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Sunday, October 7, 2007

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A Look at the Nature Conservancy's Mount Hamilton Project

http://www.nature.org/wherewework/northamerica/states/california/preserves/art6323.html


San Antonio Valley, Mount Hamilton

San Antonio Valley.
Photo © Gary N. Crabbe

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Map of Mount Hamilton

Fast Facts

Location: East of San Jose and the San Francisco Bay, between Highway 101 and Interstate 5, in the southern Diablo Range.

Size: 1.2 million acres.

At Stake: Streamside forests, oak and sycamore woodlands, vast grasslands and seasonal wetlands that support migrating birds, bobcats, mountain lions, endangered San Joaquin kit foxes, tule elk, red-legged frogs, western pond turtles, steelhead and endangered bay checkerspot butterflies.

Threats: Expanding development, incompatible agricultural practices, proposed infrastructure projects.

Results: 81,000 acres in acquisitions and easements for a total of 300,000 acres protected by the Conservancy and its partners.

Mount Hamilton

Hikers in Mount Hamilton.
Photo © Grant Johnson


Encroaching development and proposed infrastructure projects threaten to fragment the last significant expanse of open space between the San Francisco Bay Area and the Great Central Valley.


Time stands still on the southeastern edge of the San Francisco Bay Area, where the wild west of Old California quietly unfolds toward the Great Central Valley. Tule elk graze in secluded valleys among colossal oaks. Rainbow trout and red-legged frogs navigate canyon streams. Cougars prowl the high ridges of the Diablo mountain range, and kit foxes scamper across open grasslands.

Straddling six counties and 1.2 million acres, The Nature Conservancy’s Mount Hamilton project supports a wide variety of natural communities that have graced Central California for centuries. But this last significant expanse of wilderness between Silicon Valley and the Central Valley is feeling the pinch of a growing population. New housing developments creep toward the project’s outer rims every year, and proposed infrastructure projects for rail lines, freeways and water projects threaten to carve the expansive wilderness into pieces. The Nature Conservancy is pursuing a number of strategies to protect Mount Hamilton and preserve its biological richness for future generations.

Ring of Conservation

The Conservancy launched its Mount Hamilton project in 1998 with the acquisition of two large ranches totaling 61,000 acres. Since then, we have worked cooperatively with landowners to acquire land or restrict development on key private properties situated among the region’s many public parks. As these private and public parcels merge into larger, contiguously conserved landscapes, they will eventually form a ring of protection around Mount Hamilton. This will allow ranchers to preserve their way of life and give native plants and animals the open space they need to survive. Protection of Mount Hamilton’s watersheds provides the additional benefit of keeping the region’s water supply clean.

Lifeline for Wildlife

The Nature Conservancy is also working with partners to preserve the upper Pajaro River floodplain. Located between Gilroy and Hollister, this 20,000-acre spread of agricultural lands, perennial streams and seasonal wetlands is the most defensible, undeveloped wildlife corridor remaining between the inland Diablo Mountains and the coastal Santa Cruz mountain range. Preserving it will allow animals to travel safely between the two ranges, giving large mammals the territory they need to maintain a genetically diverse population.

Here, the Conservancy’s strategy is two-fold: to protect the immediate banks of the upper Pajaro River, and to create an additional buffer by limiting the use of adjacent lands to wildlife-friendly agriculture.

Smart Planning

As California’s population grows, demands for new public works projects increase as well. Three such projects — proposals for new reservoir, a new freeway and a new high-speed rail line — threaten to fragment the Mount Hamilton wilderness and undermine the long-term health of its native plants and animals. The Nature Conservancy is working with many organizations and to ensure that the environmental impacts of these proposed projects are scientifically rigorously studied, and that the projects — should they go forward — be sited along existing transportation corridors or in already-developed areas.

With your help, The Nature Conservancy can preserve a vital part of Old California for future generations, while allowing a new California to blossom.

Friday, October 5, 2007

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2000 Acres in Marin and Sonoma Counties to be Saved by Coastal Conservancy


At the Coastal Conservancy meeting on Thursday, September 20, 2007, the board discussed preserving two properties, 1234 acres in Sonoma County and 750 acres in Marin County. Click on the project names for more details:


Consideration and possible Conservancy authorization to disburse up to $750,000 to Sonoma Agricultural Preservation and Open Space District for acquisition of the 1,235-acre Poff Property for addition to Sonoma Coast State Beach in western Sonoma County.

