Low-Effect Habitat Conservation Plan
for the Endangered Smith’s Blue Butterfly
for Repair of Five Bridges That Provide
Access to the Light Station and Lighthouse at Point Sur State Historic Park in Monterey County, CA
Prepared for:
Joan Carpenter, PE, Associate Civil Engineer State of California Department of Parks & Recreation Monterey District 2211 Garden Road Monterey, CA 93940 (831) 649-2839 [email protected]
Prepared by:
Richard A. Arnold, Ph.D. Entomological Consulting Services, Ltd. 104 Mountain View Court Pleasant Hill, CA 94523-2188
April 2015
HCP for the Bridge Repair Project at Point Sur State Historic Park Table of Contents
Table of Contents
Executive Summary ...... 1
Section 1. Introduction and Background ...... 3 Overview/Background ...... 3 Permit Holder/Permit Duration ...... 4 Permit Boundary/Covered Lands ...... 4 Species to be Covered by Permit ...... 5 Regulatory Framework ...... 5 Federal Endangered Species Act ...... 5 The Section 10(a)(1)(B) Process – HCP Requirements and Guidelines ...... 6 National Environmental Policy Act ...... 7 National Historic Preservation Act ...... 7 California Public Resources Code ...... 7 California Endangered Species Act (CESA) ...... 8 California Environmental Quality Act (CEQA) ...... 8 Big Sur Local Coastal Plan (California Coastal Act) ...... 8
Section 2. Project Description/Activities Covered by Permit ...... 12 Project Description...... 12 Activities Covered by Permit ...... 14
Section 3. Environmental Setting/Biological Resources ...... 20 Environmental Setting ...... 20 Climate ...... 20 Topography/Geology ...... 20 Hydrology/Streams, Rivers, Drainages...... 20 Existing Land Use ...... 21 Habitats ...... 21 Covered Wildlife Species: Smith’s Blue Butterfly ...... 21 Status and Distribution ...... 21 Habitat Characteristics ...... 22 Occurrences within the Project Area ...... 23 Life History ...... 23 Other Special-Status Species ...... 25
HCP for the Bridge Repair Project at Point Sur State Historic Park Table of Contents
Section 4. Potential Biological Impacts/Take Assessment ...... 26 Direct and Indirect Impacts ...... 26 Direct Impacts ...... 26 Permanent Habitat Loss ...... 26 Indirect Impacts ...... 27 Anticipated Take of Covered Wildlife Species ...... 27 Effects on Critical Habitat ...... 29 Cumulative Impacts ...... 29 Anticipated Impacts of the Taking ...... 30
Section 5. Conservation Program/Measures to Minimize and Mitigate for Impacts ...... 32 Biological Goals...... 32 Minimization and Mitigation Measures ...... 33 Measures to Minimize Impacts ...... 34 Locate Project on and Adjacent to Current Development ...... 34 Delineate Boundaries of Each Impact Area ...... 34 Dust Control ...... 34 Measures to Mitigate Unavoidable Impacts ...... 34 Protection of Dune Mitigation Site ...... 35 Habitat Management and Revegetation ...... 35 Monitoring ...... 35 Construction and Compliance Monitoring...... 36 Worker Environmental Awareness Training ...... 36 Construction Monitoring ...... 36 Effects Monitoring ...... 36 Smith’s Blue Butterfly Monitoring ...... 36 Access to Project Site...... 37 Reporting...... 37 Compliance Report ...... 37 Annual Mitigation Monitoring Report ...... 38
Section 6. Plan Implementation ...... 40 Plan Implementation ...... 40 Changed Circumstances ...... 40 Summary of Circumstances ...... 40 Listing of New Species ...... 41 Discovery of Other Currently Listed Species ...... 41 Natural Disasters ...... 42 Unforeseen Circumstances ...... 42 Amendments ...... 43 Minor Amendments ...... 43 Major Amendments ...... 43 HCP for the Bridge Repair Project at Point Sur State Historic Park Table of Contents
Suspension/Revocation ...... 43 Permit Renewal ...... 44 Permit Transfer ...... 44
Section 7. Funding ...... 46 Costs of HCP Implementation ...... 46 Funding Source(s) ...... 49 Funding Mechanism and Management ...... 51
Section 8. Alternatives ...... 53 Summary ...... 53 Alternative #1: No Action ...... 53 Alternative #2: Redesigned Project (Reduced Take) ...... 53 Alternative #3: Proposed Action ...... 54
Section 9. References Cited ...... 55
Section 10. Appendix ...... 57
HCP for the Bridge Repair Project at Point Sur State Historic Park Tables and Figures
Tables and Figures
Table Title ...... Pages
1 Areas of Ground Disturbance for the Bridge Repair Project at PSSHP ...... 13
2 Special-status Species of the PSSHP……… ...... 25
3 Permanent Impacts to SBB Habitat Resulting from Features of the Proposed Bridge Repair Project ...... 27
4 Numbers of Buckwheats by Age Class for Each Impact Area ...... 28
5 Estimated Costs to Implement the Conservation Program for the Bridge Repair Project (Initial Phase – Year 1) ...... 46
6 Estimated Costs to Implement the Conservation Program for the Bridge Repair Project (Years 2 – 10) ...... 48
Figure Title ...... Pages
1 Regional Location Map for Bridge Repair Project at PSSHP ...... 9
2 Aerial Photograph of PSSHP ...... 10
3 Topo Map of Moro Rock illustrating Locations of the 5 Bridge Repair Work Sites ...... 11
4a Site Plan for Bridge #1 ...... 15
4b Site Plan for Bridge #2 ...... 16
4c Site Plan for Bridge #3 ...... 17
4d Site Plan for Bridge #4 ...... 18
4e Site Plan for Bridge #5 ...... 19
5 Map of Buckwheat Occurrence Zones within Impact Area...... 31
6 Map of Dunes Mitigation Site...... 39
7 Locations of Areas A, B, C, and D at Mitigation Site ...... 61 HCP for the Bridge Repair Project at Point Sur State Historic Park Tables and Figures
HCP for the Bridge Repair Project at Point Sur State Historic Park Executive Summary
Executive Summary
The Monterey District of the State of California’s Department of Parks & Recreation (CDPR) has applied for a permit pursuant to section 10(a)(1)(B) of the Endangered Species Act of 1973 as amended (16 U.S.C. 153101544, 87 Stat. 884), from the U.S. Fish & Wildlife Service (Service) for the incidental take of the endangered Smith’s Blue butterfly (SBB) (Euphilotes enoptes smithi: Lepidoptera: Lycaenidae). The potential taking would occur incidental to repairs to five timber bridges that are located along two access roads (Light Station and Fog Signal Roads) for the Point Sur Lighthouse and the Light Station at Point Sur State Historic Park (PSSHP). Vehicular traffic is no longer allowed to cross two of the five bridges and the other three require repairs to restore their structural integrity to allow safe vehicular access to the Pt. Sur Lighthouse and the Light Station that are located at the top of Moro Rock.
The Bridge Repair Project at PSSHP will include the following activities: a) structural repairs to the five existing timber bridges; b) installation of erosion control and storm water improvements; c) periodic maintenance of Light Station and Fog Signal Roads (0.88 mi.) and their ditches throughout the life of the permit; d) revegetation and monitoring activities in areas impacted by the bridge repairs, and e) weed control, revegetation, and monitoring activities at the long term mitigation site for the project.
The five timber bridges are located along Light Station Road and Fog Signal Road, which wind up from the base of Moro Rock to the facilities at its peak. These roads extend 0.88 mi. and traverse steep hillsides where slopes often exceed 50 percent. Vegetation at the bridge work sites and roadsides is primarily northern coastal bluff scrub with areas of barren or sparsely vegetated rock outcrops. These habitats support Seacliff buckwheat, Eriogonum parvifolium (Polygonaceae), a food plant for the SBB. The total amount of habitat disturbance at the work sites due to temporary and permanent impacts is 10,196 ft.2 (0.2341 acre). A recent CDPR inventory of these areas identified 646 individuals of seacliff buckwheat growing there.
The SBB is known to occur at locations near the project area at PSSHP and suitable habitat for SBB occurs within the project’s proposed work areas. For this reason, CDPR has assumed that SBB is present at the project site and has applied for a section 10(a)(1)(B) permit. It proposes to implement the habitat conservation plan (HCP) described herein, which provides
1 HCP for the Bridge Repair Project at Point Sur State Historic Park Executive Summary
measures for mitigating adverse effects on the SBB for activities associated with the Bridge Repair Project at PSSHP. Although all bridge repairs should be completed in about six (6) months, the CDPR requests issuance of the section 10(a)(1)(B) permit for a period of ten (10) years to accommodate unforeseen delays, ongoing maintenance activities, and to meet the success criteria of its conservation program to mitigate for the anticipated impacts of this project.
This HCP summarizes information about the project and identifies the responsibilities of the Service and the CDPR for implementing the actions described herein to benefit the SBB. The biological goals of the HCP are to avoid and minimize take of the SBB and to replace the SBB habitat impacted by this project at a secure site in perpetuity. For mitigation, the CDPR will protect and restore 3.6 acres of dune habitat at the base of Moro Rock at PSSHP. The proposed mitigation area is a Natural Preserve subunit of PSSHP. As part of the habitat restoration, invasive plants will be removed from the dune mitigation site and 1,938 Seacliff buckwheat plants will be propagated and outplanted, along with other dune endemic plants to improve habitat quality for the SBB. This HCP also describes measures that ensure the elements of the HCP are implemented in a timely manner. Funding sources for implementation of the HCP, actions to be taken for changed circumstances, alternatives to the proposed permit action, and other measures required by the Service are also discussed.
2 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
Section 1 Introduction and Background
1.1 Overview/Background
The Point Sur Lighthouse and Light Station are located on the Big Sur Coast in Monterey County, California at the Point Sur State Historic Park (PSSHP), which is located approximately 135 miles south of San Francisco and 23 miles south of the City of Monterey via California State Highway 1 (Figure 1). This lighthouse has been in continuous operation since 1889 and is accessible by a paved service road that leads to the top of Moro Rock at Point Sur and crosses five timber bridges in need of deferred maintenance and repair.
As illustrated in Figure 2, PSSHP consists of four parcels managed by the Monterey District of the California Department of Parks & Recreation (CDPR): a) the Light Station complex on top of the prominent Moro Rock and two beaches at its base, which measure 24.6 acres; b) the former U.S. Navy Facility (NAVFAC), which measures 38.5 acres, c) the Schoolhouse site, measuring 2.0 acres; and d) the Spring site, located east of Highway 1, and measuring 6.5 acres. An access road from Highway 1 follows an easement that connects Moro Rock with the Schoolhouse site. Collectively, these four parcels measure approximately 72 acres. The U.S. Coast Guard owns the Lighthouse on Moro Rock and the U.S. Navy owns the Terminal Equipment Building (also known as the Naval Research Center) at the NAVFAC. All other portions of PSSHP are owned and managed by CDPR.
Point Sur experiences rather severe weather conditions, and the five timber bridges are located along the service road that leads to the Light Station complex on top of a prominent rock that juts out into the Pacific Ocean and is known as Moro Rock. The service road and the five bridges are situated on steep, rocky slopes where soils are highly erodible. Bridges #1 and #2 (Figure 3) are located on the lower part of Light Station Road and are essential for access to the Point Sur Light Station and the Point Sur Light House. Bridges #3, #4, and #5 (Figure 3) are located higher on Moro Rock along Fog Signal Road. These three bridges are in very poor condition and at present are closed to all vehicles, including fire trucks.
This Habitat Conservation Plan (HCP) is for the proposed replacement and repair of these bridges, installation of permanent erosion control mats, and storm drain improvements, as well as future routine maintenance activities for the access road and its associated ditches. It also covers revegetation activities that would occur at the bridge repair sites and other locations adjacent to the service road as well as at the dunes mitigation site located east and northeast of the base of Moro Rock. This HCP and its associated incidental take permit will cover project-related impacts to federally-listed endangered species that cannot be avoided.
3 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
This HCP has been prepared pursuant to the requirements of section 10(a) of the Federal Endangered Species Act (Act). It is intended to provide the basis for issuance of a section 10(a)(1)(B) permit to the permit applicant, the State of California’s Department of Parks & Recreation, to authorize incidental take of the Smith’s Blue butterfly (SBB) (Euphilotes enoptes smithi: Lepidoptera: Lycaenidae). This insect is a federally- listed, endangered species and may potentially be impacted by activities of the bridge repair project. A qualified entomologist determined that the project site supports suitable habitat for this federally-listed insect within the proposed project area. Impacts to the endangered insect from project-related activities will be primarily limited to small work areas associated with repairs to the five bridges and erosion control measures. Additional impacts will occur due to storm water improvements and periodic routine road and ditch maintenance.
