THREATS FROM COASTAL DEVELOPMENT TO THE ECOSYSTEMS OF NAPLES REEF AND BEACH
In July 2006, Santa Barbara Ranch owner Matt Osgood submitted plans and the required environmental document (DEIR) to develop within the coastal zone near Naples reef, in Santa Barbara County. The location of the Naples area is shown below.
The Naples area is the gateway to the Gaviota coast, the last coastal remnant of southern California that has yet been urbanized and developed for residential use. Additional information on the planning process and how you can participate in the prevention of coastal development at Naples can be found at savenaples.org The Santa Barbara County Planning Commission will be meeting to consider the draft environmental planning report on Thursday, July 27 in the Hearing Room of the County Administration Building, 105 East Anapamu, first floor from 6:30 to 9:30 pm. This meeting is open to all citizens. This is your opportunity to voice your concerns about the development proposal detailed in the draft EIR.
This first bioregional blog for the south coast bioregional project describes the ecology of the coastal marine area of Naples reef and beach, and offers a critical review of the impacts that the proposed residential development will have on the habitats and associated biodiversity of this rare and unique area. A table that shows the proposed residential development of the area is attached.
The Significance of Naples Reef. The significance of the nearshore marine area, intertidal wetland zone, beach and bluff area at Naples is briefly described in the DEIR, with no reference to the substantive scientific research on this area’s coastal and marine environment. The nearshore ocean zone extends from the onshore area that includes sandy beaches, boulder fields and rocky outcroppings, including associated kelp beds and sandy bottoms, to the boundary between the continental shelf and continental slope. Waters of this nearshore marine area are rich in nutrients primarily from upwelling currents and partially from freshwater inflows from coastal watersheds, supporting an abundance of habitats and organisms which also offer many economic and recreational opportunities.
The Naples reef is home to a rich diversity of benthic invertebrates, fish and seaweeds that form a unique ecosystem in this area. The Naples reef includes a rare and sensitive intertidal area classified as a Reef Wetland by Lafferty et al. This class of wetland rarely occurs in the marine intertidal area of southern California, and is defined by cover dominance of invertebrate animals such as bivalves and worms. Note that the term “reef” is used to describe a type of hydrogeomorphic unit. Reefs in this sense are fixed structures made of consolidated substrate that rise out of the bottom, frequently in subtidal deepwater habitats (e.g., Carpinteria Reef and Naples Reef in Santa Barbara County).
The approximate total Naples nearshore marine area of kelp and rocky reef coverage is 18.98 square n.m. The total shoreline length is 6.49 n.m. Habitats include rocky reef, kelp beds, sandy bottom with a depth range 0 to 145 fathoms, or 0 to 265 meters. There are a series of three ridges that extend like fingers roughly parallel to shore. Depths range from as deep as 70 feet along the outer edge of the outer ridge to 15 feet at the point of the shallowest ridge. Most of the kelp growth is on the upper portions, and is associated with the boulders and rocky reef substrate.
As the DEIR briefly describes, the Naples reef is one of the two most thoroughly studied rocky reefs in southern California, and is part of UC Santa Barbara’s Long Term Ecological Research (LTER), which has received funding from the National Science Foundation. The LTER Program was established by the NSF in 1980 to support research on long-term ecological phenomena. This LTER site became the 24th site in the LTER network in April of 2000, and has received an additional 5 years of support in 2006. Scientists show that the Naples reef and wetland areas contain the highest diversity of intertidal organisms within the County. The benthic algae on Naples reef are considered one of the best examples on the region.
The walls and other parts of the reef are adorned with a large variety of nudibranchs. Bright yellow sea lemons, hermissenda, and Spanish shawl are the most common. Other invertebrates include shiny chestnut cowries, feather duster worms, and rose anemones. Rose anemones always make excellent photo material with their deep, rich red color and soft texture. Larger fish are present in moderate numbers. There are sheephead, rockfish and lingcod in this marine area. Naples Reef does have also has an excellent reputation as being a good place for recreational and commercial fishers – last year, there were 5 commercial lobster fishers who used the Naples reef area.
The high productivity of plants and algae in this coastal marine area attract a large number of animals. For instance, habitat provided by submerged seagrass vegetation provides spawning, nursery, and feeding grounds for important fishery species. Other prominent coastal birds, such as the snowy egret, great blue heron, and endangered least tern, are common to the seagrass habitats of this area. The intertidal wetland and beach area is also an important haul out for seals and the roosting area for brown pelicans. The seal haul out area is located at the eastern end of the Naples beach area, while brown pelicans use the entire beach area.
