History has record of the strong local effort to protect the wetlands and lakes of the Oso Flaco area, including the work done by the ‘Dune Mother’. Kathleen Goddard Jones. Our comments are hereby confined to issues surrounding the Oso Flaco Campground and Public Access Project, also termed Project A in SVRA Public Exhibits.

Besides the obvious disruption to the natural environment of Oso Flaco Lake through vastly increased vehicle traffic which will disrupt an extremely important birding area, CNPS plant specific concerns are hereby listed and should receive thorough analysis of projected loss and mitigation in the environmental review process.

These plans for the southern entrance represent an existential threat to the rare plant species in the Oso Flaco region.

  1. Federal and State Endangered Arenaria paludicola have extant populations (verified 9/2018) on the west and east shores of Oso Flaco Lake (northern half).  Improvements in the causeway, and the riding area extension trail will destabilize the hydrology of the northern half which supports this population.
  2. Federal Endangered and state endangered Nasturtium gambelii (California Rare Plant Rank: 1B.1) seriously threatened and eligible for listing) had populations immediately north and south of the causeway, and any “traffic capacity” improvement in the causeway would directly impact those locations.
  3. Federal Endangered and state endangered Lupinus nipomensis (California Rare Plant Rank: 1B.1) is found growing within the refinery waste pipe right-of-way, and using that ROW, as envisioned in the Concept 1 plan threatens this core population.
  4. Cirsium scariosum var. loncholepis California Rare Plant Rank: 1B.1, State of California as Threatened and by the Federal Government as ‘Endangered) was recorded growing in damp swales south of the Refinery ROW in the OHV trail drawn in the Concept 1 plan.
  5. The locally significant stand of Leptosyne gigantea (aka Coreopsis) is found on the west side of Osos Flaco lake, and within the redline OHV route shown in the Concept 2 plan.

In view of the long history of labor and resources that has taken place in the protection of these species, and of the integrity of the dune scrub ecosystems, we believe that a southern entrance to the SVRA should be removed from future development plans.

Screen shot from the SVRA’s planning documents. Note the two entry points that would carve roads across vegetated dunes on the eastern edge, and the proposed 40 acres of new OHV roads just north of the Oso Flaco Lake area. You can find project documents at oceanodunespwp.com/en/documents.