1.2 Permit Holder/Permit Duration
The State of California’s Department of Parks & Recreation requests an incidental take permit to cover take of the SBB commencing on the date of permit issuance. Joan Carpenter, PE, Associate Civil Engineer, is the point of contact at the CDPR for this project. She can be contacted at CDPR via mail at 2211 Garden Road, Monterey, CA 93940, or via telephone (work) at (831) 649-2839, via fax (831) 647-6239, or via email at [email protected] .
Although project construction is expected to be completed within a six-month period, issuance of local permits, availability of funds needed for the project, as well as seasonal constraints on repair and re- construction activities may delay project initiation following issuance of the incidental take permit. Road repairs and as-needed routine maintenance activities will occur after completion of the bridge repairs. Also, the habitat restoration work will require several years to achieve its success criteria. For these reasons, a permit duration of ten (10) years is requested to ensure that all of the covered activities will be completed during the term of the incidental take permit.
1.3 Permit Boundary/Covered Lands
Bridges #1 and #2 are along Light Station Road while bridges #3, #4, and #5 occur along Fog Signal Road. The bridge repair project area is located within the Point Sur, CA 7.5’ United States Geological Survey (USGS) topographic quadrangle in an area where Township, Range, and Sections numbers associated with the Mount Diablo Meridian have not been designated (Figure 3). Both roads will be traversed by construction vehicles and used for equipment and materials storage during bridge and storm drain work. Thus, the requested permit boundaries (“covered lands”) are the same as the boundaries of the 0.88-mile long repair project area, which consists almost entirely of existing paved roadways. Future road and ditch maintenance will include off-road areas within 1 to 3 ft. immediately adjacent to the edge of pavement as illustrated in Figure 3. The requested permit boundaries for these impact areas cover a total of 10,196 ft.2 (0.2341 acre) of ground and vegetation disturbance. In addition, the requested permit boundaries (covered lands) include the southeastern portion of the dunes near the base of Moro Rock (Figure 2), where habitat restoration for project mitigation will occur on 3.6 acres within the Natural Preserve subunit of PSSHP. Thus, the covered lands for which CDPR is requesting an incidental take permit to authorize take of the SBB include a total of 3.8341 acres and include the entire 0.2341-acre impact area for the bridge repair project plus the 3.6-acre mitigation
4 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
area.
1.4 Species to be Covered by Permit
One insect species is referred to as a "covered species" in this HCP and its related incidental take permit.
Covered Species Federal Status/State Status Smith’s Blue butterfly Endangered /None (Euphilotes enoptes smithi)
1.5 Regulatory Framework
This section discusses the various federal, state, and local environmental laws and ordinances that this project may need to comply with to receive its necessary permits.
1.5.1 Federal Endangered Species Act
Section 9 of the Endangered Species Act (Act) and Federal regulation pursuant to section 4(d) of the Act prohibit the take of endangered and threatened species, respectively, without special exemption. Take is defined as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to engage in any such conduct. Harm is further defined by the U.S. Fish and Wildlife Service (Service) to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing essential behavioral patterns, including breeding, feeding, or sheltering. Harass is defined by the Service as intentional or negligent actions that create the likelihood of injury to listed species by annoying them to such an extent as to significantly disrupt normal behavioral patterns which include, but are not limited to, breeding, feeding, or sheltering. Incidental take is defined as take that is incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.
Pursuant to section 11(a) and (b) of the Act, any person who knowingly violates section 9 of the Act or any permit, certificate, or regulation related to section 9, may be subject to civil penalties of up to $25,000 for each violation or criminal penalties up to $50,000 and/or imprisonment of up to one year.
Individuals and State and local agencies proposing an action that is expected to result in the take of federally listed species are encouraged to apply for an incidental take permit under section 10(a)(1)(B) of the Act to be in compliance with the law. Such permits are issued by the Service when take is not the intention of and is incidental to otherwise legal activities. An application for an incidental take permit must be accompanied by a habitat conservation plan, commonly referred to as an HCP. The regulatory standard under section 10(a)(1)(B) of the Act is that the effects of authorized incidental take must be minimized and mitigated to the maximum extent practicable. Under section 10(a)(1)(B) of the Act, a proposed project also must not appreciably reduce the likelihood of the survival and recovery of the species in the wild, and adequate funding for a plan to minimize and mitigate impacts must be ensured.
Section 7 of the Act requires Federal agencies to ensure that their actions, including issuing permits, do not jeopardize the continued existence of listed species or destroy or adversely modify listed species’ critical habitat. “Jeopardize the continued existence of…” pursuant to 50 CFR 402.2, means to engage in an action that
5 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
reasonably would be expected, directly or indirectly, to reduce appreciably the likelihood of both the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or distribution of that species. Issuance of an incidental take permit under section 10(a)(1)(B) of the Act by the Service is a Federal action subject to section 7 of the Act. As a Federal agency issuing a discretionary permit, the Service is required to consult with itself (i.e., conduct an internal consultation). Delivery of the HCP and a section 10(a)(1)(B) permit application initiates the section 7 consultation process within the Service.
The requirements of section 7 and section 10 substantially overlap. Elements unique to section 7 include analyses of impacts on designated critical habitat, analyses of impacts on listed plant species, if any, and analyses of indirect and cumulative impacts on listed species. Cumulative effects are effects of future State, tribal, local or private actions that are reasonably certain to occur in the action area, pursuant to section 7(a)(2) of the Act. The action area is defined by the influence of direct and indirect impacts of covered activities. The action area may or may not be solely contained within the HCP boundary. These additional analyses are included in this HCP to meet the requirements of section 7 and to assist the Service with its internal consultation.
1.5.1.1 The Section 10(a)(1)(B) Process - Habitat Conservation Plan Requirements and Guidelines
The Section 10(a)(1)B) process for obtaining an incidental take permit has three primary phases: (1) the HCP development phase; (2) the formal permit processing phase; and (3) the post-issuance phase. During the HCP development phase, the project applicant prepares a plan that integrates the proposed project or activity with the protection of listed species. An HCP submitted in support of an incidental take permit application must include the following information:
• impacts likely to result from the proposed taking of the species for which permit coverage is requested; • measures that will be implemented to monitor, minimize, and mitigate impacts; funding that will be made available to undertake such measures; and procedures to deal with unforeseen circumstances; • alternative actions considered that would not result in take; and • additional measures the Service may require as necessary or appropriate for purposes of the plan.
The HCP development phase concludes and the permit processing phase begins when a complete application package is submitted to the appropriate permit-issuing office. A complete application package consists of 1) an HCP, 2) an Implementing Agreement (IA) if applicable, 3) a permit application, and 4) a $100 fee from the applicant. The Service must also publish a Notice of Availability of the HCP package in the Federal Register to allow for public comment. The Service also prepares an Intra-Service Section 7 Biological Opinion; and prepares a Set of Findings, which evaluates the Section 10(a)(1)(B) permit application as in the context of permit issuance criteria (see below). An Environmental Action Statement, Environmental Assessment, or Environmental Impact Statement serves as the Service’s record of compliance with the National Environmental Policy Act (NEPA), which has gone out for a 30-day, 60-day, or 90-day public comment period. An implementing agreement is required for HCPs unless the HCP qualifies as a low-effect HCP. A Section 10(a)(1)(B) incidental take permit is granted upon a determination by the Service that all requirements for permit issuance have been met. Statutory criteria for issuance of the permit specify that:
6 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
• the taking will be incidental; • the impacts of incidental take will be minimized and mitigated to the maximum extent practicable; • adequate funding for the HCP and procedures to handle unforeseen circumstances will be provided; • the taking will not appreciably reduce the likelihood of survival and recovery of the species in the wild; • the applicant will provide additional measures that the Service requires as being necessary or appropriate; and • the Service has received assurances, as may be required, that the HCP will be implemented.
During the post-issuance phase, the Permittee and other responsible entities implement the HCP, and the Service monitors the Permittee’s compliance with the HCP as well as the long-term progress and success of the HCP. The public is notified of permit issuance by means of the Federal Register.
1.5.2 National Environmental Policy Act
The purpose of the National Environmental Policy Act (NEPA) is two-fold: a) to ensure that Federal agencies examine environmental impacts of their actions (in this case deciding whether to issue an incidental take permit); and b) to utilize public participation. NEPA serves as an analytical tool on direct, indirect, and cumulative impacts of the proposed project alternatives to help the Service decide whether to issue an incidental take permit (ITP or section 10(a)(1)(B) permit). NEPA analysis must be done by the Service for each HCP as part of the incidental take permit application process.
1.5.3 National Historic Preservation Act
All Federal agencies are required to examine the cultural impacts of their actions (e.g. issuance of a permit). This may require consultation with the State Historic Preservation Office (SHPO) and appropriate American Indian tribes. All incidental take permit applicants are requested to submit a Request for Cultural Resources Compliance form to the Service. To complete compliance, the applicants may be required to contract for cultural resource surveys and possibly mitigation.
1.5.4 California Public Resources Code
The five bridge repair sites are located within the PSSHP, while the proposed mitigation area is within a designated State Natural Preserve that is a subunit of the PSSHP. As described by the California Public Resources Code Section 5019.50, the mission of the CDPR is to provide for the health, inspiration and education of the people of California by helping to preserve the state’s extraordinary biological diversity, protecting its most valued natural and cultural resources, and creating opportunities for high-quality outdoor recreation. Per Section 5019.65, State Natural Preserves consist of areas selected and managed for the purpose of preserving their native ecological associations, unique faunal or floral characteristics, geological features, and scenic qualities in a condition of undisturbed integrity. Resource manipulation shall be restricted to the minimum required to negate the deleterious influence of man. PSSHP exemplifies a State Park where the three priorities, cultural, natural, and recreation of the CDPR’s mission, are balanced.
7 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
1.5.5 California Endangered Species Act (CESA)
The California Endangered Species Act (CESA) provides for the designation of native species or subspecies of fish, wildlife, and plants as endangered or threatened (CESA Sections 2062-2067). However, insects are specifically excluded as a type of animal that may be designated as endangered or threatened species. Thus the SBB is not listed under CESA. Since the covered species treated in this HCP is not listed as endangered or threatened species by the CESA, this HCP will not further address CESA permitting requirements.
1.5.6 California Environmental Quality Act (CEQA)
In many ways the California Environmental Quality Act, commonly known as CEQA (Public Resources Code Section 21000 et seq.), is analogous at the State level as NEPA is to the Federal level. CEQA requires state and local governmental agencies to complete an environmental review of discretionary projects that might impact environmental resources. CEQA differs from NEPA in that it requires that a project’s significant environmental impacts be reduced to a less than significant level through the adoption of feasible avoidance, minimization, and/or mitigation measures unless overriding considerations are identified and documented. With regard to wildlife and plants, those that are already listed by any State or Federal governmental agency are presumed to be endangered for the purposes of CEQA (Section 15380) and impacts to such species and their habitats may be considered significant.
The project presented in this HCP is subject to CEQA review. A Mitigated Negative Declaration was prepared for the project (CDPR, 2014).
1.5.7 Big Sur Local Coastal Plan (California Coastal Act)
The Big Sur Coast Land Use Plan and Local Coastal Plan (LCP) was adopted by the Monterey County in 1985. This LCP area ranges over 70 miles along the coast, from Carmel to near San Simeon. It emphasizes environmental protection, public recreation, and coastal access. CDPR will need to coordinate with Monterey County about the need for a coastal development permit or whether the bridge repair project qualifies for an exemption.
8 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
FIGURE 1. Regional Location Map of PSSHP.
9 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
FIGURE 2. Aerial photo of PSSHP.
10 HCP for the Bridge Repair Project at Point Sur State Historic Park Introduction and Background
FIGURE 3. Topo map of Moro Rock at PSSHP illustrating locations of the 5 bridges.
11 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Section 2 Project Description/Activities Covered by Permit
2.1 Project Description
This project covers five activities:
a) structural repairs to the five bridges; b) installation of erosion control and storm water improvements; c) periodic maintenance of Light Station and Fog Signal Roads and their ditches; d) revegetation and monitoring activities in areas impacted by the bridge repairs, and e) weed control, revegetation, and monitoring activities at the long term mitigation site for the project.
The bridge repairs are intended to restore structural integrity to all five bridges so they are in proper working condition and at full load capacity to provide access for all visitor, service, fire and emergency needs. Figure 3 illustrates the locations of the five timber bridges in need of repair. Existing timber bridge members are aged and rotten and will be replaced with new timbers. Concrete footings have been undermined and weakened by erosion. Existing footings need to be replaced with deeper footings that can resist surface erosion and bear on firm rock. Rock anchors will be added to the new bridge footings. The timber structures will be seismically upgraded with metal connections. The existing bridge decks will be restored to an all wood surface and the more recently installed asphalt surfaces will be removed. Vehicle rails on the sides of the bridge decks will be replaced with new timber rails that meet current safety requirements.
