including obtaining BLM’s agreement on the scope of a Grant Application for very substantial wildlife monitoring on both San Vicente Redwoods and Cotoni-Coast Dairies. I indicated that FONC, DNCA, and RBDA would like to work collaboratively to fill in gaps or improve data collection and have taken steps themselves toward this end. For example RBDA’s Dave Rubin, an expert on sedimentation in streams had a phone call with Ben Blom (at Ben’s request) about Dave’s desire for better data collection methods as to sedimentation and Dave provided Mr. Blom with contact information with two UCSC professors to help in this respect. There are other examples we could share in a phone call.
Excerpts from RBDA Meeting with Panel including Ben Blom and Grey Hayes
Of concern to us, and of possible interest to you as Coastal Commission staff, are some statements made and exchanges Mr. Blom had as a Panel member for the RBDA Program on Trails at Cotoni-Coast Dairies for its public meeting held virtually on March 16, 2022. We understand you are busy but hope you will have time to read them before our phone call.
Ben Blom: And we've been working with the Coastal Commission to identify which indicators we're going to monitor on the property. And so some of that is underway. We certainly don't have the funding to monitor everything on the property. And so we've tried to pick and choose looking at kind of a landscape approach.
[Later] Lee Otter: You mentioned in your presentation that there were some indicators that you agreed with the Coastal Commission on, and I wondered if you could summarize what those indicators are.
Ben Blom: To answer Lee's question there. So we developed this plan to have phase development of trails on the property. And in order to go from phase one to phase two, we included some triggers in the Management Plan having to do with how effective we are at managing the phase one trails. And this was part of our work with the Coastal Commission. So, for example, we have to show that we're able to address social trails. ….. We[also] need to prove that we're effective in managing preventing people from going into sensitive habitat areas. So those zones that we said we didn't want public access, we don't want to see public visitation to those areas. …. We also have committed to monitoring our parking …. And I think there's a fourth one, … the trail condition. So we've committed to monitoring the condition of the trails for erosion features and basically ensuring that our trails are hydrologically disconnected from all the waterways, and that if there are issues with trail erosion that they're addressed quickly and effectively. So those are the four triggers that we agreed to with the Coastal Commission.
****
Frans Lanting: Ben, if I may, I have a follow up question about monitoring. Does BLM have plans in place for any baseline biological assessments prior to opening up the property to public recreation? Because in my humble opinion, that needs to be part of the process, because you can't really monitor the changes without knowing what is there right now. What are your plans for doing that, and how can this be facilitated if that is not in place yet?
Ben Blom: So I think it depends on what you mean by baseline inventory. And we've had this back and forth with Friends of North Coast about this for many months now. We have developed a monitoring plan with the Coastal Commission and others. We feel like that will give us a good baseline of information to move forward so that we can determine before we go to phase two of development if we are successful in meeting the objectives of the plan. Now should we be doing a baseline inventory of every species on the property and how we would do that and what that would tell us? That's where I think there's a bit of a disagreement here, because we feel like we could certainly do an inventory and spend ten years inventorying every species on the property. But what is that going to tell us in relation to our management? We're trying to balance the most effective way to monitor with our desire to have more information, and we're certainly open to having more science done on the property and doing studies on specific species. If people have indicator species they want to study on the property, we're certainly open to those opportunities. But the best ways to develop this adaptive management plan? I think that's where there's some agreeing to disagree happening here between the BLM and the Friends of the North Coast, and we tried to work with the Coastal Commission, Fish and Wildlife Service, and all these other agencies to develop a plan that they agreed with and that they approved with. We're trying to figure out the best balance here between trying to understand everything about the property and also meeting our commitment to have public access on the property, which is also something that we're obligated to do.
Grey Hayes: Ben suggests that there's a demand for monitoring every species on the property. I'm very concerned that there are a list of very specifically outlined Objects of the Monument in the Proclamation, and they aren't every species. They're a very small subset, and I think they must have been very wisely chosen as good indicators for ecosystem health. It seems to me somebody did a brilliant job of informing the Monument Proclamation in that way because they're common species, they're not rare species, and it seems like you could easily monitor those species as indicators because you'd have enough data fairly easily to notice if there were changes. And after all, they are Objects of the Monument, and so one would think that they would be required to be monitored, as the 6220 Manual suggests.
****
Frans Lanting: Ben, I'd like to kind of probe around in that issue one more time because there's a historic process underway. Coast Dairies has been closed to the public for close to a century, and it's about to open up. So I think there's a really unique opportunity for a combination of volunteer naturalists, professional researchers, and other volunteers to band together for the sake of gathering information, first for baseline use and then for what you call adaptive management. And I've got to believe that there are enough people and entities here in the community that would participate in it. You mentioned previously that you referred to a couple of institutions, but what is your process? Are you Proactive about this or are you waiting for people to knock on your door? And if it is the latter, how could this be shaped in a more Proactive fashion so that we can actually get something going before the gates open at Coast Dairies?
