California Coastal Commission Presentation
On July 14, 2022, FONC and its allies made a presentation to the Coastal Commission in an effort to bring attention to the situation with BLM and Cotoni Coast Dairies.
Watch the video of the presentation:
Meeting transcript and slides
Jonathan Wittwer:
My name is Jonathan Wittwer. Good morning. I'm the president of the Friends of the North Coast. Along with the Davenport North Coast Association and Rural Bonny Doon Association. We are here to broach the subject of BLM non compliance with your commissions to Cotoni Coast Dairies federal concurrence decision. We sent your chair a letter a few weeks ago seeking a win-win reopener so as to enable opening to the public by the end of 2022. Okay, so looking at this first slide, Cotoni Coast Dairies is the light green area along the Santa Cruz County north coast. There have been three major changes since your decision making it necessary for the commission to revisit the parking lots and BLM's refusal to do a baseline inventory. Specifically, if we can go to the next slide, BLM's planned southern entrance is non-viable because it cannot obtain the necessary easement bisecting the agricultural land as can be seen on this slide. The good news, however, is that the revised southern entrance on the next slide is supported in concept by BLM. This Yellow Bank south gate alternative will be supported by all when supplemental concurrency comes to your commission and will satisfy the resource management plan requirement to include parking areas in the north and the south to reduce the concentration of impacts at a singular parking area. As to the northern entrance, the next speaker will explain the need for a reopener given that BLM recently unilaterally revised your commission approved Warenella Gate parking lot so as to reduce the parking by 40% and create an unsafe access driveway per analysis by a traffic engineer. The third change is that BLM recently informed RBDA that it will not be doing a baseline inventory. Status quo is noncompliant; win-win is feasible. Our three organizations have proposed it and are committed to supporting it. Mike of DNCA will now address the northern location. Mike Eaton: Thank you, John. Thank you, commissioners. I'll be focusing on the northern trail access parking lot, which has seen major plan alterations by BLM since your consistency review. These changes are substantial, including a 40% reduction in spaces, a realigned entry that makes the parking directly visible from a stretch of Highway One, and next slide please, creates conflicts with large vehicle use of Warenella and Cement Plant Roads. What it looks like on the ground is this next slide, please, and invites a situation of serious conflict. Next slide, please. Our alternative parking proposal, which we put on the table about four years ago, would provide substantially more spaces, avoid visual impacts, avoid tree removal, largely avoid grading, and avoid an outcome where we end up with two parking lots, which appears to be BLM's current intention. This is because the restoration of the Cheese Barn, which has received funding commitment from the Great America Outdoors Program, includes creation of a parking lot at that site, enabling use of the Cheese Barn as an interpretive and event center. A combined trailhead and history center parking lot is feasible, and it is far preferable. We understand BLM's desire to fast track development of a parking lot that would enable opening of the trails. We believe that a single larger parking lot at the Cheese Barn site could be developed expeditiously with the collaboration of the commission and the local community. And we would eagerly join in such a collaboration. Thank you for this opportunity. Thank you. Dave Rubin: Hi. I'm Dave Rubin, chair of the Rural Bonny Doon Association. Thanks for the opportunity to speak today. I'd like to make two points. First, Bonny Doon was devastated by the CCU fire and our residents want to minimize future fire hazards. And for this reason, RBDA supports the recommendation to site the north entrance parking lot at the Cheese Barn. The road to the Cheese Barn is more accessible to firefighters. Imagine hikers returning to their cars and trying to leave the parking lot when firefighters are trying to drive in on the narrow road. Moreover, the Cheese Barn is situated in grazed lands where the grass are low rather than the high grass lands at the previously proposed site. And siting it at the Cheese Barn then would lower the immediate fire hazard. And that's in addition to environmental reasons for consolidating the two lots. The second issue I'd like to discuss is baseline sediment data. Go to the next slide, please. I've worked as a sedimentologist for 47 years at UCSC and at the US Geological Survey where I designed the sediment restoration floods in Grand Canyon National Park. RBDA urges collection of baseline sediment concentrations and streams so that the impact of the development that's going to happen soon in the northern area of the monument can be used to inform future development elsewhere in the monument. This slide I extracted from a 2004 report by the North Coast Regional Water Quality Control Board showing the importance of sediment in impacting survival of salmonids and low concentrations for short duration don't have an impact, but high concentrations for