Uncontrolled storm water runs off the existing road in several locations and causes erosion where it concentrates on the steep native slopes. Large hillside gullies have formed as a result of the concentrated runoff in some locations and Bridges #3, #4, and #5 have been damaged by erosion from storm water runoff. Existing road side ditches and culvert outfalls near or under Bridges #1 and #1 will be repaired to provide non-eroding storm water conveyance of the runoff. Permanent erosion control mats will be installed under Bridges #4 and #5 and a vertical wall will be constructed at Bridge #3 to control on-going erosion next to the bridge foundations.
12 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
A minimal amount of ground disturbance will occur around the existing bridges in order to remove the existing concrete and timber. The Contractor will stage all equipment, materials, and waste on the paved roads or within the foot print of the bridges while working. Areas outside of previously disturbed areas for bridge and road construction will not be disturbed for this project.
This project has been designed to carefully remove the bridges and build new footings in the same location as the existing footings. Additionally, all timber structural members will be inspected. If the timber members are in good condition they will be reinstalled. Timbers that have rotted or exhibit other problems will be replaced with new timbers. The plans include construction control devices to assure that nearby resources will not be impacted during the removal and replacement of these structures. All construction waste will be retained in the construction area and removed off-site. Areas disturbed for construction will be restored to native vegetation.
Upon completion of the bridge repairs, periodic debris removal from the ditches and roadway will occur on an as-needed basis. Due to the steep topography, the ditches and roads often have dirt, rocks, or vegetation that needs to be removed, especially after storm events. Also, future repairs to the asphalt roadways may occur as needed throughout the remaining term of the incidental take permit.
During the bridge repair work, the existing parking area just beyond the base of Moro Rock will be a staging area and will provide parking for workers’ vehicles (Figure 3). Also, a construction trailer will be situated within the former US Naval property (NAVFAC), as illustrated in Figure 3.
Table 1 itemizes the expected area of disturbance for each of the aforementioned features of the reconstruction project.
Table 1. Areas of ground disturbance and other impacts for the Bridge Repair Project at PSSHP. Proposed Area of Ground Disturbance Feature Square feet Acres Bridge #1 401 0.0092 Bridge #2 370 0.0085 Bridge #3 955 0.0219 Bridge #4 581 0.0133 Bridge #5 586 0.0135 Storm Drain #1 100 0.0023 Debris Removal from Ditches & Road Repairs 7,203 0.1654 Totals 10,196 0.2341
13 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
2.2 Activities Covered by Permit
Although all of the proposed impact areas have previously been disturbed by construction and subsequent facility maintenance, the buckwheat food plant for the endangered SBB grows in several locations. To complete the needed repairs to the bridges and maintain the facilities at PSSHP, food plants growing within the impact areas must be removed. Thus, an incidental take permit is requested to cover impacts to the SBB that could result from vegetation clearing, grading, excavation and other construction activities necessary to repair the five bridges and future maintenance activities for the repaired bridges, install the new erosion control and storm water improvements, as well as future debris removal from and immediately adjacent to the roadways and ditches and storm water improvements. Also, any revegetation of the impact areas, plus weed eradication, revegetation, and monitoring activities at the long term mitigation site on the dunes will be covered by the permit. The estimated construction period for bridge repairs, plus the erosion control and storm drain improvements is about six months. Upon completion of all construction activities at the five bridges and storm drain locations, native plants may be installed around these features to restore the impacted habitat. Periodic debris removal from the roadways and ditches will continue throughout the remainder of the requested permit period. Future inspection and maintenance activities for the repaired bridges will also occur throughout the remainder of the permit period. Mitigation and monitoring activities will continue annually through the full 10-year permit term.
14 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Figure 4A – Bridge 1
15 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Figure 4B – Bridge 2
16 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Figure 4C – Bridge 3
17 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Figure 4D – Bridge 4
18 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Figure 4E – Bridge 5
19 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Section 3 Environmental Setting/Biological Resources
3.1 Environmental Setting
3.1.1 Climate
Point Sur State Historic Park, where the bridge repair project will occur, is characterized by a Mediterranean climate with a dry summer and fall and a wet winter and spring. August is usually the warmest month, with temperatures ranging from 50°F to 77°F. In contrast, January is the coolest month, with temperatures ranging from 43°F to 60°F.
Annual precipitation is about 41 inches. Most precipitation falls as rain, but there is also fog drip. The rainy season runs from October to May, with the majority of the rainfall occurring between December and March.
3.1.2 Topography/Geology
At PSSHP a prominent, dome-shaped rock, known as Moro Rock, juts out from the shoreline into the Pacific Ocean. It is located near the northern end of the Santa Lucia Range and is within the Coast Ranges Geomorphic Province. Moro Rock ranges in elevation from sea level to 361 feet. Its geology is characterized by Franciscan formation (CDPR 2004). Access roads are located on the southern hillsides and top of Moro Rock, where the slopes are often greater than 50%, with exposed rock and generally shallow soils. Cook (1978) identifies the soil on Moro Rock as rock outcrop. In contrast, the proposed mitigation site at the dunes near the base of Moro Rock, are characterized by sandy soils and fairly flat or gently rolling sand dunes and beaches.
3.1.3 Hydrology/Streams, Rivers, Drainages
PSSHP is situated on a coastal terrace between the Little Sur River, which is approximately 2 mi. to the north, and the Big Sur River, which is approximately 3 mi. to the south. Bixby Creek lies about 2.25 mi. east of the base of Moro Rock.
20 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
3.1.4 Existing Land Use
The project site is located within PSSHP, while the proposed mitigation site is within a designated State Natural Preserve that is a subunit of the PSSHP. Natural areas in the park and State Natural Preserve are maintained by the California State Parks Natural Resources Program and volunteers from the Central Coast Light Keepers. The volunteers work under the direction of the State Environmental Scientist for the park. Routine maintenance activities include removal of non-native plants, planting of native plants, removal of man-made debris that washes ashore. The State Natural Preserve and adjoining beach are permanently closed to public use.
The Point Sur NAVFAC is one of the Sound Surveillance System (SOSUS) facilities still operated by the US Navy and today is the only remaining one on the West Coast. Most of the former NAVFAC property has been acquired by CDPR. The Lighthouse at Point Sur continues to operate. Guided tours of the facilities occur on weekends throughout the year and seasonally also on Wednesdays.
3.1.5 Habitats Habitats at PSSHP include northern foredunes, northern coastal bluff scrub, central coastal (Lucian) scrub, non-native grassland, coastal terrace prairie, freshwater seep, and maritime lichen fields. Much of Moro Rock is characterized by bare rock, but native plant communities include coastal (Lucian) scrub, northern coastal bluff scrub, and maritime lichen fields. Vegetation cover is often sparse on the steep slopes. Ruderal vegetation is evident at the top of Moro Rock, in association with the facilities. At the eastern and northern bases of Moro Rock are sand dunes, characterized by a northern foredune plant community. Invasive plants have colonized Moro Rock and the sand dunes where mitigation would occur. Kikuyu grass (Pennisetum clandestinum), European beach grass (Ammophila arenaria), Sea Fig (Carpobrotus chilensis), Hotentot Fig (ice plant) (Carpobrotus edulis), Sweet Alyssum (Lobularia maritima), Common Stock (Matthiola incana), and sorrel (Oxalis pes-caprae) are some examples of the invasives growing at these locations.
3.2 Covered Wildlife Species: Smith’s Blue Butterfly (Euphilotes enoptes smithi: Lepidoptera, Lycaenidae)
3.2.1 Status and Distribution The SBB was recognized as an endangered species in 1976 by the U.S. Fish & Wildlife Service (1976) due to loss and alteration of its habitat. Habitat changes via urbanization, overgrazing, invasive plants, succession, and absence of fire are primary threats to the butterfly. Critical habitat was proposed at the time of its recognition as endangered, but to-date has not been finalized by the Service. A recovery plan was published by the Service (1984) in 1984. A review of the butterfly’s status (Service 2007) concluded that it could be downgraded to threatened status, but this action has not yet occurred. The State of California’s Fish and Game
21 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
Code does not allow insects to be listed as endangered under its regulations. However, the SBB does receive consideration under the California Environmental Quality Act (CEQA) since it satisfies the definition of a rare species under this statute.
SBB was originally described in the genus Philotes by Mattoni (1954), and referred to as Philotes enoptes smithi. Shields (1975) realigned several genera of blues, resulting in the placement of the species enoptes in the genus Shijimiaeoides. Thus, the scientific name of the SBB, when it was first recognized as an endangered species (Service 1976), was Shijimiaeoides enoptes smithi. Mattoni (1977) subsequently made a number of nomenclatural rearrangements in several genera of the blue butterfly tribe Scolititandini, which resulted in the placement of enoptes in the genus Euphilotes. Today, the SBB is known scientifically by the name, Euphilotes enoptes smithi; however, all of these names may be encountered in the literature.
Mattoni (1954) described Euphilotes enoptes smithi from specimens that he and Claude Smith collected at Burns Creek, near California State Highway 1, in Monterey County in 1948. Two colonies, in the vicinity of Big Sur, were known at the time of its description.
Today, the butterfly is known from the mouth of the Salinas River in Monterey County, to about San Carpoforo Creek in San Luis Obispo County. Between the Naval Postgraduate School in Monterey and the mouth of the Salinas River, the SBB is found on the foredunes of coastal sand dunes in association with Coast Buckwheat (Eriogonum latifolium), although recent studies by Pratt and Emmel (1998) suggest that these populations should be referred to as E. enoptes arenicola, a new subspecies.
From the vicinity of Stillwell Hall at Fort Ord to the Naval Postgraduate School, there are several sand dune-inhabiting populations that occur in association with seacliff (also commonly known as dune) buckwheat (Eriogonum parvifolium). South of Monterey and into northern San Luis Obispo County, the SBB is found at numerous locations in the Santa Lucia Mountains and along the immediate coastline, where there is coastal sage scrub, cliff chaparral, or grassland habitats and E. parvifolium. It is also found on coastal bluffs and slopes at the immediate coast, such as Point Sur. Similarly, inland populations of the butterfly, such as those occurring in the Carmel River Valley, are primarily associated with coastal sage scrub and cliff chaparral habitats, as well as the ecotone between neighboring grasslands and these aforementioned habitats and feed on E. parvifolium or E. latifolium. At some interior locations, adults of the SBB have also been observed nectaring on naked buckwheat (E. nudum), but it is not known if larvae feed on this buckwheat (Arnold 1991a and 1991b).
3.2.2 Habitat Characteristics Habitats where SBB have been found include sand dunes (both foredunes and rear dunes), coastal sage scrub, cliff chaparral, coastal bluffs, and at the ecotone of scrub and grassland habitats. Although it is a long-lived, perennial subshrub, Eriogonum parvifolium is a poor competitor in the scrub and chaparral habitats and may get crowded out or overgrown by other shrubs. Thus, it is often observed growing in areas characterized by sparse vegetation
22 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
cover or thin soils, such as rock outcrops, along the margins of trails, or even disturbed areas.
3.2.3 Occurrences Within the Project Area Surveys for both the larval and adult life stages of the SBB were performed at Point Sur State Historic Park on 6 dates in July and August of 2002 by entomologist, Dr. Richard A. Arnold (2002). Despite an intensive search effort, no life stages of the SBB were observed at Point Sur. Windy and foggy weather conditions somewhat hindered surveys at Point Sur. However, during the summer of 2002 SBB life stages were observed under similar conditions at nearby Pfeiffer Beach (6.5 mi. south of Point Sur) and Cooper Point (5.5 mi. south of Point Sur). More recently, Arnold (personal observation) found SBB adults on the dunes south of the Little Sur River at Highway 1 (1.8 mi. north of Point Sur) and just north of the Bixby Bridge at Hwy. 1 (4.6 mi. north of Point Sur). Arnold has also observed SBB life stages at various locations along the old Coast Highway that winds through the hills east of Point Sur (BUGGY Data Base 2014 and California Natural Diversity Data Base 2014. For these reasons, CDPR assumes that the butterfly occurs at Point Sur.