Impacts from Proposed Coastal Development. Lafferty et al. write, “Coastal access is linked to human impacts. Coastal private property usually inhibits access, whereas public property usually provides it.” The proposed developments described under the MOU and Alternative I would increase the public use and access of the sensitive coastal beach, intertidal reef wetland, and nearshore marine areas. There will likely be Class I impacts to the coastal marine area from the coastal development as proposed for the MOU and Alternative I described in this DEIR. There is no analysis in this DEIR that supports the classification of Class II impacts. This is especially the case given the cumulative impacts from multiple use and public access provided by other properties, such as the Bacara Resort.
Major hydrological changes in a watershed drainage (associated with the Dos Pueblos Creek) will adversely reduce or increase the supply of water and nutrients to the coastal intertidal and rocky reef areas. These changes that will be produced during development and after construction of homes in the coastal zone will likely increase sediment loads and runoff, causing adverse effects to watershed ecosystems that include smothering flora and fauna, increased streambank erosion, and increased turbidity. Water quality degradation from polluted runoff generated within inland watersheds and from point sources will affect resources such as shellfish beds and nursery habitats for various species of fish. It is unclear how a future watershed plan or open space plan as proposed in the DEIR will mitigate for these significant impacts to the coastal watersheds of the Naples and Dos Pueblos areas.
In addition, sea level rise is a phenomenon that will significantly affect the coastal area associated with Naples. There is no discussion or analysis of the potential impacts of climate change on the coastal watersheds, beaches or bluffs of this area. There are predictions that global warming may cause the sea level to rise another 2 to 3 feet in the next several decades. With respect to the Naples’ coastal marine area, the rise in sea level could lead to the permanent loss of the beach area, increase the undercutting of the bluff and coastal erosion (and associated bluff top landslides), and threaten proposed recreational amenities (the stairway and public trails) and private property.
There are a number of other impacts associated with the MOU and Alternative I projects that will significantly impact the nearshore marine and coastal area. We can expect further habitat alteration, including modifications in water management regimes, increased pollutant loads, and impacts of introduced plant and animal species, to adversely impact many fish and wildlife populations that are dependent upon the waters of the coastal marine area.
Of particular concern is the impact of coastal development and increased pollution and sedimentation (from erosion and other land-uses) on kelp forest stability. The Naples coastal marine area will be significantly impacted from non-point and point source pollution including sewage and coastal runoff. Scientists show that high sedimentation from coastal run-off can bury new kelp plant shoots. Similarly, kelp may experience reduced growth rates and reproductive success in more toxic waters and sediments. Studies on microscopic stages of kelp suggest that kelp is sensitive to sewage and other causes of poor water and sediment quality.
Impacts of Increased Public Access and Resource Use on Naples Beach, Intertidal and Rocky Reef Area should be considered Class I, Significant. Recreational amenities are described for the MOU and Alternative I, and include the following major constructions:
Ø A trail system will include 16 ft. wide public riding and hiking trail, east-west direction, along northern perimeter of proposed equestrian village area. The trail turns north-south along eastern edge of Santa Barbara Ranch property (lot 97). A 24 ft. wide road would parallel the riding and hiking trail, along the northern and eastern perimeter of lot 97.
Ø A .75 acre public parking lot near lot 97 will include public restrooms and showers.
Ø A concrete access tunnel, under the railroad, would be constructed and lead to a 20-ft. wide concrete stairway for access to Naples beach. Staircase requires 8 16” concrete pilings at the top of the bluff, plus 4 additional pilings at the base of the cliff. The trail will include a wildlife interpretive kiosk.
Ø A riding and connector trail will link to the bluff top trail, and would provide a loop trail back the primary access road thru the middle of SBR.
The DEIR briefly concludes that these recreational amenities will have Class II impacts that can be mitigated by a number of future plans, which are only briefly described in the environmental document. It is unclear what the thresholds of significance are for this assessment and conclusion in this DEIR.
The fact is that human population residing in the coastal zone is growing by more than 1% per year in the United States. This growth has been particularly rapid in coastal southern California counties, where the population has increased by more than 50% over the past three decades. The disturbance produced by the activities of this expanding population is thought to have resulted in a widespread reduction in the biodiversity of southern California’s rocky shores.
Previously, declines in rocky intertidal biodiversity have largely been ascribed to chronic, persistent disturbances including discharged sewage, industrial effluents and urbanization of coastal areas. Scientists show that episodic disturbances resulting from visitor foot traffic can have significant impact on the ecology on nearshore marine areas. The collection of organisms for human consumption, fish bait, aquariums, and other purposes; and the exploratory manipulation of rocks and specimens can also significantly affect rocky intertidal populations and communities.