Ben Blom: So in terms of funding specific research questions, we have research that happens all over our properties, all over the Central Coast, and usually it's related to a specific research question. That a professor or graduate student comes up with and approaches us with. …. And basically it needs to be a partnership, right? It needs to be a question that a University is interested in studying and interested in funding a graduate student for. But it also needs to be something that we're supportive and that wouldn't have overdue impacts of itself on the property. …. it's not us going to them or them coming to us. It's a partnership where we work together to identify kind of common interests and common goals that we can work towards in terms of research questions. So it's not as simple as us going to UC Santa Cruz or another entity and saying, we want you to study this. It needs to be, like I said, a partnership.
****
Mary Flodin: Sorry, but I don't think you have addressed the whole concern that many people have expressed that we need to have baseline data about the wildlife before the park opens, and I don't think that's possible with a summer ‘22 opening. I feel like you're just kind of not heard that. Many people have mentioned it this evening.
Ben Blom: Yeah, I hear what you're saying, that there's this desire in the RBDA that we need to do additional baseline monitoring of specific wildlife species or specific measures. From our perspective. The plan was finalized in June 2021, and we're meeting our obligations that the plan was approved by the Coastal Commission, US Fish and Wildlife Service, National Marine Fisheries Service, all these entities. And we are starting monitoring. But we don't feel like some of these research questions that are being asked, how is trail development going to impact the Grasshopper Sparrow? That's really interesting information that we would love to have, but it's not necessarily a prerequisite before we would open the property to the public. And that's where we, I think, are going to have to agree to disagree tonight about what is required before we can open the property of the public. We have an obligation to open the property to the public, just like we have an obligation to manage and protect the resources of the property. And so we have to meet both of those commitments. And so we've done a little bit of looking at what Friends of the North Coast has requested in terms of monitoring. We were talking the magnitude of millions of dollars just focused on a monitoring program for the property and many years of data collection before you would have an effective baseline inventory of the 42 species that are included in the Proclamation for the property. So our annual budget for our whole field office and all the counties that we manage is less than $3 million. So that just gives you a sense of where this agreeing to disagree. We feel like in the way we design the plan, we're minimizing impacts to wildlife, and a better approach to doing that is to do it from the beginning. As opposed to trying to establish studies to detect an impact, the better way to do it is to avoid impacts in the first place. And so we hang our hat on the way we developed the plan, including with the phased approach that we've taken to try to minimize and avoid impacts, as opposed to trying to establish multiple years of baseline monitoring of individual species on the property to develop individual carrying capacities for each of those species. We don't feel like that's actually a feasible approach to managing this property.
Jacob Pollock: So, Ben, you vastly overstated the amount of money and the amount of time that FONC has asked you to monitor. I just want you to be aware of that. You have a responsibility to the public to open up. You have an equal responsibility to ensure that these things aren't destroyed, the Objects [of the Monument]. Simply saying you're going to try to do something, you need to look and see if you're doing it. You’ve got to have feedback. You got to know what you're doing. You can't just say we tried in the beginning to do something well and cross our fingers. You’ve got to know what you're doing. You’ve got to have feedback. You can't just say we tried in the beginning to do something well and cross our fingers.
*****
Ben Blom: So we have priced out what it would cost to establish a wildlife camera monitoring program that would generate statistically significant data across both our property and the San Vicente Redwoods property. And we've been trying to get funding for that with Sempervirens Fund to pay for that. We price that out at half a million dollars. You can see numbers, okay, you can look at the numbers, but you can get presence/absence data on wildlife by setting up a smaller array of cameras. But our biologists have looked into it, and it's a big effort involving a lot of cameras in order to get statistically significant information on that. And then how you use that data to feedback in terms of some sort of a carrying capacity number is also something that is not as simple to develop as it would seem.
****
Frans Lanting: Hey, Ben, if your own calculations are that this monitoring effort would cost $500,000 or more, it seems to me like a no brainer for you to have a follow up conversation with Jacob if he has a proposition that comes in at a fraction of the cost. And I've got to believe that whatever you could work out together would be supported by other people, including several people who are present in this meeting right now. And I just want to say one more time that this is a historic opportunity. All the other publicly protected properties on the North Coast have seen major incursions from recreational use over the last couple of decades. Here is a unique case study, and I really would like the BLM to step up to the plate in a way that is commensurate with the opportunity and the responsibility. This isn't just any BLM property. This is Conservation Land status property that has been elevated to National Monument status. And I really think that as a parallel to the significant investment that is being made in trail development, that we need to see something as a parallel to that to invest in the natural resources. And I'm sorry, but I haven't heard anything yet in this conversation this evening that shows that you're willing to make a step forward to meet some of the people here halfway.
Thank you for your consideration of this email.
Jonathan Wittwer, FONC President