3.2.4 Life History The SBB is a small butterfly, whose adult wingspan measures about one inch. It is a member of the lycaenid subfamily, the blues, because the dorsal wings of adult male are primarily blue in color. In contrast, the dorsal wings of females are colored grey. The undersides of the wings of both sexes have a pale gray background, with various black markings (i.e., maculations), and a band of orange at the outer margin of the hindwings. Larvae are slug- shaped and vary in color from cream to pale yellow or rose, to match the buckwheat flowerheads on which they feed. Color illustrations of the adult and larval stages are presented in Arnold (1983a) and at his web site, www.ecsltd.com . Other illustrations of the adult butterfly can be found in Arnold (1983b), Howe (1975), Service (1984), Scott (1986), Steinhardt (1990), Lowe (1990), and Thelander and Crabtree (1994).
SBB is univoltine, i.e., it has only one generation per year. Adult emergence and seasonal activity is synchronized with the blooming period of the particular buckwheat used at a given site. At a particular location, adults are active for about four to ten weeks, but the adult activity period and duration can vary dramatically from year-to-year and from one location to another.
Individual adult males and females live approximately one week, and both sexes spend the majority of their time on Eriognonum flowerheads (Arnold 1983a, 1983b, and 1986). There they perch, bask (i.e., thermoregulate), forage for nectar, search for mates, copulate, and lay their eggs. Females lay single eggs on the buckwheat flowers. Larvae hatch in about one week and begin feeding in the buckwheat flowerheads. Young larvae feed on the pollen and developing flower parts, while older larvae feed on the seeds. Older larvae are tended by ants, which may provide some protection from parasites and predators. Upon maturing in about one month, the larvae pupate in the flowerheads or in the leaf litter and sand at the base of the buckwheat plant. Pupae that form in the flowerheads later drop to the ground.
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Dispersal data from capture-recapture studies (Arnold 1983b and 1986) indicate that most adults are quite sedentary, with home ranges of no more than a few acres. However, a small percentage of adults disperse farther and exhibited home ranges between 20-30 acres (Arnold 1986).
All populations of the three buckwheat food plants, within the range of the SBB, are not always used by the butterfly at a particular point in time. Lycaenids that feed on Eriogonum flowers favor mature, robust individuals of the perennial buckwheats because they produce more flowers (Arnold 1983a and 1983b; Arnold and Goins 1987; Arnold 1990). Thus, buckwheat stands that consist of younger or older, senescent individuals, which produce fewer flowers, may not be visited by the butterfly until these plants mature or are augmented by robust, flowering specimens.
Among butterflies, it is somewhat unusual for both the adult and larval stages to feed only on one plant, and, in particular, only on just the flowers. Most butterflies feed as caterpillars on one or a few closely-related plants, and then as adults obtain nectar from flowers that are generally unrelated to what the caterpillars fed on. Because of the SBB's dual dependency on the flowers of its buckwheat food plants, it is more susceptible to habitat degradation. Although it is more extinction prone because of its total dependence upon the flowers of buckwheats, conservation efforts are greatly simplified because resource managers only need worry about a single plant rather than several plants to maintain this endangered butterfly. The California Department of Parks and Recreation (CDPR) has successfully revegetated sand dunes at Marina State Beach, the former small arms firing ranges at Fort Ord State Beach, and at Monterey State Beach to re-establish habitat for the SBB.
In contrast to the adults of SBB, which move from flower-to-flower on a single buckwheat plant, and among buckwheat plants, larvae are more stationary and can complete their development on a single plant if there are adequate numbers of flowers for feeding. At buckwheat locations that are more exposed or where adults were not observed, observations of larvae can provide evidence of occupation by the SBB.
However, the larvae are smaller and more cryptic than the adult life stage of the SBB. Full-grown larvae are slug-shaped, approximately 0.5 inch long, and range in color from cream to pale yellow or rose. These different colors match those of the buckwheat flowerheads at various stages of its flowering. Because of their smaller size and color, young larvae can be difficult to detect. Mature larvae are large enough to observe without damaging the buckwheat flowerheads. They lay nestled in the flowerhead or also on top of the flowers. Ants often tend the larvae or are near the larvae, so following the ants on a buckwheat plant may lead you to a larva.
24 HCP for the Bridge Repair Project at Point Sur State Historic Park Environmental Setting/Biological Resources
3.5 Other Special-Status Species
Several other special-status species occur along the Big Sur coast and a few are known from PSSHP. Table 2 lists these taxa and their federal and state conservation statuses.
American Peregrine Falcons (Falco peregrinnus anatum) have been observed nesting on the northwestern portion of Moro Rock, but recent surveys by the Ventana Wilderness Society did not find any evidence of nesting activity within the bridge repair project area (Jeff Frey, Environmental Scientist, CDPR, personal communication). It was formerly recognized as an endangered species at both the federal and state levels but was delisted because recovery efforts were successful.
Sensitive plant taxa include: the federally-threatened Monterey spineflower (Chorizanthe pungens var. pungens), and two plants recognized by the California Native Plant Society (CNPS) Little Sur Manzanita (Arctostaphylos edmundsii) and Monterey Indian Paintbrush (Castilleja latifolia). At Point Sur State Historic Park, the spineflower is limited to a small, sandy area on the former NAVFAC parcel and is outside of the project’s impact area, while the manzanita and paintbrush both occur on Moro Rock in association with central coastal scrub. The paintbrush can also be found in the northern coastal bluff scrub and northern foredune communities. Surveys conducted by CDPR Environmental Scientist, Jeff Frey, indicate that none of these plants grow within the bridge repair project area.
Table 2. Special-Status Species of the PSSHP. Common Scientific Conservation Status Name Name Federal State CNPS American Peregrine Falco peregrinnus Delisted Delisted Falcon anatum Monterey Chorizanthe pungens var. Threatened Spineflower pungens Little Sur Arctostaphylos edmundsii 1B Manzanita Monterey Indian Castilleja latifolia 4 Paintbrush
Note: CNPS is the California Native Plant Society, whose lists of rare plants are often treated as endangered species by resource agencies.
25 HCP for the Bridge Repair Project at Point Sur State Historic Park Biological Impacts/Take Assessment
Section 4 Potential Biological Impacts/Take Assessment
4.1 Direct and Indirect Impacts
4.1.1 Direct Impacts
The proposed project has the potential to directly impact life stages of the SBB by causing mortality of immature and adult life stages within the impact areas where the bridge repairs, erosion control, and storm water improvements will occur. Construction and worker vehicles travelling on the roads to the bridge repair sites could injure or kill life stages of the SBB. Upon completion of these activities, weed control, revegetation and monitoring activities could also impact life stages of the butterfly. Future road maintenance activities as well as debris removal from the roads and ditches could also impact the butterfly. Both direct and indirect impacts may occur.
4.1.1.1 Permanent Habitat Loss
At the five bridge repair locations permanent habitat loss will result from the vegetation clearing and excavation for the repair of support footings and installation of replacement footings. Similarly, repairs to existing roadside ditches and culvert outfalls near or under the bridges will result in permanent habitat loss at some locations. Installation of the erosion control mats under Bridges #4 and #5, plus construction of the vertical wall at Bridge #3 will result in permanent habitat loss, as will the installation of storm drain #1. These ground-disturbing activities will remove the existing vegetation, including buckwheat plants that may be fed upon by the SBB, as well as kill, injure, or remove life stages of the SBB that are associated with these plants. The total area of permanent habitat loss due to bridge repairs is 2,993 ft.2 (0.0687 acre), as detailed in Table 3.
Due to the steep slopes adjacent to the access roads, rock and dirt slides occur. This debris must be removed from the roadways and roadside ditches. Similarly, road maintenance, is done on an as-needed basis. Since the SBB likely occurs in association with the buckwheat plants that grow immediately adjacent to the paved roads and ditches, these activities could result in permanent habitat loss and impact the butterfly’s life stages. Although these impact areas may
26 HCP for the Bridge Repair Project at Point Sur State Historic Park Biological Impacts/Take Assessment be revegetated, the buckwheat food plant of the SBB will not be included in the planting palette because of the high likelihood that debris from the same areas of the roadways and ditches will need to be removed again at a later time. For this reason, the impact area of 7,203 ft.2 (0.1654 acre) associated with these activities is treated as a permanent habitat loss, as detailed in Table 3.
4.1.2 Indirect Impacts
Indirect impacts are those caused by covered activities that may occur at a different time or in a different place than the direct impacts. Although the bridge repairs are expected to take approximately six months to complete, because the bridges are limited to very small portions of the roadways, indirect impacts on the SBB are expected to be minimal. For example, dust can clog the spiracles used by the butterfly to breathe and accumulation of dust on flowerheads of the buckwheat can render them inedible. Thus, appropriate dust control measures will be implemented to minimize the dispersal of airborne dust due to project activities.
Table 3. Permanent impacts to SBB habitat resulting from features of the proposed bridge repair project at PSSHP. Project Feature Type of Impact Area of Impact Square feet Acres Bridge #1 Permanent 401 0.0092 Bridge #2 Permanent 370 0.0085 Bridge #3 Permanent 955 0.0219 Bridge #4 Permanent 581 0.0133 Bridge #5 Permanent 586 0.0135 Storm Drain #1 Permanent 100 0.0023 Roadside Areas (i.e., within 1 or 3 Permanent 7,203 0.1654 feet of edge of pavement) Project Totals 10,196 0.2341
4.2 Anticipated Take of Covered Wildlife Species
There are no accurate estimates of the numbers of SBB that reside at the five bridge repair work sites or in the areas immediately adjacent (i.e., 1 to 3 ft.) to the access roads on Moro Rock. Thus, it is not possible to quantify the exact number of individual animals that could be taken by the permanent or temporary removal of its habitat within these impact areas. For these reasons, the level of take of the SBB is expressed as the total affected acreage, i.e., 0.2341 acre, of these impact areas. Take due to injury or mortality of SBB life stages could result from disturbance to approximately 0.2341-acre of degraded habitat within the impact area.
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This impact area acreage supports 646 buckwheat plants. CDPR ecologist, Jeff Frey, inventoried the numbers of buckwheat plants by age class (Table 4) observed within each of the permanent or temporary impact areas illustrated in Figure 5.
Table 4. Numbers of buckwheat plants by age class for each impact area of the proposed bridge repair project at PSSHP. Impact Map Buckwheat Age Class Area Id Seedling Juvenile Mature Senescent Dead Unknown Totals Bridge #1 4 2 7 1 0 0 0 10 Bridge #2 7 1 0 0 0 0 0 1 8 1 2 2 0 0 0 5 Bridge #3 24 3 10 3 0 0 0 16 25 7 20 11 0 0 0 38 Bridge #4 28 3 1 11 0 0 0 15 29 4 9 6 1 0 2 22 Bridge #5 30 1 3 3 1 0 3 11 31 1 5 8 0 0 0 14 Subtotals 22 67 45 2 0 5 141
Roadside 1 9 4 2 0 0 0 15 2 12 17 10 0 0 0 39 3 1 0 0 0 0 0 1 5 3 0 0 0 0 0 3 6 1 0 0 0 0 0 1 9 10 5 3 0 0 0 18 10 19 15 2 0 0 0 36 11 9 2 6 0 0 0 17 12 3 0 0 0 0 0 3 13 5 1 1 0 0 0 7 14 9 4 2 0 0 0 15 15 3 3 1 1 0 0 8 16 5 14 15 3 0 0 37 17 5 5 7 0 0 0 17 18 26 10 13 0 0 0 49 19 9 3 3 0 0 0 15 20 15 6 0 0 0 0 21 21 10 12 4 2 0 0 28 22 3 10 4 0 0 0 17 26 8 7 15 5 1 0 36 27 16 14 20 0 0 0 50 32 19 13 11 0 0 0 43
28 HCP for the Bridge Repair Project at Point Sur State Historic Park Biological Impacts/Take Assessment
33 3 12 13 0 1 0 29 Subtotals 203 157 132 11 2 0 505 Grand Totals 225 224 177 13 2 5 646
As many as 646 buckwheat plants could be impacted by this project, including 141 buckwheat plants during repair work on the five bridges and an additional 505 buckwheat plants during road maintenance or debris removal in roadside areas located within 1 to 3 ft. of the edge of pavement. Of the 646 plants only 27.3% (177) are mature plants, while 69.5% (449) are seedlings or juveniles (Table 4).
4.3 Effects on Critical Habitat
Critical habitat has not been designated for the SBB. For this reason, no critical habitat will be affected by the proposed project.
4.4 Cumulative Impacts
During the past two decades, the Service has published notices for incidental take permits in the Federal Register for four other small projects affecting the SBB. These include two new residential projects in Carmel and two commercial projects, one in Big Sur and the one in Sand City. These issued permits covered impacts to approximately 142 acres of habitat. In addition, a Safe Harbor Agreement is in preparation for trail repairs and removal of invasive plants at Garrapata State Park.
