Conservation Issues of the Ventana Chapter | monterey county
Sierra Club Submits Letter Opposing Monterey Bay Shores Resort to California Coastal Commission
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This graphic shows the negative impacts of the Project in the dunes on western snowy plover nests. It also gives the areas of predicted coastal erosion from sea-level rise. Data provided by conservation biologists. (Graphic design by Steve Zmak).
Sierra Club, Center for Biological Diversity and Audubon have drafted comments for the upcoming hearing at the California Coastal Commission scheduled for April 9, 10 and 11. Chapter members will be attending the hearing and speaking on our behalf.
This massive development will occur on beachfront land currently undeveloped and used by the western snowy plover, a threatened species under the federal Endangered Species Act. Due to significant concerns with the Project detailed in our attached comments (PDF here | See also comments from Peter R. Baye Ph.D.), these groups urge the Commission to deny Project approval because the Commission has failed to meet its obligations under CEQA by not analyzing all Project impacts on the plover, including increased public access to western snowy plover habitat, beach erosion, sea level rise and cumulative impacts from neighboring property. The Commission has also failed to adopt all feasible mitigation measures for the Project and the Project, as currently proposed, will result in the likely "take" of the threatened western snowy plover, an important coastal resource.
Our letter also states that if the Commission chooses to grant approval for the Project and issue a Coastal Development Permit, we urge the Commission to condition the approval on a requirement that prior to the start of construction, the developer must apply for and obtain an Incidental Take Permit (ITP) for the Project's likely "take" of western snowy plover and that a comprehensive Habitat Conservation Plan (HCP) approved by the U.S. Fish and Wildlife Service should replace the developer's inadequate Habitat Protection Plan.
Without an ITP and HCP in place for the western snowy plover, the Coastal Commission could be implicated in any resulting "take." The Commission's statutory duty to protect coastal natural resources from adverse impacts from development gives the Commission the authority to include an ITP and submittal of a HCP to the USFWS as a project condition.