EBCNPS Submits Report to Regulatory Agencies Regarding Oakland Zoo’s Biological Assessment for its Proposed Expansion Project in Knowland Park

Field of Lupines in the Knowland Park Grassland Spring 2013 photo: Mack Casterman

In March, the Oakland Zoo submitted a Biological Assessment to the Regulatory Agencies as part of their permit process for their proposed expansion project in Knowland Park. Unfortunately, the Zoo omitted any mention of the rare maritime chaparral plant community that would be impacted by the project. This omission came in spite of the fact that the top state vegetation ecologist visited the site with Zoo personnel and confirmed the occurrence in person. In response to this omission, EBCNPS submitted a detailed report last month, including a legal letter, to the agencies documenting the “denial and disappearance” strategy that the zoo is using to try to gain its permits.

You can view a copy of EBCNPS’s report to the regulators here: EBCNPS Letter to Agencies RE Oakland Zoo 2013 Biological Assessment

And a copy of the accompanying legal letter from our attorneys here: Legal Letter to USACE and CDFW re Oakland Zoo expansion

Included in EBCNPS’s report package to the agencies was an extensive review by wildlife biologist, Dr. Shawn Smallwood, of the highly flawed Alameda whipsnake portion of the zoo’s Biological Assessment.

The Center for Biological Diversity concurred with this analysis and submitted a letter of its own to the agencies, urging that they withhold permits from the project.

We will be following up our letter with actions in which the public can become involved.  Stay tuned to this website in the coming weeks for our next steps.

EBCNPS Submits Comments on James Donlon Boulevard Extension DEIR

Grading Map of Proposed Project

On May 29^th, EBCNPS submitted comments on the DEIR for the proposed James Donlon Boulevard Extension in Pittsburg. This roadway extension would involve the filling of multiple drainages and require more than 2 million cubic yards of grading (2,165,000 cubic yards) including areas of native grassland, oak woodlands, and riparian areas. Our letter commented on the inadequacy of the alternatives analysis, the need to consider the growth-inducing impacts of this project, the need to plan for weed management measures, and the importance of using local ecotypes of native species for landscaping and revegetation.

A copy of our comment letter can be viewed here: EBCNPS_comments_on_Donlon_extension.pdf

Public Response from EBCNPS Regarding FEMA Fuels Management EIS

From the EBCNPS Conservation Committee 05/30/13:

California residents continue to move into the urban-wildland interface, much like residents of other western states.  “Urban-wildland interface” came into media use in coverage of western states’ wildfires. Western wildfires, in turn, have claimed more media spotlight because of lives and homes lost by residents at the urban fringe.

Several years ago, the Federal Emergency Management Agency (FEMA) solicited fire prevention grant proposals from managers of public lands in the East Bay, including City of Oakland, East Bay Regional Parks, and UC Berkeley.  Unfortunately, early efforts to present a coordinated, transparent grant proposal by all of the agencies did not materialize.  FEMA is now considering separate proposals and draft environmental impact statements (EIS) submitted by each of these agencies.

In March 2009, local chapters of the California Native Plant Society, Golden Gate Audubon and the Sierra Club jointly issued a Green Paper on Fuels Management in the East Bay Hills to reconcile ecological values of the East Bay hills with realistic fire management.  These environmental groups agreed in this policy statement that removal of exotic, invasive trees and understory plants can fulfill both the goals of reducing catastrophic fire risk and maintaining native habitat.

Groves of Eucalyptus globulus (blue gum trees) have had a century’s head start on fire control efforts.  Many residents moved into Claremont and Strawberry Canyons before local planning agencies grasped the fire/Eucalyptus connection.  Beginning in the 1930s, East Bay Regional Parks acquired some of the remaining open land in the East Bay hills, which continue to present a mosaic of native and exotic plant species.  Now, population density in these hills makes the use of prescribed burns almost impossible.

In Australia, land managers discovered that prescribed burns best manage healthy populations of Eucalyptus and Acacia, provided that nearby residents take proper care in home construction and maintenance.

For an Australian perspective on Eucalyptus and fire management, see current information available at www.csiro.au/en/Organisation-Structure/Divisions/Ecosystem-Sciences/BushfireInAustralia.aspx.

The East Bay Chapter of The California Native Plant Society cannot deny the pressure on land managers to choose tree removal over prescribed burns.  However, the proposals of different agencies present different methodology for removal. For that reason, the conservation committee recommends the tree removal program as presented by UC Berkeley for its lands in Strawberry and Claremont Canyons.

However, among the detailed comments that EBCNPS plans to submit to FEMA on its fuels management plan, we will be urging both FEMA and the East Bay Regional Park District (EBRPD) to use the current survey standards of the Manual of California Vegetation, 2d edition, to update EBRPD’s fuel management plan vegetation surveys for all its “recommended treatment areas” (RTAs), including those RTAs subject to the FEMA fire management plan (and FEMA funding conditions).

Berkeleyside Article Describes FEMA Fuels Management Project in East Bay Hills

From Berkeleyside.com: Eucalyptus trees in Claremont Canyon: Cal is seeking federal funds to cut down many such non-natives. Photo: Tracey Taylor

Please read this recent article posted on Berkelyside describing the ongoing FEMA process to fund fuels management plans in the East Bay Hills: http://www.berkeleyside.com/2013/05/17/uc-berkeley-seeks-funds-to-cut-down-22000-non-native-trees/

EBCNPS is working to review the FEMA EIS and will be submitting comments on the report. Those comments will be posted on this blog as soon as they are completed.