In contrast, impacts of the proposed bridge repair project at PSSHP on the long term persistence of the SBB are low because of the small sizes of the impact areas. Also, even though the buckwheat food plant of the butterfly grows there, the majority of the plants represent age classes that produce fewer flowerheads than mature buckwheats or those that grow in more sheltered locations. Thus, the permanent and temporary losses of habitat and food plants will be quite small and are not expected to affect the range-wide survival of the butterfly due to its occurrence and abundance at several nearby locations, as well as elsewhere throughout its entire geographic range.
Future development along the Big Sur coast would reduce the amount of available habitat for the SBB. Nonetheless, significant portions of the SBB’s habitat along the Big Sur coast has been protected and support significant populations of the endangered butterfly, including portions of various State Parks and State Beaches as well as portions of the Los Padres National Forest.
29 HCP for the Bridge Repair Project at Point Sur State Historic Park Biological Impacts/Take Assessment
4.5 Anticipated Impacts of the Taking
The level of take of the SBB at the bridge repair sites at PSSHP, is expected to have negligible effects on these species overall survival and should not hinder its recovery. This is because the actual number of animals incidentally taken will be very low and the percentage of habitat affected is very small relative to the SBB’s known geographic range. Due to the exposed and windy conditions at Point Sur, many of the buckwheat plants there are prostrate or nearly so and produce fewer flowerheads than buckwheat plants that grow in more sheltered locations. Although these buckwheat plants may still support the SBB, they cannot support as many individuals of the butterfly as locations characterized by buckwheat plants with plentiful flowerheads. Thus, the relative importance of work sites on Moro Rock to the species, both regionally and throughout its range, is thought to be minor. For these reasons, the amount of take of the SBB that would result from the project is considered negligible.
Even though the habitat within the project site probably supports lower numbers of the butterfly, from a conservation perspective it still has value to the endangered SBB because it provides connectivity between other nearby locations that also support the butterfly. Connectivity is essential to maintain genetic diversity and to facilitate re-colonization of habitat where populations may be locally extirpated following fire, disease or other stochastic events.
30 HCP for the Bridge Repair Project at Point Sur State Historic Park Biological Impacts/Take Assessment
Figure 5
31 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
Section 5 Conservation Program/Measures to Minimize and Mitigate for Impacts
5.1 Biological Goals
Section 10(a)(2)(A) of the Act requires that an HCP specify the measures that the permittee will take to minimize and mitigate to the maximum extent practicable the impacts of the taking of any federally listed animal species as a result of activities addressed by the plan. As part of the “Five Point” Policy adopted by the Services in 2000, HCPs must also establish biological goals and objectives (65 Federal Register 35242, June 1, 2000). The purpose of the biological goals is to ensure that the operating conservation program in the HCP is consistent with the conservation and recovery goals established for the species. The goals are also intended to provide to the applicant an understanding of why these actions are necessary. These goals are developed based upon the species’ biology, threats to the species, the potential effects of the covered activities, and the scope of the HCP.
The following biological goals and objectives were developed based on the SBB’s biology and potential impacts of the covered activities within the scope of this HCP. They include on-site measures that will minimize take of the SBB at the project site and off-site measures that will restore degraded habitat and provide long term protection of the restored habitat to benefit the butterfly.
Goal 1: Avoid and minimize, to the extent practical, take of the SBB within the project site.
Objective 1.1: Locate project work areas within existing developed roadways or immediately adjacent to them.
Objective 1.2: Minimize removal of plant taxa indigenous to the Big Sur coastal area that grow at the project site, including food plants of the SBB.
32 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
Objective 1.3: Revegetate the disturbed portions of work areas at the project site with plant taxa of the northern coastal bluff scrub plant community that are indigenous to the Big Sur coast.
Goal 2: Protect and restore habitat for the SBB in the Natural Preserve at PSSHP with high conservation value for the butterfly.
Objective 2.1: Protect 3.6 acres of northern foredune habitat at the PSSHP Natural Preserve with fencing to exclude cattle.
Objective 2.2: Remove ice plant, European beach grass, and other invasive plants from the dunes mitigation site.
Objective 2.3: Propagate and outplant a minimum of 1,938 Seacliff buckwheat plants at the dunes mitigation site along with other endemic dune plants to restore the habitat to benefit the SBB.
Objective 2.4: Manage and monitor the habitat restoration annually throughout the life of the permit.
5.2 Minimization and Mitigation Measures
Section 10 of the Endangered Species Act requires that all applicants submit HCPs that “minimize and mitigate” the impacts of take authorized by an incidental take permit, and that issuance of the permit will not “appreciably reduce the likelihood of the survival and recovery of the species in the wild.” In general, HCPs should include mitigation programs that are based on sound biological rationale, practicable, and commensurate with the impacts of the project on species for which take is requested. Additionally, the Service encourages applicants to develop HCPs that contribute to the recovery of a listed species. If the proposed project is expected to result in permanent habitat loss, then the mitigation strategy must include compensatory mitigation consisting of the permanent preservation of suitable habitat or similar measures.
In accordance with these guidelines and the requirements of the Endangered Species Act, the conservation program of this HCP is intended to achieve its biological goals and objectives and to ensure that the impacts of covered activities on the SBB are minimized and mitigated to the maximum extent practicable.
33 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
5.2.1 Measures to Minimize Impacts
The following measures are designed to minimize the indirect effects of the covered activities on the SBB by reducing incidental take of individuals and the degradation of habitat adjacent to the project’s impact areas.
5.2.1.1 Locate Project On or Adjacent to Current Development
Repairs will occur to existing bridges. Additional project-related impacts may occur within 1 to 3 ft. beyond the edge of existing, paved access roads. All worker parking, equipment storage, and laydown areas will be on existing paved roads and designated parking areas. Dirt or gravel pull-offs to the side of existing roads will not be used. To minimize temporary disturbances, vehicle traffic will be restricted to established roads, construction areas, and other designated areas. Vehicular speed along the access roads should not exceed 5 mph to minimize the potential of collisions between butterflies and construction vehicles and equipment.
5.2.1.2 Delineate Boundaries of Each Impact Area
Temporary fencing and signs will be erected to clearly delineate the boundaries for each of the project’s five bridge repair impact areas before any vegetation clearing, excavation, or other activities occur. Warning signs will be posted on the temporary fencing to alert equipment operators and other construction workers not to proceed beyond the fence protecting adjacent habitat. All protective fencing will remain in place until all construction and other site improvements have been completed. Signs will include the following language:
"NOTICE: SENSITIVE HABITAT AREA. DO NOT ENTER."
5.2.1.3 Dust Control
Dust can clog the spiracles of butterfly life stages. Accumulated dust on plants, such as the buckwheat, may cause them to experience a decline in vigor or even die. Appropriate dust control measures, such as periodically wetting down the work areas, will be used as necessary during any project-related activities that generate dust within the project’s impact areas.
5.2.2 Measures to Mitigate Unavoidable Impacts
To mitigate for unavoidable impacts of the bridge repair project at PSSHP, the CDPR proposes to restore 3.6 acres of northern foredunes at the dunes mitigation site near the base of Moro Rock (Figure 6). The next two sections describe these mitigation measures in more detail.
34 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
5.2.2.1 Protection of Dune Mitigation Site
Approximately 3.6 acres of existing and restored northern foredune habitat will be protected at the dune mitigation site, which is located within the Natural Preserve subunit of PSSHP (Figure 6). A new fence will be erected to protect this acreage from cattle. Encroachment in this area is prohibited except for activities related to the maintenance, restoration and monitoring of the habitat and sensitive species that occur there.
5.2.2.2 Habitat Management and Revegetation
The management goals and techniques described in this section are intended to mitigate the take of SBB and its habitat. The primary goal of the management program is to provide up to 3.6 acres of an enhanced and protected area of northern foredune habitat at the PSSHP’s Natural Preserve that will support the endangered SBB. Of this total protected acreage, up to 0.85 acre of existing habitat for the butterfly will be protected. In addition, 2.75 acres of degraded northern foredunes will be restored by the removal of ice plant, European beach grass, and other invasive plant taxa and will be revegetated with E. parvifolium and other associated dune endemic plant taxa.
Specific management goals are as follows: a) removal and control of invasive vegetation to less than 5% cover at the mitigation site; b) erosion control; c) restoration of the northern foredune habitat including revegetation with 2,769 Seacliff buckwheat plants with a 70% survival rate (net of 1,938 plants or a 3:1 ratio of mitigation to impacted plants) five years after planting; and d) revegetation of other dune plants endemic to the dunes at PSSHP.
The appendix (Section 10) to this HCP provides more details about the existing conditions at the Natural Preserve as well as the specific techniques that will be used to eradicate and control the invasive plants, plus the erosion control, habitat restoration, revegetation, and monitoring activities to benefit the SBB. If new information about the SBB, its buckwheat food plant, or site conditions becomes available during the life of the permit, management techniques may be altered to incorporate this new information.
5.3 Monitoring Monitoring tracks compliance with the terms and conditions of the HCP and incidental take permit. This project will include compliance, effects, and effectiveness monitoring. Compliance monitoring will track the permit holder’s compliance with the requirements specified in the HCP and permit, as described below. Effects monitoring tracks the impacts of the covered activities on the covered species. Compliance and effects monitoring will be conducted by the biological monitor for this project. All biological effectiveness monitoring,
35 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program which tracks the progress of the conservation program in meeting the HCP’s biological goals and objectives, will be conducted at the dunes mitigation site near the eastern base of Moro Rock.
5.3.1 Construction and Compliance Monitoring
5.3.1.1 Worker Environmental Awareness Training Prior to the start of any construction activities, the project’s biologist will conduct a training session for all construction workers involved with the project. The program will include a brief presentation about the biology of the SBB, their habitats, and the terms of the HCP. The orientation will also inform equipment operators and other workers about the impact area’s boundaries, equipment storage locations, materials laydown areas, construction activity restrictions, and identify other habitat protection and work procedures. Workers will be directed to immediately cease work if any life stage of the SBB is observed within the designated impact area and contact the permitted project’s biologist, who can relocate the butterfly.
5.3.1.2 Construction Monitoring
Throughout the construction and the other covered activities the project’s biologist will conduct regular inspections of the project site during all phases of the project to ensure that the perimeter fencing and signs that delineate the impact area remain in place, that other avoidance and minimization measures are being followed properly.
A USFWS-approved biological monitor will be present during delineation of the impact areas with protective fencing, all vegetation removal and ground disturbing activities associated with the bridge repairs. Site inspections should also occur at weekly intervals throughout the remainder of all bridge repair work.
5.3.1.3 Effects Monitoring
To quantify the amount of incidental take at the end of the project, the project biologist will calculate the area of habitat disturbance (i.e., incidental take), and tally the number of any SBB that were found and translocated during the project. This information will be summarized in the Compliance Monitoring Report (see Section 5.4.1).
5.3.2 Smith’s Blue Butterfly Monitoring
Because CDPR has assumed that the endangered butterfly is present at PSSHP, regular monitoring for the butterfly is not part of the monitoring program for this HCP. Nonetheless, it would be desirable to know if the habitat restoration efforts have encouraged the butterfly to successfully colonize the mitigation area. Thus once the mitigation buckwheats mature and produce sufficient flowerheads, a one-time survey will be undertaken. It will consist of three, two-day site visits to the mitigation area and a nearby location known to support the SBB. Since
36 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
E. parvifolium plants generally require about 3 to 5 years of growth to produce sufficient flowerheads to attract the SBB, CDPR will work with an entomologist, who is familiar with the butterfly and approved by USFWS to conduct this survey, to determine the appropriate timing for this survey.
5.3.3 Access to Project Site
The permit holder shall allow representatives from the Service access to the project site and mitigation site to monitor compliance with the terms and conditions of this HCP and the effects of the covered activities of this project.
5.4 Reporting
5.4.1 Compliance Report
By January 31st following each year of that the permit is in effect, the CDPR will submit a report to the Ventura Fish and Wildlife Office of the Service and any other permitting agencies to document the status of the project. The report will provide the following information:
1. Brief summary or list of project activities accomplished during the reporting year (e.g. this includes development/construction activities, and other covered activities) 2. Project impacts (e.g. number of acres impacts, status of repairs completed or in-progress, etc.) 3. Description of any take that occurred of the covered species (includes cause of take, form of take, take amount, location of take and time of day, and deposition of dead or injured individuals) 4. Brief description of conservation strategy implemented 5. Monitoring results (compliance, effects and effectiveness monitoring) and survey information (if applicable) 6. Description of circumstances that made adaptive management necessary and how it was implemented. Please include a table including the cumulative totals; by reporting period all adaptive management changes to the HCP, including a very brief summary of the actions. 7. Description of any changed or unforeseen circumstances that occurred and how they were dealt with 8. Funding expenditures, balance, and accrual 9. Description of any minor or major amendments
If the CDPR completes its project before the end of the 10-year permit duration, it will notify the Ventura Fish and Wildlife Office that it has completed all covered activities and mitigation measures; thus, subsequent annual compliance reports will not be necessary.
