A POTENTIAL DISASTER FOR THE ECOLOGICAL INTEGRITY OF OSO FLACO LAKE AND THE SURROUNDING DUNES
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.
- 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.
- 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.
- 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.
- 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.
- 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.
Beginning in 2015, an LA-based investment group, in partnership with a prominent local landowner and local planning firm, began the process of seeking to develop a large residential project in the City of San Luis Obispo at the corner of Los Osos Valley Road and Calle Joaquin. The project, known as the Froom Ranch Specific Plan (FRSP), proposes to develop some 404 units of senior housing, including so-called “memory care”, plus a more standard development of 130 apartments and associated commercial development as a separate but related project on the 110 acre Froom Ranch property. CNPS-SLO has not opposed the FRSP per se, but we have strong reservations about the severe environmental impacts the project would impose on the community in general and the Irish Hills in particular.
An Environmental Impact Report on the project was undertaken beginning in mid-2017. That report was finally released in November 2019, and described many impacts from the project. It recommended numerous changes to the project to reduce or eliminate those impacts, and recommended many more “mitigations” to offset those that could not be eliminated. CNPS-SLO has followed this process closely, as we have long been advocates of the City’s environmental policies, and we have been quite vocal about them. Among the most important impacts we have objected to are:
- Allowing development above the 150 foot elevation along the base of the Irish Hills, including a sensitive and natural serpentine bunchgrass community;
- Placing an isolated part of the development in a site surrounded by sensitive woodland;
- Placing two Chorro Creek bog thistle populations at risk; 4. Rerouting Froom Creek around the project site;
- Exposing downstream areas to increased flood potential; 6. Potentially damaging the Calle Joaquin wetland and other sensitive wetland habitats;
- Eliminating part of an existing conservation easement to accommodate the development.
With release of the EIR, the project sponsors themselves saw the severity of one of the most significant impacts and publicly announced that they would drop most of the project above the 150 foot elevation in order to avoid those impacts. They also approached CNPS-SLO to discuss other issues of the project in an attempt to blunt our opposition to other aspects of the project or to modify them if possible. That is where we are today. We are calling for changes to those parts of the project which compromise the integrity of Irish Hills Natural Reserve, or which degrade the environment of Froom Creek or the Calle Joaquin wetland.
Specifically we seek the following changes:
- Preservation of all lands above 150 foot elevation; dedication to the City of SLO, with conservation easement held by the Land Conservancy;
- Preservation of the wooded “cove” area, and its inclusion in the dedication described above;
- Establishment of a park at the former quarry area, with trailhead, historic buildings, and enhancement project on Froom Creek’s north bank and adjacent flood plain (see #7 below); (Note: All of the above items are recommended in the Froom Ranch EIR)
- Presentation of 1, 2, and 3 above, together with adjusted agricultural conservation easement, as a package to justify said adjustment of conservation easement;
- Reasonable proof that rerouting of Froom Creek will: result in establishment of healthy native riparian gallery forest plantings, include use of appropriate native upland species on any elevated surfaces, result in restoration of ecological functions lost due to destruction of existing detention basins in proposed new basin;
- Reasonable proof that rerouting of Froom Creek will not: interrupt groundwater flow, exacerbate flooding or drying of Calle Joaquin wetland, or damage the wetland;
- Mitigation for losses of native bunch grass habitat to include enhancement on the flood plain of Froom Creek at the mouth of Froom Creek Canyon where an excellent opportunity exists in an area now dominated by the non-native fountain grass (Pennisetum);
- Mutual agreement on boundaries of the development and the nature of the required buffer areas between the new development and lands that will remain in open space uses.
CNPS-SLO will continue to press for these changes right through the approval process, which is expected to take at least a year. As nearly all the listed plants (listed here on p.6) lie above the 150 ft. contour, this is most important issue facing CNPS.
Neil Havlik: CNPS _SLO Conservation Committee
Wetlands and sensitive habitat area, southern end. Photo D. Chipping
This URL will give you access to the project description and EIR: https://www.slocity.org/government/department-directory/community-development/planning-zoning/specific-area-plans/froom-ranch
Listed Plants Observed on Froom Ranch above the 150 ft. elevation (from EIR)
Perideridia pringlei (adobe yampah); Chorizanthe ssp. breweri (Brewer’s spineflower); Dudleya blochmaniae (Blochman’s dudleya); Calystegia subacaulis ssp. episcopalis (Cambria morning glory); Senecio aphanactis (Chaparral (rayless) ragwort); Cirsium fontinale var. obispoense (Chorro Creek bog thistle); Calochortus clavatus ssp. clavatus (Club hair mariposa lily); Centromadia parryi ssp. congdonii (Congdon’s tarplant); Delphinium parryi ssp. eastwoodiae (Eastwood’s larkspur); Layia jonesii (Jones’ layia ); Streptanthus albidus ssp. peramoenus (Most Beautiful Jewel-flower); Chorizanthe palmeri (Palmer’s spineflower); Calochortus obispoensis (San Luis mariposa lily); Castilleja densiflora ssp. obispoensis (San Luis Obispo owl’sclover)
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 <firstname.lastname@example.org>. 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.