In the DEIR, there is no review and analysis of impacts associated with increasing public access and coastal resource use, despite the evidence that large numbers of people that use the Naples rocky shores throughout the year for activities such as recreational fishing, food and specimen gathering, educational field trips, exploration, walking, and enjoyment of the out-of-doors, which will likely have significant, Class I Impacts. Moreover, it is unclear how a proposed future beach plan can prevent significant impacts. This DEIR for the proposed coastal development and associated impacts to the coastal marine area is incomplete.
Significant Impacts on Rocky Intertidal Species. The activities of high concentrations of visitors, including their foot traffic, can significantly damage a wide variety of rocky intertidal species. Southern California intertidal populations susceptible to trampling include fleshy seaweeds, coralline algae, fragile tube-forming polychaetes, bivalves such as niussels, acorn barnacles, limpets, and grapsid crabs that seek refuge under loose rocks and seaweeds during low tide. Upper-shore fleshy seaweeds have been shown to be particularly susceptible to damage from human foot traffic throughout the world.
The proposed coastal development will increase public access and associated impacts to coastal and marine habitats and associated species, and should be considered Class I impacts. Alternative I describes mitigation with reference to the development of future coastal watershed, open space and habitat, and beach plans, with particular reference to UCSB’s Coal Oil Point Natural Reserve Management as a guide. It remains unclear if the proposed plans can mitigate the significant impacts to coastal marine ecosystems from increased public access and resource use.
UCSB’s Coal Oil Point Natural Reserve is a very different coastal marine ecosystem from the Naples beach, bluff, intertidal wetland, and rocky reef areas. The Coal Oil Point Natural Reserve Management Plan prioritizes the protection of the ecosystems of the area by “closing” public access trails to sensitive habitat areas for shorebirds. The UC Natural Reserve System prioritizes the ecosystem values of the reserve, and protects the scientific and educational use of the reserve rather than the development of recreational opportunities. At Coal Oil Point, a lagoon mouth (Devereux Slough) attracted birds around its margin (and snowy plovers that roosted on the dry sand of the delta) and a rocky point provided rich foraging habitat at low tide for many species, especially in the winter where rocks were exposed.
The Naples beach and intertidal area includes approximately 6.5 n.m. of a unique intertidal wetland system and does not include a slough or estuary. There is evidence in the historical record that the mouth of Dos Pueblos Creek included a coastal wetland, and that the creek was an important southern steelhead area. In many ways, the intertidal area serves as a wetland to shorebirds and invertebrates and a wide diversity of habitats. The Naples intertidal and marine area includes the highest diversity of invertebrate species in southern California.
Protecting the ecological relationship between the coastal watersheds, bluff, beach, intertidal and marine area is essential if we are to protect these unique habitats and associated species.
Seacliffs and coastal bluffs are formed by a rapid uplift of the shore relative to sea level. When the relative uplift of the shore is slow or zero, a wave-cut terrace is formed. The term "coastal bluff" refers to the entire slope between a marine terrace or upland area and the sea. The word "seacliff" refers to the lower, near vertical portion of a coastal bluff. Erosion of the entire seacliff-bluff system must be considered together.
Bluff face erosion (which can include major landslides and rockfall) is common during and after major rain events along the Naples beach area. Bluff face erosion and landslides pose a threat to public health, and may threaten proposed bluff top homes as cliff erosion in this area has been shown to be significant.
Note, the retreating bluff provides boulders that are used by kelp forests and other marine life. The future development of a sea wall to protect the large mansions proposed under the MOU and Alternative I along the coastal bluff would significantly impact the natural process of bluff loss and sand distribution which is so essential for coastal and marine species. If the coastal development along the bluff on SBR is approved, it is highly recommended that one condition for development be approved that will not allow the building of a seawall to protect these bluff top homes. We sea level rise, we can expect increase in bluff erosion and beach loss that will threaten private property in the coastal zone.
Significant Impacts on Shorebirds and Coastal Biodiversity. About half of the shorebird species in North America are in decline, primarily due to habitat destruction and degradation. The world’s growing coastal population continues to increase the encroachment of people into shorebird habitat. A good example is southern California, where the climate and culture make beach recreation popular along the Pacific Flyway. The resulting disturbance from humans and pets degrades habitat for shorebirds because disturbance may reduce foraging efficiency and opportunities for rest. Chronic, cumulative disturbance could, therefore, reduce shorebird reproduction and survivorship. In particular, short flights are energetically costly for small birds and shorebirds unsuccessful in gaining necessary fat reserves have very low survival rates.