37 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
5.4.2 Annual Mitigation Monitoring Reports
CDPR must submit an annual monitoring report to the Ventura Fish and Wildlife Office of the Service, describing activities performed to benefit the SBB at the dunes mitigation site. This report shall be submitted to Service by December 31st of the monitoring year. This report shall include:
1) a general assessment of the condition of the habitat at the dunes mitigation site; 2) a description of all management actions taken along with an assessment of their effectiveness toward enhancing the biological goals and objectives; 3) a description of any problems encountered in managing the dunes mitigation site; 4) results of monitoring studies for the endangered species and/or communities conducted during the year and an assessment of their implications for the biological goals and objectives; 5) a description of other activities designed to enhance the dunes mitigation site; and 6) a description of the next year’s work plan and budget as described further in Section 7.1.
38 HCP for the Bridge Repair Project at Point Sur State Historic Park Conservation Program
Figure 6. Map of dunes mitigation site at PSSHP.
39 HCP for the Bridge Repair Project at Point Sur State Historic Park Plan Implementation
Section 6 Plan Implementation
6.1 Plan Implementation The proposed project described herein will be implemented by the applicant, the California Department of Parks & Recreation, and its contractors. The schedule of implementation of the covered activities will depend on the timing of issuance of the incidental take permit and local permits as well as seasonal constraints.
6.2 Changed Circumstances
6.2.1 Summary of Circumstances
Section 10 regulations [(69 Federal Register 71723, December 10, 2004 as codified in 50 Code of Federal Regulations (C.F.R.), Sections 17.22(b)(2) and 17.32(b)(2))] require that an HCP specify the procedures to be used for dealing with changed and unforeseen circumstances that may arise during the implementation of the HCP. In addition, the HCP No Surprises Rule [50 CFR 17.22 (b)(5) and 17.32 (b)(5)] describes the obligations of the permittee and the Service. The purpose of the No Surprises Rule is to provide assurance to the non-Federal landowners participating in habitat conservation planning under the Act that no additional land restrictions or financial compensation will be required for species adequately covered by a properly implemented HCP, in light of unforeseen circumstances, without the consent of the permittee.
Changed circumstances are defined in 50 CFR 17.3 as changes in circumstances affecting a species or geographic area covered by an HCP that can reasonably be anticipated by plan developers and the Service and for which contingency plans can be prepared (e.g., the new listing of species, a fire, or other natural catastrophic event in areas prone to such event). If additional conservation and mitigation measures are deemed necessary to respond to changed circumstances and these additional measures were already provided for in the plan’s operating conservation program (e.g., the conservation management activities or mitigation measures expressly agreed to in the HCP or IA), then the permittee will implement those measures as
40 HCP for the Bridge Repair Project at Point Sur State Historic Park Plan Implementation
specified in the plan. However, if additional conservation management and mitigation measures are deemed necessary to respond to changed circumstances and such measures were not provided for in the plan’s operating conservation program, the Service will not require these additional measures absent the consent of the permittee, provided that the HCP is being “properly implemented” (properly implemented means the commitments and the provisions of the HCP and the IA have been or are fully implemented).
Foreseeable changed circumstances within the project area of this HCP including the following:
• the new listing of a species; • the discovery of other endangered or threatened species at the project site; or • natural disasters.
6.2.2 Listing of New Species
If a new species that is not covered by the HCP but that may be affected by activities covered by the HCP is listed under the Act during the term of the section 10(a)(1)(B) permit, the section 10 permit will be reevaluated by the Service and the HCP covered activities may be modified, as necessary, to insure that the activities covered under the HCP are not likely to jeopardize or result in the take of the newly listed species or adverse modification of any newly designated critical habitat. CDPR, the permittee, shall implement the modifications to the HCP covered activities identified by the Service as necessary to avoid the likelihood of jeopardy to or take of the newly listed species or adverse modification of newly designated critical habitat. The permittee shall continue to implement such modifications until such time as the permittee has applied for and the Service has approved an amendment of the Section 10(a)(1)(B) permit, in accordance with applicable statutory and regulatory requirements, to cover the newly listed species or until the Service notifies the CDPR in writing that the modifications to the HCP covered activities are no longer required to avoid the likelihood of jeopardy of the newly listed species or adverse modification of newly designated critical habitat.
The occurrence of a newly listed species at the CDPR’s project site during the 10-year permit is unlikely due to the small size of the five bridge repair impact areas as well as the areas immediately adjacent to the existing, paved access road and ditches, where future maintenance activities would occur. Furthermore, the short duration of the incidental take permit, makes this unlikely.
6.2.3 Discovery of Other Currently Listed Species at the Project Site
In the event that one or more other currently listed endangered or threatened species are found within the project’s work areas, the permittee will cease project activities that would likely result in take of the newly-discovered listed species and apply for a permit amendment. Prior
41 HCP for the Bridge Repair Project at Point Sur State Historic Park Plan Implementation
surveys have documented where the other listed species occur near the project site. Due to the short duration of the project permit, this circumstance is extremely unlikely to actually happen.
6.2.4 Natural Disasters
As to other potential changed circumstances, the CDPR has applied for a permit for incidental take of the SBB throughout the entire 0.23 acre project site, which constitutes the impact area. Therefore, the CDPR does not anticipate that any additional changed circumstances will occur during the 10-year life of the incidental take permit in the area covered by this HCP that will result in unanticipated levels of take of the covered species.
Additional changed circumstances; e.g., wildfire, erosion, extended drought, earthquake or other natural disaster, may occur at the dunes mitigation site. However, the short duration of the permit (i.e., 10 years) lessens the likelihood that one of these phenomena may cause substantial changes to the off-site mitigation area during the permit period. Furthermore, some types of changed circumstances, for example a wildfire, may actually enhance habitat values in the long term because Eriogonum parvifolium and other members of the northern foredune plant community are adapted to, and regenerate well after such fires. Winter storms or earthquakes could cause landslide or erosion problems in habitat areas that would require subsequent repairs, such as slope stabilization and revegetation.
6.3 Unforeseen Circumstances
Unforeseen circumstances are defined in 50 CFR 17.3 as changes in circumstances that affect a species or geographic area covered by the HCP that could not reasonably be anticipated by plan developers and the Service at the time of the HCP’s negotiation and development and that result in a substantial and adverse change in status of the covered species. The purpose of the No Surprises Rule is to provide assurances to non-Federal landowners participating in habitat conservation planning under the Act that no additional land restrictions or financial compensation will be required for species adequately covered by a properly implemented HCP, in light of unforeseen circumstances, without the consent of the permittee.
In case of an unforeseen event, the permittee shall immediately notify the Service staff who have functioned as the principal contacts for the proposed action. In determining whether such an event constitutes an unforeseen circumstance, the Service shall consider, but not be limited to, the following factors: size of the current range of the affected species; percentage of range adversely affected by the HCP; percentage of range conserved by the HCP; ecological significance of that portion of the range affected by the HCP; level of knowledge about the affected species and the degree of specificity of the species’ conservation program under the HCP; and whether failure to adopt additional conservation measures would appreciably reduce the likelihood of survival and recovery of the affected species in the wild.
42 HCP for the Bridge Repair Project at Point Sur State Historic Park Plan Implementation
If the Service determines that additional conservation and mitigation measures are necessary to respond to the unforeseen circumstances where the HCP is being properly implemented, the additional measures required of the permittee must be as close as possible to the terms of the original HCP and must be limited to modifications within any conserved habitat area or to adjustments within lands or waters that already set-aside in the HCP’s operating conservation program. Additional conservation and mitigation measures shall involve the commitment of additional land or financial compensation or restrictions on the use of land or other natural resources otherwise available for development or use under original terms of the HCP only with the consent of the permittee.
Thus, in the event that unforeseen circumstances adversely affecting the SBB occur during the term of the requested incidental take permit, the CDPR would not be required to provide additional financial mitigation or implement additional land use restrictions above those measures specified in the HCP, provided that the HCP is being properly implemented. This HCP expressly incorporates by reference the permit assurances set forth in the revised (U.S. Fish & Wildlife Service 2004) Habitat Conservation Plan Assurances ("No Surprises") Rule (50 CFR Part 17).
6.4 Amendments
6.4.1 Minor Amendments
Minor amendments are changes that do not affect the scope of the HCP’s impact and conservation strategy, change amount of take, add new species, and change significantly the boundaries of the HCP. Examples of minor amendments include correction of spelling errors or minor corrections in boundary descriptions. The minor amendment process is accomplished through an exchange of letters between the permit holder and the Service’s Ventura Field Office.
6.4.2 Major Amendments
Major amendments to the HCP and permit are changes that do affect the scope of the HCP and conservation strategy, increase the amount of take, add new species, and change significantly the boundaries of the HCP. Major amendments often require amendments to the Service’s decision documents, including the NEPA document, the biological opinion, and findings and recommendations document. Major amendments will often require additional public review and comment.
6.5 Suspension/Revocation
The Service may suspend or revoke their respective permits if the CDPR fails to implement the HCP in accordance with the terms and conditions of the permits or if suspension or revocation is otherwise required by law. Suspension or revocation of the Section 10(a)(1)(B)
43 HCP for the Bridge Repair Project at Point Sur State Historic Park Plan Implementation
permit, in whole or in part, by the Service shall be in accordance with 50 CFR 13.27-29, 17.32 (b)(8). 6.6 Permit Renewal
CDPR, the permit applicant, requests a permit duration of ten (10) years. This period of time should ensure that the covered activities associated with the proposed project can be completed prior to permit expiration.
Upon expiration, the Section 10(a)(1)(B) permit may be renewed without the issuance of a new permit, provided that the permit is renewable, and that biological circumstances and other pertinent factors affecting covered species are not significantly different than those described in the original HCP. To renew the permit, the CDPR shall submit to the Service, in writing:
• a request to renew the permit, along with reference to the original permit number; • certification that all statements and information provided in the original HCP and permit application, together with any approved HCP amendments, are still true and correct, and inclusion of a list of changes; • a description of any take that has occurred under the existing permit; and • a description of any portions of the project still to be completed, if applicable, or what activities under the original permit the renewal is intended to cover.
If the Service concurs with the information provided in the request, it shall renew the permit consistent with permit renewal procedures required by Federal regulation (50 CFR 13.22). If the CDPR files a renewal request and the request is on file with the issuing Service office at least 30 days prior to the permits expiration date, the permit shall remain valid while the renewal is being processed, provided the existing permit is renewable. However, the CDPR may not take listed species beyond the quantity authorized by the original permit. If the CDPR fails to file a renewal request within 30 days prior to permit expiration, the permit shall become invalid upon expiration. The CDPR must have complied with all annual reporting requirements to qualify for a permit renewal. 6.7 Permit Transfer Since the proposed project site is located within the Point Sur State Historic Park, no permit transfer is anticipated at this time. However, in the event of a sale or transfer of ownership of a property covered by the permit for the project during the life of the permit, the following will be submitted to the Service by the new owner(s): a new permit application, permit fee, and written documentation providing assurances pursuant to 50 CFR 13.25 (b)(2) that the new owner will provide sufficient funding for the HCP and will implement the relevant terms and conditions of the permit, including any outstanding minimization and mitigation. The new owner(s) will commit to all requirements regarding the take authorization and mitigation
44 HCP for the Bridge Repair Project at Point Sur State Historic Park Plan Implementation obligations of this HCP unless otherwise specified in writing and agreed to in advance by the Service.
45 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding
Section 7 Funding
7.1 Costs of HCP Implementation
The overall cost of the conservation program described in this HCP is $157,750.00. A breakdown of the estimated costs to implement the conservation strategy for the initial project phase – year 1 is listed in Table 5. Similarly, a breakdown of the estimated costs for years 2-10 of the conservation program is provided in Table 6.
