From: Friends of San Lorenzo River Wildlife
Date: June 22, 2015 1:36:29 PM PDT
To: City Council <[email protected]>
Subject: Pilot Paddling Program, Item 32, June 23 Council agenda
Dear Council members ~
After carefully reading the staff report, Friends of San Lorenzo River Wildlife (FoSLRW) opposes, absolutely, the proposed Paddling Pilot Program before you and the public. The proposed pilot program is doing everything wrong and for all the wrong reasons.
We begin by addressing your attention to Page 6 of the Concerns/Resolution document, on which you will find the following Concern and staff's Resolution:
Concern: Get written opinion from CDFW & NOAA, and other resource agencies about Fish & Wildlife. Resolution: These agencies will have opportunities to officially comment through the CEQA process.
The staff report admits that "There is potential for impacts to birds and wildlife at any time through the paddling activity, but much less so during the period of August - December (post bird nesting season)."
The staff report acknowledges that the "City Council, as an alternative to the Recommended Paddling Pilot Program, could explore a seasonal study prior to moving the pilot forward..."
Yet the staff report stresses there is not going to be a CEQA process for this pilot program! This, in the face of recognition that there can be harm to an endangered species and its habitat (Tidewater Goby) as well as harm to avian species (disruption). This in the face of no baseline data for existing avian species of the SLR. This in the face of one already completed pilot program, last year's experiment, that demonstrated impacts to avian species on the SLR. This in the face of legitimate alternatives to paddling on nearby waters that will not produce the same impacts to the environment that paddling on the SLR will produce.
We reiterate what you have already heard: "Given that the San Lorenzo River has not only Federally protected species such as the Tidewater Goby, along with California Fish and Wildlife jurisdiction over City activities on the River, and the oversight of the U.S. Corps of Engineers, review by other public agencies of the Pilot Paddling Program in a CEQA document is essential."
In addition to CEQA concerns, we notice that signage is recommended with the thought that it will actually stop improper behavior by paddlers. People ignore signs all the time. Parks staff knows this very well. When it comes to endangered species, protected migratory bird species and wildlife habitat, we need more than signage as mitigation for harm.
Regarding the portion of the river to be allocated for recreational opportunities, choosing the "lagooned" river is hardly a good idea. Annual algal growth gets thick late in the summer. These algae pads become foraging sites for birds and other insects (e.g., dragonflies). This river algae is also, therefore, habitat and should not be disturbed by paddlers. We have photo-documentation of this phenomenon.
We are very concerned that the City did not include an avian ecologist in the Advisory Group. We are also concerned that one of the votes to recommend the pilot program was by a biologist who is employed (contractually) by the City. We think this person should have recused himself from the Advisory Group vote. We also find troubling the idea that the same biologist who voted to recommend a pilot program will most likely be recording the behavior of paddlers. It all seems a bit too improper to us.
Even though NOAA recommends maintaining 150 foot distance from birds, staff recommends 100 feet, and doesn't say how anyone will even know what 100 feet is. Birds, especially migratory birds, occupy the center of the river as well as its edges. How can paddlers stay 100 feet away from all birds? The answer is they cannot. We witnessed this during last year's pilot program. We have photo-documented evidence of this.
The staff report states "Habitat restoration could be an important component to the long-term health of river, however, this is not pertinent to the pilot program." This seems to imply that the river is currently degraded at the proposed pilot program reach, so why not go ahead with further riverine wildlife degradation?! This is not acceptable.
To three separate concerns about bird stress, disruption of resting and feeding birds, and potential flush kills, staff responded that "The hired biologist will cocument (sic) the occurances (sic); can potentially be mitigated through paddler education." This is wishful thinking. We should not be making policy, especially policy that involves sensitive species, based on hope.
We ask Council to vote no on the pilot program before you.
Sincerely,
Michael Lewis, PhD
Jean Brocklebank
on behalf of Friends of San Lorenzo River Wildlife
http://foslrw.weebly.com/
Date: June 22, 2015 1:36:29 PM PDT
To: City Council <[email protected]>
Subject: Pilot Paddling Program, Item 32, June 23 Council agenda
Dear Council members ~
After carefully reading the staff report, Friends of San Lorenzo River Wildlife (FoSLRW) opposes, absolutely, the proposed Paddling Pilot Program before you and the public. The proposed pilot program is doing everything wrong and for all the wrong reasons.
We begin by addressing your attention to Page 6 of the Concerns/Resolution document, on which you will find the following Concern and staff's Resolution:
Concern: Get written opinion from CDFW & NOAA, and other resource agencies about Fish & Wildlife. Resolution: These agencies will have opportunities to officially comment through the CEQA process.
The staff report admits that "There is potential for impacts to birds and wildlife at any time through the paddling activity, but much less so during the period of August - December (post bird nesting season)."
The staff report acknowledges that the "City Council, as an alternative to the Recommended Paddling Pilot Program, could explore a seasonal study prior to moving the pilot forward..."