Update: The Claremont Canyon Conservancy (http://claremontcanyon.org/) is circulating a petition in support of the findings of the FEMA EIS and the fuels management measures outlined in the plan (removing flammable and invasive eucalyptus). You can view their petition here: http://petitions.moveon.org/sign/support-east-bay-hills?source=s.icn.em.mt&r_by=7897161 .

EBCNPS submits comments for Concord Naval Weapons Station NOI

On April 19, EBCNPS submitted comments for the Notice of Intent to Prepare an Environmental Impact Statement for the Disposal and Reuse of the Naval Weapons Station Seal Beach Detachment Concord (CNWS).

The Concord Naval Weapons Station is one of our chapter’s Botanical Priority Protection Areas due to its large expanse of valley grassland (which occupies most of the site) connecting an intact mosaic of saline bayland habitats with uplands that extend into the summits of Mt. Diablo. This crucial strip of land sits in one of the least developed “urban” watersheds that connects mountains to marshes.

The forthcoming EIS will consider three alternatives, one of them being The Concord Reuse Project Area Plan which received broad support from the Concord community and local environmental organizations and after a complete environmental review, was adopted by the City of Concord. This plan is described in “Alternative 1” of the NOI document. EBCNPS was very active in providing input and supporting the plan during its development and therefore is recommending “Alternative 1” of the forthcoming EIS be adopted so that the City of Concord can begin implementing it.

You can view EBCNPS’s comment letter here: EBCNPS Comments for 2013 CNWS EIS final

“New Farm” Development Withdrawn!

Thanks to a united opposition by EBCNPS and other environmental allies including Save Mt. Diablo and The Greenbelt Alliance, the “New Farm” development project in the Tassajara Valley (Part of our “East Dublin and Tassajara” BPPA) has been withdrawn. In its place, the developer has proposed a smaller project that is being called “Tassajara Parks.” EBCNPS is reviewing the details of the proposed project and will have more to report in the coming weeks. You can view a Contra Costa Times article on this environmental victory here: http://www.contracostatimes.com/breaking-news/ci_23015616/tassajara-valley-housing-plan-shrinks-again .

You can also view an article that ran in The Valley Sentinel that makes note of EBCNPS’s involvement in the effort: http://valleysentinel.com/news/county/developer-asking-for-30-acre-adjustment-of-urban-limit-line/

EBCNPS Submits Letter to Regulatory Agencies RE: Knowland Park Development

Upper Knowland Park – site of the proposed zoo expansion photo: Mack Casterman

On April 2, EBCNPS submitted this letter: [ EBCNPS Letter to USACE 4_02_13 ] to the California Department of Fish and Wildlife and the Federal Fish and Wildlife Service regarding the recently prepared revised Biological Assessment for the Oakland Zoo’s expansion project into Knowland Park. We received the Biological Assessment from a Public Records Act request and were frustrated (but not surprised) to find that the Zoo had once again failed to identify the rare Maritime Chaparral plant community that will be impacted due to their proposed visitor center and gondola. This blatant mischaracterization of their project site comes even after a letter from the CDFW identifying the chaparral at Knowland Park as Maritime Chaparral and a site visit where CDFW biologists directly told Zoo executives and contract-biologists that the chaparral did indeed represent a rare plant community. We are hopeful that CDFW will require an accurate Biological Assessment of the project site before this process is allowed to move forward.

Also attached are the documents referred to in our above letter: CDFG_Letter_to_Joel_Parrott_5_2_12 ; VegMou_11.07.01; briefingMOU;

New Tesla Park Article in Livermore Independent: “Alliance Aims to Change Plans For Tesla Park”

Field of wildflowers in the Tesla Park grasslands. photo: Mack Casterman

Check out this article that was published in today’s Livermore Independent about the ongoing debate regarding the future of Tesla Park in our Corral Hollow Botanical Priority Protection Area: Click Here to See Article

CNPS Submits Comments for Board of Forestry’s draft Vegetation Treatment Program EIR

Last week, the California Native Plant Society submitted comments to the California Board of Forestry regarding the Draft EIR for their Vegetation Treatment Program. The Draft EIR can be found here.  EBCNPS’s botanists provided specific comments for this State letter and many other CNPS chapters throughout the state submitted comments as well. CNPS’s main concerns with this document included procedural irregularities and the general lack of scientific evidence to back up the document’s recommendations. You can view our letter here: CNPS Comment on Draft VTPEIR.

EBCNPS Submits Comments on NOP for LBNL’s “Richmond Bay Campus” at Richmond Field Station

The Richmond Field Station, site of the proposed LBNL second campus. Photo courtesy of: Lawrence Berkeley National Labs

On February 4^th, EBCNPS submitted comments on the Notice of Preparation for the Lawrence Berkeley National Laboratory’s “Richmond Bay Campus 2013 Long Range Development Plan and Phase 1 Development Environmental Impact Report.” A copy of the Notice of Preparation document can be found HERE. The Richmond Field Station makes up part of our Richmond Shoreline BPPA due to its remnant stands of native coastal prairie grassland. EBCNPS is hopeful that the forthcoming EIR will include complete avoidance and protection measures for the native grassland at the site. We are looking forward to the forthcoming EIR and we will comment again at that time.

A copy of our NOP comments can be viewed here: 02_04_13 EBCNPS LBNL at Richmond Field Station NOP Comment Letter.