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Attention: please return to this post as pictures and links are added through the end of October.

The Carnegie State Vehicular Recreation Area (SVRA) proposed expansion parcel of more than 3000 acres, otherwise known as Tesla Park to those supportive of its preservation, is not yet safe from the impacts of Off- Highway Vehicle (OHV) recreation. Unfortunately, on Friday, October 21, 2016, the OHMVR Commission convened in Sacramento to approve the General Plan and certify the Final Environmental Impact Report (EIR) for the existing park and expansion. In my three minutes at the podium, I presented a few main points from our EBCNPS letter to the OHMVR Commission. I held out hope that comments from all of the groups in attendance on Friday, may have swayed the commissioners to delay a decision. Our organization has advocated for years that the plan lacks: admission of the significant impacts of OHV recreation to biotic resources; adequate mitigation measures incorporated into this EIR; and most importantly, adequate plant surveys.

The OHMVR Commission heard public comments from about 50 people, approximately 11:00am to 3:45pm, with a lunch break. A multitude of organizations, individuals, politicians, local government agencies, and state government agencies have opposed this expansion project. Read the full list here. Members from several of these groups attended an in-person meeting with OHV Division Deputy Director Mathew Fuzie, on October 12, but this did not result in action to stop the Final EIR and General Plan approval process. On a happy note, related to our organization’s past advocacy at several meetings with the Altamont Landfill Open Space Committee, ALOSC submitted a letter declaring their support for prioritizing funding applications for acquiring or conserving the Tesla expansion area. Commissioners on Friday took only about 15 minutes to review the stack of letters submitted into the record, and then continued with questions for staff regarding some of the comments heard from the public. A couple of public agency representatives also returned to the podium for a few minutes of commission questioning.

By this point, astute listeners realized the public had not yet seen a document referenced to several times throughout the day, and this realization resulted in a big hiccup. The commission had referenced the existence of a CEQA document called a “Statement of Overriding Considerations,” as an existing document already created by the Director of State Parks. This type of document is important for understanding how an agency addressed environmental impact analysis concerns, because it provides an outline that typically both acknowledges significant impacts and declares the agency- level (State Parks’) reasoning for ignoring these impacts. In a last minute twist before a commission vote, the commission broke to tell the remaining audience we would receive a copy of this Statement so as to read it, immediately followed (about 10 minutes later) by a supplementary public comment period. The text of two resolution documents were distributed, which referenced the Statement. But, it ended up that the meeting was adjourned without the public ever having seen the text of this Statement (still unavailable as of this writing). The commissioners themselves appeared not to have read this Statement yet, or know whether or not it existed. Remaining members of the public were allowed two minutes to comment on the resolutions. In my brief reading, these resolutions did not provide substantive information on the agency’s reasoning for dismissing significant impacts. They simply declared the OHMVR Commission’s intent to approve the General Plan and certify the Final EIR. Certainly, under no circumstance is a 10 minute review of any document sufficient for public comment. Minutes later, the commission adopted the resolutions. The ultimate meaning of this hasty action will be addressed by Friends of Tesla Park and others undertaking likely future litigation.

Read EBCNPS comment letter here.

Our conclusion holds that Tesla is not an appropriate place for OHVs, and comparing areas within it to each other to find a “relatively” appropriate development area for OHVs is inappropriate. The General Plan’s Preferred Concept Map clearly demonstrates project intentions for construction of facilities of all types, including trails. Think of this: A programmatic EIR is the last and only environmental analysis document that would look at the Carnegie SVRA and Tesla as a whole recreational facility. Did I mention, that Carnegie SVRA’s only recognized significant impact in these reports, was impacts to air quality?

In the coming months, return for updates on the status of the ill-conceived Carnegie SVRA Tesla expansion project. Following certification of an EIR, the public is also notified of State Parks’ intention to carry out the project when they file a Notice of Determination. We hope that Carnegie SVRA understands that work cannot proceed until at least this notice is posted, as well as a 30- day period following the posting. Additionally, although we question Carnegie’s allegiance to this fact, this Final EIR commits to subsequent environmental review processes before any project proceeds. Regardless, the valuable resources on Tesla should not be consumed as they would be with OHV recreation activity, and we continue to hope Tesla will be preserved.


