Peter R. Baye, Ph.D. Coastal Ecologist, Botanist Letter to PRMD on Coastal Plan

sonoma coastTo: Lisa Posternak, Sonoma County Permits & Resource Management Department
Cc: Interested parties
Date: September 30, 2015
SUBJECT: General comments on preliminary draft Local Coastal Plan: significant
environmental baseline deficiencies and consequences
Dear Ms. Posternak:
I would like to provide only preliminary and general comments on some selected basic
aspects of the preliminary draft Local Coastal Plan update (PLCP). Detailed technical
comments and corrections would be inappropriate for a preliminary draft LCP, since I
believe systemic and substantial revisions are due for characterization and planning of coastal
biological resources, including ESHA (Environmentally Sensitive Habitat Areas, effectively
“special-status” habitats under the Coastal Act).
My comments are based on over 35 years’ professional and academic experience in
management, restoration, planning, regulation, and research in coastal wetland and terrestrial
ecosystems, with emphasis on the Central and Northern California coast. My professional
experience included regulation and planning of wetlands and endangered species for the U.S.
Army Corps of Engineers and U.S. Fish and Wildlife Service in the Bay Area for over 12
years, followed by independent consulting work on major coastal restoration and habitat
management projects for agencies including California State Parks, State Coastal
Conservancy, National Park Service, U.S. Fish and Wildlife Service, and non-profit
conservation organizations.
Although I appreciate efforts PRMD has made to provide a PLCP to the public, the PLCP
currently lacks a minimally adequate environmental baseline of coastal biological resources to
support adequate, balanced coastal planning.
Many figures representing the distribution of
coastal habitats and resource types are basically inaccurate, and appear to be drawn in part
from outdated sources of data applied uncritically (and without any field validation) to
existing conditions.
The representation of “special-status species” appears to be arbitrary and
woefully incomplete compilations past localities – stale data – gleaned from databases in the
absence of reasonable professional judgment or expert review,
rather than contemporary
review of the scientific literature and resource agency plans informed by scientific expertise.
Database queries of species distributions are biased towards incidental reports and public
lands where survey access has been available, and are not in any way equivalent to either
surveys or assessments. Reporting database queries as occurrences (in contrast with absence
of data) provides a profoundly misleading and erroneous baseline of coastal biological
resources, primarily from very significant errors of omission. Database queries of species
distributions are at best a crude preliminary scoping tool for assessment; LCP guidance does
not state or imply that they should be the basis of biological resource planning in themselves.
This applies to public as well as private land within the geographic scope of the PLCP.
PRMD should at a minimum incorporate basic sound science from multiple regional
recovery plans for special-status species to provide a well-informed broad classification of
coastal habitats. This is also essential for any CEQA-regulated or CEQA-equivalent
regulatory program compliance.
An accurate baseline and assessment of existing coastal biological resources, however, is not
in itself sufficient to support a sound LCP. The LCP must systematically assess the likely
effects of ongoing (in progress) or reasonably foreseeable land use changes to identify
threats and opportunities to conserve coastal resources. This step requires some basic
understanding of how environmental and land use changes (including the combined,
interactive effects of changing land use, water use, climate changes, and human economic
and population change) affect the ecology of important biological resources. This simply has
not been done in the PLCP to any meaningful extent for any coastal resources.
biological baseline has changed and is changing, along with coastal land use pressures; both
must be rigorously updated in the LCP. Including segregated discussions of climate change
and sea level rise, not actually integrated with direct discussion of coastal biological
resources, cannot address this deficiency. Please refer to the Coastal Commission’s 2013
LCP Update Guide.
Intensification of agricultural land uses, expansion of intensive agriculture, intensification of
coastal development, and the indirect consequences for changes in surface and subsurface
(groundwater exploitation) water demand (and their impacts on aquatic and wetland habitats,
and water-dependent coastal species) are chief among the highly foreseeable and
controversial coastal land use changes affecting Sonoma County. The segments of the
Sonoma coastal zone that are especially vulnerable or threatened are coastal stream and river
mouths, embayments and lagoons, coastal prairie, and riparian or wetland habitat associated
with them. The LCP should focus its efforts on these distinctive segments of the coast,
rigorous and comprehensive analysis of changes in coastal land use there, and LCP
programmatic actions to prevent or mitigate degradation of coastal resources.
The tasks I recommend require interdisciplinary expertise and strong background in the
physical geography and ecology of the entire Sonoma Coast. If this is not available “inhouse”
among staff at PRMD, I recommend that PRMD either assemble a scientific and technical advisory
group of qualified experts in coastal planning and biological resources, or
retain the services of a qualified environmental consulting firm, to provide adequate
biological resource baseline and assessments. Without this background, scientifically sound,
meaningful and effective LCP update policies will not be feasible.
Peter R. Baye, Ph.D.
Coastal Ecologist