By Andrew Christie, Chapter Director
As part of its four-decade kabuki drama attempting to make its management of the Oceano Dunes State Vehicular Recreation Area comply with the California Coastal Act, the California Department of Parks is rolling out a Public Works Plan, with “site specific proposed park improvement projects.” Project A is the Oso Flaco Campground and Public Access Project.
For some reason, local folks are looking askance at the proposed conversion of approximately 120 acres of agricultural land into a “campground and vehicle staging area” with more “motorized recreation access” in the middle of the top birding spot in San Luis Obispo County. Proposing to carve out the heart of a habitat area for more than 200 avian species and drop this project into it isn't getting a great reception.
But here’s the main problem for State Parks: Converting agricultural land requires a zoning change and an amendment to the County’s Local Coastal Plan, which must be approved by the California Coastal Commission. Everything in the proposed Public Works Program must be consistent with the LCP. The conversion of ag land is controlled by Section 30242 of the Coastal Act, "Lands suitable for agricultural use; conversion":
All other lands suitable for agricultural use shall not be converted to nonagricultural uses unless (l) continued or renewed agricultural use is not feasible, or (2) such conversion would preserve prime agricultural land or concentrate development consistent with Section 30250. Any such permitted conversion shall be compatible with continued agricultural use on surrounding lands.
Campgrounds, roads, and vehicle staging areas for improved motorized recreation access need not apply.
Would you like to tell State Parks that this is the worst possible spot in the ODSVRA to put a 120-acre campground, staging area, etc., or suggest that the agency write 500 times on a blackboard "We must comply with the California Coastal Act and the Local Coastal Plan?" They are eager to get your input.
Just kidding. State Parks has devised a parody of a public comment form for all the proposed projects in their Public Works Plan that restricts the public to exactly two choices: You may comment that you like one version of the project somewhat more than you like another slightly different version of the project, or vice versa. Go around it:
By Email: info@OceanoDunesPWP.com
By Mail: California Department of Parks and Recreation
Attn: Katie Metraux, Acting OHMVR Planning Manager
1725 23rd Street, Suite 200
Sacramento, CA 95816
The opportunity for actual public input will come when this plan is presented to the Coastal Commission for certification. When that public hearing convenes, State Parks may wish to bring along that blackboard and a box of chalk.
127 strikes and you’re out
Meanwhile, the Scientific Advisory Group (SAG) established to ride herd on State Parks’ Draft Particulate Matter Reduction Plan for the Oceano Dunes has kicked it back with a withering evaluation for (another) do-over. State Parks submitted its plan on February 1, and a revised DPMRP on February 21. Now they’ve been told to try again.
Here’s the meat of the matter from the SAG’s 51-page analysis [emphasis added]:
“SAG wishes to emphasize a number of concerns and shortcomings of the PMRP document in its present form. Specifically, the PMRP lacks a clear plan and assignment of responsibilities for implementation of the dust mitigation interventions. While in principle adaptive management is a well-justified approach in working with highly complex natural systems, it can lead to unacceptable delays and eventually the discoordination of key sequential tasks, if not addressed in a highly efficient and proactive manner. This is evident in a lack of commitment on behalf of Parks to contract and coordinate the recommended startup of activities in early spring 2019, during the critical windy season. Further, the PMRP is seriously deficient in targeting robust metrics against which to judge the progress of any dust mitigation activities. In particular, the baseline condition needs to be re-evaluated. Among the many detailed recommendations provided in this report to the APCO, SAG strongly advises that
•monitoring campaigns (e.g., PI-SWERL, Met towers, UAS, Lidar) must be deployed immediately to establish the baseline conditions.
•creation of the foredune restoration exclosure and continued back dune vegetation campaigns must be undertaken immediately to ensure continued reductions in dust emissions and fulfill the timeline of the SOA. The supplement provided to SAG at the last moment on February 23, 2019, during finalization of the present report, suggests a fall 2019 start-up after the peak 2019 riding season. We suggest that such a delay is unacceptable under the conditions of the SOA.
•Parks must set and adhere to a clear and detailed timeline for the implementation of all dust mitigation activities, and foremost, it must establish clear lines of responsibility and communication for project management.
•Parks currently appears under-resourced with regard to personnel capable of carrying out such duties. SAG strongly recommends the hiring of a contractually limited and highly qualified Project Coordinator with strong managerial skills outside of the ODSVRA division. This individual needs to be assigned exclusively to prioritizing the mandate of the SOA within the context of services provided by Oceano State Park.
Based on these concerns the SAG does not accept the Particulate Matter Reduction Plan (02-01-2019) in its present form and recommends that the APCO return the document to Parks for revision.”
The changes requested by the SAG and SLO County APCD are supposed to be addressed by March 22. The APCD will then circulate a revised draft at least 30 days prior to a public workshop scheduled for May 1 at 6:00 p.m. at the South County Regional Center, 800 West Branch Street in Arroyo Grande.
The willingness of regulators to give State Parks a seemingly infinite number of strike outs over decades without sending it to the bench is legendary. We, along with the long-suffering residents of Oceano and the Nipomo Mesa, will be looking to see if the above changes are actually addressed by March 22 -- and if “addressed” means “implemented” or “argued with” -- and if a May 1 workshop will result in State Parks’ 3rd attempt at a dust reduction plan actually including the things that Parks has spent years determinedly avoiding: a timeline, numbers, responsibility, and any action that would draw a bright line of correlation between wind, offroad activities, and hazardous levels of particulate pollution.
Hold your breath.