long periods cause 40% to 60% mortality. Thanks. Dr. Jacob Pollock: Hello. My name is Dr. Jacob Pollock. I'm an ecological researcher specializing in ecological monitoring, design and analysis. I hope today to impress upon you that the BLM monitoring plan for Cotoni Coast Dairies is inadequate. It's overly vague, too general, and is not based on the latest science. In simple terms, it is lacking. First, it is lacking in a baseline knowledge of what it is supposed to be protected. You can't know what has changed if you don't know where you started. Second, it is lacking any monitoring of the specific protected species or objects of the monument. You can't see what has changed if you don't look at the things you care about. Third, it is lacking any monitoring of the specific causes of impacts. You can't know why things change if you don't look at the stressors. Fourth, it is lacking in science based management informed by monitoring results. You can't fix what has changed if you don't decide how much changes is too much, and if you don't learn from mistakes. Next slide, please. I also want to impress upon you that BLM is refusing to do effective monitoring and refusing to obtain adequate baseline data. The BLM monitoring plan, biological monitoring plan states, quote, monitoring protocols for each species discussed in the proclamation is not recommended or proposed. Also, at a community meeting in Bonny Doon, Central Coast Field Manager Ben Blom, in a discussion about baseline monitoring, left everyone feeling powerless and unheard by proclaiming that "baseline monitoring is not necessarily a prerequisite before we would open the property to the public." And that's where I think we are going to have to disagree. Thank you very much for your time. Thank you. Dr. Grey Hayes: Hi, I'm Dr. Grey Hayes. I'm a restoration ecologist that's been focusing on the north coast of Santa Cruz for many years. I'm here to reiterate what Dr. Pollock said that BLM's biological monitoring plan does not include baseline data collection on natural resources. Such baseline data establishes how healthy, especially environmentally sensitive natural resources are before the proposed new visitor use activities commence. Such a baseline is absolutely necessary to comply with the Coastal Commission's federal consistency conditional concurrence. Without a baseline, BLM cannot evaluate the effectiveness of their project design features and or change those features if resource objectives are not met. I'd refer to you the consistency determination on page 28. California Coastal Commission consistency determination relies on these project design features for minimizing resource impacts. Also, BLM's required monitoring results and lessons learned cannot be ascertained during phase one of recreational improvements in a way that can adequately inform future planning and activities allowable in phase two. Again, please look at your consistency determination on page 22 for that language. Here's what our request for reopener says about a compromise as to the baseline opening the property for public visitor use would be conditioned on BLM adopting funding implementing reasonably effective baseline data collection. It is understood that this baseline data collection would be collected after trail construction and public visitation. So BLM must establish thresholds and adaptive management techniques for the zone one, as well as a more robust version for zone two through four. This has already been agreed to by the Coastal Commission and BLM and all the parties, and the results of that baseline document should be agreed upon prior to you so that we can inform future management and phase two opening. Thanks very much. Thank you. James Robbins: Good morning, Chair Brownsey, Commissioners and Commission staff. My name is Jim Robbins. I'm speaking on behalf of the Trust for Public Land. I'm here to confirm that TPL has been working with BLM toward implementation of an alternative south entrance known as the Yellow Bank South Gate Alternative. This alternative was a product of a joint proposal to BLM about a year ago from the seven organization group, which includes TPL, Sempervirens, the Santa Cruz Puma Project, Santa Cruz County Farm Bureau, Big Creek Lumber, Friends on the North Coast, and the Rural Bonny Doon Association. BLM supports this alternative in concept as of the July 30, 2021 letter and has been working out the details with TPL. As a result of our discussions, in early March of this year, TPL presented BLM with three views of a professionally drawn preliminary plan for the Yellow Bank South Gate alternative entrance. This plan has been vetted with the Santa Cruz Regional Transportation Commission and preliminarily with Caltrans, and it includes a traffic engineer evaluation. Unfortunately, shortly thereafter, the BLM field Manager left Federal Service. Once a new field manager is in place, we hope BLM and TPL can jointly expedite efforts to implement this plan. One step along the way will be for the plan to return to the Coastal Commission for supplemental federal consistency concurrence. We look forward to this opportunity. Thank you very much. |
Click on slides to enlarge
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Kate Hucklebridge Transcript - Response to question
Chair, Donne Brownsey
A short break and then Vice Chair, you had a question.