People can disturb birds if they approach too closely or too quickly. In addition, some dogs may actively chase birds for prolonged periods. The sensitivity of shorebirds to dogs is illustrated by the observation that snowy plovers react at twice the distance to dogs that they do to pedestrians. Perhaps this heightened reaction is because being chased conditions birds to be wary of dogs or because birds instinctively view dogs as predators. Although they do not remove habitat or kill birds directly, disturbances cause birds to suspend feeding and/or expend energy in flight, movement or vigilance.
Impacts to birds are most likely a result of cumulative effects on reproduction and survivorship. Birds that forage slowly or ineffectively may not build the requisite fat reserves that are especially important to stressed and depleted migrants who must rest and feed to successfully resume their migratory journey.
Disturbance caused by increased human use of areas used by birds can lead to the abandonment of these sensitive habitat areas. In Ventura County, for example, shorebird abundance is low on beaches with high human use, presumably because disturbance causes birds to seek more isolated locations. Pet activity, in particular, reduces shorebird abundance and those birds that remain must spend more energy on vigilance and escape at the expense of foraging and rest.
It remains unclear how a beach plan or education plan as briefly noted in this DEIR for the MOU and Alternative I projects can mitigate the significant impacts to coastal habitats and associated biodiversity. It is strongly recommended that major conditions for coastal development in this area focus on limiting the impacts of public access and associated disturbance on shorebirds and other coastal biodiversity. The vague appeal to the development of future beach and education plans in no way guarantees that the significant impact of coastal development in this area can mitigate these significant impacts.
Policy Inconsistencies. Section 6 of the DEIR describes consistency with plans and policies. In addition to the state and federal government, the County of Santa Barbara recognizes the importance of the coastal marine area in the twenty-five year old CLUP (1982). Since the early 1980s, the status of the coastal marine environment of the south coast has been shown to be degraded by a combination of natural and human factors. The proposed development will exacerbate the degradation and loss of coastal marine ecosystems of the south coast.
The DEIR fails to describe existing county policies. For instance, existing county policies state the following:
Ø CLUP Policy 7-19: In order to protect the marine resources of Naples Reef and the adjacent beach as a hauling out area for harbor seals, intensive recreational use shall not be encouraged. Access to the site should continue to be by way of boats [emphasis added].
There are a number of clear policy inconsistencies with respect to the development proposed for the MOU and Alternative I in the coastal zone. The proposed development will likely increase public access and coastal resource use. Public access is limited by a number of county policies:
Ø CLUP Policy 7-19: In order to protect the marine resources of Naples Reef and the adjacent beach as a hauling out area for harbor seals, intensive recreational use shall not be encouraged (emphasis added). Access to the site should continue to be by way of boats [emphasis added].
Ø CLUP Policy 9-24: Recreational activities near or on areas used for marine mammal hauling grounds shall be carefully monitored to ensure continued viability of these habitats.
Ø CLUP Policy 9-25: Marine mammal rookeries shall not be altered or disturbed by recreational, industrial, or any other uses during the times of the year when such areas are in use of reproductive activities, i.e., mating, pupping, and pup care [emphasis added]..
Ø CLUP Policy 9-31: Only light recreational use shall be permitted on public beaches which include or are adjacent to rocky points or intertidal areas [emphasis added].
Ø CLUP Policy 9-33: Naples reef shall be maintained primarily as a site for scientific research and education. Recreational and commercial uses shall be permitted as long as such uses do not result in depletion of marine resources [emphasis added].
The proposed coastal trails, stairway and access to the beach area, water quality concerns associated with point and non-point source pollution (that will likely be produced by coastal development) within coastal watersheds, coastal bluff erosion (and associated ecological and public health issues) among other issues and constraints should be addressed by the developer in the EIR.
Lack of cumulative impact analysis. In addition, the cumulative impacts of coastal development and increased public access and coastal resource use should be considered Class I, Significant. There is no cumulative impact analysis that considers the proposed development and increased public access in light of the access provided by the Bacara Resort, and the coastal development associated with other Gaviota projects currently under review by the county.
Moreover, the DEIR fails to offer substantive mitigation measures to address these significant cumulative impacts to the coastal ecosystems and associated biodiversity for the Naples area. Coastal development and public access to this area is inconsistent with existing state and county policies.
Alternative II will likely have less impact on coastal and marine resources. Alternative II limits public access facilities that do not encourage a significant increase in public use. Amenities to include: 20 space parking lot; a rustic trail system from parking area to beach; up to 2 interpretive kiosks; wooden stairs; and no public restroom. This is an important point that should be clearly noted in the EIR.
Overall, given the national and international significance of the Gaviota coast and the nearshore marine area, this DEIR fails to evaluate or assess the general character of the ecological impacts that will occur to the Naples coastal marine area. Vague reference to the promise of future plans to mitigate these significant impacts associated with coastal development is inadequate.