Yet the staff report stresses there is not going to be a CEQA process for this pilot program! This, in the face of recognition that there can be harm to an endangered species and its habitat (Tidewater Goby) as well as harm to avian species (disruption). This in the face of no baseline data for existing avian species of the SLR. This in the face of one already completed pilot program, last year's experiment, that demonstrated impacts to avian species on the SLR. This in the face of legitimate alternatives to paddling on nearby waters that will not produce the same impacts to the environment that paddling on the SLR will produce.
We reiterate what you have already heard: "Given that the San Lorenzo River has not only Federally protected species such as the Tidewater Goby, along with California Fish and Wildlife jurisdiction over City activities on the River, and the oversight of the U.S. Corps of Engineers, review by other public agencies of the Pilot Paddling Program in a CEQA document is essential."
In addition to CEQA concerns, we notice that signage is recommended with the thought that it will actually stop improper behavior by paddlers. People ignore signs all the time. Parks staff knows this very well. When it comes to endangered species, protected migratory bird species and wildlife habitat, we need more than signage as mitigation for harm.
Regarding the portion of the river to be allocated for recreational opportunities, choosing the "lagooned" river is hardly a good idea. Annual algal growth gets thick late in the summer. These algae pads become foraging sites for birds and other insects (e.g., dragonflies). This river algae is also, therefore, habitat and should not be disturbed by paddlers. We have photo-documentation of this phenomenon.
We are very concerned that the City did not include an avian ecologist in the Advisory Group. We are also concerned that one of the votes to recommend the pilot program was by a biologist who is employed (contractually) by the City. We think this person should have recused himself from the Advisory Group vote. We also find troubling the idea that the same biologist who voted to recommend a pilot program will most likely be recording the behavior of paddlers. It all seems a bit too improper to us.
Even though NOAA recommends maintaining 150 foot distance from birds, staff recommends 100 feet, and doesn't say how anyone will even know what 100 feet is. Birds, especially migratory birds, occupy the center of the river as well as its edges. How can paddlers stay 100 feet away from all birds? The answer is they cannot. We witnessed this during last year's pilot program. We have photo-documented evidence of this.
The staff report states "Habitat restoration could be an important component to the long-term health of river, however, this is not pertinent to the pilot program." This seems to imply that the river is currently degraded at the proposed pilot program reach, so why not go ahead with further riverine wildlife degradation?! This is not acceptable.
To three separate concerns about bird stress, disruption of resting and feeding birds, and potential flush kills, staff responded that "The hired biologist will cocument (sic) the occurances (sic); can potentially be mitigated through paddler education." This is wishful thinking. We should not be making policy, especially policy that involves sensitive species, based on hope.
We ask Council to vote no on the pilot program before you.
Sincerely,
Michael Lewis, PhD
Jean Brocklebank
on behalf of Friends of San Lorenzo River Wildlife
http://foslrw.weebly.com/
From: Friends of San Lorenzo River Wildlife
Subject: Wildlife Trouble on the SLR
Date: August 14, 2014 10:05:33 AM PDT
To: City Council <[email protected]>
Cc: Dannettee Shoemaker <[email protected]>, City of Santa Cruz <[email protected]>, Martin Bernal <[email protected]>, Juliana Rebagliati <[email protected]>, [email protected], Joe Hall <[email protected]>, Gary Kittleson <[email protected]>, Mark Dettle <[email protected]>
Dear City Councilmembers ~
As some of you may already be aware, an unfortunate incident occurred at the August 9 Paddle Event on the San Lorenzo River. For those of you who have not yet seen the report (text and video), go to http://foslrw.weebly.com/paddle-event-bird-observations.html
Besides the unfortunate incident documented in the video, we have witnessed -- at all events -- an unprecedented flushing of birds and waterfowl into the sky, up and down the river, as documented on our web site. There have been numerous reports and photographs by concerned community members of baby waterfowl in high levels of stress as they were scattered trying to find escape paths from the watercraft. At one event an observer remarked that she had "never seen so many birds fly over Santa Cruz before." At the February 15 paddle event, two species of river bird were flushed onto Front St. and one bridge roadway. Some were killed and some were injured and taken to Native Animal Rescue.
Overall, the river was left with fewer birds after the paddle events. Once river birds fly many may never return to the river. This is especially troublesome for some may be forced to fly before they are ready, such as those who stopped during migration or those that are resting due to injury or caloric needs.
The San Lorenzo Urban River Plan, developed by and for the City, after three years of extensive work, "provides a vision...that promotes conservation and enhancement of the river as a wildlife area with complimentary recreation and community uses." All of the recommendations of the Plan, including those for recreation, "recognize that the River is first a habitat area for fish and wildlife and second a passive recreational area for enjoyment of the community." (Page 8 of the Plan).
This working document was meant to guide all City Councils and City staff in any actions related to the San Lorenzo River (SLR). The SLR Plan has never been superseded by another document.
So far, the Coastal Watershed Council (CWC) has been given an open-ended series of paddle events on the river, with no restrictions, which is inconsistent with the SLR Plan -- an unusual precedent to say the least, since 238 bird species, either migratory or resident, are documented in the San Lorenzo riverine habitat.
