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Comments on Monterey Bay Shores Resort Project Habitat.pdf

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The April 7, 2014, letter from the USFWS relayed eight specific concerns pertaining to
the Applicant’s Draft HPP (dated Oct 2013). These eight concerns were intended to
serve as examples, not an exhaustive list, of the inadequacies of the Applicant’s Draft
HPP with respect to protection of western snowy plovers.8 In the subsequent section I
address the inadequacy of the revised HPP in resolving the eight specific concerns
identified by the USFWS. I then discuss other inadequacies of the revised HPP,
particularly with respect to Project impacts on the western snowy plover. Appendix A to
this letter summarizes the status of the western snowy plover and threats to the species.
The USFWS commented that the Draft HPP did not discuss nesting activity during the
2012 and 2013 breeding seasons. The revised HPP provides a discussion of western
snowy plover nesting activity on the Project site between 1989 and 2014. However, it
continues to misrepresent the location of nest sites. Specifically, the revised HPP claims:
“[n]esting activity has not been found above 20 feet MSL [mean sea level] in elevation or
on the upper bluff of the site since 1994; however, observations of one or two nests per
year within the open sandy sites above the high tide line and below the toe of the bluff
indicate that suitable breeding habitat remains within the strand area.”9 This statement is
inconsistent with survey data collected by Point Blue Conservation Science (“Point
Blue”).10 Those data demonstrate snowy plovers nested in the foredune/secondary dune
portion of the Project site (referred to as Management Area 2 in the HPP) between 1990
and 2002 (Figure 1), and again in 2014.11
The revised HPP indicates: “[i]n 2014, one unsuccessful nesting attempt was documented
on the lower beach portion of the Monterey Bay Shores site.”12 However, it subsequently
indicates that nesting attempt was an “alleged sighting.”13 That statement is incorrect.
The geographic coordinates of the nest site were recorded with a global positioning
system, and the nest was photographed. Those sources of information prove there was a
nest on the Project site, and that the nest site was within the foredune/secondary dune
portion of the Project site—not on the lower beach as reported in the revised HPP
(Figures 2 and 3).


U.S. Fish and Wildlife Service. 2015 Apr 7. Letter to M Watson, California Coastal Commission
regarding Monterey Bay Shores Resort Development, Sand City, Monterey County, California. p. 3.
Revised HPP, p. 3-6.
Point Blue Conservation Science. 2014 Apr 1. Letter to the California Coastal Commission regarding
Agenda Item 10a; Application A-3-SNC-98-114. See also Point Blue Conservation Science. 2015 Aug 20.
Letter submitted to the California Coastal Commission regarding the SNG Dune Restoration Plan.
Revised HPP, p. 3-7.
Revised HPP, p. 4-13, footnote 3.