A few main points I covered, also in the EBCNPS comment letter dated October 21, 2016:

The conclusion of no significant impact on biotic resources is not supported. Facility siting and trail design so as to avoid sensitive species and communities is not viable. This avoidance strategy is demonstrated as ineffective based on the history and currently regular occurrence of illegal and unmitigated off-trail damage occurring at Carnegie SVRA even in trails-only areas. Additionally, the vaguely qualified standards of success for project goals are stated as “relative” to an uncertain and unclarified standard of time or management, without descriptions of quantifiable failure or success measurements. Certainly these have been learned from years of Carnegie SVRA operations. Leaving past work and lessons learned unrecognized will place natural resources at risk.

Plant Goal 1 and Plant Guidelines 1.1 to 1.6 of the General Plan will not adequately protect special-status plant resources or sensitive natural communities. The General Plan’s goals and guidelines for plants are necessary but insufficient to identify and avoid special-status plants during planning of future projects. This General Plan is intended to be “sufficient for future planning processes,” including expansion into Tesla. Approval of this document in its current condition, would set a guideline for unacceptable baseline inventory criteria throughout the Carnegie SVRA. The Final EIR and General Plan lack suitable rare plant survey efforts that don’t allow for true impact analysis.

Even the currently deficient state of surveys for this EIR demonstrate an abundance of overlapping rare plant occurrences, habitats, and sensitive natural communities, all with legitimate legal protection status. Already, the opportunity for on-the-ground protocol project surveys which would assist in determining cumulative impacts over the entire project, has been pigeon-holed into checking in on known occurrence information which is itself from spottily- acquired and outdated original survey work. Where there could be significant impacts, it is inadequate to defer impact analysis and/or mitigation measures to subsequent CEQA analysis, especially as there are not any provisions ensuring that impact analysis and/or mitigation would occur.

Apparently, no combination of resources (biotic, cultural, etc) is deemed valuable enough to completely ban OHV facilities from any area of Tesla or Carnegie SVRA, according to the project’s Preferred Concept Map legend descriptions in the General Plan. A reasonable consideration and preparation for avoidance is required before an agency is allowed to delve into mitigation measures. Supposedly limiting trails to the “minimum necessary to serve their intended purpose” is simply appropriate protocol for management of a trail located anywhere. An actual commitment to avoiding impacts on sensitive resources would specify at least some areas where all OHV facilities are banned with no exception, or would provide language on methods of avoidance, with at least as much specificity as proposed mitigation measures. The EIR needs to take into account potential impacts from imperfect enforcement and management mis-steps, not rely solely on perfect management as its own class of mitigation measure.

Some of the inadequately acknowledged/ surveyed rare plants we have brought to their attention include an unidentified Fritillary species (Fritillaria sp.), and CNPS Rare Plant Rank 1B species such as bent-flowered fiddleneck (Amsinckia lunaris), recurved larkspur (Delphinium recurvatum), Tracy’s eriastrum (Eriastrum tracyi), Mt. Diablo phacelia (Phacelia phacelioides), and many others. EBCNPS Rank A species also previously mentioned include shredding evening primrose (Eremothera boothii ssp. decorticans), green fiddleneck (Amsinckia vernicosa), large flowered fiddleneck (Amsinckia grandiflora), few flowered buckwheat (Eriogonum nudum var. pauciflorum), and many others. These species have been overlooked as “unlikely to occur” even as “potentially suitable habitat” on site is acknowledged, and supporting surveys were not performed.

The OHMVR Commission did conclude that a programmatic EIR was an appropriate level of analysis for this project. Briefly, allow me to explain that opting for a programmatic EIR is not by itself objectionable. For some projects where future project plans are uncertain, this selection of a less-specific analysis document is appropriate. However, in this case, our organization does not recognize that Carnegie SVRA has met the requirements for surveys and impact analysis of even a programmatic EIR. Proper surveys upon which to base a sound EIR are still absolutely necessary. Selection of a programmatic EIR versus a project- level EIR, may not be the correct choice for Carnegie SVRA given that their project plans are actually quite well- known. The Preferred Concept Map clearly demonstrates project intentions for construction of facilities of all types, including trails. Think of this: A programmatic EIR is the last and only environmental analysis document that would look at the Carnegie SVRA and Tesla as a whole recreational facility. Did I mention, that Carnegie SVRA’s only recognized significant impact in these reports, was impacts to air quality?