Table 5. Estimated costs to implement the conservation program for the Point Sur Bridge Repair Project (Initial Phase – Year 1) Item or Conservation Units Costs ($) Activity Strategy Type Number Per Unit Total Minimization and Mitigation Measures Minimization Install Construction 1000 ft. 5.00/ft. 5,000.00 Measure construction fencing 5.2.1.2 fencing at 5 bridge repair sites Minimization Install signs signs 20 signs 10.00 200.00 Measure 5.2.1.2 Minimization Dust control Spray water 250 50.00 12,500.00 Measure applications 5.2.1.3 Mitigation Install Wire Field 1,500 ft. 18.00/linear 27,000.00 Measure fencing to Fence to ft. 5.2.2.1 protect dune exclude Cattle
46 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding
mitigation site Mitigation Invasive plant Herbicide and 336 hr. 17.85/hr. 8,200.00 Measure control labor (average) & 5.2.2.2 2,200.00 for herbicide Mitigation Erosion Install straw 176 hrs 19.88/hr. 4,000.00 Measure control plugs (average) & 5.2.2.2 500.00 for straw Mitigation Seed Various 506 hrs. 19.76/hr. 14,500.00 Measure collection, (average) & 5.2.2.2 propagation 4,500.00 for of buckwheat various and other planting dune endemic supplies plants Mitigation Outplanting Various 904 hrs. 17.73/hr 16,275.00 Measure of propagated (average) & 5.2.2.2 plants and 250.00 for periodic flagging, supplemental stakes, and watering misc. supplies Subtotal 87,675.00
Monitoring Compliance Project Labor/hr. 161 hrs. 14.28/hr 2,300.00 monitoring biologist 5.3.1.2 (intern) Effects Project Labor/hr. 161 hrs. 42.36/hr. 6,800.00 monitoring biologist 5.3.1.3 Subtotal 9,100.00 Grand Total 96,775.00
47 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding
Table 6. Estimated costs to implement the conservation program for the Point Sur Bridge Repair Project (Years 2 – 10) Item or Conservation Units Costs ($) Activity Strategy Type Number Per Unit Total Minimization and Mitigation Measures Mitigation Invasive plant Herbicide and 672 hr. 17.85/hr. 14,200.00 Measure control labor (average) & 5.2.2.2 2,200.00 for herbicide Mitigation Erosion Install straw 176 hrs 19.88/hr. 4,000.00 Measure control plugs (average) & 5.2.2.2 500.00 for straw Mitigation Seed Various 506 hrs. 19.76/hr. 14,500.00 Measure collection, (average) & 5.2.2.2 propagation 4,500.00 for of buckwheat various and other planting dune endemic supplies plants Mitigation Outplanting Various 904 hrs. 17.73/hr 16,275.00 Measure of propagated (average) & 5.2.2.2 plants and 250.00 for periodic flagging, supplemental stakes, and watering misc. supplies Subtotal 48,975.00
Monitoring Smith’s Blue Presence- Labor/hr. 33 hrs. 150/hr. 5,000.00 5.3.2 absence survey in mitigation area Subtotal 5,000.00
Reporting Project Labor/days 165 hrs. 42.36/hr. 7,000.00 biologist to (2 days per
48 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding
complete year) annual monitoring reports Subtotal 7,000.00
Grand Total 60,975.00
In conjunction with the annual monitoring report, the CDPR will prepare an annual work plan and budget for the upcoming implementation year. The work plan will describe the CDPR’s planned activities, including those related to the implementation of conservation measures expected during the upcoming year. The annual work plan will document any mitigation provided for impacts. The budget will set out projected expenditures and the funding for those expenditures. The information in the annual work plan will contain sufficient information to demonstrate the CDPR’s ability to meet its financial obligations under the HCP. In addition to annual reporting, in the event of any material change in the CDPR’s ability to meet its financial obligations, the CDPR will immediately notify the Service. The CDPR understands that the ITP coverage would be at risk and federal enforcement measures could be possible if adequate budgets are not approved and measures are not implemented as required under the HCP.
7.2 Funding Source(s)
The applicant, the CDPR, will pay for all costs associated with implementing this HCP’s conservation strategies, including minimization measures, plus effects and compliance monitoring as itemized in Tables 5 and 6. In recognition of the fact that the costs for these activities in Tables 5 and 6 are estimates, the actual incurred costs may be less or more than these estimates. However, if the actual costs for the minimization activities are higher than estimated in Tables 5 and 6, the CDPR agrees to pay the actual costs.
CDPR operates the Pt. Sur SHP natural resources areas under the guidelines in California Public Resources Code Section 5019.53 and the Departmental Operations Manual (DOM) Section 3, Natural Resources. The park acreage under the care of CDPR will be unchanged by the HCP because the proposed mitigation area is already maintained by CDPR as part of the Pt Sur Natural Reserve. CDPR is obligated by the Public Resources Code and the DOM to protect and enhance natural resource values on the property at all times. The budget CDPR receives annually for Natural Resources Recurring Maintenance is for the purpose of maintaining natural resources in the parks. Each District develops its own Natural Resources work program to perform work such as removing non-native plants, controlling feral animals, and propagating and planting appropriate plants for the parks. Since Pt Sur State Historic Park was acquired by State
49 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding
Parks the annual Natural Resource Recurring Maintenance budget has been used to replace non- native plants with native plants and improve habitat values. Once the site restoration phase is complete CDPR will continue to apply it annual resource maintenance funding to fulfill the mitigation maintenance requirements of the HCP.
By fulfilling the initial work under this HCP (fencing, nonnative plant removal, and planting of native plants) CDPR will be better able to manage the Nature Reserve area of the park. For example the installation of cattle exclusion fencing will prevent repeated damage of the native plants by cattle, reduce erosion, and allow for newly planted native plants to get established. The work of maintaining the new native plants for the HCP and the area to be maintained by the HCP is the same type of work and the same area CDPR currently maintains with the Natural Resources Recurring Maintenance budget. With the addition of the new fence the labor lost from repeatedly protecting the property from cattle damage will be re-directed into more productive tasks and allow for the area to become high quality habitat. For these reasons State Parks can commit to fulfill the requirements of the HCP with the existing Natural Resources Recurring Maintenance budget.
Total funding will come from various sources. For example, fence materials have been pre-purchased using Monterey District’s annual operating funds; construction-related items, such as construction fencing, signs, and dust control, will be paid (50%) by a donation from the Central Coast Light Keepers (CCLK) and by AB1478 State Parks Matching Funds (50%) as part of the construction contract. Installation of the cattle exclusion fence and the work to manually remove non-native plants is under contract with the California Conservation Corps as well as the manual labor to out-plant native plants, maintain the area, and water plants that are establishing. Monterey District has already implemented and funded an agreement with the California Conservation Corps for labor needs to install and maintain the mitigation work. The State’s Environmental Scientist will oversee the work of the California Conservation Corps. One-time costs to collect seed and propagate native plants will be covered by Natural Resources Recurring Maintenance budget. After all initial planting is completed, and the project is in the maintenance phase, the Natural Resources Recurring Maintenance budget will be used for all work associated with this project. If for any reason the Natural Resources Recurring Maintenance budget is insufficient during the term of the agreement to fulfill the Monitoring and Mitigation work needed the Monterey District will supplement the funding with the District operating budget.
Pt Sur SHP is a unique park in that it has the support of an active volunteer association that operates public tours, raises funds for restoration projects, and performs work directly with its volunteers. The CCLK have provided significant private donations to fund the restoration work on the historic bridges that is the basis of this HCP. The CCLK has committed to assisting the State Park’s Environmental Scientist in the work of maintaining the mitigation area. Under the direction of the State’s Environmental Scientist the CCLK can help by manually removing non-native plants that grow in the mitigation area after the initial planting is installed. The CCLK will not only be available to assist State Parks in maintaining the mitigation area during
50 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding term of the HCP, but also in years following the term of the HCP. The CCLK will further assist the State’s Environmental Scientist by educating public tour visitors about the work going on at the park to protect and enhance coastal resources and about the recovery efforts for the Smith’s Blue Butterfly on the Central Coast of California.
7.3 Funding Mechanism and Management
The CDPR will provide all funds needed to implement the conservation program measures itemized in Tables 5 and 6 via the Monterey District’s Natural Resource Recurring Maintenance program. To further guarantee that funding is available for the maintenance of the mitigation area per the HCP Monterey District intends to fund any shortage from the Natural Resources Recurring Maintenance fund with Monterey District’s annual operating budget. The applicant understands that failure to provide adequate funding and consequent failure to implement the terms of this HCP in full could result in temporary permit suspension or permit revocation.
The conservation program measures identified in Tables 5 and 6 are consistent with the current management of the proposed mitigation area. The CDPR is obligated by California Public Resources Code Section 5019.65(a) to manage and maintain the proposed mitigation area as part of the existing Pt Sur SHP Natural Reserve in perpetuity. Section 5019.65(a) states that
“State natural reserves, consisting of areas selected and managed for the purpose of preserving their native ecological associations, unique faunal or floral characteristics, geological features, and scenic qualities in a condition of undisturbed integrity. Resource manipulation shall be restricted to the minimum required to negate the deleterious influence of man. Improvements undertaken shall be for the purpose of making the areas available, on a day use basis, for public enjoyment and education in a manner consistent with the preservation of their natural features. Living and nonliving resources contained within state natural reserves shall not be disturbed or removed for other than scientific or management purposes.”
The CDPR employs permanent full time Environmental Scientists (ES) who are qualified and responsible to organize and implement natural resource management activities to preserve and protect Pt Sur SHP. The Environmental Scientist at Pt Sur SHP will be organizing and implementing the work to fulfil the requirements of the HCP. Additionally, State Park Rangers prevent unauthorized uses of the property and patrol the area to prevent damage. The State’s Environmental Scientist will also consult with a qualified entomologist as needed to fulfill requirements under the HCP.
51 HCP for the Bridge Repair Project at Point Sur State Historic Park Funding
To demonstrate its ability to cover the costs of fulfilling the HCP obligations, the applicant has provided a table from the Monterey District’s Annual budget to the Service.
12175 MONTEREY DISTRICT-HB BP100000 7,801,339 BP300000 436,792 TBA13121 7,507 TBA13123 1,437 TBA13214 4,308 TBA13259 25,000 TBA13271 53,812
Total PCA 12175 8,330,195
The above is a reflection of the Department of Parks and Recreation’s allocation of budget dollars for the Monterey District for fiscal year 13/14, is indicative of the trend for future fiscal years, and reflects budgeted dollars which can be used for the purposes of meeting Point Sur State Historic Park’s obligations under this HCP should the annual Natural Resource Recurring Maintenance Funding that is intended for the project be insufficient.
52 HCP for the Bridge Repair Project at Point Sur State Historic Park Alternatives
Section 8 Alternatives
8.1 Summary Section 10(a)(2)(A)(iii) of the Endangered Species Act of 1973, as amended, [and 50 CFR 17.22(b)(1)(iii) and 17.32(b)(1)(iii)] requires that alternatives to the taking of species be considered and reasons why such alternatives are not implemented be discussed. Three alternatives for the proposed project are discussed.
8.2 Alternative #1: No Action
Under the No Action Alternative, the proposed Bridge Repair Project for PSSHP would not occur and the CDPR would not request an incidental take permit, and an incidental take permit would not be issued by the Service. Bridges #4 and #5 would remain closed to all vehicular traffic attempting to access the Point Sur Lighthouse. The conditions of Bridges #1, #2, and #3 would continue to deteriorate, and existing erosion and storm water issues would not be corrected.
Furthermore, the conservation measures described in this HCP would not be implemented and the restoration of the 3.6-acre dune mitigation site to benefit the SBB would not occur. Thus the No-Action Alternative is concluded to be of lesser conservation value to the covered species than the proposed project and accompanying HCP. For this reason it has been rejected.
8.3 Alternative #2: Redesigned Project (Reduced Take)
Under this alternative, the impact areas of the Bridge Repair Project at PSSHP would be reduced at the five impact areas located along the access roads, which presumably would result in reduced take of the SBB. Unfortunately, smaller work areas would not satisfy the CDPR’s need to properly repair the five timber bridges and correct the erosion and storm water issues, thus the Redesigned Project Alternative is not practical and no reduced take can actually be realized. The proposed project provides greater habitat conservation benefits than the Redesigned Project Alternative. For these reasons the Redesigned Project Alternative has been rejected.
53 HCP for the Bridge Repair Project at Point Sur State Historic Park Alternatives
8.4 Alternative #3: Proposed Action
Under the Proposed Action Alternative, the CDPR would repair the five bridges and complete the erosion control and storm drain measures as described in section 2. This alternative would require the issuance of a section 10(a)(1)(B) permit to allow construction of the project. The project would cause the loss of approximately 646 Seacliff buckwheat plants growing within the 10,196 ft2 (0.23 acre) impact area of habitat for the SBB and possible mortality of any butterflies living within the the project work areas. However, the conservation measures proposed in this HCP would result in greater conservation value for the SBB than either the No Action or Redesigned Project alternatives, while best meeting the needs of the applicant. Therefore, the Proposed Action is the preferred alternative.
54 HCP for the Bridge Repair Project at Point Sur State Historic Park References Cited
Section 9 References Cited
Arnold, R.A. l983a. Conservation and management of the endangered Smith's blue butterfly, Euphilotes enoptes smithi. Journal of Research on the Lepidoptera 22:135-153.