There has not been a lot of progress on the two large projects of greatest immediate concern. Chapter members attended several meetings, one of which was at the Coastal Commission, on plans to build a southern access to Oceano Dunes State Vehicle Recreation Area. There is zero indication that State Parks is changing it’s mind concerning building a campground and access roads adjacent to Oso Flaco Lake and its special, protected dune and wetland habitat. When the Environmental Impact Report is released, we will have greater opportunity to comment. The other issue, the large development at the mouth of Froom Creek at the Los Osos Valley Rd/ Hwy 101 junction, is having issues with wetland protection, and we are still awaiting an EIR on that.
We are still awaiting the Draft EIR for the Froom Ranch development at Highway 101 and Los Osos Valley Road. We are also watching very carefully the Trump Administration orders to BLM to examine the oil leasing potential of all of its holdings. This is not a problem for most BLM lands in the County, as most are situated on geology extremely unlikely to contain oil deposits.
The county has been extensively drilled over the last century, with most being dry holes, although there is some potential in northern Santa Barbara County, the Huasna area, and some lands adjoining the Carrizo Plain National Monument. We will address any new lease sales as they occur. There are no chances of Morro Rock being drilled, as some conservation organizations have suggested.
We are also following the Diablo Canyon Decommissioning Process very closely, and attended panel hearings.
Lastly, we are also following developments in the Sustained Groundwater Management Act regarding the protection of surface waters:
Our chapter wrote to the California Coastal Commission to support an appeal against the illegal approval by SLO County of a subdivision of a large lot situated is an area mapped as ESHA (Environmentally Sensitive Habitat Area) immediately adjacent to the Dept. of Fish and Wildlife’s Morro Dunes Preserve in Los Osos. The Coastal Plan specifically prohibits subdivision in ESHA. The site supports Morro manzanita, and is occupied by Coastal Dune Scrub, a rare plant association.
Garden Products That Might Be Harmful to Bees
BeeAction.org warns that any gardening product than contains one or more of the following compounds should be avoided if you want to protect our bees. These are Acetamiprid, Clothianidin, Dinotefuran, Imidacloprid and Thiamethoxam. (more…)
With record global temperatures, giant storms, extended tree-killing droughts, and all the other assorted disasters we are experiencing, our fears that we humans are messing up the planet are becoming true. For CNPS, we see a lot of potential threats to the flora, as if the dead oaks and Sierra Nevada pines weren’t evidence enough. (more…)
PROPOSED CLIMATE CHANGE WORKING GROUP
David Chipping (email@example.com)
The CNPS Chapter Council elected to explore how we might deal with issues associated with climate change, and a statewide working group is starting up with me as Chair. One thing I would love to do is to make SLO Chapter a ‘test bed’ for different approaches to the problem. I invite anyone interested to contact me and share their views.
To kick things off I see the following key issues for our consideration:
- What do climate models say about the most likely changes in climate that might reasonably be expected?
- Looking at our plant species and vegetation, where are the greatest risks given the expected climate change, in terms of many changes that might be expected. Use some existing methodology for assessing and ranking multiple risk factors.
- 3) Start doing vulnerability analyses of CNPS listed plants in our chapter area. This will include seeing what happened during the extreme stressor of the drought we have just experienced.
- Gain better knowledge of existing trends, including initiating plant surveys and gaining information on historic population distribution. Lots of field trips and field work here. We would work at the individual species and the grosser level of ‘vegetation’.
- Examine what our chapter would recommend regarding future CNPS actions and policies. For example, would we support “assisted migration” in which a plant at risk of extirpation would be transplanted into areas it has never historically occupied?
Do we, after assessing that there are too many variables that could affect future conditions, throw up our hands and leave it to Darwin to sort out?
Another summer has passed, and there are a few clouds on the horizon.
- The Froom Ranch project is of great concern, as it impacts Chorro Creek Bog Thistle, wetlands, and violates City policy regarding the maximum elevation for development.
- The Las Pilitas quarry project appears to be coming up again now that the political balance on the Board of Supervisors has changed, but we don’t know what changes will be proposed to justify resubmission.
- The Eagle Ranch development in Atascadero seems to have taken a step backward based on financial issues with the City, but we have no specific details.
- The Avila Ranch Project in southern San Luis Obispo does not have any apparent impact on native plants.
- We have protested any changes to Carrizo Plain National Monument.
– David Chipping