Recently, we asked both the CWC and City Parks to either cancel the August 9 paddle event or at least change the hours, to be responsive to the scheduled 5:00 pm paddle start time as the worst possible for birds who are just settling down for their late day final feeding and roosting. The event went forward as planned, despite our concerns.
Obviously "hoping everything would be okay" did not work out so well for the birds on August 9. It is time for a different approach.
We write today to request three specific actions from appropriate City entities:
1. In light of bird disruptions that have already transpired at all of the seven paddle events to date, especially the unnatural flushing of normally reclusive birds - including the Green Heron offspring - that led to its death and is directly attributable to the recreational watercraft activity on August 9, we ask that the September 13th paddle event be cancelled.
2. We also ask that no further paddle event permits be issued.
3. Should the City continue considering the CWC proposal to allow "water sports equipment" on the SLR, then we ask the City to begin a public process to review the proposal, including an environmental analysis per CEQA of impacts to wildlife, especially avian species.
For the City to consider such a drastic change of use on the San Lorenzo River it must provide adequate public input as well as an EIR (with baseline data of the river as it exists today) in order to make an informed decision. We think Councilmembers and City staff will agree with us that this is a wise and proper course of action.
Sincerely,
Jean Brocklebank
Michael Lewis
Jane Mio
Lisa Sheridan
On behalf of Friends of San Lorenzo River Wildlife
Subject: Wildlife Trouble on the SLR
Date: August 14, 2014 10:05:33 AM PDT
To: City Council <[email protected]>
Cc: Dannettee Shoemaker <[email protected]>, City of Santa Cruz <[email protected]>, Martin Bernal <[email protected]>, Juliana Rebagliati <[email protected]>, [email protected], Joe Hall <[email protected]>, Gary Kittleson <[email protected]>, Mark Dettle <[email protected]>
Dear City Councilmembers ~
As some of you may already be aware, an unfortunate incident occurred at the August 9 Paddle Event on the San Lorenzo River. For those of you who have not yet seen the report (text and video), go to http://foslrw.weebly.com/paddle-event-bird-observations.html
Besides the unfortunate incident documented in the video, we have witnessed -- at all events -- an unprecedented flushing of birds and waterfowl into the sky, up and down the river, as documented on our web site. There have been numerous reports and photographs by concerned community members of baby waterfowl in high levels of stress as they were scattered trying to find escape paths from the watercraft. At one event an observer remarked that she had "never seen so many birds fly over Santa Cruz before." At the February 15 paddle event, two species of river bird were flushed onto Front St. and one bridge roadway. Some were killed and some were injured and taken to Native Animal Rescue.
Overall, the river was left with fewer birds after the paddle events. Once river birds fly many may never return to the river. This is especially troublesome for some may be forced to fly before they are ready, such as those who stopped during migration or those that are resting due to injury or caloric needs.
The San Lorenzo Urban River Plan, developed by and for the City, after three years of extensive work, "provides a vision...that promotes conservation and enhancement of the river as a wildlife area with complimentary recreation and community uses." All of the recommendations of the Plan, including those for recreation, "recognize that the River is first a habitat area for fish and wildlife and second a passive recreational area for enjoyment of the community." (Page 8 of the Plan).
This working document was meant to guide all City Councils and City staff in any actions related to the San Lorenzo River (SLR). The SLR Plan has never been superseded by another document.
So far, the Coastal Watershed Council (CWC) has been given an open-ended series of paddle events on the river, with no restrictions, which is inconsistent with the SLR Plan -- an unusual precedent to say the least, since 238 bird species, either migratory or resident, are documented in the San Lorenzo riverine habitat.
Recently, we asked both the CWC and City Parks to either cancel the August 9 paddle event or at least change the hours, to be responsive to the scheduled 5:00 pm paddle start time as the worst possible for birds who are just settling down for their late day final feeding and roosting. The event went forward as planned, despite our concerns.
Obviously "hoping everything would be okay" did not work out so well for the birds on August 9. It is time for a different approach.
We write today to request three specific actions from appropriate City entities:
1. In light of bird disruptions that have already transpired at all of the seven paddle events to date, especially the unnatural flushing of normally reclusive birds - including the Green Heron offspring - that led to its death and is directly attributable to the recreational watercraft activity on August 9, we ask that the September 13th paddle event be cancelled.
2. We also ask that no further paddle event permits be issued.
3. Should the City continue considering the CWC proposal to allow "water sports equipment" on the SLR, then we ask the City to begin a public process to review the proposal, including an environmental analysis per CEQA of impacts to wildlife, especially avian species.
For the City to consider such a drastic change of use on the San Lorenzo River it must provide adequate public input as well as an EIR (with baseline data of the river as it exists today) in order to make an informed decision. We think Councilmembers and City staff will agree with us that this is a wise and proper course of action.
Sincerely,
Jean Brocklebank
Michael Lewis
Jane Mio
Lisa Sheridan
On behalf of Friends of San Lorenzo River Wildlife
Sierra Club Santa Cruz County group letter
The Sierra Club Santa Cruz County Group sent a letter to the City with comments on proposed changes to the San Lorenzo River Watercraft Ordinance. Click HERE to read the Sierra Club letter.