| From Valerie Haley, Botanist and
Docent Coordinator, Bonny Doon Ecological Reserve.
November 11, 2003 Mr. Jack Nelson, Resource Planner
Re: Comments on the Bonny Doon Ecological Reserve Erosion Control
Plan
Dear Mr. Nelson: I have reviewed the erosion control plan prepared by Timothy Best, and have prepared the following comments. I have grouped my comments according to page number and topic. Please note that I have been the Docent & Volunteer Coordinator for the past 10 years at the Bonny Doon Ecological Reserve. As a professional botanist and revegetation specialist, I have led many nature walks at the Reserve, and therefore I am familiar with the plant species, trails system, and locations of sensitive resources at the Reserve. Tim Best has cited me in the erosion control plan. 1. Page 1, Parcel Numbers. Please verify the parcel numbers according to owner, as listed at the beginning of the plan. There is no parcel number specified for Dave and Mary Jessen, and the bulldozed road crossed their property near Martin Rd. 2. Page 2, Impact Discussion. I was misquoted in the top paragraph. Although exact counts of special status plant species damaged by the bulldozer are not known, it was more than several plants. Please revise the top paragraph as follows: Approx. Numbers of special status plants damaged on the 1.5 mile bulldozed road: Ben Lomond Spineflower (Chorizanthe pungens hartwegiana)- 150 to 200 plants Bonny Doon/Silverleaf Manzanita (Arctostaphylos silvicola)- 10 to 12 plants Santa Cruz Manzanita (Arctostaphylos andersonii) 24 to 30 plants 3. Page 2, General Site Conditions. The percent gradient slopes (3% to 20%) were given for the first mile of the dozed road, but not given for the steep gorge slopes on the RMC property. Please include the percent gradients for the gorge slopes. 4. Page 6, Discussion Section. Concur with statement that the best solution would be to relocate the road and RMC's right-of-way to an area with less special status species and where less Zayante sand is present. Please make an effort to research other access routes such as through the Warren Drive approach or via part of Dave & Mary Jessen's property. 5. Reserve Title/Designation. Please be consistent with naming. It is the Bonny Doon Ecological Reserve, not Preserve. This may seem a minor point, but the Dept. of Fish and Game has regulations and game codes that specifically apply to Ecological Reserves. For example, resources are protected; one is not to take any plants, animals or rocks from the Reserve, nor introduce plants etc. that are not already present. 6. Page 12, Maintenance Section. Section states that the property owners will be responsible for maintenance of the erosion control protection. This is not appropriate. Since the bulldozing conducted by RMC has greatly increased the erosion potential of the road, RMC should be responsible for maintenance for all of the 1.5 miles of graded road. 7. Page 9, Rocked Waterbreaks. The proposed waterbreaks for Zayante sands would introduce foreign gravel/rock that is not present at the Reserve, and could bring in unwanted weed seeds. Rocked surfaces should be minimized, and wooden water bars should be mainly used. This will help to keep the sands open so that the endangered Ben Lomond spineflower may recolonize. Monitoring after the rainy season may prove that the short-term wooden water bars are adequate, if they are checked and maintained frequently during the rainy season. 8. Page 10, Waterbreak Outlets. If rocked waterbreaks and their water outlets have to be constructed, a botanist should evaluate the areas in late spring 2004 prior to their construction. If special status plants are found, the waterbreak and outlet locations should be adjusted to avoid damage to special status plants to the maximum extent possible. 9. Page 11, Seeding and Mulch. As per our earlier discussion, crop barley (Hordeum vulgare) may be used to seed portions of the bulldozed road. Erosion control specialist Steve Singer recommends an application rate of 200 Lbs. per acre. If seeding is used in combination with a light mulch layer, 100 Lbs of barley per acre should be considered. Where mulch is deemed necessary, it should only cover 70% of the soil surface. Open spaces in the mulch will allow for seed germination. Site-collected pine needles would provide excellent mulch, and may be an option in parts of the dozed road adjacent to ponderosa pines. Suggest increasing the length of the seeding and mulching area by Laguna Creek from 50 feet to 100 feet. 10. Page 13, Inspection/Monitoring. The text
says that the erosion control measures will be monitored several times.
This is not frequent enough. Suggest check-ups and
11. Page 12, Short Term Erosion Control Measures. Please clarify the section of road to receive wooden waterbars. What is the fall line of the Zayante sands? Do you mean all areas of the dozed road with Zayante coarse sand? Wooden water bars are not indicated on Figures 1A, 1B, and 1C. Text says 25-foot spacing on page 12, yet 75 to 100-foot spacing on the bottom of page 8. Wouldn't wooden water bars placed every 75 feet along the road be adequate in areas having gently sloping Zayante sands? 12. Restoration and Monitoring Plan Needed. The Current erosion control plan does not cover mitigation for impacts to special status plants or address vegetation monitoring. It is a well-known fact that weeds and invasive, non-native species easily invade disturbed roads, which could threaten native plant species at the Reserve. A qualified third party, restoration specialist should prepare a restoration and monitoring plan for the dozed road and associated impact areas. The restoration plan should have measures for monitoring natural recruitment of Ben Lomond spineflower and other native sandhills plant species, revegetation if needed, and include maintenance weeding and control of invasive, non-native plants. Thank you for the opportunity to review and comment on Tim Best's erosion control plan. Sincerely, Valerie Haley, Botanist and
CC: Terry Palmisano, CDFG
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