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Comments on Monterey Bay Shores Resort Project Habitat.pdf

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The comments contained herein focus on Project impacts to the western snowy plover
(Charadrius nivosus nivosus). My comments are based on my review of the
environmental documents prepared for the Project, a review of scientific literature
pertaining to the western snowy plover, and the knowledge and experience I have
acquired during more than 23 years of working in the field of natural resources
The revised Habitat Protection Plan (“revised HPP”) claims it contains measures for the
protection, preservation, and recovery of the western snowy plover.1 It further claims
that the Project has been specifically designed to create new, restored, and enhanced
habitat elements that would make the Project site more attractive than the existing site to
breeding snowy plovers.2 The revised HPP concludes the proposed Project would not:
(1) significantly impact plover habitat, (2) impair essential behavioral patterns (including
breeding, feeding or sheltering), or (3) cause take or harm of any snowy plovers.3 These
claims and conclusions are unfounded and contradict existing evidence. Indeed, the
revised HPP provides no evidence that a project similar to what the Applicant proposes
has ever been built without having a significant impact on the western snowy plover. To
the contrary, there is overwhelming scientific evidence that projects similar to what the
Applicant proposes have had numerous direct and indirect impacts on the species.
Eight USFWS Concerns
On April 7, 2014, the U.S. Fish and Wildlife Service (“USFWS”) submitted a letter to the
California Coastal Commission regarding Project impacts on the western snowy plover.4
The USFWS concluded the Project, as currently proposed, could not be built without
resulting in take of snowy plover and other listed species.5 The USFWS further
concluded the HPP is not adequate to avoid take of listed species and that it is not a
substitute for a Habitat Conservation Plan (“HCP”) or incidental take permit.6 Thus, the
USFWS recommended to the California Coastal Commission that the Applicant prepare a
HCP in support of an application for an incidental take permit.7 I concur with the
USFWS that the proposed Project would result in take of the western snowy plover and
that the Applicant should prepare a HCP.


Revised HPP, p. 1-3.
Revised HPP, pp. 1-5, 4-2, and 4-48.
Revised HPP, pp. 3-10 and 4-1.
U.S. Fish and Wildlife Service. 2014 Apr 7. Letter to M Watson, California Coastal Commission
regarding Monterey Bay Shores Resort Development, Sand City, Monterey County, California.
Ibid. See also 2015 May 13. Letter to M Watson, California Coastal Commission regarding Monterey Bay
Shores Resort Development, Sand City, Monterey County, California.