Consideration and possible Conservancy authorization to disburse up to $750,000 to the Marin Agricultural Land Trust to acquire a conservation easement over the 750-acre Poncia Ranch south of the town of Tomales, in western Marin County.

Thursday, October 4, 2007

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Extension of Western Kern County Rails to Trails being discussed

By Doug Keeler
Published: Friday, September 28, 2007

http://www.taftmidwaydriller.com/articles/2007/09/28/news/news05.txt

City officials are hoping grant funding can extend the Taft Rails to Trails walking path more than three miles to the east where it will join a large walking, biking and nature area.

Plans are preliminary and funding has not yet been obtained, but Lucille Holt, the city's grants administrator, is envisioning several hundred acres of pathways, a nature area, possibly an amphitheater on 454 acres of land currently owned by the Federal Bureau of Land Management.


Holt calls it a walking park - three-quarters of a square mile of open land crisscrossed by paths for walking, jogging, biking or skating.

It could even include a nature preserve or an amphitheater built in a natural depression.

“It's an ambitious plan and it won't happen overnight, but I think it would be a wonderful addition to Taft,” Holt said.



Grants - both state and federal - will be needed to get the project going. Federal grants can be used to extend trails to trails east from its current end at Second Street for nearly 31/2 miles along the old Sunset Railroad right-of-way to the site of the proposed park, currently an L-shaped parcel of vacant land.

The project would need a pedestrian bridge over Highway 33 stretching from Petroleum Club Road to Gardner Field Road near the intersection with Gas Company Road.

It is also located near where Sandy Creek crosses Gardner Field Road.



Plans have been discussed over the past six years to someday turn Sandy Creek into a recreational walking and biking path.

That fits in well with the proposal that Holt is looking at.

“We would really like to turn Taft into a walking community,” Holt said.

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Actors and Others Form Foundation to Protect and Expand National Monuments

Diana Marrero • Desert Sun Washington Bureau • October 2, 2007

also see http://fotdm.org, Friends of the Desert Mountains


WASHINGTON - The San Jacinto and Santa Rosa mountains - as well as millions more acres of national monuments - could gain extra funding through a new conservation foundation.


Actor Edward Norton, a big supporter of environmental causes, is joining former Interior Secretary Bruce Babbitt, who last week announced the creation of the National Conservation System Foundation to raise awareness and funding to protect these lands.

"Many of these special places are not protected in national parks or wildlife refuges," Norton says in a Web video featuring footage of unspoiled Western vistas. "Today, these national treasures face growing threats and could be damaged forever by development, vandalism and neglect."

Those problems are expected to grow as more people move out West, causing lands that were once isolated to fall victim to vandalism, artifact theft and off-road vehicles that trample plants and other wildlife habitats.

Among areas joining the valley's mountains are the rugged plateaus and cliffs of the Grand Staircase-Escalante in Utah and the islands, rocks and exposed reefs that hug California's coast.

Former President Bill Clinton designated the lands as conservation areas during his last term in office. But they have not received the attention or funding they deserve, said Babbitt, who helped Clinton create the current conservation system of lands.

"We can wind up destroying the values that brought us here in the first place," Babbitt said.

In 2000, Rep. Mary Bono, R-Palm Springs, won designation of the Santa Rosa and San Jacinto mountains as national monuments. Bono, a member of a congressional conservation caucus, says more funding is needed to protect the mountains, which are just footsteps from her home.

Last week, she joined Democratic Sen. Barbara Boxer, who has a house in Rancho Mirage, in introducing legislation that would expand the Santa Rosa and San Jacinto Mountains National Monument and designate nearly 200,000 acres of pristine and ecologically sensitive lands in Riverside County for conservation.

The lands protected under the bill provide habitat for threatened bighorn sheep, the desert tortoise and bald eagles.

"If these things ever vanish," Bono said, "they're gone for good."

article continues: http://www.mydesert.com/apps/pbcs.dll/article?AID=/20071002/NEWS07/310020003


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Promised San Diego Refuge Teeters Between Fulfillment and Failure

A view of the San Diego National Wildlife Refuge Photo: Rob Davis

By ROB DAVIS Voice Staff Writer

http://www.voiceofsandiego.org/articles/2007/10/04/news/01sdnwr100407.txt


Thursday, Oct. 4, 2007 | Two thousand feet below the peak of San Miguel Mountain, the brown landscape is cut in half. Look west, and the San Diego metroplex starts, all red-tile roofs and new asphalt and car windshields twinkling in the streaming sunlight. Look east, and jagged mountain ridges jut up through the haze, blanketed in native plants home to 22 endangered and threatened species.

