October, 7, 2010

Agenda Item No: Th8a

Permit Number: 3-09-068

CNPS Opposes the Project

Dan Carl, District Director
California Coastal Commission
725 Front Street, Suite 300
Santa Cruz, CA 95060

RE: Revised Arana Gulch Master Plan, Permit Number 3-09-068, October 14, 2010

Dear Staff and Commissioners:

At the March 2010 Coastal Commission hearing, Commissioners requested the City of Santa Cruz consider alternatives that could meet the project objectives while avoiding environmental impacts identified by many experts testifying before the Commission.

At the March hearing the California Native Plant Society (CNPS) displayed a conceptual alternative depicted by an unsurveyed line on a map. The CNPS alternative skirted the periphery of the endangered tarplant habitat to avoid bisecting the habitat of the federally and state listed tarplant.

After the March meeting the City of Santa Cruz did not consult or collaborate with CNPS. Instead, the City interpreted the conceptual plan as literal, hired a GIS consultant to survey the conceptual alignment, and proceeded to discredit what they are calling the "CNPS alternative."

When CNPS asked to view the publicly-funded GIS data (not the consultant's report, just the data points), the City refused to provide the data. CNPS did not have the resources to conduct its own GIS survey. Thus no detailed CNPS alternative was ever developed or evaluated by the City or CNPS.

The result is that the City created a straw man alternative which they then proceeded to discredit. If CNPS had had the GIS data, the conceptual route could have been properly evaluated and adjusted to eliminate the extensive grading (and resultant cost and environmental degradation) attacked by the City in its report.

The revised plan submitted by the City does not meet the scientific and environmental standards of CNPS.

• The revised City plan still routes a paved trail through the middle of Arana Gulch tarplant grassland instead of going around the habitat as CNPS recommends.


• The City attacks the conceptual CNPS alternative for traversing some areas of common native grasses (Danthonia, Nassella), yet the City's revised plan has a paved, multi-use trail which traverses the more fragile and much more rare habitat for the endangered tarplant.


• Although the City's Master Plan contains an unpaved walking path (Coastal Prairie Loop Trail) on essentially the same route as the conceptual multi-use CNPS trail, the City attacks this alignment in its report stating that this alignment would be subject to erosion and meander. The Coastal Prairie Loop Trial would be subject to the same impacts of erosion and meander, (indeed probably greater impacts as it would be unpaved) as a multi-use paved path replacing the Canyon Trail and the Creek View Trails which bisect the habitat.


• Routing a multi-use trail along the more southerly Coastal Prairie Loop Trail alignment would provide a superior experience for interpretation of the coast, harbor and gulch areas, affording better views and an overlook of the coast, especially for visitors in wheelchairs.

CNPS urges the California Coastal Commissioners to reject the City's revised Master Plan that ignores best practices of a science-based reserve design. This plan fragments the meadow and introduces long-term edge effects into the center of the tarplant management area. The project as proposed is still a non-resource dependent transportation project. The EIR admits that there is a significant impact to the habitat from the project.

The California Coastal Act gives paramount protection to ESHA, preventing any non-resource-dependent development. Access to this greenbelt for all - those in wheelchairs, pedestrians, bicyclists, dog walkers, elders, and children - can be provided with much less impact to the coastal prairie remnant.

It is regrettable that the City chose not to collaborate with CNPS in developing its revised plan. CNPS is still willing to work with the City to develop a route that achieves the City's objectives and follows best scientific practices for protecting endangered tarplant habitat.

Thank you for your time and consideration,