Our conclusion holds that Tesla is not an appropriate place for OHVs, and comparing areas within it to each other to find a “relatively” appropriate development area for OHVs is inappropriate. Additional important points our organization has made on why this project does not adequately analyze native plant resources present, include:

  • Mapping units (such as acres) are unclear on the maps, map legends, and survey records. Also, maps do not show all relevant survey results, including appropriate areas and population sizes.
  • All vascular plants need to be identified to a taxonomic level allowing rarity to be determined. State Parks has yet to analyze the genetics of a Fritillary (Fritillaria) which could not be identified by professional botanists using available keys. This means it may be an undescribed species new to science. Until identified, this species merits default treatment as special-status and rare, and thus requires adequate surveys and mapping throughout the project area.
  • Native grass surveys identified species which are indicative of sensitive native grassland communities [purple needlegrass (Stipa pulchra), California melic grass (Melica califonica), June grass (Koeleria macratha), curly blue grass (Poa secunda)], but surveys for these communities were not performed, their identification and potential presence as grassland communities was not disclosed, and thus these individual species and their likely sensitive natural community structures were not analyzed for impacts across Carnegie SVRA.


The current version of the Final EIR, is the third attempt in 15 years to approve an EIR including expansion plans into the Tesla expansion parcel. All versions contained little significant change to the project, and continued absence of declaration of significant impacts to biotic resources. This is not what usually occurs for public agencies obligated to follow CEQA process.



On 29 March 2016, our chapter’s Conservation Committee gathered at a volunteer’s private home to discuss current native plant conservation issues in the East Bay Area. Here is an outline of our main topics:

  • Antioch, CA: Vineyards at Sand Creek development: Several of our volunteers have attended public meetings to understand the impacts of this housing plan on our Four Valleys Botanical Priority Protection Area (BPPA) (map), southeast of the Black Diamond Mines Regional Preserve. The City of Antioch and Antioch Planning Commission is deciding how to embrace this idea for a Highway 4 gated private residential community, also called the Sand Creek Focus Area. Unfortunately, Antioch decided several years ago not to participate in the East Contra Costa County Habitat Conservation Plan (HCP). This particular valley is an important remainder of a once larger east-west migration corridor for plants and animals.
  • Richmond, CA: Point Molate: Conflicts over land use are settling, and this beautiful area is receiving broom removal treatments. The Urban Land Institute recently delivered six future plan alternatives to Richmond City Council, including two favoring total parks or mixed use with public parks and only some housing. This would be great news compared to the alternative of a casino discussed several years ago. It is concerning to note that City of Richmond plans to perform rezoning in the area as early as this week. Our chapter’s objective is to maintain the native vegetation corridor as much as possible from hilltop to beach and eel grass beds beyond. We favor continued public recreational enjoyment of the beautiful Point Molate with simultaneous protection of native plants. The Bay Trail Commission is in planning stages for making a connection through the area, as well.
  • East Bay Regional Parks District and fuels treatments: Our chapter continues to express worry about unclear management protocols for areas like the Huckleberry Preserve, specifically for care of sensitive maritime chaparral and the endangered pallid manzanita (Arctostaphylos pallida). We are working cooperatively with the Parks District on clarifying that forthcoming vegetation management plan. Additionally, we excerpted from their current Wildfire Hazard Reduction and Resource Management Plan for discussing how native plant protections are framed in contract language grazing guidelines, in other regions where fuel breaks are needed.
  • Oakland, CA: Knowland Park addition to Oakland Zoo:  The East Bay Zoological Society is building its California Trail project, but several of our volunteers noted enough (17) permit violations to merit an impressive letter to California Department of Fish and Wildlife (CDFW) asking for immediate action to protect remaining rare plant communities and Alameda Whipsnake habitat, including independent monitoring, penalty fee collection for mitigation, and beginning weed removal. We have not received a reply yet from CDFW.


