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On June 29th, EBCNPS submitted a comment letter in response to the Preliminary General Plan and accompanying Draft Environmental Impact Report for the Carnegie State Vehicular Recreation Area in Eastern Alameda County. This letter is a major step in a multi year process that will continue into the future.
EBCNPS’s concern regarding this plan is that it proposes to expand motorized off road vehicle recreation into a 3,000 acre parcel that is known as Tesla Park. This area is listed as a Botanical Priority Protection Area by EBCNPS, and the plan and its DEIR fail to consider and address the major environmental impacts that would occur if such an expansion was to take place.
Our letter can be viewed here: EBCNPS General Plan_DEIR letter FINAL June 2015 with attachments
The Oakland Zoo recently submitted a request to the City of Oakland for a permit to kill 57 heritage Oaks and other native trees in Knowland Park. Many many more trees that don’t require a permit to kill will be taken out, and the Zoo acknowledges 481 could be impacted during the construction of the Zoo’s proposed expansion development in the highlands of Knowland Park.
Please join us in writing a formal letter protesting the issuance of this permit. The citizens of Oakland must speak out to make sure that the publicly funded Oakland Zoo is not allowed to destroy these native heritage trees on public park land. These trees make up part of Oakland’s natural heritage and indeed lend their name to the city itself.
The Friends of Knowland Park have made it easy to let your concern be heard by sending the one click letter available at this link:
The comment deadline is June 23rd.
Thank you for your help!
Please email your comments on the Carnegie SVRA Preliminary General Plan/Draft EIR (General Plan /DEIR) before the June 29, 2015 deadline.
Your comments can be emailed to CarnegieDEIRcomments@gmail.com .
You can view the documents at www.CarnegieGeneralPlan.com .
Following is a sample comment letter that you can use to prepare your personal email:
To OHMVR Carnegie SVRA General Plan:
The Carnegie SVRA Preliminary General Plan and Draft EIR do not protect the sensitive resources in the expansion area, also referred to as the Alameda-Tesla property or Tesla. The General Plan and DEIR may provide Carnegie SVRA the maximum flexibility to develop OHV use in the existing DEIR and expansion area anyway that they desire, but it deprives the public of needed specific information about the proposed plan and its impacts. It makes a mockery of the CEQA process.
The General Plan and DEIR do not describe the project in sufficient detail; this deficiency is significant because the General Plan and DEIR specifically state that further environmental review is not required if future projects are found to be consistent with the General Plan and DEIR. (GP 1-7; DEIR 1-2) The General Plan does not accurately describe Existing Conditions (Chapter 2); there is no mention that a Critical Linkage Habitat Corridor runs directly through Tesla and there are no pictures of the extensive damage from OHV use in Carnegie SVRA. (GP Chapter 2) The DEIR concludes there will be no significant impacts from converting 3,100 acres of agricultural grazing and natural resource conservation land to OHV use is not supported by evidence or analysis (DEIR Chapter 3); you only need to compare the damaging impacts from OHV use at the existing Carnegie SVRA to prove that DEIR is not credible. The General Plan and DEIR attempt to substitute vague and un-measureable guidelines for required mitigation; the DEIR states that no mitigation beyond best management practices and unenforceable guidelines is required (DEIR Chapter 3). The DEIR does not consider any non-OHV use alternatives and the cumulative impacts from the existing Carnegie SVRA on the unique Corral Hollow ecosystem. (DEIR Chapter 4 and 6)
Opening the 3,100 acre Tesla expansion area to OHV use will result in irreparable damage its sensitive resources which include several rare plant communities and species, California Red-Legged Frog, California Tiger Salamander, Western Pond Turtle, Yellow-legged Frog, Western Spadefoot Toad, Golden Eagle, Tule Elk, Alameda Whipsnake, Townsends Big-eared Bat the historic Tesla town site and coal mine, significant features from indigenous cultures, and much more. The Tesla expansion area is not suitable for damaging OHV use. I oppose the expansion of Carnegie SVRA into the Tesla expansion area. The General Plan and Draft EIR should not be approved or certified as written and need to be revised and recirculated for public review with the entire expansion area designated as a permanent preserve area with No-OHV use allowed.