Arnold, R.A. 1983b. Ecological studies of six endangered butterflies: island biogeography, patch dynamics, and the design of habitat preserves. Univ. of Calif. Publications in Entomology 99: 1-161.
Arnold, R.A. 1986. Ecological studies of the endangered Smith's blue butterfly at Marina State Beach in 1986. Final report for an interagency agreement between the Calif. Dept. of Parks & Recreation and the University of California's University Research Expedition Program. 32 pp.
Arnold, R.A. 1990. The ecology and conservation of two endangered Southern California butterflies. IN, Endangered Wildlife and Habitats in Southern California. P.J. Bryant and J. Remington, eds. Memoirs of the Natural History Foundation of Orange County. Vol. 3, pp. 36-47.
Arnold, R.A. 1991a. Habitat and status surveys for the endangered Smith’s blue butterfly at Garland Park in Carmel Valley, California. Final Report. 30 pp.
Arnold, R.A. 1991b. Habitat and status surveys for the endangered Smith’s blue butterfly at Rancho San Carlos in Carmel Valley, California. Final Report. 35 pp.
Arnold, R.A. and A.E. Goins. 1987. Habitat enhancement techniques for the El Segundo blue butterfly, an urban endangered species. IN, Integrating Man and Nature in the Metropolitan Environment. L.W. Adams and D.L. Leedy, eds. Proc. Natl. Symposium on Urban Wildlife, Chevy Chase, MD, 4-7 Nov. 1986. Published by the National Institute for Urban Wildlife. pp. 173-181.
Arnold, R.A. 2002. Report of presence-absence survey for the endangered Smith’s Blue butterfly at Point Sur. Letter report addressed to Amy Palkovic, California Department of Parks & Recreation, dated 30 August 2002.
BUGGY Data Base. 2014. Sensitive species report for the Smith’s Blue butterfly. Data base maintained by Entomological Consulting Services, Ltd. Pleasant Hill, CA.
California Department of Parks & Recreation. 2004. General plan for Point Sur State Historic Park. 174 pp.
California Department of Parks & Recreation. 2014. Mitigated Negative Declaration for the Repair of 5 Bridges at Point Sur State Historic Park.
55 HCP for the Bridge Repair Project at Point Sur State Historic Park References Cited
California Natural Diversity Data Base. 2014. Sensitive species report for the Smith’s Blue butterfly. Data base maintained by the California Department of Fish & Wildlife. Sacramento, CA.
Cook, T. 1978. Soil survey of Monterey County. US Department of Agriculture, Soil Conservation Service. 228 pp. + maps.
Howe, W.H. 1975. The butterflies of North America. Doubleday, Garden City, N.Y.
Lowe, D.W. (ed.) 1990. The official World Wildlife Fund guide to endangered species of North America. 2 Vols. Beacham Publishing, Inc. Washington, D.C. 1180 pp.
Mattoni, R.H.T. 1954. Notes on the genus Philotes. I. Descriptions of three new subspecies and a synoptic list. Bull. So. Calif. Acad. Sci.53:157-165.
Mattoni, R.H.T. 1977. The Scolitantidini: I. Two new genera and a generic rearrangement (Lycaenidae). Journ. Res. Lepid. 16:223-242.
Pratt, G.F. & J.F. Emmel. 1998. Revision of the Euphilotes enoptes and E. battoides complexes. IN, Emmel, T.C. (ed.). Systematics of western North American butterflies. Mariposa Press. Gainesville, FL. pp. 207-270.
Scott, J.A. 1986. The butterflies of North America: a natural history & field guide. Stanford Univ. Press, Stanford, CA.
Shields, A.O. 1975. Studies on North American Philotes (Lycaenidae). V. Taxonomic and biological notes, and new subspecies. Bulletin Allyn Museum, No. 28: 1-30.
Steinhardt, P. 1990. California's wild heritage: threatened and endangered animals in the Golden State. California Dept. of Fish & Game. Sierra Club Books. Craftsman Press, Seattle, WA. 108 pp.
Thelander, C.G. and Crabtree, M. (eds). Life on the edge: a guide to California’s endangered natural resources. BioSystems Books. Santa Cruz, CA. 550 pp.
U.S. Fish & Wildlife Service. 1976. Determination that six species of butterflies are endangered species. Federal Register 41:22041-22044.
U.S. Fish & Wildlife Service. 1984. Smith's blue butterfly recovery plan. Portland, OR. 87 pp.
U.S. Fish & Wildlife Service. 2007. Five year review for the Smith’s Blue butterfly.
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Section 10 Appendix
10.1 Introduction
This appendix describes the existing habitat conditions at the Natural Preserve of the PSSHP, where mitigation activities for the bridge repair project will occur. In addition, it also describes the site protective measures that will be implemented, along with measures to control non-native plants. Procedures for seed collection, plant propagation, outplanting and monitoring are also detailed. These same procedures have been used by CDPR at other State Park locations in coastal Monterey County to successfully restore dune habitats at locations known to support the endangered Smith’s Blue butterfly. Lastly, proposed monitoring activities and success criteria are discussed.
10.2 Existing Conditions of the Natural Preserve at PSSHP
The Natural Preserve is located at the eastern base of Moro Rock (Figure 6) and consists of four subareas, A, B, C, and D (Figure 7). The remainder of this section describes the existing habitat conditions at the Natural Preserve, including the degree of plant cover and bare ground for each of these subareas, and identifies the predominant plants, including natives and non- natives.
Area A is characterized by 70% plant cover and 30% bare ground. Within the vegetated portions, most of the plant cover is non-native, including 60% Carpobrotus edulis, 5% Oxalis pes-caprae, and 2% Alyssum sp. Native vegetation comprises about 33% of the plant cover, including: 4% Eriogonum parvifolium, plus smaller percentages of Eschscholzia californica var. maritima, Erigeron glaucus, Dudleya spp., Abronia latifolia, Armeria maritime, Camissonia cherranthifolia, Lotus heermannii, Cirsium occidentale, Castilleja latifolia. Corethrogyne fillaginifolia, Lupinus arboreus, and Cakile maritime.
Area B is characterized by 90% plant cover and 10% bare ground. Within the vegetated portions, 90% of the plant cover is the introduced Ammophila arenaria. The remaining 10% of the plant cover is primarily composed of Pennisetum clandestinium, Abronia latifolia, Lupinus arboreus, and Astragalus sp.; with smaller amounts of Atriplex lentiflomis; Eschscholzia californica var. maritima, Camissonia cherranthifolia, Ambrosia chamissoni,; Cakile maritima, and Claytonia perfoliata.
Area C is characterized by 80% plant cover and 20% bare ground. Within the vegetated portions, dominant plants include 30% Ammophila arenaria, 20% Abronia latifolia, 10% Carpobrotus edulis, 10% Eschscholzia californica var. maritima, and 5% Cakile maritima. The remaining 25% plant cover is composed of Artemesia pycnocephala, Corethrogyne fillaginifolia,
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Erigeron glaucus, Lupinus arboreus, Astragalus sp., Dudleya sp.,Oxalis pes-caprae, Ambrosia chamissonis, Cirsium occidentale, Castilleja latifolia, and Camissonia cherranthifolia.
Area D is characterized by 95% cover plant cover and only 5% bare ground. Within the vegetated portions-the majority of plant cover is non-natives including 50% Carpobrotus edulis, 15% Oxalis pes-caprae, and a small amount of Alyssum sp. Native plant cover includes about 5% Lupinus arboreus, 5% Eschscholzia californica var. maritima, 5% Abronia latifolia, 5% Eriogonum parvifolium, 5% Eriophyllum staechadilfolium, 5% Astragalus sp., with the remaining 5% composed of: Ambrosia chamissonis, Castilleja latifolia, Camissonia cherranthifolia, Dudleya sp., Cakile maritima, Tetragonia tetragonoides, Corethrogyne fillaginifolia, Armeria maritima, Erigeron glaucus, and Artemesia pycnocephala.
10.3 Habitat Restoration Plan
The habitat restoration plan includes fencing and a gate to protect the Natural Preserve, control of non-native plants within the mitigation area, seed collection propagation of indigenous dune plants for revegetation, straw plugging, and outplanting of propagated plants. Monitoring will occur regularly to insure that restoration success criteria are met.
10.3.1 Cattle Fencing and Gate at Entrance Road
A fence will be installed to prevent cattle from trespassing into the mitigation areas. Fencing will consist of wood posts with barbless wire strands and welded wire mesh with large openings for small animal passage. The gate will be metal tubing.
10.3. 2 Non –Native Plant Control
The first stage in this plan will be manual and chemical control of Ammophila arenaria, Carpobrotus edulis, Carpobrotus chilensis, Pennisetum clandestinum, and Oxalis pes-caprae within the mitigation site. Ammophila is most prevalent in Area B , where it has formed solid stands. Carpobrotus is scattered throughout the other three areas, and forms some solid mats in Areas A and D. Of less significance are Pennisetum, which is present in Area A, and Oxalis which grows in-between native vegetation in Areas A, C and D.
After the fence is constructed to keep cattle out of the mitigation site, initial non-native plant control will begin. In areas where the four target species listed above are growing in solid mats or away from native vegetation, a foliar application of herbicide will be used. Where target species are in close proximity to native species, they will be manually removed and either piled or removed from the site. All non-native plant control will be done between October 1 and March 1, in order to reduce non-target (native plant) damage from trampling and overspray, during their growing season, and to avoid impacts to snowy plovers (which occur on the beach north of the project site) and other sea birds. Follow up spot spraying and manual removal will occur yearly for at least ten years after commencement of the project.
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10.3.3 Native Plant Seed Collection
Seed collection of plants natives to the dunes at the Natural Preserve will follow the initial non-native plant control. Seeds will be collected on-site from dune species that are represented in the project site, including Eriogonum parvifolium, Eschscholzia californica, Lotus heermannii, Abronia latifolia, Artemisia pycnocephala, Camissonia cheiranthifolia, Dudleya sp, Lupinus sp, Castilleja latifolia, Eriophyllum staechadifolium and Armeria maritima. Seeds will be collected from fewer than 20 % of available seed heads on individual plants, and from at least 10 individual plants from each species. Seeds shall not be collected from plants growing more than 0.25 mile from the planting site. Collection of seeds will occur from late June through early October, with actual timing depending on seed maturation of the target species.
10.3.4 Native Plant Propagation
Propagation of native plant taxa at the Natural Preserve will occur from July through December of the first year. All plants will be grown in stubby cell containers using a native soil and commercial planting mix blend. They will be started in a greenhouse, then moved to a shade house for at least one week before outplanting at the mitigation site.
10.3.5 Straw Plugging
Straw plugging (inserting small bunches of straw into bare sand at regular intervals) will be done during September through December of the first year, in areas that are prone to wind erosion, due to lack of vegetation. In areas where this technique will be used, handfuls of straw will be dug into the sand approximately every two feet. Only certified weed free straw will be used.
10.3.6 Outplanting of Propagated Native Plants
From December 1 – March 1 of the first year (earlier if significant rain falls before December 1,) plants shall be outplanted into the mitigation site. Plants will be installed every two – three feet, in bare areas, and in large patches of dead Carpobrotus thatch. In areas where a significant percentage of native vegetation occurs, plants shall be installed in bare spots as deemed appropriate by a State Parks environmental scientist. Plants shall be planted within a small basin that will catch rainwater during the first wet season after planting. Species ratios and arrangement will be based on what is known to exist in other Northern Foredune and coastal scrub plant communities in surrounding areas. Eriogonum parvifolium plants will be installed in groups of 10 plants arranged in a circle (following the procedures described by Arnold and Goins (1987). Supplemental planting will occur during the same window in subsequent years, to achieve the success criteria.
10.3.7 Monitoring
To document progress of the restoration, vegetation transects, Eriogonum survival and flower monitoring, and photo monitoring will be conducted between April 1 and September 1 of the first year, after the cattle fence is constructed, but before any non-native plant control is
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implemented. In subsequent years of the 10-year permit term, monitoring will be performed annually to assess survival rates and the need for supplemental plantings to achieve success criteria. Also, flowering of Eriogonum parvifolium should be assessed annually. Once the success criteria are satisfied, subsequent monitoring will be done at two -year intervals for the remainder of the permit term.
10.3.8 Success Criteria
At the end of five years after the initial planting, at least a 70% survival rate of Eriogonum parvifolium and all other northern coastal foredune and coastal scrub species outplanted in the mitigation site will be considered successful. The plants should represent a mixture of ages and at least 50% of the planted Eriogionum parvifolium should be flowering. If that survival rate is not reached, supplemental planting shall be done in order to meet the target survival rate until it is achieved.
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Figure 7. Map of Subareas at Mitigation Site
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