This is the dividing line between coastal sprawl and the eastern backcountry, the buffer between new California and the chaparral-covered landscape that defined old California.

U.S. Fish and Wildlife Service biologist John Martin looks out from the 2,500-foot peak east of San Diego, and sweeps his hand across the horizon.


"As San Diego marches east," Martin says, "this is the front line."

That front line has a name: The San Diego National Wildlife Refuge. It was created in 1996 as part of the Multiple Species Conservation Program, a plan that outlined a blueprint for the region’s future growth. The program was a tradeoff that allowed less important habitat to be developed in exchange for protecting the most vital remaining land. Instead of land being conserved or developed on a housing project-by-housing project basis, the program outlined a region-wide preserve system.

The refuge was among the most vital parcels designated for conservation, because of its size and location -- and because it was intact.

As envisioned, the refuge was a keystone of undeveloped land that would connect preserved land along the South County coastline with conserved land in the Cleveland National Forest and the mountain ranges beyond.

But the refuge has not yet lived up to its promise, according to a report recently authored by Jerre Stallcup, an Encinitas-based conservation biologist. Property acquisition has slowed as funding has decreased. The refuge today is a jumbled patchwork of 25,000 acres owned by a variety of government agencies, private landowners and a nonprofit conservation group. Some development has pushed into land that was targeted for conservation.

"The concern is that as funding sources change, as attitudes change, as politicians change, there may not be the same level of support in the future as there was in the past," says Stallcup, who is affiliated with the Oregon-based Conservation Biology Institute. "I'm concerned that we're already seeing that trend."

The refuge grew rapidly in its first five years. The U.S. Fish and Wildlife Service, which manages the refuge, spent $19 million and acquired 7,155 acres -- some from donations -- in that time. But in the six years since, the service’s spending dropped to $11 million and 887 acres were set aside.

As conservation has slowed, development pressures have been pushing closer to the refuge’s target boundary. Two subdivisions are under construction within the refuge’s western boundary. A one-street-long gated community called The Pointe reaches like a tentacle into the preserve’s northern edge.

Andy Yuen, the Fish and Wildlife Service’s refuge project manager, says he is concerned about development pushing into the refuge. But he points out that while some homes have been built inside the refuge’s target boundary, other permitted projects have not been developed, instead being preserved.

But development pressure is increasing, Stallcup says. And if private landowners inside the refuge boundary decide to develop their land instead of selling or donating it for conservation, the existing preserve -- about 25,000 acres in all -- would lose much of its value, she says.

When homes are built near undeveloped land, a variety of effects impact the open space. Domestic cats may chase after endangered birds. ATV riders may carve new trails over previously undisturbed terrain. Invasive grasses (and more people nearby) can increase fire risk.

Martin, the wildlife biologist, points to a hillside on San Miguel Mountain that used to house a golden eagle nest as evidence of those effects. As development pushed closer to the refuge, the eagles vacated their nest.

If the refuge isn’t preserved as a contiguous space and is instead fragmented, its ecological value will drop, Stallcup says. A larger landscape helps promote genetic diversity among resident species. More space helps maintain normal relationships between predators and their prey.

"Unless you maintain those linkages, we’re not going to have that," Stallcup says. "If you start developing within that area and fragmenting it into smaller pieces, then you impact not only the 25,000 acres, but all of the preserved land in South County."

Bureaucratic hurdles created by the numerous government agencies owning land within the refuge boundary add to the challenges. The county and city of San Diego own property, as does the California Department of Fish and Game, the federal Bureau of Land Management, the Fish and Wildlife Service and the Nature Conservancy. That wide ownership makes law enforcement problematic.

Like bandits escaping to Mexico in old Westerns, illegal ATV riders who cross from federal land onto state or private land can’t be pursued, Yuen said. This barrier exists in an area where off-roading has clearly impacted the terrain and its sensitive habitat. Clay-colored off-road trails are carved into the hillsides.