Vice Chair, Caryl Hart
Thank you so much. I would just have a question for staff on the coast dairies issue, will that be returning to us and could you just respond briefly the concerns?
Kate Hucklebridge
Yeah, no, we've been in active discussions with BLM as well as with Friends of North Coast and the group that came today. There's been a lot of activity related to that federal consistency determination.
So we did approve a preliminary I think it's not preliminary, I think it was the final monitoring plan that does include some baseline monitoring. So that is ongoing right now. It was not in full agreement with what the Friends of the North Coast were looking for, mostly due to funding constraints. But we have been working sort of actively with BLM on that monitoring and then in some of the changes that were discussed today.
So the different entrances, different parking, so we're currently evaluating all of that with BLM right now. As you may recall, it was sort of a phased approach that we took. So there certainly will come back to the commission before a Phase two.
And part of the idea of that monitoring and some of these was to have that information available for a Phase two that's far down the line. As far as I'm aware.
You also did hear there have been changes in the staffing at BLM. The folks that we've been working with are no longer with BLM, so we're trying to re establish that, figure out who's going to be the new director and who we're working with. So it's sort of all in flux right now.
If there are changes to entrances or parking lots, that certainly will come before the commission, either as a supplemental CD or some other federal consistency mechanism before phase two is what I imagine. Or maybe it'll be part of phase two. We're not really clear yet. But we are in active discussions with all these folks and there's been a lot of work towards a different entrance point and I'm not as familiar with all the details.
We can bring back more if you'd like, but there's been a lot of effort and there is a lot of agreement on some potential alternatives and if that comes to fruition, we'll let you know.
Vice Chair, Caryl Hart
Thanks so much. Doctor Hucklebridge. Yeah, I've received outreach from these folks, many of whom I've known for a long time, and so particularly with the entrance, the cheese barn, all of that. So I'll look forward to just getting an update. Thank you so much.
Chair, Donne Brownsey
Thank you, Vice Chair, for those questions.
A short break and then Vice Chair, you had a question.
Vice Chair, Caryl Hart
Thank you so much. I would just have a question for staff on the coast dairies issue, will that be returning to us and could you just respond briefly the concerns?
Kate Hucklebridge
Yeah, no, we've been in active discussions with BLM as well as with Friends of North Coast and the group that came today. There's been a lot of activity related to that federal consistency determination.
So we did approve a preliminary I think it's not preliminary, I think it was the final monitoring plan that does include some baseline monitoring. So that is ongoing right now. It was not in full agreement with what the Friends of the North Coast were looking for, mostly due to funding constraints. But we have been working sort of actively with BLM on that monitoring and then in some of the changes that were discussed today.
So the different entrances, different parking, so we're currently evaluating all of that with BLM right now. As you may recall, it was sort of a phased approach that we took. So there certainly will come back to the commission before a Phase two.
And part of the idea of that monitoring and some of these was to have that information available for a Phase two that's far down the line. As far as I'm aware.
You also did hear there have been changes in the staffing at BLM. The folks that we've been working with are no longer with BLM, so we're trying to re establish that, figure out who's going to be the new director and who we're working with. So it's sort of all in flux right now.
If there are changes to entrances or parking lots, that certainly will come before the commission, either as a supplemental CD or some other federal consistency mechanism before phase two is what I imagine. Or maybe it'll be part of phase two. We're not really clear yet. But we are in active discussions with all these folks and there's been a lot of work towards a different entrance point and I'm not as familiar with all the details.
We can bring back more if you'd like, but there's been a lot of effort and there is a lot of agreement on some potential alternatives and if that comes to fruition, we'll let you know.
Vice Chair, Caryl Hart
Thanks so much. Doctor Hucklebridge. Yeah, I've received outreach from these folks, many of whom I've known for a long time, and so particularly with the entrance, the cheese barn, all of that. So I'll look forward to just getting an update. Thank you so much.
Chair, Donne Brownsey
Thank you, Vice Chair, for those questions.