(Name, address, email)
The East Bay Chapter of the California Native Plant Society strongly supports the litigation action by SPRAWLDEF and the Sierra Club, against FEMA’s surprising Record of Decision regarding fuels management in the East Bay Hills. The California Native Plant Society is a statewide organization of over 10,000 members dedicated to the preservation and appreciation of our state’s native flora. We recognize the importance of native plant communities and native plant habitats, in the intricate and complex web of life that is our natural world. Our locally evolved flora supports a rich palette of interconnected life, from the insect world to birds, amphibians and reptiles, mammals, fungi, etc. In order to allow these natural and native associations to repair themselves, and to thrive, we support the efforts of our collaborators SPRAWLDEF and the Sierra Club, in their suit against FEMA. FEMA’s Record of Decision left a confusing and murky set of unanswered questions, with unspecific parameters particularly around the management of stands of exotic eucalyptus, pine and acacia trees. We hope to see this confusion resolved in such a way as to allow complete removal of exotic trees in some specific places, so as to allow the regeneration of native species, with more manageable fire behavior characteristics. Attentive follow up weed management is a must. We believe this approach will meet the twin goals of reducing the risk of catastrophic fires, while maintaining native habitats. Also, this approach is fiscally responsible, and sustainable, whereas maintaining stands of huge exotic trees is not. The serious shortcomings and confusion of FEMA’s final Record of Decision should be re- examined and clarified, so as to allow for more responsible and effective management and stewardship of our East Bay Hills vegetation and habitats. Sincerely, Jean Robertson Conservation Committee Chair East Bay Chapter, CNPS
On April 23rd, the California State Park’s Off-Highway Motor Vehicular Recreation Division released its new Preliminary General Plan for and accompanying Environmental Impact Report for Carnegie State Vehicular Recreation Area (CSVRA) . This plan includes the expansion of Carnegie onto 3,400 acres of wildland in eastern Alameda County (an area commonly referred to as Tesla Park). The General Plan and EIR can be found at this link: http://carnegiegeneralplan.com/document-library
EBCNPS is preparing to submit detailed comments on the plan. We are working to establish Tesla Park as a non-motorized low impact historic and natural resource park and preserve. We believe that such a designation would provide the best protection for the rare native habitats and critical wildlife corridor encompassed by the Tesla Park land while still providing recreational and educational value to the general public.
To learn more about Tesla Park and its wonderful natural resources, please visit: www.teslapark.org . While you’re there, be sure to sign up to the mailing list, like the facebook page, and consider making a donation to the effort. Also, be sure to check out our Corral Hollow Botanical Priority Protection Area description on page 12 and 13 of our BPPA Guidebook at: http://ebcnps.org/bppabotanical/GuidebookBPPA-EBCNPS-download-web.pdf
We need all the help we can get to show strong support for a non-motorized alternative land use for this area. Please, review the documents and submit comments before the deadline on June 29th. We will be sending out more info shortly so stay tuned!
On April 3, 2015, EBCNPS submitted comments to Caltrans regarding the DEIR for the Alameda Creek Bridge Replacement Project. Our letter expresses concern that Caltrans has designed this project as an overbuilt highway widening project with little regard for the sensitive natural resources of Niles Canyon that will be permanently damaged as a result.
The DEIR examines several project scenarios, all of which would result in the removal of between 284 and 414 native trees in the riparian area of the canyon.
EBCNPS’s letter also noted that Caltrans is attempting to segment the Niles Canyon Corridor Project into several different projects that will all be subjected to independent environmental reviews. The cumulative effects of this entire project, the Niles Canyon Safety Improvements Project, Niles Canyon Short Term Improvements Project, and Arroyo de la Laguna Bridge Project must be properly considered as part of a total environmental review to ensure that cumulative impacts are properly quantified and understood.
EBCNPS’s letter can be found here: EBCNPS letter re: Alameda Creek Bridge Replacement DEIR 4_3_15
In 2011, the Alameda Creek Alliance had to sue Caltrans to halt its original project in the canyon due to inadequate environmental review. Unfortunately, Caltrans had already cut down nearly 100 native trees along the creek by the time the courts stopped the project. Caltrans has yet to mitigate for that damage.