Brief updates

– Hilltop Drive, Richmond: One of our volunteers noted construction spoils and indiscriminate herbicide spraying on native grasslands off of this Highway 80 exit.

– Point Pinole, Richmond: Wildlife populations may be declining due to drought or park management practices, including vegetation management.

– Berkeley Global Campus, Richmond: Construction plans are currently paused, which gives us the opportunity to learn more about the native flora and prairie grasslands.


Our Conservation Chair Jean Robertson led the meeting and kept our discussions focused. Want to get involved with our committee meetings? We love having more hands on deck! Please contact myself, or our Conservation Chair Jean Robertson ( Let us know  briefly what conservation projects in your area you are interested in contributing to, and what skills you can volunteer.

The Conservation Committee will meet again on 26 April, 2016.

Participate in field trips with our chapter from our Meetup page.

Read more conservation updates from our April 2016 chapter newsletter, the Bay Leaf.


Karen Whitestone

Conservation Analyst

On 19 February 2016, our organization participated in an Environmental Advisory Council hosted by Assemblywoman Catharine Baker. About thirty representatives from other conservation and land management organizations, park districts, municipalities, and nonprofits around the East Bay Area attended to represent our top important issues to Baker over a two hour period. I represented our chapter by reiterating our stance on the value of the Tesla area. Most of the others also used this council gathering as a platform to state that Tesla contains many more possibilities than an off-highway vehicle (OHV) recreation park expansion. Additionally, many agreed that the Environmental Impact Report (EIR) did not appropriately address extensive evidence submitted that OHV use is inappropriate for an area containing so many biological and botanical treasures. I delivered copies of the letter we delivered to the Off-Highway Motor Vehicle Recreation (OHMVR) Commission on 05 February 2016, plus a map and description of our Corral Hollow Botanical Priority Protection Area (BPPA).

The Tesla debate is not news to our readers. In fact, this issue was not news to Ms. Baker, either. She supports keeping open space for varied recreation, especially in support of healthy lifestyle education. She responded to many points, and spoke briefly to us on her engagement with the Carnegie park employees. As of this date since the meeting, we have not heard her take a public, political stance on the Tesla expansion.

In related news, the OHMVR Commission has further delayed deciding on the Tesla expansion. The Carnegie State Vehicular Recreation Area (SVRA) General Plan Team emailed a project update on 18 March 2016, to those who signed up for that free service on their website. The team is incorporating feedback received from the 05 February 2016 meeting in Tracy, CA, which will then be published as the Draft General Plan and Final EIR to the project website. The OHMVR Commission will set a date to meet again and consider approval. The meeting will be public, and preceded by a 30-day public notice. This is great news, because it indicates that the 60 speakers and large volume of submitted written comments inspired the Commission to wait to vote on approval until another round of revisions could be assimilated into the document. We look forward to investigating these revisions when it is published sometime in Summer 2016.

Baker represents California’s Assembly District 16, which stretches from Orinda over to Walnut Creek, to Livermore and further South. The Carnegie SVRA falls neatly within her constituency boundary. Baker plans to convene Environmental Advisory Council meetings every six months or so, throughout her elected term.

Our organization’s mission declares important goals for promoting and protecting native California plants. We primarily do this by increasing understanding among the public of the importance of our native plants, and providing reliable information in support of their conservation. I enjoyed the opportunity to engage with our elected official to present reliable information on Tesla, for the possibility of influencing public policy and opinion.

We encourage you to engage, as well. Attend a city council or utility district public meeting to learn about your local projects and issues. Elected officials want to hear from the people they represent, and these days, many host informal hikes or coffee groups to inspire candid conversation. Share native plant news or events with us as you hear about them, we will spread the word, and we may see each other at a meeting!