Stallcup says those bureaucratic barriers are "ridiculous." Pointing to those agencies that own land within the refuge’s boundaries, she says, "They’re all managing it independently of each other -- or not managing it. Where we have such scarce resources, it would be so much more cost-effective to pool those."

One agency may undertake a project to remove invasive plants from a river’s edge, Stallcup says, without consulting with another agency upstream to see if similar steps are being taken. What can result, she says, are often fruitless efforts to manage the land. If the upstream owner leaves invasive plants in place, their seeds wash downstream, germinate and grow back.

Asked why the ownership isn’t consolidated, the Fish and Wildlife Service’s Yuen pointed to his three-member staff already managing 8,500 acres of federally owned land on the refuge.

"My concern would be how much thinner can I spread those people out," he says, "and still have them be effective?"

David Hogan, conservation manager for the Center for Biological Diversity, an environmental group, says despite the challenges, he remains hopeful that the refuge will live up to its potential.

"Because of its large size and connectivity, the area provides a tremendous opportunity for good management," he says. "Unfortunately, good management is not occurring today."

Stallcup says it remains imperative for the refuge to be completed. About 20,000 acres would need to be preserved.

"It’s a big area, it’s going to take a lot of resources to finish," she says. "But all of the state, federal and local monies that have been spent were spent with the knowledge that this would be conserved."

Wednesday, October 3, 2007

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State Water System Doesn't Have Enough for North L.A. County Housing Tract; Is This the Beginning of the End of Sprawl?



Officials float rejecting new housing tract

This story appeared in the Antelope Valley Press on Monday, October 1, 2007.
http://www.avpress.com/n/01/1001_s4.hts

By JAMES RUFUS KOREN
Valley Press Staff Writer
LOS ANGELES - With California Aqueduct water supplies in question because of a court ruling over an endangered fish, Los Angeles County water officials have proposed refusing to allow construction of a 650-home tract in west Lancaster. County supervisors will be asked Tuesday to approve a report showing there is an inadequate water supply for a 160-acre tract proposed near Avenue J and 70th Street West. The Antelope Valley-East Kern Water Agency cannot guarantee water from the State Water Project will be available for the new tract, according to the report from Los Angeles County Waterworks District No. 40, which supplies much of Lancaster and west Palmdale as well as other parts of the Antelope Valley. The trouble stems from a U.S. District Court action that protects the delta smelt, an endangered fish species that has been hurt by water pumps in the Sacramento-San Joaquin River Delta - the source of the water that flows down the California Aqueduct to Southern California. "While state and local water agencies are still analyzing the court ruling, the decision might result in a significant reduction in water supplies from the State Water Project to AVEK and other State Water Project contractors," the report said. "As AVEK is currently unable to assure the (Waterworks) District of the availability of State Water Project water supplies ... the District is unable to conclude that sufficient future water supplies are available for this project." According to the report, the 650-home tract would create demand for 780 acre-feet of water per year. A single acre-foot is 325,851 gallons. Supervisors face the decision against a backdrop of controversy over the Valley water supply's ability to support population growth. With last winter the driest on record for Southern California, coupled with the delta smelt court decision, AVEK officials have warned that local supplies from the California Aqueduct might be cut back drastically if next winter is dry. Waterworks officials have not ordered their customers in Lancaster or elsewhere to reduce water consumption, but Palmdale Water District officials last month told customers to stop hosing down sidewalks and to take other conservation measures. District officials had contemplated ordering a 30% reduction in water use, but shelved that plan after city officials accused them of failing to prepare for an emergency and of engaging in scare tactics. This is the second time the Waterworks District has said there is not enough water for new developments in the Valley. In July 2004, the district stopped issuing new "will-serve" letters - documents that say the district will supply water - to proposed housing tracts. The waterworks district never officially refused water service, but it had sent letters saying water might not be available. That dispute was settled in December 2004 when the waterworks district and AVEK struck a deal that required AVEK to provide District No. 40, which covers most of Lancaster and Palmdale, with a set percentage of its water supply. The deal also increased fees paid by developers to enhance the Valley's water system.

Tuesday, October 2, 2007

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PACIFIC LUMBER BANKRUPTCY REORGANIZATION PLAN WOULD SELL, DEVELOP AND LOG LAND
(click on map to enlarge)

(from the Bay Area Coalition for Headwaters Forest, http://headwaterspreserve.org/)

The long-awaited corporate reorganization plan that Pacific Lumber must, by law, submit to the bankruptcy court under Chapter 11 bankruptcy proceedings is out, after two extensions. Under bankruptcy law, the debtor (PL) gets the first whack at a proposed management plan, after which the court decides whether present management will retain control.

