Action Alert: support 10-mile Dunes Project

by Victoria Brandon, Redwood Chapter Chair

As has has previously been mentioned, Redwood Chapter is supporting a project to protect natural dunes habitat at MacKerricher State Park on the Mendocino coast. The Mendocino Board of Supervisors gave the project (which  will restore natural conditions in a 1,285 acre natural preserve by removing 2.7 miles of remnant sections of a former logging road paralleling the beach, two failing culverts, and large quantities of invasive European beach grass) a green light late in August, but their decision has been appealed to the Coastal Commission, which will probably consider the appeal in November.

We’re now asking Club members and others to send letters to the Commission staff urging that they recommend a “no substantial issue” position on the project — in effect, that the Commission reject the appeal by refusing to consider it. Letters have to be handwritten or printed, signed (with contact info) and MAILED (no emails) to Bob Merrill, California Coastal Commission, 1385 8th Street, Suite 130, Arcata, CA 95521.

A sample letter and additional talking points (all supplied by Mendocino Group activist Linda Perkins) are pasted below — please take a few minutes to help in preserve our coast.


Sample letter:

Bob Merrill
California Coastal Commission
1385 8th Street, Suite 130
Arcata, CA 95521

RE: Commission Appeal A-1-MEN-13-241 – Oppose Appeal, Support Project

We urge that your staff recommend to the Coastal Commission that no substantial issue exists with respect to Mendocino County’s approval of CDP #12-2012, California State Parks’ Dune Rehabilitation Project at Inglenook Fen-10 Mile Dunes MacKerricher State Park.

We are in agreement with Mendocino County Coastal Permit Administrator’s (CPA) approval of the proposed project and their findings and conditions as adopted in the June 11, 2013 CPA Staff Report, and amended by the Board of Supervisors at their August 26th, 2013 special hearing.

In regard to the proposed road removal, we believe the project to be in conformity with the public access and recreation policies of the California Coastal Act and the Local Coastal Program.

The ocean has washed sections of the remnant road away, leaving hazardous chunks exposed; other portions are covered with sand. The road is discontinuous with other roads, requiring a hearty walk of 20 minutes through sand to reach the remnant portions; current usage is therefore very low. Sea level rise will continue to undermine the remainder. It would be infeasible to retain or to reconnect this piece of road – both because of its impacts to natural ecosystem processes and endangered species habitat, and because maintenance would be nearly impossible in a naturally shifting dunes system.

After having carefully reviewed the issues, taking note that the Parks permit  was specifically conditioned by the planning department to enhance recreational opportunities for hikers and bicyclists, considering that Parks has plans to upgrade and maintain the popular hiking and biking sections of haul road within MacKerricher Park south of the Preserve, and that Parks is helping facilitate development of a bike path along Highway 1, we believe that the restoration of these rare natural dune areas is a priority project of statewide significance that deserves our full support.


Additional talking points:

    * Purpose of a natural preserve (PRC 5017.91): “The purpose of natural preserves shall be to preserve such features as rare or endangered plant and animal species and their supporting ecosystems, representative examples of plant or animal communities existing in California prior to the impact of civilization…”

     * Natural Preserve is one of few remaining intact, relatively pristine dune and wetland complexes remaining in California; estimated that only 3% of intact dune systems remain in northern CA

    * Project will restore ecosystem processes in a 1,285 acre natural preserve by removing 2.7 miles of remnant sections of a former logging road paralleling the beach, two failing culverts, and European beach grass

    * Project planning and design conducted in collaboration with a team of well respected scientists, including botanical experts, a PhD Coastal Ecologist, and California Geologic Survey Senior staff

    * Southern section of road began washing out in 1983; nearly 1 mile is completely gone and most of remaining sections are covered in sand; road has not functioned as a through trail for bicycles, or people in wheelchairs for 30+ years

    * Road base, asphalt veneer, culverts, and European beach grass block natural sand movement, altering natural ecosystem processes that are critical for endangered species

    * Habitat to be restored supports three federally listed species: western snowy plover, Howell’s spineflower, and Menzies wallflower, and over eight additional special status species

    * Connecting the washed out sections of road would never be approved through the environmental permitting processes due to direct impacts to endangered species that cannot be mitigated to a level of insignificanc

    * State Park attempts to plan for multi-use trail development in dunes were abandoned in 2000 after a lengthy process determined that the project was not feasible based on engineering, cost, incompatibility with unit classification, and jeopardy to survival of listed species

    * Environmental document and permit approvals completed for the project include: an unchallenged Mitigated Negative Declaration, CDFW 1600 permit, Water Quality 401 certification, CDFW Incidental Take Permit, State Lands Commission permit, Air Quality Permit

    * County Coastal Planning and Board of Supervisors approved Coastal Development Permit; approval appealed to the State Coastal Commission based on misinformation formulated by local opposition

    * Project supported by CDFW, USFWS, Audubon Society, Sierra Club, CNPS, and political representatives Wes Chesbro, Noreen Evans, and Jared Huffman

    * Time is of the essence, as further State permitting delays may result in loss of Prop 84 funds to implement the project


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