Los Osos Draft Habitat Conservation Plan (DHCP)

CNPS has concerns about the estimated impacts to Morro manzanita that are described in the DHCP. On Table 4-1, page 4-37, the impact of development on residential parcels greater than 1 acre is given as 1 acre per parcel. However the area within the DHCP includes core manzanita habitat south, east and west of the southern edge of the Cabrillo Estates subdivision. The DHCP shows no recognition that this parcel was the target of a large scale subdivision in 1998. This was Vesting Tentative Tract Map 1873, which was approved by the SLO County Board of Supervisors, but defeated on appeal by CNPS and others to the California Coastal Commission, which recognized that area as ESHA (Environmentally Sensitive Habitat Area).

The 1998 project was described as the division of 124 acres into 41 residential lots and 3 open space lots, the latter totaling 88 acres, and therefore indicating that the 41 lots and roads would consume 124-88 = 36 acres. The 1996 subdivision described the developable envelope and associated buffer for each lot as being limited to 20,000 sq.ft., with a cumulative footprint of 18.82 acres. When fire clearances are considered at the Wildland-Urban Interface, acreage impacts are more severe. Manzanita is considered flammable by fire departments, and vegetation clearances of a minimum of 50 feet, and as much as 100 feet could remove as much as 1.5 acres of the plant around a single lot.

It must be remembered that this was actually approved by the Board of Supervisors, and only stopped at the Coastal Commission as a violation of the local coastal plan’s protection of an Environmentally Sensitive Habitat Area (ESHA).

We have some other concerns as well. The DHCP requires a fee to be paid into a conservation fund by anyone seeking to ‘take’ of a covered species. The other species are Indian Knob mountain balm, whose populations are already protected, and two animals, the Morro Bay kangaroo rat and the Banded dune snail. The idea is to spend the collected funds on habitat enhancement, such as veldt grass removal, and the purchase of mitigation lands. One of the problems is that there are plenty of people ready to pay fees as the cost of doing business, but willing sellers of mitigation lands are hard to find. In addition, most of the core manzanita habitat is in pretty good shape, although becoming senescent, so that there is really not much mitigation that can be done, and for the manzanita, the DHCP appears to be a negative-sum game. The DHCP appears to underestimate the impacts to the plant, particularly as the protection of federally listed plants is weak relative to that of animals, and that could dictate where limited mitigation funds will be spent.

I can send you a copy of the DHCP if you email me at <dchippin@calpoly.edu>. The files can be downloaded from the Ventura office of the U.S. Fish and Wildflife Service <https://www.fws.gov/ventura/>. Comments are accepted up to November 18th.