In brief, PL proposes to sell the Marbled Murrelet Conversation Areas, some 6,600 acres of ancient redwood forest contained in 6 groves that were set aside for 50 years under provisions of the 1999 Headwaters Deal. They propose to sell an additional 22,000 acres adjacent to and surrounding those groves as high-end housing development, sell the town of Scotia, and retain ownership of approximately 181,000 acres of forestland for timber production.

Our good friends at the Alliance for Sustainable Jobs and the Environment have posted the entire plan, along with a map at http://asje.org/PL_Reorganization_Plan.html

While PL CEO George O'Brien calls the plan "win-win" in the business pages, there are clearly losers, and at best, the proposal assumes an assembling of buyers for the land they wish to sell at unbelievably inflated prices. ($400 million for the ancient groves) Some manipulations are fairly bald-faced, as in Maxxam's "forgiving" of a $60 million "debt" that is an engineered claim against its own subsidiary in the first place, and PL financial architects clearly hope to woo the bondholders to their side of the court with their promises of cashing out the debt burden. The bondholders are owed about $785 million (from PL's refinancing of its original purchase debt) and would receive only (approx.) 67 cents on the dollar under that plan.

PL also claims as a chit in their favor the real estate expertise of its parent Maxxam. Hurwitz's Maxxam has been in the real estate business far longer than they have been in the timber business. High end development is their ball game and they play hard ball. An interesting story from Maxxam's past involves a development in the Palm Springs area proposed for bighorn sheep lambing ground.

PL is fighting to keep other proposals from coming before the court. A hearing to extend that exclusivity to February is scheduled for Nov. 23.

The SF Chronicle ran a story today about the PL plan and are offering a comment opportunity at http://www.sfgate.com/cgi-bin/article/comments/view?f=/c/a/2007/10/02/MN41SI0CB.DTL

You can link to the full story from there as well. Please weigh in, making the points that

*this is not a sustainable *reorganization*. It is proposed highway robbery with land values inflated in some cases 10 fold, and another attempt to raid private and public coffers and send hundreds of millions of dollars to the pockets of Charles Hurwitz.

*Old growth forests and BUFFERS are not negotiable. Isolated old growth groves need buffers to survive and thrive as habitat. Housing developments are NOT biological buffers.

*The bankruptcy court should receive alternative plans for management from creditors, Humboldt county residents, workers and other stakeholders.

*No conversion, ever, of forest land to development. It has happened to an extreme degree in Sonoma, to a large degree in Mendocino, and must not happen in the redwoods in Humboldt county!

NOTE: BACH will have a public activist get-together soon to present the situation in full, and also to bring updates from the oak grove tree-sit. Please watch for the notice!

Monday, October 1, 2007

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San Diego Sewer and Water Bills to Double to Provide Water for Next Wave of Development?


UNION-TRIBUNE EDITORIAL
Perrier, it isn't
Aguirre toilet-to-tap plan doubles sewage bills http://www.signonsandiego.com/uniontrib/20070915/news_lz1ed15top.html

September 15, 2007

Should San Diegans pay a staggering $4.5 billion for the privilege of drinking treated sewage water from their faucets? City Attorney Mike Aguirre believes they should. What's more, he hopes to persuade federal regulators to require San Diego to adopt his enormously costly and wildly unpopular toilet-to-tap program. Exactly how expensive would it be? City wastewater engineers calculate Aguirre's scheme would drive up the typical household sewage bill, which today is about $38 per month, to a whopping 102.50 per month, or $1,230 per year. Under a series of rate hikes already adopted by the City Council, the typical monthly sewage bill is set to rise to $50.62 cents by 2012. Aguirre's toilet-to-tap proposal would more than double this figure. And this is only the sewage portion of your monthly bill. It does not include your water bill, which also is rising dramatically. If Aguirre has his way, typical homeowners would pay a combined sewage-water bill of $160.77 per month, or $1,929.24 per year – double what they now pay. With this huge outlay by ratepayers, sewage from the Point Loma treatment plant would be processed to higher levels than currently and pumped through a new network of pipelines many miles uphill and deposited directly in city reservoirs. Then it would be treated yet again before flowing to your faucet. Aguirre says San Diego must resort to this high-priced scheme because of looming water shortages. Yet, today San Diego produces thousands of acre-feet a year of recycled irrigation water that is dumped into the Pacific because there are no buyers for it. Before we stoop to drinking our own sewage water – a prospect that raises a variety of health concerns – we should first use all of the recycled irrigation water that we already produce at a much lower cost. We're counting on Mayor Jerry Sanders, who is adamantly opposed to Aguirre's toilet-to-tap plan, to save us from it.

