On Oct. 4, the Humboldt County Planning Commission heard a proposal to continue dune restoration activities on land purchased with state monies for Friends of the Dunes (FOD). The original Restoration Plan approved in 2008 stated (Page 1) that the plan would guide activities through 2010 upon which time a review would be completed, and the plan updated. The required review nor the update was ever done, yet activities continued for eight years. That is not a minor technicality.
The Coastal Development Permit (CDP) was issued stating that mapped wetland areas called buffers, would be avoided during all restoration work. These terms continue to be violated. Wetland area maps overlaid onto work area maps expose that violation.
FOD’s literature (FAQs, 2015) indicates that one of the goals of restoration is to cause localized wetland losses through the destabilization of the dunes that follows vegetation removal. The State Water Board sent a letter to the Humboldt County Planning Department in 2012 stating that any development that might impact wetlands needs to be fully permitted by the water board. The water board was not even consulted on these projects.
So why was there no required review completed or plan updated? Why were wetland areas violated? Why was the water board not noticed? How was all this over looked when the assigned county planner was a director for the applicant at the time? One can only speculate. A severe lack of transparency has also accompanied this project.
What we have been saying is that there are constraints associated with any permit. The constraints identified in this case require maintaining stability of the dunes in order to protect wetlands, the municipal water mains, and the water treatment facility for Manila. The review requirements make sure identified constraints are met.
Plans for these specific types of projects have specific time limits (10 years) as identified in the Local Coastal Plan (Samoa Area Plan). Review requirements are reiterated here as well. The 10-year period has obviously expired.
If there is indeed “science” guiding these publicly funded projects where are the reports and public review? Are we supposed to just take the applicant’s word for it? If so, why do we even have a planning process?
It is reasonable to expect a permit to reflect the actions on the ground. If the applicant’s intent is to destabilize and alter sand dunes in the neighborhood of homes, municipal water facilities and protected wetland habitats then a permit should be taken out to do so. Assigned mitigations and more appropriate insurance would need to be included.
To FOD’s credit they have come out along with the North Coast Environmental Center, in opposition to spraying poisons on dune plants which is an approach the Fish and Wildlife Service unfortunately continues to employ.
To be clear, it is not a just a handful of horsemen raising significant concerns over current dune management, it is an ever-expanding contingent of the community that includes a very accomplished California Environmental Quality Act attorney, multiple neighbors, former county planning staff, the unanimous opinion of the Planning Commission and Friends of the Dunes themselves.
Minor technicalities are not the issue here. Major ones are.
Uri Driscoll resides in Arcata.