Karen Whitestone


Upcoming Events:

04/23/2016: Walk and Talk with Assemblywoman Baker

05/22/2016: Pelican Dreams fundraiser benefiting Save Tesla Park


A brief update on the Meeting of the Off Highway Motor Vehicle Recreation (OHMVR) Commission, taking place at Tracy City Hall, regarding planned expansion project into the Tesla area, as proposed by Carnegie State Vehicular Recreation Area (SVRA):

On Friday, February 5th, 2016, many local organizations and members of the public stood up with EBCNPS at the OHMVR Commission Meeting. We spoke out on the Carnegie SVRA General Plan and proposed expansion into the Tesla area. Passion was high at this event, the last opportunity for public comment on this project. Sticker badges of “I Own Carnegie” contrasted with “Save Tesla Park” around the room. Most importantly, a majority of speakers remained adamantly opposed, and submitted succinct opposition comments into public record.

Please read EBCNPS’ submitted comments from the Commission Meeting, stating that this Proposed Final Environmental Impact Report (EIR) lacks appropriate consideration of important evidence previously submitted in full. The true effects of the General Plan and Final EIR on botanical resources continue to be misjudged, to the point of failing to satisfy California Environmental Quality Act (CEQA) requirements. We asserted, yet again, that these Proposed Final EIR  and General Plan documents should not be certified or approved.

As Conservation Analyst, I represented EBCNPS at this meeting. I spoke to summarize important points from our submitted comment letter. We attached our Corral Hollow Botanical Priority Protection Areas (BPPA) map with description, and a Special- Status Species and Habitat Occurrences on Tesla Expansion Area map, which specifically illustrates a talking point on curly blue grass grassland, a rare natural community. This grassland is recognized by California Department of Fish and Wildlife (CDFW) and depicted as up to 175 acres in size on the special- status map. It is unclear why the coarse vegetation mapping used for their impact analysis overlooks these and other botanical and cultural resources.

In fact, we recommended that the Tesla area is so very significant as to merit a “sensitive area” recognition as defined by Public Resources Code, to serve as permanent mitigation for ongoing impacts of OHV use at the existing Carnegie SVRA. I also reinforced in comments that EBCNPS thinks Tesla should be permanently preserved with no OHV use.

As you analyze these documents for yourself, please keep in mind that delaying the planning of smaller projects as part of a program- level planning process is an over- generalized approach in this case, inadequately accounting for the summary impact of small projects on the whole Tesla area. Where there could be significant impacts to resources requiring legal protection, appropriate steps to analyze those impacts must be taken, and definitely were not taken by this Proposed Final EIR. Any small project would undeniably effect the whole. Steps to ensure complete analysis is performed before action would be taken on the expansion plan are also not outlined. The only impact deemed significant and unavoidable by this Proposed Final EIR is that on air quality, which is not supported by the evidence we and many other groups submitted. We are thrilled that so many others agreed with us.

Reporting on this event included The Independent’s article summary of the “sharp criticism” for the Tesla expansion plan, and, an article on how to understand the fuel tax allocation source of funding for the purchase of Tesla property by Carnegie SVRA in the 1990s.

Small victory that the OHMVR Commission did not vote on the General Plan and Proposed Final EIR at this meeting! What can we do now? Within 6 months, the Commission will decide whether to approve the General Plan and EIR. Hopefully, they will take extensive time to consider the resources needing protection on the Tesla property. Please continue to show your support by keeping your ears open about Tesla topics.

If you have the time, read through the FEIR, comments, or appendices. Many groups also made important opposition points backed by valid evidence.

We will await the Commission’s decision, and report back to you.

Karen Whitestone



EBCNPS's Warm Springs BPPA

EBCNPS’s Warm Springs BPPA

The City of Newark is currently working on a General Plan Revision. Among the proposed changes to the general plan are land-use changes that pave the way for the development of an 18-hole golf course and nearly 500 houses on 550 acres of historic baylands. The area in question, referred to as “area 4” overlaps a section of our Warm Springs BPPA.

On September 26th, I submitted a comment letter in support of preserving this as-yet undeveloped area of tidal marshands and uplands as part of the Don Edwards National Wildlife Refuge rather than developing it into a golf course and housing units. Our letter echoes the concerns and recommendations of other environmental groups who have weighed in on this issue including Save the Bay, the Sierra Club, Ohlone Audubon Society, Citizens Committee to Complete the Refuge, San Francisco Baykeeper, and the USFWS.

You can view a copy of our letter here: EBCNPS Letter to Newark RE Area 4 General Plan

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