On January 21st, EBCNPS submitted a letter to FEMA in response to the recently released Final Environmental Impact Statement for their East Bay Hills Fuels Management Plan. EBCNPS’s concerns are focused on changes FEMA has made to the Final EIS – specifically, modifying the projects proposed by Berkeley and Oakland which planned to remove Eucalyptus and restore native habitat. FEMA is now requiring that UC Berkeley and Oakland adopt a plan that is similar to that proposed by the East Bay Regional Park District, where Eucalyptus stands would be thinned and managed rather that removed. This raises an issue with the regulatory process since both UC Berkeley and Oakland’s projects were determined to be self mitigating due to the native habitat restoration that would have been achieved.
EBCNPS’s letter can be viewed here: CNPS FIES Response Letter 1_12_15 FINAL
The release of the Final EIS has raised more questions that it has answered. EBCNPS plans to continue following this issue as it develops.
The 2015 CNPS Conservation Conference is coming up in a few weeks. Join over 1,000 conservation and native plant enthusiasts in San Jose! Attendees include scientists, conservationists, CNPS chapters, university professors and students, policymakers, professional and amateur botanists, landscaping professionals, and land-use planners from California and beyond. The Conference will take place on January 15th 16th and 17th and there are pre-conference workshops and field trips occurring on January 13th and 14th. Visit the conference website for more information and to register to attend: http://www.cnps.org/cnps/conservation/conference/2015/
This event only happens once every three years, and with the location so close to our chapter area, this is one not to miss!
On November 14th, EBCNPS submitted comments to the East Bay Regional Park District regarding their Notice of Preparation for a Supplemental Environmental Impact Report for their Albany Beach Restoration and Public Access Project. Our comments focused on the importance of making sure the eelgrass beds that exist just offshore of the project area are protected both during construction and during recreational use of the beach after the project is completed. A copy of our letter can be viewed here: 11_14_14 NOP Comment
On November 18th, the Oakland City council voted 6-2 to approve the Oakland Zoo’s proposed conservation easement – taking the final step in approval for the Zoo’s proposed expansion project that would remove public access to roughly 77 acres of public wildland in Knowland Park. With this vote, the Oakland City Council sent a message that public land in Oakland is up for grabs to any private entity that wants to profit from it.
The most heartening part of the challenging night was that supporters of the park packed the council chambers and were eloquent to a person in their support for protecting the park. It was clear that had the audience voted, the easement would have been crushed. And the divide between what the public wants and what it got from this city council is manifest. On the zoo’s side I can recall only zoo staff, a few zoo volunteers, and zoo board members speaking. We also know that hundreds of e-mails were sent to CC members, and one of our petitions hit 17,000 signatures. So, the outpouring for the park, for the native plant and wildlife resources was overwhelming. Four reps from Sierra Club spoke, one from Defense of Place, and letters came in from the Center for Biological Diversity and other environmental organizations. Not a single local environmental organization supports the Zoo’s project.
Councilmembers Councilmembers Kaplan and Kalb were the dissenting votes. Kaplan gave no reasons for her vote (although we know from our talks with her that she is a park user, was deeply offended by the removal of public access to benefit a private entity). The person who nailed the reasons for opposing the conservation easement was Councilmember Kalb who made it clear that the easement on already protected public park land is double-dipping–regardless of what the zoo’s paid biological consultant said–and that easements like these shouldn’t be used. He also made plain that the city—regardless of whether it was a successful legal strategy–should have required the Zoo to complete a full EIR with the implication that the mess that the city is facing is because it never did the Alternatives Analysis which would have been required in an EIR document. Although Dan doesn’t lose his temper, he scolded the city and the Zoo for dodging this critical step. “It’s not something that a good nonprofit should’ve done,” Kalb said to Zoo representatives, adding, “The city made a mistake in not pushing you to do it.”
While we obviously failed to win the vote (which we knew was a long shot), we succeeded in getting this issue out in front of the public after a long uphill fight. Those of us who remember the meetings in 2011 recall the challenging efforts to inform decision makers and the public about the native plant species and communities in the park. CNPS was often cited in the discussions and certainly vilified by the opposition, which if anything has helped us in the eyes of the public. I don’t think we’ve ever had more media attention, and the environmental community did join our cause in full force.
The Knowland Park Team will be de-briefing and assessing next steps, so stay tuned. We cannot adequately thank those who have poured their hearts into this effort. For now, let’s get out to the park and continue to enjoy and learn from it while we can.