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EARTHJUSTICE e-BRIEF
SEPTEMBER 2007

Smelt Victory Ignites Water War
A statewide water war is brewing over the threatened delta smelt, slaughtered to the point of near-extinction by massive water pumps. A federal court judge ruled Aug. 31 that water project operators must increase flows through the Sacramento-San Joaquin Delta at certain times of the year to help the smelt survive. Titans of California agribusiness and residential water consumption immediately launched scare campaigns predicting water shortages and economic catastrophe. Earthjustice, which represented plaintiff groups in the successful lawsuit, is girding for the next round as political leaders resurrect previously discredited water delivery schemes such as the Peripheral Canal and new dams. Read Executive Director Buck Parker's analysis.

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Coastal Commission Staff Calls South Orange County Tollroad Project a Disaster for Wildlife






The Project is Scheduled to be decided upon at the Commission' s meeting on October 11th In San Pedro, at the Crowne Plaza Los Angeles Harbor Hotel, 601 S. Palos Verdes Street


To read the full staff report: http://documents.coastal.ca.gov/reports/2007/10/Th19a-10-2007.pdf

Here is an excerpt from the summary:

Environmentally Sensitive Habitat Areas (ESHA):
The project is fundamentally inconsistent with the spirit and letter of numerous resource protection policies of the Coastal Act. The project involves development within environmentally sensitive habitat areas (ESHA) and is inconsistent with the ESHA policy (Section 30240), which only allows “uses dependent on the resource” within an ESHA. Moreover, the project is inconsistent with the additional requirements of Section 30240 because it would not protect the ESHAs against any significant disruption of habitat values; not be sited and designed to prevent impacts which would significantly degrade those areas; and not be compatible with the continuance of the ESHAs. The ESHAs include habitat for the Pacific pocket mouse, tidewater goby, arroyo toad, coastal California gnatcatcher, least Bell’s vireo, and southern California coast steelhead. The most significant adverse impacts, impacts which cannot be mitigated, would be to the Pacific pocket mouse. In fact, it is highly likely that the project would result in the complete loss of one of the three remaining limited populations of Pacific pocket mouse and thereby hasten the extinction of the entire species, which is federally listed as endangered. The project would also likely result in the loss of the only remaining coastal population of the arroyo toad, also federally listed as endangered, because it proposes at least three years of significant construction activities within more than 66 acres of ESHA for this species. The project also proposes to conduct grading, vegetation removal, and substantial landform alteration associated with the placement of the six lane toll road within 50 acres of the vitally important coastal sage scrub vegetation community that provides federally designated critical habitat for the coastal California gnatcatcher, a third species listed under the federal Endangered Species Act. Moreover, the project proposes permanent and prolonged use of wetland areas totaling over 29 acres, areas that have included federally designated critical habitat for two species that are federally listed as endangered, the tidewater goby and arroyo toad, and provide essential ESHA habitat for two others also provided with this listing status, the least Bell’s vireo and southern California coast steelhead.

In addition to the disturbance and destruction of untold numbers of these six species and potentially irreparable harm to their local, regional and global populations, populations which have been consistently recognized as both vitally important and gravely threatened, the project would fragment and transform one of the last remaining intact watersheds and coastal canyon ecosystems in all of southern California. Considering the magnitude, extent and duration of activities associated with the project it is highly likely that well over 66 acres of ESHAs would be degraded or permanently lost. As evidenced by the large number of threatened or endangered species and federally designated critical habitats within the relatively small portion of the project area that is proposed to occupy the coastal zone, and the fact that nearly 48% of the 138 acre project footprint within the coastal zone has been found to meet the Coastal Act definition of ESHA, it would be difficult to imagine a more environmentally damaging alternative location for the proposed toll road and one which would be more clearly inconsistent with the environmentally sensitive habitat resource protection requirements contained within Coastal Act Section 30240.

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